The Coalition of Large…

The Coalition of Large Distributors ("CLD") consists of Alectra Utilities Corporation, Elexicon Energy Inc., Hydro One Networks Inc., Hydro Ottawa Limited, and Toronto Hydro-Electric System Limited. Together, the CLD’s members represent more than 3.6 million, or approximately 70% of electricity consumers located across the province. CLD members are on the forefront of the energy transformation in Ontario and are actively working with customers to enable distributed energy resources (“DER”) while managing the impacts on local grids. The vast majority of DERs currently connected in Ontario are connected to the grids of CLD members.

The CLD is pleased to offer comments on this proposal, and is generally supportive of measures that clarify net metering arrangements for customers, electricity distributors, and service providers alike. In this submission (attached), the CLD offers its feedback on several areas of the proposed amendments to O. Reg. 541/05. The points below represent a summary of CLD’s recommendations:

• The CLD recommends that amendments should remain consistent with the OEB staff’s interpretation bulletin issued on October 25, 2021.
• The CLD strongly encourages the Ministry to allow for the opportunity to comment on draft regulatory language that would allow for more detailed comment on potential implementation considerations.
• The CLD notes that the Ontario Energy Board (“OEB”) in coordination with the Independent Electricity System Operator (“IESO”) are developing innovative models of compensating DERs based on the value of the attributes they provide to various parts of the electricity system. The CLD believes that Ontario’s net metering framework should work in unison with those initiatives to ensure net metering does not work at cross purposes with the outcomes of those processes.