Please see below City of…

Please see below City of Kitchener's comments to the Ministry of Energy in response to the open consultation on ERO 019-7853: Amendments Related to the Treatment of Corporate Power Purchase Agreements.

Comments:

- Depending on the scope of the amendments, some industries or businesses may not be eligible to participate in the industrial conservation initiative, which could lead to inequalities or discrepancies in energy conservation efforts.

- These amendments allow for virtual net-metering of a specific sub-set of facilities (Class A only). Allowing virtual net-metering across a full portfolio of buildings would be more beneficial for meeting corporate GHG reduction goals / implementing local renewable energy projects.

- Depending on the specifics of the amendments, some industrial sectors might argue that the changes limit their operational flexibility or constrain innovation, potentially impeding their ability to adapt to changing market conditions. It is unclear if projects using PPAs could also benefit from other programs.