TPO:…

TPO:

  e. vii. Estimated savings realized by the customer, if any;

  We think this section should include an example for customer review, along with a statement suggesting ongoing tracking/monitoring by the customer to allow for identification of failed equipment or other events that could lead to less than expected savings.

  e. viii. Estimated cost of electricity purchased from the distribution system utilized, if any;

  It is our suggestion that this section be better defined. For instance, by “cost of electricity”, does this refer to TOU or Tiered pricing structure, or some other form of cost structure?

  e. ix. Any costs for which the customer will be responsible, including but not limited to: Ongoing operation and maintenance costs, connection costs, if any;

  We believe these costs must be transparent and not part of ‘fine print’. A billing/payment example that highlights all charges and credits should be provided to the customer as a point of reference. We also believe agreements should clearly identify the process for property access during any on-site repairs or regular maintenance necessary to ensure operation (e.g. advanced notice requirements, circumstances when access can be refused, etc.).

  VNM:

  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.

  We think this section should provide clear expectations for electricity distributors. By suggesting they are ‘permitted’ implies they are not ‘required’ to participate in customer VNM requests. Are electricity distributors required to participate in customer VNM demonstration projects?

  b. A generation facility utilized for a VNM demonstration project would be required to be a renewable generation facility.

  Please clarify if this is meant to imply that the facility must be a renewable generation facility at the time of application.

  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.

  The County would appreciate clarity as to whether this implies that VNM that spans the licensed territory of more than one electricity distributor can only occur if all affected electricity distributors agree to participate. Also, whether or not this discretion understood to be a on a case-by-case basis.

[Original Comment ID: 212072]