Dear Mr. Weir:…

Dear Mr. Weir:

  We would like to offer our most sincere thanks for the opportunity to contribute to this consultation process.

  As an early adopter of best practices for climate change mitigation, the City of Guelph was the first municipality in Canada to adopt a community energy plan in 2007. This later became the Community Energy Initiative (CEI), and was not mandated by the Province but rather was implemented solely on the basis of the City taking a leadership position on a critical environmental responsibility matter. Net metering promises to be a critical component of ongoing efforts to increase local generation of renewable energy, a key objective of the CEI.

  GENERAL COMMENTS

  The citizens of Guelph have been enthusiastic adopters of solar photovoltaic systems, as evidenced by the fact that in 2016 Guelph had a rate of participation in the MicroFIT program that was 49% higher than the provincial average. Now that the MicroFIT program has been concluded (as have its companion programs, Feed-In Tariff and Large Renewables Procurement), we would like to see a successor program that will be as effective in encouraging uptake of this important low-carbon energy generation technology as well as other renewable energy generation methods.

  We believe that virtual net metering, third-party ownership, and multiple entity virtual net metering have the potential to continue contributing to the propagation of renewable energy generation systems. This will continue to drive down the cost of such systems, helping Guelph to become progressively more energy self-sufficient, thereby reducing the amount of money that must be sent out of the city to pay for imported energy. Because such energy is produced without carbon emissions, it will also help reduce our community’s contribution to climate change. We therefore encourage the Ministry to implement these measures expeditiously.

  We would like to see Combined Heat and Power (CHP) considered as an eligible technology for net metering. Although CHP typically uses non-renewable fossil fuel, it displaces fuel usage for heating and results in lower emissions overall. Given that CHP also has the potential to migrate to a renewable fuel source such as renewable natural gas, in the medium to long term it can make a more meaningful contribution to emissions reduction goals.

  SPECIFIC COMMENTS - 013-1915

 •Ensuring Appropriate Customer Protections: In general, it is not clear to what extent this section duplicates customer protection measures that are already in place for other types of service providers (e.g. rental water heater providers). Should such protections already exist, it would not be necessary for the regulation to duplicate them. If such protection measures must be applied to net metering, we would request that they be applied to all relevant technologies where third party ownership might be employed.

  CONCLUSION

  The City asks that these comments and recommendations be taken into consideration when drafting the legislation associated with net metering in Ontario.

  Sincerely,

  Mario Petricevic

 General Manager

 Facilities Management

 City of Guelph

 T 519-822-1260  x 2668

 E mario.petricevic@guelph.ca

  Alex Chapman

 Manager, Climate Change Office

 Facilities Management

 City of Guelph

 T 519-822-1260  x 3324

 E alex.chapman@guelph.ca

[Original Comment ID: 212076]