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withdrawn from the distribution system or supplied by the embedded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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