January 18, 2018…

   January 18, 2018

  Ben Weir

 Ministry of Energy

 Conservation and Renewable Energy Division

 Conservation and Energy Efficiency Branch

 Renewable Energy Facilitation Office

 77 Grenville Street, Floor 5

 Toronto, ON M7A 2C1

  Re:  Proposed New Net Metering Regulation – EBR-013-1916

  Dear Mr. Wier:

  Attached please find Cornerstone Hydro Electric Concepts Association’s (CHEC) comments with respect to the Ministry’s invitation to comment on the proposed new net metering regulation to be made under the Electricity Act 1998.  This submission addresses the several sections outlined in the proposed amendment dated November 29, 2017 and follows the same format (Attachment A).

  CHEC is an association of seventeen (17) local distribution companies (LDC’s) that have been working collaboratively since 2000.  The comments over the following pages express the views of the CHEC members.

  We trust these comments and views are beneficial to the Ministry’s initiative.  CHEC looks forward to continuing to work with the Ministry in this matter.

  Yours truly,

   Kenneth B. Robertson

   ATTACHMENT A

  The Ministry of Energy is proposing a new regulation to be made under the Electricity Act, 1998, to ensure that prescribed types of renewable energy generation facilities are sited appropriately.

  1. Under the proposed regulation, the following types of renewable energy generation facilities would not be permitted to be connected to the distribution system or the transmission system.

  a)Non-Rooftop Solar PV Facilities proposed to be sited less than 15 metres from the facility property boundaries.

 b)Non-Rooftop Solar PV Facilities and Wind Facilities proposed to be connected to a residential dwelling.

 c)Non-Rooftop Solar PV Facilities over 10 kW proposed to be located on properties within prime agricultural areas, as defined in the Provincial Policy Statement and designated in an official plan.

 d)Non-Rooftop Solar PV Facilities over 10 kW proposed to be located on a property that is not captured by an official plan for which the prime agricultural area designation process has been completed.

  Many rural and farm residences may not be suitable for a rooftop solar facility but could be suitable for non-rooftop solar facility.  CHEC would suggest that a non-rooftop solar facility under 10 kW be allowed to be connected to a residential dwelling under certain circumstances (i.e.: rural areas, zoned agricultural, etc.).  Non-rooftop solar facilities are already permitted for the FIT program.  Similar requirements should be considered for net-metering facilities.

  2. Generators would be required to provide confirmation to the distributor or transmitter, signed by a relevant professional (e.g. a surveyor licenced by the Association of Ontario Land Surveyors), that the renewable energy generation facility meets the property boundary setback requirements (1a, above).

  This proposed amendment seems to be excessive for a small installation.  CHEC would suggest that a non-rooftop solar facility less than 10 kW only require a drawing showing the location and distances from property boundary rather than professional confirmation from a surveyor.

  3. Generators would be required to provide confirmation to the distributor or transmitter, signed by a relevant professional (e.g. a member in good standing of the Canadian Institute of Planners who is a registered professional planner in Ontario), as evidence that a renewable energy generation facility meets the prime agricultural area siting requirements (1c and 1d, above).

  CHEC has no issue with this proposed regulation section.

  4. In recognition of the authority of band councils elected under the Indian Act (Canada) to make decisions regarding land use on reserves, it is the policy of the Ministry of Energy to defer to band councils in relation to the use of reserve land for power generation purposes. As a result, the proposed siting restrictions for renewable energy generation facilities would not apply to reserve land.

  CHEC has no issue with this proposed regulation section.

  5. The proposed siting restrictions would not apply to:

  a)Any Non-Rooftop Solar PV Facility or Wind Facility that has been constructed as of the in-force date of this regulation; and

 b)Any Non-Rooftop Solar PV Facility or Wind Facility that has received a microFIT, FIT, or Large Renewable Procurement (LRP) Contract (whether or not that facility has been constructed as of the in-force date of this regulation).

  CHEC has no issue with this proposed regulation section.

[Original Comment ID: 212044]