Dear Ben Weir,…

Dear Ben Weir,

 I wanted to take the time to write you a comment on your question related to the role of submetering as it pertains to the LTEP, and the introduction of Net metering.  Allow me to explain a little bit about my background and what we do.  I am the President of Clean Cut Energy Corp, an OEB licensed Unit submetering provider (USMP) located in Guelph, ON.  We currently service close to 2,000 customers all across Canada for all utilities and work specifically with condominiums.  I have been following this discussion very closely because I believe there is a significant role for submetering suppliers to play in helping the province meet the objective of the LTEP and more specifically in the Net metering space.

 What has become abundantly clear over the last couple months is that very few outside the submetering industry really understand what submetering is and how we operate differently from Local Distribution Companies (LDC) here in the province.  The role of submetering really came from a need for better utility management by Multi-residential buildings.  For most condominiums they operate like mini-communities or cities.  They are often self-sufficient, often provide many of their own services like snow plowing, garbage removal and lawn care in many cases simply because the municipality won’t or can’t service them.  Utilities are no exception.  Most LDC’s desire to service multi-residential customers the same way they service commercial customers with a 1 building 1 meter mentality.  But as numerous studies have detailed in multi-residential spaces you get stratifications of energy consumption.  For example in a townhouse complex a quick rule of thumb for water consumption is that 50% of the water is used by 20% (high water users) of the units and the remaining 50% is used by the other 80% (low consuming majority) of units.  This disparity in behavior is only corrected by applying individual metering and ensuring that each person pays for only what they consume.  Our company prides ourselves on not only billing owners for utilities the consume but also helping the building manage common area utilities.  Most boards of directors of condominiums are volunteers that invest their time to better their “little community”.  They often don’t have the expertise to trouble shoot complex utility issues.  They don’t have the money to source industry experts and consultants to help them with these issues.  Submetering service providers fill this gap.  Our company can’t and won’t treat every building the same because each one is different and what makes our company uniquely effective in this space is that we work with each building to help them manage their energy and water use.  An LDC that services an entire community doesn’t have the expertise or the resources to perform this job on an individualized basis and customers suffer for that lack.

 So as you consider the role of submetering in LTEP and how submetering service provider can benefit Net metering allow me to posit how we see our role can be enhanced in a Net Metering scenario.

 Consider a townhouse complex that is submetered for electricity by a USMP.  They have a single connection to the LDC at the property line.  They decide that they want to start to generate electricity on their own and install a large solar system on the roof of their building.  At the same time they install a reversible Net Meter at the property line so that when they over generate electricity they can send that energy back to the grid to accumulate an energy credit with the LDC. Electricity now enters the complex either through the LDC connected meter at the property line or is generated from the new solar system.  To get the best result from their solar system the townhouse community will want to track generated electricity from the solar system.  Consumed electricity inside the condominium complex and electricity they purchase from the LDC.  They will want to know how much electricity they purchased from the LDC and how many credits they generated with the LDC so that they can ensure they get the benefit of those credits from the LDC.  This process requires a very complex energy accounting architecture.  It requires building level analysis and tracking of the flow of electricity throughout the condominium complex.  I think it would be extremely difficult and costly for an LDC to specialize their systems to be able to accommodate this kind of energy accounting for individual net metered buildings.  Luckily Submetering service providers are already capable of this.  Our systems already track the flow of energy inside our customer buildings and report on it to our clients and this is simply an extension of the architecture that already exists.  We also have the flexibility to tie in other information like weather and sunlight information so they can assess when solar panel efficiency and react quickly when they are underperforming.

 We are currently working with a developers interested in this exact scenario I described above and I would be very happy to work with the province, the regulator and the developer to see if we can make this pilot project a public display of how submetering, energy management and Net metering can benefit multi-residential buildings.

 For many year multi-residential buildings have been treated as if they were simply commercial office towers when they are actually a group of users that all partake in individualized utility use.  As the Government considers the role of LDC’s and USMP’s in this new Net Metering world I hope they create a frame work that works to the strength of both parties so that the end users all benefit.

 I would be happy to discuss or consult on this in more detail if you think I might be able to offer more valuable information or insight into our capabilities.

 Sincerely,

 Mike Kazmaier, P.Eng

 President

 Clean Cut Energy Corp.

[Original Comment ID: 212070]