Compass Renewable Energy…

 Compass Renewable Energy Consulting Inc. (“Compass”) and Power Advisory LLC (“Power Advisory”) have prepared this submission on behalf of the newly formed Distributed Energy Resources Advisory Committee (“DER AC”). The DER AC is an industry-led group that consists of energy service providers with an interest in developing resources at the distribution-level to meet the needs of electricity customers; including solar PV, energy storage, demand response, energy efficiency, electric vehicles, and other demand-side resources. The purpose of the DER AC is to coordinate well-informed stakeholders for the purpose of contributing meaningfully to the government and its agencies on the quickly evolving electricity market. The DER AC will also provide stakeholder input to the Market Renewal Program and the implementation of the Ministry of Energy’s 2017 Long-Term Energy Plan (“LTEP”).

  The LTEP commits to enhance Ontario’s net metering framework to give customers new ways to participate in clean, renewable electricity generation.  The Ministry of Energy intends to expand net metering eligibility to include new ownership models and to ensure appropriate consumer protection provisions and siting restrictions are in place.  The government of Ontario is proposing amendments to regulations made under the Ontario Energy Board Act, the Energy Consumer Protection Act and the Electricity Act.

  Members of the DER AC offer the following feedback on the proposed amendments,

 which we understand are to be in force on July 1, 2018.

  Proposed changes under the Ontario Energy Board Act regulation, EBR Registry

 Number: 013-1913

  The proposed amendments are intended to:

 1. enable Third-Party Ownership, and

 2. provide flexibility for distributors to enable virtual net metering.

 1. Third party owners of net metered facilities would require disclosure and

 customer acknowledgment of standard business and contractual terms, such as:

 o annual electricity production from the net metered facility

 o any customer payments or expected future costs

 o estimated customer savings and cost of electricity purchased

 o warranty provisions, assignment provisions and term

 o lien rights and termination provisions

  DER AC members have not flagged any significant concerns, however there are

 questions around how the third party would calculate savings, and the basis for

 estimating future electricity costs in Ontario is expected to vary from company

 to company. Further, it should be noted that some customers may not be

 motivated by financial savings but rather by environmental savings.

  2. Included in their LTEP implementation directive, the IESO’s is to develop “a

 program to support a select number of innovative renewable distributed

 generation demonstration projects, strategically located and paired with other

 distributed energy resources and smart-grid technologies, as well as virtual

 net-metering demonstration projects.” The IESO is to submit their

 implementation plan to the Minister of Energy by the end of January. There is

 a need for flexibility for distributors to enable virtual net metering (VNM),

 as the current regulatory structure does not allow distributors to allocate

 surplus production from one customer bill to another, which is needed for these

 virtual net metering demonstration pilot projects.

  o IESO administered pilot VNM program, design details to be determined

 o will require distributor collaboration in participating customer settlement

 o criteria for determining best demonstration projects are critical to

 understand the logistics and market opportunity

  DER AC members have not flagged any significant concerns in regard to the intent and implementation of changes in the draft regulation.  Future regulation amendments may be required to enable virtual net-metering on a broader-scale outside of these demonstration projects.  The DER AC membership has significant experience in the implementation of VMN in other markets and expects to be actively involved with the IESO in program design and implementation.

  The Ministry is also considering how sub-metered customers should be permitted to participate in both third-party ownership net metering opportunities, and in virtual net metering demonstration projects, an option which the DER AC supports.

  Jim MacDougall (Compass)

  CC:

 Clark Herring (Great Circle Solar)

 Craig Walker (Hamilton Utilities Corporation)

 Michael Savel (Oakville Entreprises Corporation)

 Peter Goodman (Solar Power Network)

 Peter Vogel (Tandem Solar)

 Steve Ray (Essex Energy Corporation)

 Vikram Sigh (Alectra)

 Mohan Wang (Polaron)

 Sarah Simmons (Power Advisory)

[Original Comment ID: 212069]