About OREC The Ottawa…

About OREC
The Ottawa Renewable Energy Cooperative (OREC) with over 1,000 members finances, builds or
acquires, and operates distributed renewable energy projects – solar, wind, and energy
efficiency – in and around Ottawa and in Southwestern Ontario. Inspired by the success of
citizen-centered energy cooperatives in other jurisdictions, OREC advocates for communities to
play a role in and thus benefit from the energy transition in Ontario.
Comments by OREC
We are pleased to learn of the proposed amendments allowing Class A market participants to
purchase virtual power from off-site non-utility renewable power generators through power
purchase agreements (PPAs).
“The Ministry of Energy is seeking feedback on amendments to O. Reg. 429/04 that would allow
qualifying Class A market participants to offset their facility's demand during each hour of a base period
for financial settlement purposes through power purchase agreements with non-emitting generators
not connected to the facility behind its meter.”
https://ero.ontario.ca/notice/019-8666
We have the following recommendations: 
1. LDC customers should be eligible to participate in this initiative and these customers
should be eligible to sign PPAs with non-utility generators feeding into LDC distribution
systems. This will allow effective use of Distributed Energy Resources (DERs) to meet
new demand in constrained parts of the distribution system.
2. ICI participants should be allowed to sign PPAs with more than one offsite non-utility
generator to offset their peak demands, and non-utility generators sign PPAs with more
than one customer. This would allow more flexibility in the use of Distributed Energy
Resources and allow for more points of ‘mid sized’ generation into the Distribution Grid.

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This also has the advantage of allowing for new generation with lower cost impacts on
the Distribution grid (Connection Impact Assessments).
3. The amendments should apply to both Class A and Class B customers so that all
customers can take advantage of using offsite renewable generation to lower their
power bills and their carbon footprints. The new federal investment tax credits will
make the price of renewable generation under long term contracts cheaper than retail
rates. Furthermore, the Ministry of Energy and energy regulators should consider
developing Virtual Net Metering (VNM) programs for Class B customers that have more
than one metered account and the ability to generate power at one site and the
demand at other site(s).
4. The protocols for triggering permitting, contracting and connection of the new
generation facilities should be simple, expeditious and primarily within the control of
the contracting parties. In general, there should be no performance securities required
by regulating authorities, but as an exception, authorizations to generate by
environmental authorities may have conditional restrictions or positive covenants, and
these would be acceptable if they are common and normal.
5. As and when the output of an offsite non-utility generator matches the system peak,
LDCs should be encouraged to compensate the non-utility generator for any identified
local benefit to the distribution system in demand constrained areas. This will
encourage the use of “non-wires” options.
6. Renewable energy co-operative non-utility generators should be eligible to participate
in the initiative thereby maximizing the local benefits of the initiative and leveraging
significant community investment.
7. The minimum size of the offsite renewable energy / battery storage system should be
500 kW. This will allow participation of renewable energy co-operatives and other
smaller non-utility generators, thereby expanding the scope and resiliency of DER
installations; while expanding the community support for the program.
8. Regulators should prioritize the siting of energy and storage infrastructure on
commercial and industrial land and discourage siting on Canada Land Class 1 through 4
or Specialty Crop Lands. Only after alternative locations have been evaluated, and there
are no reasonable alternative locations which avoid prime agricultural areas, or prime
agricultural areas with lower priority agricultural lands, should rural lands be
considered. Wherever possible, generation facilities on agricultural land should
attempt to continue to incorporate aspects of farming uses on the land (e.g.
agrivoltaics)

9. Rates agreed to by the generator and the offtaker should be as flexible as possible for
the two parties and any interconnection / carrying charges by the grid operators should
be transparent and set for 5 plus year terms with a transparent costing regime and
understood rules for how charge ‘could’ be revised at end of the 5year contract.

For more information or questions please contact:

John Kirkwood - president@orec.ca
Dick Bakker - vp@orec.ca
Roger Peters – rogerpeters95@gmail.com