New consortium seeks to develop DER Roadmap for Ontario
A range of diverse energy companies have banded together to voice the interests of distributed energy resources (DERs) and the benefits these resources provide to customers, distributors and the bulk electricity grid. The Distributed Energy Resources Advisory Committee (DER AC) was launched in January 2018 and describes itself as “an industry-led group that consists of energy service providers with an interest in developing resources at the distribution-level to meet the needs of electricity customers, including solar PV, energy storage, demand response, energy efficiency, electric vehicles, and other demand-side resources.”
The purpose of the DER AC is “to coordinate well-informed stakeholders for the purpose of contributing meaningfully to the government and its agencies on the quickly evolving electricity market.” The DER AC will also provide stakeholder input on the Market Renewal Program and the implementation of the Ministry of Energy’s 2017 Long-Term Energy Plan (LTEP). Ultimately the goal of the DER AC is to develop a DERs Roadmap for Ontario.
The DER AC’s first tasks included responding to newly proposed regulations and regulatory amendments proposed by the Ministry of Energy and providing input to the IESO with respect to the development of the Non-Emitting Resources Request for Proposal (NERs RFI).
Following the release of the LTEP, the Ministry of Energy posted three regulatory proposals: 1) an amendment of the net metering regulation to enable third party ownership of net metered generation and allow for virtual net metering demonstration projects, 2) an amendment to strengthen consumer protection, and 3) a new regulation under the Electricity Act to ensure appropriate siting of renewable generation facilities in relation to residential properties and agricultural lands.
While commending the Ministry for the net metering initiative on the whole, the DER AC expressed concerns with respect to how the Ministry has proposed to implement land use restrictions for ground mounted solar. The DER AC notes the importance of protecting agricultural lands and ensuring electricity resources are sited appropriately. That said, the blanket prohibition of ground mount system with respect to residential dwellings and property boundary set-backs could have unintended consequences; for example, “a 100 acre property with a farmhouse may be prohibited from installing a 6 kW solar carport for local electricity production. Likewise, a new, net-zero residential community development proposing to offset electricity consumption with solar produced from parking canopies would not be permitted.”
The DER AC also recommended that the Ministry implement a self-assessment and compliance declaration model, similar to the Ministry of Environment and Climate Change’s Environmental Activity and Sector Registry for eligible ground mounted solar projects up to 500 kW.
In a separate submission to the IESO, the DER AC commented on the “Non-Emitting Resources Request For Information” (NER-RFI). After acknowledging the NER-RFI provides a strategic opportunity to engage with industry for the purpose of learning more about the capabilities of resources to meet future electricity system needs, the DER AC’s submission focused on ensuring the scope of NER-RFI recognized the value of DER resources.
The submission highlighted DER benefits saying, “Not only can DERs help meet province-wide system needs, DERs can help meet local and regional system needs as well (e.g., off-setting the need for new transmission or distribution, reducing line-losses, etc.). The NER RFI should recognize the broader system value of resources, including resources developed at a smaller-scale, and encourage respondents to articulate “value-add” in their submissions.”
The submission also stated the need to provide timely input into the Market Renewal Program. While the IESO is scheduled to have final decisions and high-level design options for the proposed single schedule market and incremental capacity auction by the end of June 2018, the NER-RFI is scheduled to carry on until early 2019. If the outcome of the RFI is to be considered in the design process, some kind of adjustment to the sequencing appears to be necessary.
The DER AC has a number of connections to APPrO and the two organizations have expressed interest in collaboration. APPrO provides advocacy, networking and representation services in association with other generators based in Ontario, including DERs, whereas the DER AC is focused on the mobilizing of expert advice on DERs for the purpose of developing a DERs Roadmap for Ontario.
For more information on the DER AC, contact Jim MacDougall (Compass Energy Consulting) or Sarah Simmons (Power Advisory LLC).