Thank you for the…

Thank you for the opportunity to submit comments.

Toronto continues to experience significant growth, including the construction of new multi-residential buildings, commercial buildings, as well as, academic and heath care campus redevelopment/expansions. Along with the growth trend, there is a move towards electrification (fuel-switching) in buildings and vehicles, consistent with Toronto's TransformTO Climate Action strategy. The City has committed to net zero emissions by 2050 or sooner with more than 75% of energy to be sourced from renewable and low-carbon sources.

Updating current net-metering regulations can remove existing unnecessary barriers to renewable energy implementation. Our recommendations summarized below:

1. Allow Virtual Net Metering (VNM)

2. Continue allowing Time of Use (TOU) Billing for Net Metering

3. Make grid connection availability and process transparent, and streamlined for time/cost effectiveness.

4. Alignment with other policies: Environmental Activity and Sector Registry (EASR) and Renewable Energy Approval (REA) for carports.

- Exempt carports from REA requirements, or at a minimum allow for an EASR-like streamlined process for carport projects, regardless of system size.
- Exempt non-rooftop solar PV facility from 15 meter setback when it is sited over a paved area or on a parking lot.

5. CNM Program design elements:

The proposed basic level on aggregate Net Metering, whereby a single customer is able to offset multiple billing meters located on the same property (or adjacent/adjoining properties) with credits from the RE system is restrictive. The requirement that the CNM customers must be the owner of all meters, and that the property be owned or leased by that same customer makes this option restrictive.

a) We support Tenant Aggregation: Multiple Customers, Single Site

Multiunit buildings with separately metered tenants cannot install solar as the NM program requires the RE system to be sized according to the consumption load of a given customer meter. We recommend allowing aggregation of total consumption load of all units (meters) onsite, irrespective of ownership of meters, to size the CNM system.

b) We support Multi-Site Aggregation where the sites are not owned by the same entity but are adjacent/adjoining)

We recommend that multiple building owners be allowed to form a community/consortium to count as a single CNM customer. This would increase the financial viability of projects as funding responsibility is shared.

c) We recommend the CNM support the participation of low to moderate-income energy customers.

We recommend that you encourage participation of low to moderate-income energy customers. For example, in Colorado the utilities reserve 5% of solar projects to low-income participants.

d) Shorten the evaluation period of the demonstration projects from 5 years to 2 years.