The Ontario Energy Association (OEA) has reviewed the summary proposals which states that the Ministry is seeking to (1) amend Ontario’s net metering regulation that allow for demonstration of community net metering projects; and (2) propose a regulation to require electricity and natural gas distributors to implement Green Button Download My Data (DMD) and Connect My Data (CMD).
The OEA has reviewed these proposals and makes the following key recommendation:
Recommendation. Opportunity to Comment on Draft Regulatory Language
While the postings contain plain language descriptions of the proposed changes, neither include draft regulatory language for the proposed amendments. The opportunity of stakeholders to comment on draft regulatory language is a key part of regulatory design. The absence of draft regulatory language and the details it provides makes it difficult for stakeholders to provide substantive comments on regulatory proposals, especially when dealing with matters as technical and complex as Net Metering and Green Button.
For example, in the case of the Green Button proposal, the posting notes that the government will “require that utilities implement additional features not included in the Green Button standard to help reduce red tape and increase usability for Green Button users,” providing only examples of potential features rather than a definitive list of additional features.
Similarly, in the case of the Net Metering proposal, the posting does not provide a definition of what a “community” is for the purposes of participating in a community net metering demonstration project nor does the posting provide details regarding the parameters of the “limited participation in the demonstration (e.g., total number of projects; capacity limits for individual projects and/or all projects).”
The OEA strongly recommends that the Ministry provide stakeholders an opportunity to comment on the draft regulatory amendments regarding both regulatory proposals before the Ministry incorporates them as final regulations. This would allow participants to assess the proposed changes in detail and ensure critical issues are not overlooked and misinterpreted, so that the Ministry can successfully achieve the intended of goals of the proposals.
Submitted November 20, 2020 8:59 AM