7/28/2019 SWITCH Letter to the Ontario Minister of Energy Regarding Feed-In Tariff Changes

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To: Minister of Energy Bob ChiarelliCC: Premier Kathleen Wynne

MPP John Gerretsen

From: Tyson Champagne, Executive Director of SWITCH Ontario

Re: Changes to Feed-In Tariff Program

Date: June 21, 2013

Dear Minister Chiarelli,

Your recent directive to the Ontario Power Authority regarding changes to the feed-in tariff program

touched on numerous areas that could significantly impact the success of clean, renewable energy in

Ontario.

SWITCH and its members applaud the Government ofOntarios renewed commitment to microFIT

and small FIT projects and the decision to address the need for increased engagement with

municipalities when choosing locations for large FIT projects. We would like to offer some input that

may help the directive be successfully implemented and increase support for renewable energy

generation in Ontario.

SWITCH has facilitated sustainable energy development in Southeastern Ontario for over ten years.SWITCH brings together urban and rural businesses, researchers and innovators, educational

institutions, the public sector, and a variety of community-minded people working to create a green

future. SWITCH also believes that widespread support for sustainable energy projects is an integral

part of a truly sustainable energy future and we look forward to building that support in any way

possible. Our members are engaged in designing, building, operating and researching renewable

energy in Ontario. We have seen proof that this sector is creating thousands of new jobs and local

benefits at prices that are highly cost-competitive with other new sources of electricity, all while

helping Ontario build a stronger, cleaner and more affordable power system.

SWITCH and our membership of over 100 businesses and individuals involved in the sustainable

energy sector could play a valuable role in contributing to a workable implementation of the points

you put forward in your directive. Our access to experts and resources in the sector could be of

assistance in ensuring that well-informed decisions are made and that renewable energy continues

to be an important part of Ontarios energy mix.

Some of the concerns already brought forward by our membership regarding the changes to the FIT

program include:

A need to reassess renewable generation capacity limitso The largest provincial utility, Hydro One, currently limits renewable energy to no

more than 7% of peak demand on its distribution feeders. This is an exceedingly low

7/28/2019 SWITCH Letter to the Ontario Minister of Energy Regarding Feed-In Tariff Changes

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number that should be raised to match other regions (Utilities in California generally

agree that 15% distributed generation on a local distribution circuit is the threshold

for any problems and Hawaii allows 23% of peak load).

o SWITCH can provide you or your staff with access to experts on electricitydistribution that can provide perspective on how this rule is perhaps applied more

broadly in Ontario than technically necessary.

Potential job loss due to reduction of the Small FIT Quota from 200MW to 150MWo Our membership has already faced job loss that was likely due to the small FIT

category being reduced rather than increased.

The difficulties small and medium sized companies will have participating in a competitiveprocurement process

o Smaller developers do not have the deep pockets that will allow them to spendmillions of dollars to participate in an RFP process that could see them walk away

with nothing. Mechanisms should be added to the RFP process to make room for

smaller Ontario companies. The need to remove MW caps and provide grid access and capacity building resources for

community power projects

o Integrating commercial know-how with community interest will assist in localacceptance, more rapid deployment, and the creation of local resiliency as well as

financial resources.

The exclusion of farmers from the microFIT programo The restrictions limiting ground mount microFITs on land adjacent to residential

zoned land removes the option of a microFIT installation for many farmers (even if

they own hundreds of acres of land). A 100 metre setback would be a preferable

option.

o Also, many farmers could place 5 microFITs where they do not impact Class 1-3agricultural land or neighbours. If farmers with a current Farm Business Number

were able to install up to 50kW of microFIT it would provide support to rural Ontario

residents and local businesses.

The Ministry of Energy recently funded our GreenProfit Conference which included an expert panel

discussing many of the very issues addressed in your directive (IMBY: Earning Social License for

Renewable Energy Projects). I now feel that there is an opportunity for SWITCH to provide input and

access to resources that could assist in the development of the next generation of renewable energy

project best practices. I request a meeting between SWITCH and you or your staff so that we can

make these resources available and participate in the implementation of the directive to ensure that

Ontario continues to be a world leader in the generation of clean, renewable energy.

Thank you for your consideration and I look forward to your response.

Sincerely,

Tyson Champagne

Executive Director, SWITCH