OFA provided the Ministry of Energy with comments on the proposed amendments to O. Reg 429/04, to allow Industrial Conservation Initiative (ICI) participants to enter Power Purchase Agreements (PPAs) with certain types of off-site renewable generation facilities.

OFA’s submission noted:

• Regulators should prioritize the siting of energy and storage infrastructure on commercial and industrial land and discourage siting on Canada Land Class 1 through 4 or Specialty Crop Lands.
• Many areas with capacity to upload power for ICI virtual net metering PPAs are heavily engaged in farming, and in some cases, local parcel sizes may be too small to secure Primary Agricultural Land Class designation.
• Only after alternative locations have been evaluated, and there are no reasonable alternative locations which avoid prime agricultural areas, or prime agricultural areas with lower priority agricultural lands, should rural lands be considered. This is meant to ensure the avoidance of siting infrastructure on Ontario’s finite and declining farm lands.
• All energy generation and storage proponents and owners, should be contractually obligated, in the case of a system failure event, and at decommissioning of a system, to restore environments, and restore the land to its original purpose.
• Programs designed to establish net metering systems must include strong collaboration between developers, land owners, local government and the public. Improve public engagement to encourage compromise between grid capacity restrictions limiting site options, and host site objections.
• Explore community based solutions and encourage municipal participation in these programs. Increasing Community Net Metering (CNM) helps customers manage energy costs and supports innovation.
• OFA supports the recent efforts of the provincial government to Simplify And Clarify Net Metering Regulatory Requirements. The Ministry of Energy and energy regulators should consider developing Virtual Net Metering (VNM) programs for Class B customers that have more than one metered account and the ability to generate power at one site and the demand at other site(s).