Ben Weir…

   Ben Weir

 Senior Policy Adviser

 Ministry of Energy

 Conservation and Renewable Energy Division

 Conservation and Energy Efficiency Branch

 Renewable Energy Facilitation Office

 77 Grenville Street

 Floor (FL) 5

 Toronto Ontario

 M7A 2C1

  Dear Mr. Weir:

  Re:EBR Registry Numbers 013-1913, 013-1915, and 013-1916 regarding enhancements to Ontario’s net metering framework

  The following comments are in response to the Minister’s invitation for public consultation on the three concurrent postings to Ontario’s Environmental Bill of Rights regarding enhancements to the net metering framework in the province. We would like to offer our most sincere thanks for the opportunity to contribute to this consultation process.

  FRAMING NET METERING REGULATIONS GIVEN THE REALITY OF ELECTRIC VEHICLES

 We are concerned the proposed regulations are an example of regulatory capture – where the entity being regulated (the LDCs) has captured the regulator.  The focus of this regulation needs to prepare Ontario for the technological changes coming to the grid.  The proposed regulations are framed to protect the current distribution framework in Ontario, rather than to facilitate market driven distributed investment in Ontario’s grid. The proposed changes make Ontario’s grid vulnerable to power distributed by self-driving electric vehicles becoming the new low cost distribution technology of choice. The batteries in these vehicles will already be paid for through their main use in transportation.  Batteries on wheels can become dominant competitors over LDC’s if Virtual Net Metering technology is not facilitated quickly.

  We understand this makes current central generators vulnerable to new lower cost renewable energy and cogeneration investments.  Attempts to protect central generators and high voltage transmission assets through regulating grid connections will only accelerate market adoption of batteries on wheels over LDC fixed costs.

  GENERAL COMMENTS

  The citizens of Guelph have been enthusiastic adopters of solar photovoltaic systems, as evidenced by the fact that in 2016 Guelph had a rate of participation in the MicroFIT program that was 49% higher than the provincial average. Now that the MicroFIT program has been concluded (as have its companion programs, Feed-In Tariff and Large Renewables Procurement), we would like to see a successor program that will be as effective in encouraging uptake of this important low-carbon energy generation technology as well as other renewable energy generation methods.

  We believe that virtual net metering, third-party ownership, and multiple entity virtual net metering have the potential to continue contributing to the propagation of renewable energy generation systems. This will continue to drive down the cost of such systems, helping Guelph to become progressively more energy self-sufficient, thereby reducing the amount of money that must be sent out of the city to pay for imported energy. Because such energy is produced without carbon emissions, it will also help reduce our community’s contribution to climate change. We therefore encourage the Ministry to implement these measures expeditiously.

  We would like to see Combined Heat and Power (CHP) considered as an eligible technology for net metering. Although CHP typically uses non-renewable fossil fuel, it displaces fuel usage for heating and results in lower emissions overall. Given that CHP also has the potential to migrate to a renewable fuel source such as renewable natural gas, in the medium to long term it can make a more meaningful contribution to emissions reduction goals.

  SPECIFIC COMMENTS - 013-1913

 •Third Party Ownership

 a.Paragraph e: It is unclear why it is necessary for the regulation to include customer acknowledgement of receipt of this information. This information is fundamental to doing business in this industry, and any diligent customer should ask for this information. It may be more appropriate to provide a “how-to” guide to prospective 3rd party net metering customers to aid with their market research and purchase decision rather than mandating disclosure of specific information.

 •Virtual Net Metering (VNM) Demonstration Projects

 a.It is unclear why the regulation would assume no further action beyond demonstration projects. Other jurisdictions have implemented VNM successfully, so the only barriers would likely be regulatory in nature and therefore could be alleviated with the appropriate regulatory amendments. We are enthusiastic for VNM to be made widely available as soon as possible, and would like to see a plan to make this happen rather than only one initial step. Framing VNM projects as Demonstration makes Ontario’s grid vulnerable to power distributed by self-driving electric vehicles becoming the new low cost distribution technology of choice.

 b.Paragraph d: We enthusiastically endorse the idea of making VNM available across LDC service territories rather than requiring that the producer and consumer be located within the same service territory.

 c.Paragraph e: We would like specific consideration given to net metering being based on Time of Use (TOU) rates or on the Hourly Ontario Electricity Price (depending on the rate class of the host). Solar PV peak production coincides with some of the highest consumption periods, so it is higher value electricity than that created during off-peak periods. It should be valued accordingly.

 d.LDC adjust customer metered kWhr by 3 to 10% for line loss vs delivered power.  NM power does

 not have a line loss credit compensation.  The line loss adjustment should be mutual for import and export

  SPECIFIC COMMENTS - 013-1915

 •Ensuring Appropriate Customer Protections: In general, it is not clear to what extent this section duplicates customer protection measures that are already in place for other types of service providers (e.g. rental water heater providers). Should such protections already exist, it would not be necessary for the regulation to duplicate them.  Should such protections be applied to NM can these protections be extended to other third party ownership technologies?

  SPECIFIC COMMENTS - 013-1916

 •Ensuring Appropriate Siting of Renewable Generation Facilities – Regulatory Requirements a.Paragraph 1(a) – Municipal land use planning bylaws and supporting regulations already provide the means to protect property owners from unwanted additions to adjacent properties. It is not clear what additional value would be provided by the Ministry having responsibility for this specific aspect. If this is warranted, there should be a provision for the municipality to pass a bylaw allowing for an exception (e.g. for solar carports on parking lots, or properties where solar PV facilities on adjacent lands are unlikely to cause issues such as conservation lands). b.Paragraph 1(b) – It is not clear why the connection of a wind turbine or ground-mount solar PV system to a residential dwelling would be an issue in all cases and therefore why it warrants regulation. For example, this would prohibit installation of a solar carport in a surface parking lot adjacent to a multi-unit residential building.

 c.Paragraph 3 – Per the preceding two comments, this would be unnecessary if the matter were left to the discretion of the municipal zoning and land use planning processes.

  SPECIFIC COMMENTS- Draft Bill - November 14th, 2017, in Bill 177, Stronger, Fairer Ontario Act (Budget Measures), 2017. Specifically:

 6 This Schedule comes into force on the day the Stronger, Fairer Ontario Act (Budget Measures), 2017 receives Royal Assent.

 (b)  prescribing the methods or criteria mentioned in clause (a), which may include limiting or prohibiting the application or recognition of any credit in a manner which results in the reduction of fixed charges on an invoice.

  a.LDCs may recognize credits at a prorated value to reduce fixed charges on an invoice.  - Rationale - LDC are transitioning to prosumer (customers produce and consume power) model.  The prorated value of solar credits to cover LDC fixed charges would fund this transition, as LDCs would be able to sell this power to other customers.  This will encourage innovation Net Metering in LDCs.

[Original Comment ID: 212048]