I represent a renewable…

ERO number

019-2531

Comment ID

49826

Commenting on behalf of

Community Energy Development Co-operative Ltd.

Comment status

Comment approved More about comment statuses

Comment

I represent a renewable energy developer and a renewable energy co-operative, both of which are based in Ontario. I can’t emphasize enough how excited we are by the opportunities represented by this proposed legislation. Just a couple of the ways in which we envision developing projects that would be enabled under this legislation that would otherwise not be possible would be as follows:

Project Type 1:

1. Our Co-op would develop and fund a set of large solar PV carports in the parking lot of a “power centre” style shopping plaza, connecting the system behind the “house” meter that holds the parking lot lights, etc.
2. This would generate significant surplus net-meter credits at that “house” meter on the site.
3. As a commercial area, the electricity would largely be used by the stores located surrounding the parking lot at the site, rarely needing any significant transmission out of the commercial development.
4. Through partnership with Waterloo North Hydro (with whom we have consulted and are both eager to proceed with a pilot project), the surplus credits could be divided and distributed to be applied virtually to the meters/commercial accounts of as many as are needed of the commercial establishments on the site.
5. The operators of the commercial establishments around the parking lot would realize reductions in their electrical bills as these credits are applied to their accounts, and at the same time, make payments to the Co-op in proportion to the net-meter credits received.
6. The costs of the solar project would be funded by our Co-op, and these funds would come from investments by our Co-op members. Our investments are (optionally) eligible to be held in RRSP and TFSA accounts. Membership in our Co-op is open to everyone in Ontario, inclusively allowing anyone who wishes to be part of the project development to participate.
7. Because there are significant economies of scale realized at larger solar installations, the power produced through the commercial scale solar PV installation is able to produce electricity at or below the grid rate without the requirement of any grants or government funding.
8. This provides the following benefits:
a. Parking lot space is better utilized to also generate clean energy (and be a feature of the site rather than a wasteland).
i. With the installation of solar carports, 60% of the infrastructure is also put in place to incrementally add Electrical Vehicle charging within as needed.
ii. Black asphalt is shaded, helping reduce the heat gain of cities, extending the life of the parking lot.
iii. Vehicles are shaded in summer – reducing UV damage and extending lifespan, reducing AC usage and increasing energy efficiency
iv. Vehicles are protected in winter – reducing windshield scraping and snow clearing
b. Energy is produced very near to where it is consumed with similar generation/demand profiles, providing all of the benefits of distributed energy resources.
c. The investor-members of the Co-op are able to fund an efficient solar PV project and realize a very competitive return on investment.
d. The commercial establishments are given the choice to purchase clean energy from our Co-op for the same price as from the grid, or possibly below the price from the grid.

Project Type 2:

1. Our Co-op would develop and fund a large solar PV installation on the rooftop of an industrial/warehouse building in Waterloo where the electricity consumed within the building is much less than the amount of energy that can be generated from the rooftop.
2. This would generate significant surplus net-meter credits at the existing meter on the site.
3. As an industrial area, the electricity would largely be used by neighbouring buildings, rarely needing any significant transmission out of the industrial park area.
4. Through partnership with Waterloo North Hydro, the surplus credits could be divided and distributed to be applied virtually to the meters/residential accounts of as many as are needed of the 100+ members of our Co-op who also are customers of Waterloo North Hydro.
5. The Co-op Members would realize reductions in their household bills as these credits are applied to their residential accounts, and at the same time, make payments to their Co-op in proportion to the net-meter credits received.
6. The costs of the solar project would be funded by our Co-op, and these funds would come from investments by our Co-op members. Our investments are (optionally) eligible to be held in RRSP and TFSA accounts. Membership in our Co-op is open to everyone in Ontario, inclusively allowing anyone who wishes to be part of the project development to participate.
7. Because there are significant economies of scale realized at larger solar installations, the power produced through the warehouse scale solar PV installation is able to produce electricity at or below the grid rate without the requirement of any grants or government funding.
8. This provides the following benefits:
a. Underutilized rooftop space is used to generate clean energy. The shading of the rooftop provides reductions in air conditioning loads during the summer, providing a small additional benefit.
b. Energy is produced very near to where it is consumed with similar generation/demand profiles, providing all of the benefits of distributed energy resources.
c. The investor-members of the Co-op are able to fund an efficient solar PV project and realize a very competitive return on investment.
d. The consumer-members of the Co-op are able to purchase clean energy from their own Co-op for the same price as from the grid, or possibly below the price from the grid.

Areas of discovery, learning and innovation
1. We have already begun dialogue with the OEB on the models described above to determine what regulatory and licensing requirements may exist, including licensing our Co-op as an Electricity Retailer, and where licensed sub-metering entities are required. We are already well familiar with the installation of revenue grade metering and the requirements of Measurement Canada.
2. We are in active discussions with Waterloo North Hydro to review and solve the challenges around the mechanisms of transfer of net-meter credits between different rate classes, including Class B, General Service, Time of Use and Tiered billing structures.
3. As a Co-op, we are eager to develop efficient systems and the technology platforms to become a “market maker” for the transferring and settlement of the Net-Meter credits for the work that is needed external to the LDCs. This involves managing the kWh and $ from where we generate surpluses to where they are applied to the billing accounts of our members and customers, matching, within our organization to begin with, the “sellers” and the “buyers”. We anticipate that this would be funded internally by our Co-op, not relying on any grants or government funding.
4. Our Co-op has many Members in Waterloo, Kitchener, Cambridge and Guelph (in addition to other areas). We are working on conversations with Kitchener-Wilmot Hydro, Energy+ and Alectra, neighbouring LDCs to Waterloo North Hydro, and are eager to explore possibilities and solve challenges of Cross-LDC transfers of Net-Meter credits with those LDCs as well.

As noted, these are just a couple of the project types we would be looking to develop under the proposed legislation. We urge the Ministry to work quickly to implement this proposed legislation, and look forward to applying for opportunities to develop demonstration projects.