Dear Mr. Weir:…

 Dear Mr. Weir:

  We would like to offer our most sincere thanks for the opportunity to contribute to this consultation process.

  As an early adopter of best practices for climate change mitigation, the City of Guelph was the first municipality in Canada to adopt a community energy plan in 2007. This later became the Community Energy Initiative (CEI), and was not mandated by the Province but rather was implemented solely on the basis of the City taking a leadership position on a critical environmental responsibility matter. Net metering promises to be a critical component of ongoing efforts to increase local generation of renewable energy, a key objective of the CEI.

  GENERAL COMMENTS

  The citizens of Guelph have been enthusiastic adopters of solar photovoltaic systems, as evidenced by the fact that in 2016 Guelph had a rate of participation in the MicroFIT program that was 49% higher than the provincial average. Now that the MicroFIT program has been concluded (as have its companion programs, Feed-In Tariff and Large Renewables Procurement), we would like to see a successor program that will be as effective in encouraging uptake of this important low-carbon energy generation technology as well as other renewable energy generation methods.

  We believe that virtual net metering, third-party ownership, and multiple entity virtual net metering have the potential to continue contributing to the propagation of renewable energy generation systems. This will continue to drive down the cost of such systems, helping Guelph to become progressively more energy self-sufficient, thereby reducing the amount of money that must be sent out of the city to pay for imported energy. Because such energy is produced without carbon emissions, it will also help reduce our community’s contribution to climate change. We therefore encourage the Ministry to implement these measures expeditiously.

  We would like to see Combined Heat and Power (CHP) considered as an eligible technology for net metering. Although CHP typically uses non-renewable fossil fuel, it displaces fuel usage for heating and results in lower emissions overall. Given that CHP also has the potential to migrate to a renewable fuel source such as renewable natural gas, in the medium to long term it can make a more meaningful contribution to emissions reduction goals.

  SPECIFIC COMMENTS - 013-1916

 •Ensuring Appropriate Siting of Renewable Generation Facilities – Regulatory Requirements a.Paragraph 1(a) – Municipal land use planning bylaws and supporting regulations already provide the means to protect property owners from unwanted additions to adjacent properties. It is not clear what additional value would be provided by the Ministry having responsibility for this specific aspect. If this is warranted, there should be a provision for the municipality to pass a bylaw allowing for an exception (e.g. for solar carports on parking lots, or properties where solar PV facilities on adjacent lands are unlikely to cause issues such as conservation lands). b.Paragraph 1(b) – It is not clear why the connection of a wind turbine or ground-mount solar PV system to a residential dwelling would be an issue in all cases and therefore why it warrants regulation. For example, this would prohibit installation of a solar carport in a surface parking lot adjacent to a multi-unit residential building.

 c.Paragraph 3 – Per the preceding two comments, this would be unnecessary if the matter were left to the discretion of the municipal zoning and land use planning processes.

  CONCLUSION

  The City asks that these comments and recommendations be taken into consideration when drafting the legislation associated with net metering in Ontario.

  Sincerely,

  Mario Petricevic

 General Manager

 Facilities Management

 City of Guelph

 T 519-822-1260  x 2668

 E mario.petricevic@guelph.ca

  Alex Chapman

 Manager, Climate Change Office

 Facilities Management

 City of Guelph

 T 519-822-1260  x 3324

 E alex.chapman@guelph.ca

[Original Comment ID: 212077]