As of the end of May, project developers who had previously installed and connected in-series renewable generation projects under the FIT and microFIT programs still do not know the future of their projects. While the current official position of the Ontario Power Authority (OPA) is that it will continue to work with the necessary regulatory bodies, including the Ontario Energy Board (OEB) and Measurement Canada, and local distribution companies (LDCs) to address systems already connected, the OEB has now directed all LDCs to stop connecting facilities using in-series meters and the OPA FIT and microFIT rules have been amended to prohibit behind-the-meter, in-series facilities.

Pursuant to the FIT and microFIT rules, a generating facility must have a separate meter. Meters and metering plans must meet LDC and/or Independent Electricity System Operator requirements and must be registered with Measurement Canada. Under the original program rules, the OPA allowed projects to connect (via the project meter) to (i) a site's pre-existing customer load revenue meter either in-series ("behind-the-meter") or in parallel, or (ii) directly to the grid. Stakeholder consultation indicated that parallel and direct connections are often more costly than the in-series option. Measurement Canada, a federal authority responsible for regulating meters used for the sale of electricity, first raised its concern with these metering options this past March. Finding an "unacceptable level of error that results when two meters are used to measure electricity consumed by a load customer", Measurement Canada has refused to recognize projects using in-series metering. While in-series metering was an option to all projects under the FIT and microFIT programs, generally small-scale projects opted for this approach.

This is the second significant set-back experienced by proponents wishing to take advantage of the in-series metering option. In the fall of 2009, the OEB amended the Retail Settlement Code and the Distribution System Code to provide that "the charges for non-competitive electricity costs payable by the associated load customer shall be calculated based on the total amount of electricity consumed at the load customer's premises, whether withdrawn from the distribution system or supplied by the embedded retail generator". Prior to this amendment, a property owner generating its own electricity could reduce the volume-based charges or "socialized costs" component of its utility bill by using power from its own generation facility.

While "behind-the-meter" projects were originally proposed by the OPA as an important incentive to encouraging small-scale generators, this option was quickly stripped of its commercial incentives and now is completely prohibited. The OPA has agreed to terminate any contracts (and return any completion and performance security) upon request from FIT suppliers who determine that their project is not feasible or economic with an alternative connection scenario.

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