Entegrus Powerlines Inc. (…

 Entegrus Powerlines Inc. (“Entegrus”) is a local distribution company serving approximately 40,000 customers across 16 communities in southwestern Ontario.  Entegrus appreciates the opportunity to provide the following comments with respect to the expanding net metering framework posted November 29, 2017.

  1)Ministry Proposal:  Enable third-party ownership of net-metered generation facilities and

 virtual net metering demonstration projects

  Entegrus supports third-party ownership, subject to the registration or licencing of such parties. This step will help to ensure parties investing in the grid have sufficient capability, and willingness, to meet the responsibilities and reporting requirements involved.  This will assist with consumer protection.

  It is noted that the viability of generation facilities is contingent upon available grid capacity to accept the generation.  Entegrus has concern with net metering projects being initiated without the distributor’s knowledge and prior to a capacity verification being completed.  It cannot be assumed that the distributor will always be aware of such projects if not informed.  Entegrus recommends that a requirement for informing the distributor and a capacity check be put in place. It is noted that the ESA may be able to play a role in identifying such projects.

  Specific to virtual net metering, Entegrus seeks clarification of the ongoing IESO settlement requirements for such situations.  For projects involving multiple distributor service territories, the collection of appropriate data from third-party generators or other LDCs within the currently established timelines may be challenging.  It is noted that existing monthly industry settlement processes can be complex and that virtual networks between service territories will introduce additional complications.  Entegrus seeks clarification of how distribution and transmission charges will be calculated, settled and accounted for within such multi-distributor virtual networks.

  In terms of grid capacity, Entegrus also notes that the full or partial use of such capacity for virtual net metering projects may disadvantage “home service territory” distribution customers who participated in the cost of associated system investments.  This could occur if generators exhaust available capacity for the benefit of customers of another LDC.  Entegrus seeks to understand whether generators will be charged as if they are consuming the electricity they are providing.

  Entegrus also notes the need for clarification as to how distribution rates would be applied for virtual net metering projects.

  2)Ministry Proposal:  Adapt and enhance the existing energy consumer protection framework to support the introduction of third-party ownership arrangements

  Entegrus reiterates the importance of net metering contractual relationships remaining between the customer and the third-party owner (e.g. aggregator), akin to the retailer relationship.  Under microFIT, distributors are aware of disputes that occurred between customers and their aggregators. In some cases, customers did not understand their contract with the aggregator.  In other cases, the aggregator sought assignment of generation funds where collection issues from the customer arose.  These situations resulted in time-consuming challenges for distributors, sometimes involving legal and regulatory considerations.

  Entegrus supports information specifications that result in appropriate definition of the contractual relationship between customers and third-party owners at the outset of the arrangement. This will assist distributors in mitigating and navigating disputes.

  3)Ministry Proposal:  Ensure that prescribed types of renewable energy generation facilities are sited appropriately

  In situations where siting requires system expansion (e.g. capacity) investment, Entegrus seeks to confirm that existing Distribution System Code regulations related to customer contributions will apply.

[Original Comment ID: 212067]