January 17, 2018…

   January 17, 2018

  Mr. Ben Weir, Senior Policy Adviser

  Ministry of Energy, Renewable Energy Facilitation Office

  77 Grenville St., Toronto, ON M7A 2C1

    RE: EBR proposal 013-1913 (Net Metering)

    Dear Mr. Weir,

  The following submission is from the David Suzuki Foundation.

  Overview

  We believe the climate change situation is acute and requires strong leadership from government. In particular, we believe governments must phase out fossil fuels and replace them with renewable energy. By mid-century, renewables should be supplying all our heating, cooling, power and transportation needs. A 100 per cent renewable society is both possible and necessary.

  We appreciate Ontario's leadership in phasing out coal-fired electricity and ramping up solar and wind power. It has cleared our air, created countless jobs and helped to build a whole new industry in the province. These are not small accomplishments.

  But now the issue is growing our renewable capacity even further. We believe the proposed net metering regulation represents an important step toward this goal.

  The regulation's purpose is laudable. It will give customers new ways to participate in renewable generation; save them money; build the renewables industry; reduce the electricity system's load; and help Ontario meet its GHG reduction targets.

  Third-party ownership of net-metered generation facilities

  The third-party ownership proposal would bring much-needed flexibility to our energy system. It would end the rigid requirement that net metering can only take place when customers own or operate a generation facility. It would give customers more billing options and potentially create a new business sector that would provide renewable energy on a net-metered basis. For many homeowners, the installation of solar PV cells on their property is cost-prohibitive. Even if the installation saves them money in the long run they do not have the dollars to purchase it. This is especially true of low-income seniors. But third-party ownership would let them enjoy net metering's benefits in the absence of significant financial resources. In this sense it would also make the energy system more democratic.

    Virtual net metering (VNM) demonstration projects

  We are pleased with the proposal to allow VNM demonstration projects. We have examined VNM in British Columbia and know it can be extremely popular with the public. For example, Nelson, B.C.'s power utility recently sold PV panels for $923 to homeowners, churches, co-ops and the district school board. (The utility installed the panels on city-owned land.) The entire array of 248 panels sold out in just four weeks. Without the hassle and expense of putting PV units on their own roofs, these purchasers will enjoy the benefits of investing in solar: they'll receive up to $50 annually in electricity cost reductions. The project will also make the municipality more energy self-sufficient; it will rely less on an external power company and more on its own residents. We believe VNM will provide similar benefits to Ontarians.

  While we would like Ontario to move on VNM as quickly as possible, we do see the value of undertaking demonstration projects. These initiatives can function as laboratories in which we experiment with the VNM concept and discover how best to operationalize it before rolling it out widely. We understand there is significant interest in participation, with Oxford County being especially keen. As you may know, Oxford already has a proposal to set up a 0.9 MW solar array at its landfill facility that would offset electricity demand at other municipally owned sites. This project would add flexibility to the system by allowing the county to produce energy where space is abundant (at the landfill) and use it to displace load where space is constrained (e.g., in downtown Woodstock).

  In an April 2017 report to county council, Oxford's chief administrative officer wrote: "The 0.90 MW of energy produced has the potential to offset energy use at the landfill site operation plus the electrical loads at other County facilities, such as the County Courthouse Square in Woodstock." Summarizing the value of VNM, he wrote: "net metering and especially virtual net metering, will accelerate the adoption of renewable energy and will open doors to many more customers who are either constrained (limited access to the electrical grid) or have limited physical access to renewable energy." In short, VNM is a key strategy to boost renewables' growth. 

  We would like the design and implementation of the demonstration projects to occur as soon as possible. We believe it is realistic for the IESO to approve applications by the end of the second quarter of 2018 and allow projects to commence in the third quarter.

  Our only concern is that demonstration projects not be seen as an end-point. These pilots are appropriate on a short-term basis but must, with some urgency, give way to regulations that allow VNM throughout the province. A number of North American jurisdictions (including New York and California) have brought in VNM, and it is crucial that Ontario embrace VNM best practices quickly — otherwise we stand to lose our status as an energy leader.

  Conclusion

  Ontario's 2017 Long-Term Energy Plan says the government is committed to an electricity system in which renewables play "an essential role." This is commendable. But it must be pointed out that the great constraint on renewables' expansion is nuclear. Third-party ownership and virtual net metering will certainly help to build the renewables sector but as long as Darlington and Bruce supply about half the province's power, sources such as solar and wind will not reach their potential.

  Ontario showed global leadership in phasing out coal-fired power, and we enjoy the benefits of that policy to this day. But if the province wants to continue as an energy leader it must rethink its embrace of nuclear and, over time, reduce its reliance on this expensive and risky technology.

[Original Comment ID: 212054]