January 18, 2018…

 January 18, 2018

  Ben Weir

 Ministry of Energy

 Conservation and Renewable Energy Division

 Conservation and Energy Efficiency Branch

 Renewable Energy Facilitation Office

 77 Grenville St, Floor 5

 Toronto, ON, M7A 2C1

  Re: Proposed Amendment of Ontario Regulation 541/05 – EBR-013-1913

  Dear Mr Weir,

  Pertaining to the proposed Amendment of Ontario Regulation 541/05: Net Metering, or a new Regulation (To Be Determined), to be made under the Ontario Energy Board Act, 1998.  Lakeland Power has reached out and connected with a range of groups and organizations to get a true understanding of potential requirements and concerns from the LDC, customer and third-party perspective.

  To ensure we are not duplicating efforts, we can confirm that the following groups/organizations have submitted comments with Lakeland Powers input and support: -

  Cornerstone Hydro Electric Concepts -LDC perspective (no reference available upon submission)

 The Town of Parry Sound – Comment submitted Jan 17, 2018 - ID 212042

 AMP – Business perspective – Comment submitted Jan 18, 2018

 Electric Distribution Association – LDC perspective (no reference available upon submission)

  Required Clarification / Potential Concerns

 Reference : https://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTM0MDMx&statusId=MjAzO Dk0&language=en

  Third Party Ownership (TPO)

  a) No comment

 b) A customer could enter into an agreement with a generator to purchase electricity generated from a renewable energy source. This arrangement would allow surplus electricity that is not consumed by the customer to be conveyed into the distributor’s distribution system, and the customer would receive a credit on their bill for the value of the electricity conveyed into the distribution system.

 Lakeland Comment: A standardized contract for third party net metering arrangement should be developed by the Ministry of Energy or the IESO

  c) No comment

 d) The customer would confirm whether an agreement between the customer and a third-party generator exists for the sale/financing/leasing and installation of the generation facility.

 Lakeland Comment: Distributors do not need to know about ownership or about the private financial concerns of the customer.

 e) If an agreement between the customer and a third-party generator for the sale/financing/leasing and installation of the generation facility exists, the customer would acknowledge that the following information has been disclosed to them:

  Lakeland Comment: The Same as (d) above. Customers are responsible for their own financial matters – Distributors should only obtain information that is relevant to a net metering arrangement.

  f) No comment

  Virtual Net Metering (VNM) Demonstration Projects

  a) Electricity distributors would be permitted to enter into net metering agreements with customers to implement VNM demonstration projects, if the project is participating in a prescribed program administered by the IESO and in accordance with criteria set out in that program.

  Lakeland Comment: The IESO program will need to take this into account and a billing process should be developed prior to implementation

  b) No comment

  c) No comment

  d) Subject to the discretion of any involved distributors, customers associated with a VNM demonstration project may be located in a distributor’s distribution system other than the distribution system in which the generation facility is located.

  Lakeland Comment: This situation would require that financial transactions occur between distributors.  The OEB should establish an agreement that is to be used between the distributors involved to clearly identify requirements for this type of transaction

  e) Distributors implementing VNM demonstration projects would be required to value credits for any electricity conveyed by the generator into a distribution system based on similar principles (affecting only volumetric charges) as currently specified in the existing net metering regulation. 

  Lakeland Comment: If a generation site is being used as a VNM for more that one customer then clear rules need to be established as to how that generation is allowed.  A sample proposal would be that a percentage allocation to each customer be assigned at the time the VNM contract is established

  LDC Summary

 Lakeland Power is committed to the deployment of a VNM solutions for our customer base.  As outlined above, further clarification is required on a number of areas, we are happy to discuss further with the Ministry of Energy and work closely with the IESO to establish program guidelines. It is our recommendation that the details of the IESO program permitting VNM will be provided by March 31, 2018 and that the program will open no later than July 31, 2018, on the day the anticipated and required regulatory amendments take effect.

  Potential Project Summary

  We are actively working with The Town of Parry Sound and AMP (an established global developer of flexible clean energy infrastructure) to support the proposed VNM arrangement that will satisfy the Town of Parry Sounds annual energy requirement for all its Municipal Buildings.  The Town of Parry Sound is currently experiencing limited growth potential for large energy consumption industries (i.e. manufacturing, data centers). Furthermore, single feeder limitations lead to reduced system resiliency and create a single point of failure.   These constraints have the effects of •Limiting the ability to expand tax base and attract new businesses or expand operations of current businesses

 •Rising electricity costs are putting pressure onto the system

  Currently the proposed amendments to Ontario’s Net Metering Regulation, specifically the elements of Third Party Ownership and Virtual Net Metering demonstration projects provide significant opportunity to deploy innovative, clean renewable technology solutions including:

 •Distributed generation and energy storage

 •Net Metering & Virtual Net Metering

  The most critical element to the sustainability goals and net zero objective of the Town involves certainty of policy and incentives and the enabling of Virtual Net Metering (VNM).

 This strategic partnership of The Town of Parry Sound, Lakeland Power and Amp contains the required stakeholder buy-in and project execution experience to successfully deploy one of Ontario’s first VNM demonstration projects.

 Lakeland Power seeks comfort from the Ministry of Energy that the customer example / project described herein is applicable and will not be precluded from participation in the prescribed IESO administered program to permit the Town’s Virtual Net Metered Demonstration Project and a key milestone in the town’s Net Zero vision.

  Thank you for taking into consideration our comments, views and suggestions.  We look forward to working with the Ministry of Energy and the IESO to continue to develop the proposed Amendment of Ontario Regulation 541/05: Net Metering, or a new Regulation (To Be Determined), to be made under the Ontario Energy Board Act, 1998.

  Sincerely,

   Vince Kulchycki

    Chief Operating Officer

 Lakeland Power Distribution Limited

[Original Comment ID: 212062]