Dear ENERGY, It is…

Dear ENERGY,

It is encouraging to see Ontario finally consider amendments to enable bilateral corporate PPAs. However, as with almost all innovations enacted by Ontario, the current policy proposal is a half measure which does not go far enough.

In its current form, the proposed amendments only create a practical path for existing renewable generators to sign bilateral PPAs with Class A consumers when their current contracts expire. If the government wishes to succeed at enticing more foreign direct investment, especially in automotive manufacturing, they are going to need to expand the supply of renewable energy. The current supply is not adequate.

There are too many barriers to new generation, including community acceptance, restrictions on prime agricultural land, and transmission congestion. The limitation to transmission connected projects is too restrictive, distribution connected projects should be also be permitted to participate.

Distribution connected projects, particularly 10-20 MW solar farms, are typically smaller, less land intensive, less intrusive to the landscape, and easier to win community buy-in. Solar generation is better aligned with system peak, and therefore more valuable for reducing global adjustment charges.

We have to stop using renewables as conventional generators and start making the most of our distribution networks. Many smaller projects are more advantageous than a few big ones.

As usual, Ontario tries to do something new (or new for Ontario anyways), and then boxes itself into so many corners that the resultant policy only helps a handful of stakeholders. Notwithstanding these complaints, it is a step in the right direction.

Thank you for the opportunity to comment.