Compass Renewable Energy…

 Compass Renewable Energy Consulting Inc. (“Compass”) and Power Advisory LLC (“Power Advisory”) have prepared this submission on behalf of the newly formed Distributed Energy Resources Advisory Committee (“DER AC”). The DER AC is an industry-led group that consists of energy service providers with an interest in developing resources at the distribution-level to meet the needs of electricity customers; including solar PV, energy storage, demand response, energy efficiency, electric vehicles, and other demand-side resources. The purpose of the DER AC is to coordinate well-informed stakeholders for the purpose of contributing meaningfully to the government and its agencies on the quickly evolving electricity market. The DER AC will also provide stakeholder input to the Market Renewal Program and the implementation of the Ministry of Energy’s 2017 Long-Term Energy Plan (“LTEP”).

  The LTEP commits to enhance Ontario’s net metering framework to give customers new ways to participate in clean, renewable electricity generation.  The Ministry of Energy intends to expand net metering eligibility to include new ownership models and to ensure appropriate consumer protection provisions and siting restrictions are in place.  The government of Ontario is proposing amendments to regulations made under the Ontario Energy Board Act, the Energy Consumer Protection Act and the Electricity Act.

  Members of the DER AC offer the following feedback on the proposed amendments, which we understand are to be in force on July 1, 2018.

  Proposed changes under the Energy Consumer Protection Act regulation, EBR Registry Number: 013-1915 

 The intent focuses on consumer protection and disclosure under third-party ownership under the net metering framework.

  The changes would require disclosure of standard business information, such as:

 oany penalties under existing electricity retailer contracts triggered by the installation of a

 net metered project

 oCancellation and any early termination penalties

 oEquipment recovery costs in the event of cancellation

  DER AC members have not flagged any significant concerns in regard to the intent and implementation of changes in the draft regulation.  For those considering third-party arrangements with customers, this new regulation puts the onus on the third-party provider to ensure clarity of information provided to customers.  It is not clear from the regulation what recourse a customer would have, for example, if they claimed that penalties in their contract with the third party owner were unclear.

  Jim MacDougall (Compass)

  CC:

 Clark Herring (Great Circle Solar)

 Craig Walker (Hamilton Utilities Corporation)

 Michael Savel (Oakville Entreprises Corporation)

 Peter Goodman (Solar Power Network)

 Peter Vogel (Tandem Solar)

 Steve Ray (Essex Energy Corporation)

 Vikram Sigh (Alectra)

 Mohan Wang (Polaron)

 Sarah Simmons (Power Advisory)

[Original Comment ID: 212064]