Development of a New
Large Renewable
Procurement Process
Initial Engagement Feedback and Interim
Recommendations
Report for the Minister of Energy
Prepared by the Ontario Power Authority
August 30, 2013
Intentionally left blank
Development of a New Large Renewable Procurement Process
Initial Engagement Feedback and Interim Recommendations
Report Contents
Executive Summary ..................................................................................................................... 5
1.
2.
3.
4.
Introduction and Background .............................................................................................. 7
1.1
Context ...................................................................................................................... 8
1.2
Methodology ............................................................................................................. 8
What We Learned Previously............................................................................................... 9
2.1
OPA-IESO Electricity Planning and Siting Review......................................................... 9
2.2
LTEP Review and Update .......................................................................................... 10
2.3
Prior Competitive Procurements .............................................................................. 10
2.4
Procurement Practices in Other Jurisdictions ........................................................... 12
What We Heard During the LRP Engagement .................................................................... 13
3.1
Webinars ................................................................................................................. 13
3.2
Meetings.................................................................................................................. 14
3.3
Written Submissions ................................................................................................ 15
Interim Recommendations ................................................................................................ 16
4.1
Process Leading to the Launch of the Large Renewable Procurement ...................... 16
4.2
Components to be Included in the Large Renewable Procurement ........................... 18
Appendices ............................................................................................................................... 21
Appendix A: Key Question Themes for Feedback Consideration......................................... 21
Appendix B: Comments and Questions Received During Webinars .................................... 23
Appendix C: List of Meeting Participants............................................................................ 43
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Development of a New Large Renewable Procurement Process
Initial Engagement Feedback and Interim Recommendations
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Development of a New Large Renewable Procurement Process
Initial Engagement Feedback and Interim Recommendations
Executive Summary
The OPA has been procuring renewable energy generation capacity for the province since our
inception in 2005. Most recently this has been accomplished through the standard offer Feed-inTariff (FIT) program. On June 12, 2013, the Minister of Energy directed the OPA to remove
‘large’ projects (generally those greater than 500 kW) from the FIT program and to begin
developing a new competitive process for the procurement of large renewable energy capacity.
The Minister also instructed the OPA to engage with municipalities, Aboriginal communities and
stakeholders on the development of the new process and report back with interim
recommendations by September 1, 2013. This report summarizes the results of the OPA’s
engagement and other research activities and provides the OPA’s interim recommendations.
To begin developing the new competitive process, the OPA examined the previous competitive
procurements, both for renewable and other generation technologies and the lessons learned
from these procurements. Research was also conducted into procurement practices for large
infrastructure in other jurisdictions and industries. Feedback and recommendations were
gathered from the other engagement processes, such as the joint OPA-IESO work on regional
planning and large energy infrastructure siting, as well as from the engagement specifically
undertaken for the current large renewable procurement process development.
To gather feedback, the OPA facilitated various engagement activities for municipalities,
Aboriginal communities, industry associations, the general public and other stakeholders. This
included hosting three webinars and nine meetings at which over 350 people participated. In
addition, over 50 written submissions were received during the two-week initial engagement
and feedback period.
After considering all the feedback, other recent engagements, research and past OPA
procurement experience, the OPA proposes the following interim recommendations for the
Minister of Energy’s consideration.
Leading to the launch of the procurement

Continue and expand the municipal, First Nation and Métis, and stakeholder
engagement activities in the fall of 2013

The Long Term Energy Plan (LTEP) should advise on quantity and timing of new
resources to be procured
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Development of a New Large Renewable Procurement Process
Initial Engagement Feedback and Interim Recommendations

Generation procurement should follow the provincial and/or regional electricity system
need

Conduct multiple successive rounds of procurements (e.g., whether by technology, size
or area of need)

Procurement need, goals and expectations need to be clearly set out and understood by
all parties

Municipal electricity generation preferences should be considered

Conduct local outreach prior to procurement commencement
Components to be included in the procurement

Continue procuring through the Request-for-Proposal (RFP) model

Project bid price should remain a key RFP evaluation factor

Proponent experience and financial capability should be considered

Continue to encourage community, Aboriginal, municipal and public sector entity
participation through procurement incentive mechanisms

Site due diligence evidence should be required

Interconnection information and cost estimates provided earlier in the process

Provide greater municipal control over land use and siting

Require community engagement sessions and council deputations during the RFP phase

Minimum community acceptance criteria should be considered


Further clarity on OPG participation is needed
Conduct further research on technology bundling
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Initial Engagement Feedback and Interim Recommendations
1.
Introduction and Background
On June 12, 2013, the Minister of Energy directed the OPA to make changes to the FIT Program,
including removing ‘large’ projects from the program. An excerpt from Minister’s Direction is
provided below.
The OPA shall not procure any additional MW under the FIT Program for Large FIT
projects (i.e., projects that are larger than Small FIT projects) and shall begin to
develop a competitive process for procurement of large renewable energy capacity.
In developing the competitive process, the OPA shall engage with municipalities to
help inform the identification of appropriate locations and siting requirements for
future renewable energy projects. The OPA shall also engage with and consider input
provided by stakeholders and Aboriginal communities as it develops the process and
report back to me with interim recommendations by September 1, 2013.
It is the government’s expectation that this engagement will support the
development of a competitive procurement process for large renewable energy
projects that takes into account local needs and considerations before contracts are
offered. A Minister’s direction will be issued at a later date to authorize the
commencement and content of a competitive procurement following the completion
of the Long-Term Energy Plan review.
In order to meet the Minister’s requirement to provide interim feedback on future large
renewable procurement (LRP), that is, for projects generally larger than 500 kW, the OPA
conducted initial engagement activities with municipalities, Aboriginal communities and
stakeholders. In addition, the OPA leveraged considerable previous work, including previous
procurement processes and feedback received during other recent engagement activities.
This report discusses the feedback received through the described engagements and ultimately
focuses on providing initial (or interim) recommendations on a new competitive procurement
process for large renewable projects. This report does not discuss recommendations for
identifying the quantity or types of renewable generation facilities that may be required. It is
anticipated that the current Long Term Energy Plan (LTEP) initiatives, once concluded, will
provide input into the LRP process and serve to shape certain attributes of future calls for large
renewable energy capacity.
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1.1
Context
From 2004 to 2008, the Ministry of Energy and the OPA competitively procured 1,565 MW of
large renewable energy capacity through multiple phases of the Renewable Energy Supply (RES)
procurement (RES I, II, III). Concurrently, from 2006 to 2008 the OPA led the Renewable Energy
Standard Offer Program (RESOP) and procured 862 MW of projects under 10 MW in size.
Following the conclusion of the final RES III phase and halting of RESOP, in 2009 the OPA moved
entirely to a standard offer procurement for renewable generation facilities, under the Feed-inTariff (FIT) Program (and the ancillary microFIT program for very small projects). Through FIT,
applicants who met standard eligibility and application requirements would receive project size
specific guaranteed prices for the energy they generated. More recently, an application ranking
system in the form of priority points and capacity set asides was established to encourage
participation and engagement from Aboriginal groups, communities, municipalities and public
sector entities. As at July 1, 2013, the OPA had contracted 4,684 MW of capacity under the
FIT/microFIT Programs, 4,321 MW of which are Large FIT sized projects.
1.2
Methodology
Over the summer of 2013, the OPA was involved with two related major engagement activities:

the OPA-IESO work on improving regional electricity planning and the siting of large
energy infrastructure, and

the Ministry-OPA work on the LTEP update.
As these activities took the OPA across the province, we engaged with many of the same parties
interested in renewable energy procurement immediately prior to the commencement of the
LRP engagement process. Accordingly, we reviewed all feedback previously received and
compiled items that related to renewable energy. In addition, the OPA was able to draw on its
considerable previous experience with competitive procurement processes, both for renewable
generation projects and other generation facilities. Finally, the OPA conducted a global scan of
competitive procurement processes in other jurisdictions and industries.
The OPA conducted a compressed series of engagement activities to notify stakeholders that
development on the new LRP process was commencing and to begin the process of receiving
preliminary input. Engagement activities were conducted as follows:
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
August 1, 2013: Public web posting on the OPA webpage indicating the development of
a new competitive process, dates of webinars, timelines for meetings, and instructions
on how to provide written feedback submissions.

Simultaneously, email notifications with the above information were sent to Aboriginal
groups, municipalities, industry associations, FIT Program subscribers, and discontinued
Large FIT proponents.

August 7, 2013: Meeting invitations were sent to Aboriginal communities, municipal
associations, industry associations, and discontinued Large FIT proponents.
Three webinars were held on August 7 and 8 to collect feedback from municipalities, Aboriginal
communities, and the general public and stakeholders. The webinar included a short
introductory presentation and a question and answer session structure around seven key
question themes. The questions are included in Appendix A.
Nine meetings were held August 12 to 26 and followed a similar format to webinars though with
more emphasis on targeted feedback and discussion. Discussion highlights are detailed in the
‘Meetings’ section of this report.
Throughout the course of the engagements, written submissions were received via
LRP@powerauthority.on.ca and open for anyone to provide feedback. Submission highlights are
detailed in the ‘Written Submissions’ section of this report.
2.
What We Learned Previously
2.1
OPA-IESO Electricity Planning and Siting Review
In May 2013, the Minister of Energy asked the OPA and the IESO to develop recommendations
for a new integrated regional energy planning process that would focus on improving how large
energy infrastructure projects are sited in Ontario. The final report was published on August 1,
2013 and of the 16 recommendations, several are relevant to large renewable procurement,
namely:

Strengthen processes for early and sustained engagement with local governments and
the public.

Provide local governments and communities with greater voice and responsibility in
planning and siting.

Consider broader criteria in the generation procurement process, such as local priorities

Consider including OEB review of new generation procurement processes.
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These recommendations were developed using feedback received over a six-week period from a
broad base of participants and using various mechanisms, including a web survey, webinars, inperson meetings, formal submissions and 18 regional sessions across the province. While not
specifically targeted during the engagement activities, considerable feedback was directly
related to renewable energy projects. Some themes of note included:

A desire for more and earlier opportunities for community/municipal engagement (e.g.,
during project evaluation and prior to contract award).

Include a broader set of project evaluation criteria, including an increase in the
weighting of non-economic factors.

Use the LTEP and regional planning processes to provide a context and establish need.

Pick willing hosts.

Develop a clear, transparent, well communicated process.

Identify potential sites through municipal Official Plans.

Site electricity infrastructure close to need.

Ensure a rational comparison of alternatives, subject to public input.

Opposition to wind generation.
The final report and the complete collection of submissions are available at the following
webpage: www.onregional-planning-and-siting-dialogue.ca.
2.2
LTEP Review and Update
Similar to the feedback received during the OPA-IESO engagement activities in June and July
2013, it was anticipated that the Ministry-led engagement activities related to the LTEP review
would also yield feedback relevant to the new large renewable competitive procurement
process. However, the LTEP review engagement process is ongoing and feedback is still being
accepted (until September 16, 2013) via the province’s Environmental Registry. At the time of
writing, the OPA was not able to review the feedback received. Therefore, it is recommended
that, when available, the Ministry of Energy share relevant LRP process feedback with the OPA
that was received during the LTEP review.
2.3
Prior Competitive Procurements
The OPA has been involved with a number of competitive procurements in the past. Overviews
of two of the more relevant or recent procurements are outlined below.
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2.3.1
Renewable Energy Supply III
RES III was issued in 2008 and called for approximately 500 MW of renewable energy supply.
The procurement used a two-stage Request for Expression of Interest (RFEI) / Request for
Proposal (RFP) methodology and was eligible to projects greater than 10 MW in size.
Proposals were assessed through a combination of mandatory requirements (e.g., proponent
identity, site control, status of environmental assessment, connection availability) and rated
criteria. Rated criteria were scored using a points system that evaluated proposals according to
the following criteria: status of environmental assessment, status of zoning approvals,
equipment availability, resource availability data, proponent team experience, and a financial
assessment.
Proposals that achieved the minimum required total point score (40/100) from the rated criteria
stage would proceed to the proposal price stage, which would determine a discounting factor to
be applied against the proposal bid.
Outcome: Of the 21 qualified proposals assessed, six projects were awarded contracts. RES III
observed relatively high success with approximately 85 per cent of the contracted capacity
having successfully reached commercial operation.
2.3.2
Combined Heat and Power IV
In 2011, the OPA issued CHP IV, an RFP for 300 MW of Combined Heat and Power (CHP)
generation eligible to projects greater than 20 MW in size.
CHP IV also utilized a number of mandatory proposal completeness requirements not unlike
those identified as mandatory requirements in RES III. However rather than evaluating on rated
criteria, proposals were required to meet minimum thresholds for 19 mandatory administrative,
technical, financial, experiential, and performance requirements. Proposals that met these
pass/fail requirements would proceed to economic bid evaluation and those successful would
be screened for connection availability.
Outcome: Of the three proposals submitted, two successfully proceeded through the evaluation
process, however no project was awarded a contract. It is important to note that the
procurement was considered successful. The objective of the procurement was to contract with
projects that met all the mandatory requirements at a reasonable cost to ratepayers.
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2.3.3
Lessons Learned
In both cases, the RFPs had minimum criteria that had to be met for the project to have a
chance at success in advancing through the procurement process. The RFPs differed in the way
projects were evaluated. Following both procurements, it was recognized that it is important to
attain a balance between identifying enough specificity in the RFP technical requirements while
not setting overly prescriptive thresholds that constrain flexibility in project proposals.
2.4
Procurement Practices in Other Jurisdictions
A number of large procurement case studies were reviewed to explore different approaches in
procuring large infrastructure projects. Examples of the case studies reviewed included the 2012
Nova Scotia large renewable energy procurement, the 2008 BC Hydro clean energy
procurement, the Texas transmission procurement, Canada’s national shipbuilding procurement
strategy, and Infrastructure Ontario’s Highway 407 East procurement.
Overall, procurements that were considered “successful” had very similar elements to the
procurements that the OPA previously conducted; including RES. RFPs continue to dominate
large procurements, with auction processes a close second. Although the research did not
identify one or more specific elements that have not been used or considered by the OPA for its
procurements, the research did help to affirm best practices and various procurement elements
to be potentially used in the future LRP process.
2.4.1
Common elements in successful procurements
Almost all of the large infrastructure procurements carried out by government bodies that were
examined had a set of common elements that were attributed to the success of those
procurements. Those common elements included:

Active consultation, communication and engagement with potential proponents.

No political involvement within the process.

Third party expert advice.

Transparency and fairness monitoring.

Competitive friction to drive value.

Consistent information available to potential bidders through one source.

Price not being the only deciding factor; proper allocation must be given to ability of the
proponent to execute and deliver on the project.
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3.
What We Heard During the LRP Engagement
3.1
Webinars
3.1.1
General Public and Stakeholders
The public and stakeholder webinar was held on August 7, 2013 from 2–4 pm. There were 328
people participating on the web and an additional 34 via telephone. There were 203 questions
or comments received via the web and fewer than 10 additional questions over the phone. The
full details of the questions and comments can be found in Appendix B. The following
summarizes the main feedback received:

Many participants suggested that with the right parameters, an EOI/RFP or similar
process would be an appropriate method for procuring large projects. However, some
indicated concerns that an RFP process would limit participation to only large
proponents and make it difficult for community groups to compete.

Several comments suggested separate procurements for different technology types and
sizes. Significantly fewer participants indicated that all technologies should be forced to
compete among different technologies on price. It was suggested that ‘large’ projects
should be further split into size tranches to enable smaller players to compete for
smaller sized projects.

Several participants indicated that some form of ranking or prioritization of Aboriginal
groups, cooperatives, or public sector partnership projects should maintained in a
future LRP process. Preference for FIT-style adders or similar incentive scheme was also
indicated.

Regional electricity planning processes should drive procurement requirements and be
tied to the new LRP process.

Considerable feedback indicated that communities and municipalities should be
engaged during siting of potential projects. Some respondents suggested municipalities
should have final input on siting prior to proponents being offered contracts.

Most participants indicated that proponents should be evaluated against one another
on non-price factors such as level of community involvement, municipal engagement, or
social benefit. However suggestions were mixed on how to appropriately measure these
attributes.

Transparency in the connection testing process is important. Many suggested that a
TAT/DAT-like process would be helpful in a future LRP process.
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
Concerns were raised about the role of Ontario Power Generation (OPG) in the future
competitive process. Further clarity was desired on how this may impact the
competitive field between government-owned OPG and independent power producers.
3.1.2
Municipalities
The municipal webinar was also held on August 7th. There were 35 participants on the web and
one on the phone. Approximately 50 questions or comments were received. These can be found
in Appendix B. Highlights included:

Municipal support and local participation are important factors in achieving project
acceptance in a community.

Project siting guidelines/restrictions should better align with local municipal guidelines
and zoning (e.g., similar to Industry Canada’s accommodation of “local protocols” for
the siting of radiocommunication antenna towers).

Better align project approvals with municipal site plan approval process requirements.

Difficult to provide project support prior to completion of detailed environmental
studies, site plan drawings and community engagement.

Suggested following community engagement practices established under other
processes (e.g., Official Plan development or aggregate extraction facility licensing).
3.1.3
First Nations and Métis
The First Nations and Métis webinar was held on August 8, 2013. The session was not well
attended, with no community participants—likely a result of the compressed timeframe and
scheduling of engagements over the summer months. The session was conducted and archived
similar to all other OPA webinars. As a result, it is strongly recommended that additional
engagement activities specifically tailored toward First Nation and Métis communities be held in
the fall to encourage higher rates of participation.
3.2
Meetings
In-person meetings were held with municipal associations, industry associations, FIT
stakeholders, an Aboriginal community and individual proponents who requested meetings. The
full list of meeting participants is included in Appendix C. In general, meeting participants used
the sessions to obtain additional clarity on the possible future LRP process as well as a
supplement to their written submissions.
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3.3
Written Submissions
Written submissions were received from 52 submitters during the 14-day feedback period. The
majority of the submissions were provided by independent project developers and industry
associations. Feedback was also received from manufacturers, cooperatives, municipalities,
individuals and an Aboriginal group. There were areas where there was general agreement
across submitters, such as holding different procurements for different renewable energy
technologies and project sizes. There were also areas where opposing viewpoints were heard,
such as procurement preference given to larger, experienced project developers versus local
community groups.
Some of the themes covered in various submissions are identified below.

Separate procurements based on technology (e.g., solar should not compete against
wind)

Different procurements for different size tranches (e.g., < 10 MW vs > 10 MW)

Expand FIT to include projects < 5 MW

Municipal involvement in decision making

Municipal involvement, but no veto

Additional flexibility needed in the LRP for FIT solar land use restrictions

Land use and siting criteria should be handled by municipalities (e.g., they should be
allowed to waive blanket requirements)

Public meetings needed during proposal phase to inform communities of proposed
projects

Strike a balance between impact on ratepayer (and competitiveness of province) and
promotion of ancillary benefits (e.g., job creation, environmental improvements)

Small, community based groups should be prioritized

Aboriginal communities should be prioritized

Municipal, Aboriginal, community or co-op involvement should take priority

Developer experience and track record should receive higher weighting

Higher security deposits should be required

Financial wherewithal should be assessed

Maintain capacity set asides and price adders

Maintain the FIT pricing

Maintain the FIT prioritization system

Incentives should be included to encourage local sourcing
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
An RFP process is appropriate – the EOI phase is not needed (shorter/single-stage
procurement timeframes preferred)

An EOI/RFP process is appropriate

An RFQ/RFP is more appropriate than an EOI/RFP process

Better inter- and intra-government as well as agency coordination required around
project approvals

Regular procurement ‘windows’ required to provide industry stability

Align procurements with regional energy planning and LTEP

Waive the 120% solar DC/AC limit

Concerns about government-owned OPG participation in procurement and unfair
advantage over independent power producers

4.
Include energy storage technologies in the LRP
Interim Recommendations
Incorporating the lessons learned from previous competitive procurements, research conducted
into practices in other jurisdictions, feedback and recommendations from the other recent
engagement processes, and feedback received during the initial LRP engagement process, the
OPA proposes the following interim recommendations for the Minister’s consideration. These
interim recommendations cover both the lead-up to the launch of the large renewable
procurement as well as components to be included in the large renewable procurement process
itself.
4.1
Process Leading to the Launch of the Large Renewable Procurement
1. Continue and expand the municipal, First Nation and Métis, and stakeholder
engagement activities in the fall – while valuable feedback was received through the
initial engagement activities, these activities were held during the summer months, at a
time when the OPA and the Ministry of Energy were conducting a number of other
outreach activities. Continuing the engagement would allow the OPA to report back on
these interim recommendations and to conduct additional outreach in individual
communities across the province, and especially with First Nations and Métis
communities. Continuing the engagement activities would also allow the OPA to
incorporate the feedback that is being received by the Ministry as part of the ongoing
LTEP review.
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2. The Long Term Energy Plan (LTEP) should advise on quantity and timing of new
resources to be procured – no large renewable generation procurement process(es)
should be launched prior to the completion of the LTEP review and required in-service
dates for new generation supply resources. Following this, an adequate period of time is
needed to adequately develop the required material for any new procurement.
3. Generation procurement should follow the provincial and/or regional electricity
system need – need may be identified as provincial or regional supply or a combination.
Further to the OEB’s and the OPA-IESO’s work earlier this year on the regional electricity
planning processes, procurement for new renewable generation should follow the
identification of regional need and associated timeframes where possible. As generation
need and timeframe is identified (e.g., through a regional electricity planning study or
other planning process), the OPA would be positioned to conduct competitive
procurement(s) to meet that need. This regional basis should be considered in
coordination with any province-wide procurement initiatives.
4. Conduct multiple successive rounds of procurements (e.g., whether by technology,
size or area of need) – one size does not fit all when discussing large renewable
projects. A message heard consistently from all participant types was the need to hold
different procurements, whether for different technologies, project sizes or areas of
need. As a baseline, consideration should be given to splitting ‘large’ projects down
further into at least two tranches. The larger (e.g., >10 MW) should be focused on
experienced commercial electricity project developers with the experience and
resources to bring projects to successful completion. Mid-sized projects (e.g., 500 kW –
10 MW) could encourage partnerships (Aboriginal, community, municipal, etc.) and
prioritize various social factors.
5. Clear expectations and understanding are required from all parties to define a
successful procurement outcome – procurement need, goals and expectations need to
be clearly set out and understood by all parties – these must be established prior to
commencement and reinforced throughout the process. Few large infrastructure
procurements ever have unanimous support, yet most have successful outcomes.
6. Municipal electricity generation preferences should be considered – a municipality
may be opposed to certain technologies, but supportive of others. Alternately, a
community may oppose all renewable generation, but be willing to consider other clean
energy options. A mechanism to reflect these municipal and community preferences in
the province-wide and regional plans should be considered in both planning and
procurement processes, such as advisory committees as recommended in the OPA-IESO
electricity planning and siting review report.
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7. Conduct local outreach prior to procurement commencement – prior to the
commencement of any procurement activity in a given electricity region, the OPA, or
the Ministry of Energy in the case of a procurement not directly stemming from a
regional planning study or identified need, should conduct tailored outreach in that
electricity region. The focus of this outreach should be to explain the procurement
process, solicit additional feedback and help cultivate greater local voice and
responsibility.
4.2
Components to be Included in the Large Renewable Procurement
8. Continue procuring through the Request-for-Proposal (RFP) model – participants
overwhelmingly favoured the RFP model. While there were differing viewpoints around
using a pre-qualification or pre-screening process such as a Request for Qualifications
(RFQ), the OPA believes such a tool is a valuable method of narrowing the field in any
procurement process and should be continued.
9. Project bid price should remain a key RFP evaluation factor – this would ensure the
greatest ratepayer value as well as provide additional price discovery for other
procurement programs. In addition, public bid price disclosure and market clearing
options should be further considered to increase price transparency and market-driven
pricing.
10. Proponent experience and financial capability should be considered – while project
participation by various groups and entities should be encouraged, it is imperative that
proponents have adequate experience and financing to fully develop their projects. To
that end, the full project team should be identified early in the procurement process,
e.g., proponent, environmental consultant, EPC providers, financiers, partners, O&M
provider, and major equipment suppliers. Both corporate experience and core project
team member experience, in Ontario and elsewhere, should be listed.
11. Continue to encourage community, Aboriginal, municipal and public sector entity
participation through procurement incentive mechanisms – rather than maintaining a
points system and Contract Capacity Set Aside concept similar to FIT, employ a tiered
incentive structure that is better aligned with a competitive procurement process (e.g.
price discount factors or evaluation criteria weightings).
12. Site due diligence evidence should be required – to ensure that proponents are
reasonably certain their sites are viable, pre-proposal design and environmental work
should be required through the proposal evaluation criteria. Some items that could be
considered include site design drawings including required connection line,
commitments that all required private land access has been secured for the full project
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requirements, some environmental work completed (e.g., phase 1 and 2 environmental
site assessments or REA component studies) and commencement of REA/EA
consultation activities (e.g., first public meeting held).
13. Interconnection information and cost estimates provided earlier in the process –
currently under FIT, the OPA provides province wide information regarding
transmission-level connection availability and LDCs provide information on distributionlevel availability. Detailed connection information and costs estimates are only provided
by the LDC/transmitter after an interconnection assessment is secured following OPA
contract execution. The OPA should explore new methods with the OEB, LDCs and
transmitters (and electricity consultants) to enable proponents to get a better indication
of connection information and connection costs for proposal purposes. This would be in
alignment with the OPA’s goal of increasing transparency of, and access to, useable data
and information.
14. Provide greater municipal control over land use and siting – the OPA should continue
to reflect government policy priorities and set baseline land use (e.g., zoning and soils)
restrictions in a similar fashion to FIT, however, municipalities should be allowed to
relax the restrictions if this would better align with the local municipality’s goals.
15. Require community engagement sessions and council deputations during the RFP
phase – engaging the local community early is a key message that has been received in
all recent outreach activities conducted by the OPA and our electricity partners. As there
may be different feedback provided from the grassroots, Aboriginal and local
government levels, pre-contract engagement activities should include these audiences.
16. Minimum community acceptance criteria should be considered – these criteria could
extend beyond environmental or regulatory requirements, and focus on acceptable
standards for a project in a community. Aboriginal communities and municipalities
would be able to get more involved if interested, and if disinterested could defer to the
standard.
17. Further clarity on OPG participation is needed – clear requirements and robust
processes need to be established and openly communicated to ensure an understanding
of the playing field for all participants, whether government owned or privately held.
18. Conduct further research on technology bundling – different renewable technologies
have different electricity generation profiles, with varying abilities to follow load
patterns. To date, Ontario has procured renewable generation discreetly by technology.
There may be ways of meeting electricity load needs through a bundling of various
technologies in a single project solution. This could also include the use of storage
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technologies. The OPA would like to further explore bundling, perhaps through a
competitive procurement for pilot technologies.
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Appendices
Appendix A: Key Question Themes for Feedback Consideration
1. OPA has generally used EOI/RFP processes for previous competitive procurements. Is
this still appropriate or should another selection method be used? If other, which?
Why?
2. Are there aspects of the FIT program that should be included in the new competitive
process? Are there aspects that should not?
3. Competitive procurements typically evaluate projects on a number of factors/criteria.
One is typically price/cost. Are there other measurable factors/criteria that should be
considered?
4. FIT is open to waterpower, wind, solar (rooftop & non-rooftop), renewable biomass,
biogas and landfill gas. The new ‘procurement’ could be for any project > 500 kW.
Should there be any differentiation between procurements? If so, why?
a. Different procurements for particular technology types?
b. Different procurements for different project size tranches?
5. Communities are increasingly interested in hearing about potential projects early in the
development phase. Keeping in mind that some projects competing in a competitive
procurement may not be selected, what type of community engagement should be
required prior to project evaluation? How should the OPA measure the adequacy of
community engagement?
6. Are there any specific criteria or requirements that should be considered in a
competitive procurement to inform the identification of appropriate project locations
and siting requirements?
7. Are there any specific criteria or requirements that should be included in a competitive
procurement that relate to First Nation or Métis community participation or concerns?
8. Is there anything else you would like us to consider? A number of other engagements
have recently been conducted (e.g., OPA-IESO Siting of Large Energy Infrastructure, LTEP
engagements). Do you have any feedback to reiterate during this process or anything
new to provide?
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Appendix B: Comments and Questions Received During Webinars
Note: Comments and questions are listed as received, with minimal changes including the removal of names.
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Why is there a need today to change the procurement process?
What are the alternatives to the RFP? (Q1)
Appropriate, but need to consider involvements of First Nations and other communities. An EOI or RFP process would be appropriate if
the above is considered. Will the OPA following this approach
Can we expect a priority of some kind for large projects that are community or aboriginal owned as opposed to privately held, given their
likelihood of increased community benefit and acceptance?
In the bid process will the RFP's be weighted or scored and if so how? Will OPA divulge what the weight criteria will be?
What role is Ontario Power Generation expected to have in the RFP process? I believe OPG was identified in the Minister's directive, but it
was not clear how a level playing field would be maintained between OPG and IPPs.
Will the OPA follow annual installed capacity targets for the large-scale RFP program? If so, have those annual MW targets been set? Are
the targets public?
Will there be a strict requirement that projects be located in the Province of Ontario only? Kind Regards.
Has a period/duration been decided in regards the proposed RFP process? I.e. 2 weeks, 4 weeks, 8 weeks
Can you provide an example of the scale and size for different renewable energy projects? For example, how many wind turbines vs. solar
panels would be required to generate 1MW?
Will you or have you created a financial model for minim project feasibility? How will you manage proponents under bidding contracts
during the process?
Will future large-scale renewable procurements focus on wind and solar, or could it also include other, more infrequently procured
renewable technologies such as pumped storage?
The feasibility and timing of new large FIT projects depends to a large extent on the progress and timing of priority transmission projects.
Uncertainty over progress in that area is likely a cause for significant uncertainty for the large FIT program, in most areas. Can you tell us
what the OPA is able to do to reduce uncertainty related to transmission connection capacity?
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Agreed this is the best method (EOI/RFP) going forward, as long as the greatest number of projects is allowed to participate for achieving
best price outcome for OPA. This is after all the main objective in such a procurement, cheapest power. However, given the opposition to
many large renewables projects, RFPs must be strict about the projects level of advancement, social acceptance, maturity with concrete
milestones to factor into a discount factor, multiplied by the bid price, as per RESIII.
In the first round or designated set of rounds of the RFP process that you have outlined could a pass fail component be added that
requires a FIT time stamp currently in the system
Is this program an alternative for FIT? Are there any limitations as to the size of the projects? Like 1 MW less or more? What are the
differences between this program and FIT?
Will there be an opportunity for hybrid renewable /non-renewable project, like geothermal plus CHP?
What are the time lines on the EOI/RFP process? One of the problems with FIT was the extreme delays in moving project proposals
through the system and awarding of contracts.
is this a "reverse auction" process like the former RES process (i.e., lowest price gets first offer, second lowest the second offer, etc. up to
the procurement limit?)
I think the RFP process would be preferred over an auction process.
a follow-up comment (ref a question by another caller)... in Quebec, la Regie de l'Energie publishes the full unredacted contract on
projects retained in a RFP
Brazil has gone through auctions in the past and it has drive prices to ultimate bottoms which is not good for the future or the
sustainability of the industry.
Our feedback is that the RFP process will limit participation to a select few companies which will make the process less competitive. I think
it's reasonable to consider the experience of the applicant, however, if the bar is set too high and limits participation to large or publicly
traded companies, this would not be desirable or fair to the industry. It's important to grow the industry, increase competitiveness, and
not create an oligopoly. In addition, the auction process could result in a speculative bidding resulting in unfinanceable projects that never
get built.
In my opinion, these applications should be treated in a manner similar to aggregate applications. In addition to the required up-front
planning process, there should be a requirement for operators to enter into agreements with the local municipality to address road and
bridge issues, etc. Alternatively, and like the Aggregate Resources Act, the OPA should consider imposing an annual royalty per KW
produced.
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Just like any other land use, the establishment of renewable energy facilities should consider local, County and provincial land use policies
(i.e. local and county official plans).
For question 1 RFP process too expensive for community groups. you will eliminate community groups if you go just rfp. unless there is a
set aside for community
An RFP is an appropriate procurement process for large projects. Does the OPA have a view on maximum project size? There are
economies of scale for projects in the 50 - 100 MW range. Any cap should be set high enough to capture these benefits. Does the OPA
contemplate any Domestic Content requirement?
Proximity to sensitive land uses or approved sensitive uses not yet developed/built, consideration of visual impact on for tourism or scenic
areas, environmentally sensitive areas. These would be things that the municipality may consider important that may not be captured in a
review by provincial agencies. Local conditions vary and should also be considered not just the overall Provincial view. Some of this may be
being caught in current reviews but if project not approved in our municipality we may not be aware of how that has been applied so need
to be clear.
The two approved projects in [name removed] include Class 1-3 lands, but were approved because they are zoned Rural. We would not
want to see this happen again.
I was thinking simply of the legislative notice requirements which could potentially include: notice of an application, an open house, public
meeting followed by notice of the decision. Each of these steps could be modified for a competitive procurement project from notice of a
proposal, an open house to discuss the proposal in an open forum, a formal public meeting before a local council to discuss the proposal
with potential support granted.
As planners we generally try to preserve some natural and cultural vistas. There are certain areas that the Township and likely other
municipalities would not want a project to interfere with those vistas.
Yes we would have vistas that would not be listed.
Environmental impacts and local Council approval.
Staying away from lands that are zoned EP
Load matching with local load would be a factor to consider as it support smart grid, and reduce demands to expand the grid. Example
CHP could be prioritized to balance existing solar sources. The value of CHP is higher value because it does not need stand by capacity.
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In regard to environmental impacts, our area is within the Severn Sound Watershed that was the subject of a Remedial Action Plan in the
early 80's and has tree cover targets. These targets should be respected and tree planting offsets should be a requirement along with the
protection of interior forest habitat and storm water management for quality and quantity.
6. Proximity to residential areas, environmentally sensitive areas, agriculturally sensitive areas, proximity to other renewable energy
project locations.
NYSERDA allows bidders to resubmit RFP's with changes (if it scores high, NYSERDA desires it, and there is a fir) will you allow the same?
Looking for input on the "development of the new procurement process" and asking the OPA to maintained large projects in limiting their
output to 5 MW peak.
When looking at historical criteria, should municipal involvement count in multiple parts to the bid process moving forward? For example,
with project permitting, financial and team experience the municipality is now more of a “partner” in the project.
How would a Municipality be involved or would there be any form of public consultation in a competitive procurement process and at
what stage?
Also, an important aspect of picking the right process is understanding the size of the procurement opportunity. What kind of range of
procurement, in terms of size, that the OPA is contemplating? If we are going to procure 150 MW, like in the Small FIT, it would not make
a lot of sense creating a program where the administrative costs of the application process would be unreasonably expensive.
2 Questions: 1) Has it not already been mandated that "Large procurement" of renewables be competitive (via Ministerial Decree in June)
- hence is this discussion a moot point? 2) "Large Procurement" targets >500kW is admittedly large for solar but does not currently cover
single turbine wind projects, let alone large procurement thereof. Will different strata of procurement sizes be contemplated to account
for differing economies of scale (eg. 500kW-10mW, +10MW)?
As stakeholder, our Co. has already prospects interested in large projects then we would like the OPA to maintained large projects in
limiting their output to 5 MW peak.
Will there be any regional 'limits" based on regional grid capacity?
I agree that Municipal-owned/participation projects should get some form of "advantage" over privately-owned, given that these are
reviewed and approved by municipal council in an open and public process
Will there be a requirement, as there was in FIT, that projects be located in the province of Ontario? Kind Regards.
You should preserve priority ranking for Community Projects. It's important to preserve the Ministry's directive and not create a program
that would disadvantage co-ops, public sector, and aboriginal groups in comparison to the Small FIT program.
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Since the physics of system operation require reactive power and active power inputs should the new process pay for kVa and not watts.
Will the process allow compensation for "smart inverters that may involve some aspect of co-inverter control by the system.
What are the timelines and milestone to OPA's Large Solar Procurement policy and procedure? When will we have a firm process in place 1Q14, 2Q14, 1Q15...? When will this process of "review" end and the Large Solar Procurement going live? The last time the OPA
"reviewed" FiT tariffs the solar industry was substantially in limbo for about 18 months and we lost solar jobs and industry participants.
Does the zoning criteria in these projects will be different from FIT 2.1?
Would the OPA consider priority for projects that include skills training aspects such as the Federal programs run for Aboriginal youth?
From a manufacturer's perspective if you decide to incorporate local content somehow it would be preferential not to change the rules
drastically from the fit program. The amount of capital investment to alter existing manufacturing lines would be punitive. Alternatively
get rid of the local content requirements all together.
Splitting the "large FIT competitive process" in additional size tranches, will enable the smaller players (municipalities, co-ops) to have at
least a better chance of getting contracts in the 500KW-2 MW range. Will this be considered?
One aspect of the FIT Program that should be included is the periodic publication of DAT/TAT tables.
How if any considerations is OPA taking of the effects the WTO ruling could affect the large scale RFP process?
Municipal support for the evaluation of projects is key for community acceptance. Opportunities for conditional support would also be
helpful (without frustrating the goals of the Green Energy Act).
Conditions for municipal support such as siting preferences, community benefit agreements, etc.
A concern our municipality has is that often energy applicants attempting to procure energy do not have sufficient detailed designs for
staff to review the appropriateness of the project. What's the balance between providing municipalities with enough information without
requiring applicants to overspend on design details?
Municipalities need some ability to have agreement with the proponent for things like buffering and fire department access etc.
The question is more of timing. We require those details to properly review the project prior to giving them municipal support, for
example, and this would occur prior to the REA process.
[name removed] The Premier has used the term “Unwilling Hosts”. Since this time many municipalities have passed motions declaring
themselves as “Unwilling Hosts.” Will this be taken into consideration during the approval process?
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If community engagement includes the Proponent meeting with the public without the approval authority at that meeting, then some
representation from the OPA should be be at those public meetings.
Engagement should not be a 'token' process. Opportunity for early and meaningful input that will be specifically considered as part of any
project being designed or sited.
Question 2. The sign-off sheets required from the Municipal Planner could still be required but should be changed to better to reflect the
types of provisions in rural Zoning By-laws which typically permit a single detached dwelling on all Rural zoned properties which is typically
where proposal could be located as not Class 1, 2 or 3 soils, but ruled out due to the requirement that a dwelling cannot be a permitted
use on adjacent land (Rural Zones).
As a first step, a presentation should be made to Council as they are the people who will hear from the residents. A second step would be
a public open house/meeting with a notice being circulated to affected residents (circulation distance should be determined based on the
type of energy project being considered). At the approval stage, the Ministry of Environment should be required to issue a notice of its
decision to the affected municipality (as opposed to us checking the environmental registry).
Would suggest that a notice of application be required to municipality so that staff and council could flag potential issues or questions to
be addressed through process. Perhaps public meeting to be held for general public similar to Aggregate licensing at the beginning of
process, demonstrate how concerns addressed or attempted to be addressed. Follow-up public meetings after with detailed information
available to municipality has opportunity to review so that public also has opportunity to review and input.
Public consultation could follow that contained in the Planning Act for the preparation of a new official plan.
Community involvement could be measured through ownership levels of the community in the project as part of the project evaluation.
This gives meaningful engagement as the community has some control in the project. If a project is in your community you should have
the opportunity to participate both verbally and financially.
Under pre-consultation requirements it is required to "consult" with various agencies, such as conservation authorities, municipalities, etc.
about the project. It is suggested that more than a checklist be submitted by proponents based on this consultation - is anything changing
in the new process?
Details will form part of our submission. Local protocols (similar to the concept introduced by Industry Canada siting criteria for antennas)
could establish processes that work specifically to a local context. THis could determine the level of engagement based on impact.
Suggestion: The questions be put out prior to the session so that we can give them better consideration.
Could community engagement be tied to a priority point?
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The priority points for community engagement can be measurable based on number of sessions, timing of sessions, number of attendees
(Q5)
can municipalities be treated as community participation or they will have special status for set aside projects?
The FIT program has strict criteria of what land can or cannot be used. If municipalities support and approve of the land to be used for a
large scale project, the land criteria should be allowed to be overridden if necessary.
Municipal consultation should be a mandatory requirement PRIOR to the bidding process as it would be difficult to negotiate/discuss
concerns that need to be addressed should a contract be awarded first.
What will be done to acknowledge submissions made during fit 1.0-2.0. Priority points should be given to those in the queue who have
invested in the program in good faith.
Aspects to include community and or FN IN ALL projects Aspects not to include - a window keep it open until target met
The municipal support resolutions from FIT that award an applicant priority points should be carried forward into this process.
Are you expecting procurement windows similar to FIT and microFIT? If you were to set procurement limits on any particular technology
you risk not utilizing that procurement. ie. landfill gas.
projects that produce "baseline" power on a 24-7 basis, such as landfill gas and biogas, should get priority over intermittent power sources
like wind and solar PV
The principles and priorities developed in Small FIT should be carried into larger project. This keeps energy dollars in the province and
reduces the bleeding of energy dollars out of the province.
Although the FIT program provided a criteria for community participation, it lacked specific economic development thresholds. It is
suggested that the new procurement program must include a more rigorous economic development criteria incorporating minimum
threshold and targets.
Procurement under FIT is, for all intents and purposes, driven entirely by the OPA. Furthermore, priority points aside, FIT is still a "firstcome-first-serve" process. In my opinion, the new large scale procurement program needs a much tighter integration with LDC's in order
to be successful. In other words, LDC's should be involved in answering the "where" question with respect to whom is awarded contracts.
Aspects to include. A cure period for community projects
What is your definition of a "community" project - can it consist of a few investors from a community?
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I'd like to suggest that if you are awarded a 10 MW project, if there is only 9 MW of connection capacity available once you're ready to you
build, you should be have an option to simply reduce your contract to 9 MW and complete the project.
Perhaps it is appropriate to consider rate adders for Aboriginal and Community participation. That would help to resolve the conflict
between maintaining low bid price while maximizing local participation.
Is there a way to measure concentration or spatial distribution of projects? Impacts can be greater if multiple energy projects are
approved in a certain rural location, thereby creating a more 'industrial' setting?
While I appreciate the need to strike a balance between the amount of upfront information required relative to a contract award, there
should be sufficient info provided upfront to allow the municipality to review the material in order to make an informed decision (much
like a planning application) - there are no guarantees and the Planning Act requires a complete application.
In our experience, a detailed site plan, agricultural capability studies, environmental assessments, and storm drainage reports Addressing
tile drains and/or municipal drains, for example
re: question about similar Planning Act requirements, we would probably want to see information such as Site Plan, Landscaping Plans and
elevations, environmental impact statements, etc.
There should be different procurement process for different types of renewable generation ie) solar, wind, bio, hydro, etc.
I recommend priority be given still to community/co-operative or aboriginal projects. Our co-operative had a large FIT project in the queue
waiting for an intake and we would still like to proceed.
Will the local content requirements remain in place under the new competitive process? Having a limited number of equipment suppliers
available will not help in reducing pricing.
Aspects to include. A cure period for community
What is status of "made in Ontario" content requirement? Some sort of preferential system to advantage local and provincial business as
done in early FIT is generally a good idea.
Does the OPA currently evaluate the portion of the project cost associated with the OPA application process? If so, does the OPA try to
reduce those costs by streamlining the process and simplifying the rules? In the Small FIT process, we currently find the costs
unreasonably high.
Will Large Solar Procurement require dispatchable IT and/or energy storage? Will there be a nameplate maximum/minimum where
dispatchable compliance will be required? Will the IESO have authority to disconnect large solar procurement power? Will there be similar
pricing as Gas plants that are paid irrespective of power generation (peaker-plants)?
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The example of the EOI/RFP process that was used to procure CHP indicates that capacity availability screening only occurred later on in
the RFP process. How did this work in practice? RFPs for large-scale procurement of renewables in the US, for example, are typically done
through utilities who have ensured that adequate capacity exists on the grid at an identified location or area to connect the amount of
megawatts that are being sought through the RFP. A recommendation would be to ensure that procurement targets are area-specific and
are aligned with grid capacity from day 1. Thank you.
Recommended to keep in FIT - transparency on where existing capacity is available in the network, in lead up to procurement - Protection
(limited or whole) on curtailment and some limited compensation to cap this liability - Crown land eligible, however with non-exclusive
access to prevent gaming and to allow maximum competitive bids on best sites - some advantage to FN and Community (co-op) projects,
but not a premium or adder. Rather a discount factor on bid price for evaluation purposes
Once the solar farm is no longer useable, will there be any ability for the municipalities or the province to obtain agreements for
decommissioning included?
Avoid duplication by including municipal input into scoping exercises.
A lot of the same information could be leveraged in the planning process from the EA process but would want to include what is of
concern from municipal planning perspective.
Zoning Criteria should definitely be applied as well as the opportunity to engage in some form of a site plan consultation process to
address issues such as access, communication towers, landscaping etc.
The application process for the FIT was fairly clear in documentation and expectations - I would suggest a similar standards moving
forward
The new program could mandate tighter project execution deadlines.
We recommend including a specific category within the procurement process directed at incouraging parking lot projects. The current
zoning & soil type rules are not helpful for parking lot projects at the moment. Specifically, commercially zoned properties should be able
to do a ground-mount parking lot project. In addition, a paved parking lot should be exempt from a soil study or the obligation to meet the
CLI requirements.
In contrast to FIT which is largely a "first-come-first-serve" process with procurement driven almost entirely by the OPA, the new process
needs to have a much tighter integration with LDC's in the contract award process. With a guaranteed connection, it will lower the
proponents bid.
Municipalities and co-ops should have priority over private developers in procurement.
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Aspects of FIT that should not be kept in new procurement: - an adder for community or FN projects. This has tended to operate as a form
of leverage or free equity by the community or FN partner - land criteria - previously developers just submitted a compliant land base. Any
new procurement should have a stat declaration to this effect, with LC as guarantor - No priority AT ALL should be given to historical
projects. The prime objective should be lowest price and most mature projects, i.e. lowest attrition
2. Keep local content rules the same as fit or get rid of them all together. Do not change the rules.
Q2 - Program should permit storage options.
the Small FIT application process involved a huge outlay of speculative capitol per project - the Large PV procurement process should
avoid this situation
Q2: will you be considering up and coming technologies in this new process (such as storage and off shore wind). Will you also be remove
the 10 MW cap off ground mounted solar?
Zoning requirements should not be included. If municipal support for a developer and their project is required prior application, the
municipality is clearly onside
#3 - consider benefits of "continuous" vs "intermittent" power generation
Re Q3: Yes - Aboriginal involvement measured in proportion of ownership of the project.
Can you provide listeners with instructions on how to ask a question over the phone? (ie. "star 2) I was not able to dial in at 2PM sharp...
Q3 - Need - is distributed generation needed within the TS/LDC or planning region. If not why procure?
Yes, 1) Municipal participation, 2) proponent experience, 3) evidence of secured financial support, 4) evidence of use of up-to-date
technology and that the technology works on a practical level
3. If the project is dispatchable.
Question #3 A completed TAT and DAT as part of the initial process.
Question #3: For large projects, developers should have the financial capability to execute the project and the proven track record to do
so. Also, some level of resource data collection and environmental work should be done prior to bid submission.
3. Comment - Conservation Authority Consultation & Approval should be considered and Ministry of Agriculture for farming/resources
impacts
Q3. One measureable factor/criteria that should not be considered is - a demonstration of having equipment. In FIT developers relied on
letter agreements that were not sufficiently binding and the OPA accepted as evidence of having equipment.
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#3 - in some regions with transmission constraints, consideration could be given the idea of seeking smaller "sub-tranche" of projects (e.g.,
500kW-5MW) before seeking larger projects
3. Will reference be given to areas with existing facilities to minimize land use impact?
Question 2. The current FIT Rules 2.0 where a community participation project and/or Co-op should be adhered to.
Do you see this as another way that the public sector is eliminating competition and small business by creating a long an arduous process
that will likely only be completed by larger corporations, and therefore decreasing the overall # of bidders and essentially normalizing the
process
Regional siting process should be tied into the procurement process. Proponents utilising the regional siting process should be rated
higher
Q3 include how the project contributes to economic and social development of the municipality
Yes, differentiation should be considered since projects of different types have specific land use impacts. (i.e. difference between farm
biogas vs. large scale wind).
For large scale wind, perhaps setback/noise levels should be considered
Yes. criteria should be measured for each project, points tallied, and a discount factor multiplied against the price (per RESIII) additional
criteria 1) Community support - letters of support, community involvement (co-op, muni ownership), The more support, more discount
points 2) FN support - factors rated as per above, with a minimum threshold on Crown land 3) Proponent experience - as per Nova Scotia
tender - i.e. has built a comparable project in past 24-36 months 4) Financial criteria - as per RES III - tangible net worth 5) Cost of
transmission 6) Amount of wind data
Yes different technologies supply different power. We need to balance production with load so what the load needs is what should be
prioritized. Over building in any one type of source requires the grid to respond.
Important to ascertain whether additional power is needed in the region - if not then do not open procurement in that area - this is vital
information.
Also - benefit to Ontario in terms of spend in the province, as far as this can be allowed under the WTO ruling.
Agreeing with the [name removed], Zoning criteria would be strongly recommended along with site plan approval.
#3 suggest priority for projects involving aboriginal business involvement in EPC
Proponent behind the tax vehciles/LP, etc. should be a principal guarantor.
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Potential Jobs created through the Project by the way of Man power used, Equipments used etc.
Are you able to favour Ontario companies in the procurement process under the WTO ruling?
We might as well allow geothermal, concentrating solar thermal, or other renewables. If we have to allow equipment from anywhere in
the world, we might as well open it to technology that is new to Ontario. Also, please disallow garbage incinerators.
The field should not get stacked against new entrants: factors submitted by [company name] such as experience, track record, financial
backing only serve to limit competition. Instead, the OPA should emphasise project merits and apply performance/progress criteria.
3. Existing approved REA Facilities. We have two REA approved and one pending solar within close proximity of each other....can we
anticipate more?
3. Waterpower developers should only be allowed to procure a maximum number of sites in the Province. This would prevent one
corporation from dominating the market or from taking on more than they can handle to produce a quality project.
Another factor should consider the social benefits of a project including providing energy security to the area, local economic benefits,
educational opportunities for students
Yes, as raised below, there should be different procurement process for different technology types.
#4 - yes, landfill gas projects are located (mainly) on municipal land, have a small land footprint, very low visibility, usually small nameplate
capacity (under 5 MW) and should have a simpler process compared to wind and solar
4. Yes different procurements for particular technology types based on interest and availability for example opportunity for landfill gas is
much lower than solar PV
Question 4: Please include a procurement allocation & and a price adder for projects that include storage solutions. Please add parking lot
solar to rooftop & ground-mount solar.
Why are ground-mounted tracking PV systems being put in an undesirable position, or disallowed?
Q4. There should be different procurements for different procurement types with specific targets identified in the LTEP (and as updated
periodically). Specific targets for different technology types will enable the Province greater control over the overall generation source mix
that will enable a better matching of demand and load profile.
#4 suggest priority involving Ontario developed technologies
#4 - biomass and biogas projects should also consider co-benefits (e.g., farm biogas also deals with manure management issues, urban
biogas.mass could have co-benefits with source-separated organics and FOGs)
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fats oils and greases
#5 One issue in current models of community engagement is an absence of local context for citizens. For example, what types of (local)
sources of electricity do proposed new projects replace or complement. Information such as this aids deliberation and could be required,
perhaps as a requirement to perform energy baseline studies of potential host communities.
Should not the criteria for establishing appropriate power sources be based on a smart grid concept? This would allow communities to
supply their own energy and not have to move energy around.
fats oils and greases
Yes different procurements, as the tender would never be comparing apples to apples. For instance capacity factors between wind, solar
and hydro are vastly different to calculate. Also social acceptance is widely different in nature. BC Hydro mixes procurement with wind
and hydro, and the PPA for both projects is very difficult for non-firm power sources. I would recommend tranches for each technology
type, and furthermore tranches for wind in different regions to enable the most competitive northern or FN projects
Question 4: To further elaborate on the parking lot solar project distinction. Currently, the CLI & zoning requirements are prohibitive for
parking lot projects. I believe that is an unintended consequence. First, paved parking lots that are zoned commercial should be exempt
from soil class limitations & soil studies.
#4 ensure that projects that utilize off peak rates to charge storage are disallowed
Waterpower has numerous well known and well studied negative impacts and should have a more stringent and selective process - only
local communities and First Nations or developers with a proven track record.
zoning, an agricultural operation should be allowed to align the perimeter of their properties with solar or implement biogas to benefit
from the OPA program while still operating as an agricultural operation
Question 4 cont. Also there should not be a requirement to do a REA for a parking lot project.
2. Depending on what the minister decides from the WTO ruling and Local content remains to be a part of the process. Don't change the
rules for the manufacturers. Capital investments have already been made and a change would result in more costs and would be
inefficient.
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Yes and Yes. Technology: New and emerging technologies should not be treated in the same way as old technologies. This may be a
political question, but if the OPA would like to embrace/stimulate use new technologies, they may have to run a separate procurement
process for that. Also, different generation technologies have different merits from a grid operation and ratepayer perspective, this also
suggests separating procurement by technology. Different project sizes must be treated differently. The OPA must consider cost of
preparing and submitting bids, suggesting simplifying bids for smaller
Input from the regional advisory groups should drive procurement requirements.
sorry last comment, clarify align, i meant surround the perimeter of the property
4. Municipalities are only allowed to own projects up to 10 MW, although most projects will be much lower than that. They typically do
not have resources to prepare large complicated bids, so simpler rules for smaller project would be greatly appreciated.
Q4 - Ensure that projects that have storage PERMIT use of off-peak storage for system support reasons.
Biomass depends on inputs from farming operations, which is not necessarily predictable (like wind, solar). This should be considered.
outside of the WTO the OPA should take into serious consideration that the utility scale RFP process may be the only mechanism that
allows domestic manufacturers to reach a scale that allows them to supply to smaller scales of FIT projects
It would be nice if we could add to a Small FIT, for example to expand a 500 KW ground project to 3 MW on the same property.
Yes, we'd take the lower price.
Some "communities" are "unorganized".
5. yes, community low income co-ops need to be given priority able to participate and compete, they struggle to stay open and need this
extra income, they may not be gov't or municipal owned but receive funding from gov't
the OPA should be responsible for engaging with the region/municipality prior to setting up the competitive procurement. Additionally will
regions have the ability to select which technology type they will accept in their jurisdiction?
Question 5: Significant time and resources are used to engage the communities. These community engagements provide a good platform
to discuss and address subjective issues. One of the ways could be to have a community engagement log submitted to OPA.
5. Community engagement should include a larger circulation abutting project site and a form of PIM with Municipal representation.
The Community/municipality must be consulted before a FIT Contract is issued in order to determine whether there is a need in the area if so, the proper location and type of renewable project, and should have final say in whether a FIT Contract is issued.
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Q5 you could do a communities readiness assessment designed to assess and measure community interest. This assessment also we have
found in our work generators lots of new ideas and relationship.
#5 - the OPA should engage the provincial-level associations for municipal officials (e.g., land use planners, building officials) as soon as
possible in the upcoming review process to ensure their feedback on their potential new role is captured early in the review process.
Support resolutions are difficult and don't provide municipalities with the level of confidence that they will actually have a say in the
development of a project. Each municipality has different requirements of how they would like to be involved, consulted with or approve
a site plan. These variances should be allowed to allow the developer to work with each municipality as they would like to be involved. If a
municipality can demonstrate through documentation that they are pleased with their level of involvement or can provided an agreement
that is in place with developer, this is adequate
5. Again in rated criteria, community engagement should be measured and compared. We must avoid criteria that produce a 'bidding war'
between competing developers or allow any kind of exclusive position for any single project. - highest points for local coop with minimum
number of members, or municipal ownership, or unlimited letter of support - lower points for lesser versions of these - co-op rules should
be improved to allow greater and deeper local ownership by residents
5. There should be one main point of contact throughout the process - including OPA.
#5 - a number of municipalities are engaged in community energy planning activities, and projects that align with municipal community
energy plan priorities should be encouraged
5. I would like to suggest that land owners have the ability to partner with the successful applicant. Thus allowing for multiple developers
to apply on the same parcel of land. The land owner could then sign agreements and allow access to the successful applicant.
#5 suggest priority given to communities willing to occur the costs of running a successful referendum representing the majority of
community population
5. One way would be to require or at least provide preference for project with minimum percent of community or municipal ownership
5. There should be a standardized circulation/notification process and forms approved by the OPA for consistency, similar for notification
for EASR approval.
Deputation in front of a town/City Council and at least one public consultation meeting. A formal Motion from the municipality should
provide a higher priority to the project.
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Question 5: First, I think it's great that this question is based on the assumption that Community participation has to happen at some
point. I believe the simple answer is that community equity participation & investment should simply be a requirement for every project.
This way, we don't run the risk of sending mixed messages. For instance, in the Small FIT window, co-ops spent a significant amount of
time and money collecting sworn declarations by co-op members in the presence of Commissioners of Oath, and those forms are lost
forever if an application is rejected for missing a page number.
Sorry that I am late to the discussion. Two comments of a general nature. 1) Will the OPA put online summaries of feedback heard from
stakeholders in their one-on-one meetings, and copies of written submissions received? Generally the OPA has not done that although I
notice that you have done this for the recent OPA/IESO Energy sitting report which is a very important step for transparency. 2)
Historically the OPA has held one-on-one meetings with various industry groups, municipalities, aboriginal groups etc. Will it do so with
groups who represent consumers interests (i.e. ratepayers)?
5. The complete municipal consultation for REA is preferred. However the standard forms used for municipal notification is clear and
concise.
Q4 - Inverter based technologies that can operate in all four quadrants, should be paid for consuming or generating reactive power to
provide local voltage support.
Q5 you can measure it by $$$. How much are community members willing to front in the soft cost of setting up a coop.. FSCO allows this
to occur
5. We canvass the neighbourhood around our project to explain the project and answer questions. I'm not sure it makes sense for the OPA
to mandate evidence of this, but I'd recommend that others on the call do this.
#6 - understanding the potential "upper limit" or regional transmission availability for new projects will help manage expectations
6. Yes, key plan of area, site plan showing setbacks, height information, access etc. Similar to the site plan control planning process.
is looking for input on "development of the new procurement Process" and is asking the OPA to maintained large projects in limiting their
output to 5 MW peak.
Crown land allocation - there should be a logical approach to allowing proponents to bid sites on Crown land or Un-organised territory,
that allows no exclusive control over Crown lands until a project is selected, thus preventing a 'log-jam' at MNR.
Cumulative effects must be considered on a watershed basis. When considering a waterpower site/s it is imperative that the entire
watershed be considered, taking into account all existing development pressures, such as waste water treatment facilities, mining, existing
hydro that are already stressing the system.
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#6 - LDCs could provide maps of where there is available capacity (and how much), would help local proponents
5. I will gladly send a formal email outlining what I would like to see in a formal site plan layout.
Following up: will the questions be posted on the web site or emailed to the participants for further input?
6. The OPA should not be involved in siting beyond the inputs from regional electricity planning - leave it to the MOE and Municipalities.
Specifically, following OMAFRA mapping or adding arbitrary zoning restrictions does not add anything to the RE regime - it only serves to
politicize.
Siting requirements follows regulations. If regulations are restrictive proponents will focus on compliance. If regulations included
requirements for the proponent to identify the site in context of environmental and distance between residences or other sensitive site
issues - i.e.) security; the procurement requirement should require the proponent to detail the issue(s) and specify mitigation plans.
1) WTO ruling will be a determinant and 2) it is important that mechanisms are put in place to ensure projects are of a certain quality and
not awarded to the lowest bidder ie) race to the bottom
Instead of terminating applications and costing jobs, losing deposits and cutting business, why not roll over or 'hold' applications to the
next procurement window?
Crown land - Thanks and I have looked at the revised process, and I think it is better than what proceeded it, however it still doesn’t allow
proponents to erect a mast, have MNR speak to your site or engage with FNs prior to a bid. Without these, the project cannot get to the
starting line in a competitive tender. A sort of catch 22.
Question 6: Currently, the OPA does not clearly distinguish between Rural zoning and Rural Residential Zoning. I think we the OPA should
pay closer attention to the various zoning designations made by local municipalities and be more specific to clarify the set-back
requirements. For instance, Rural projects should have the same set-back requirements as Agriculturally zoned projects.
Municipalities should determine appropriate projects and sites.
Agree that contract should not go to the lowest bidder, but instead co-ops or municipalities should take precedence.
Questions 6: Also, the CLI maps are not perfect, the certified soil study should be able to overrule the CLI map. How involved is the
Ministry of Environment in the consultation process?
OPA procurement document should include an option where a proponent may elect to dispute a particular OMAFRA soils classification on
the proposed site with science-based evidence similar to the soils survey raised by FiT 2.0 on mixed soils including class 3 (class 1, 2 soils
are precluded).
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Will feedback provided under the LTEP consultation (comments due September 8) be taken into account in this Large Renewables
consultation? Kind Regards.
Need to establish annual procurement targets for large-scale energy infrastructure.
Local municipalities, stakeholders and First Nations should have the final say on whether a site is released for any type of renewable
energy project.
Q7 - Purchases should be on volt-ampere hours not watt-hours. The system needs both active (watts) and reactive (VA) power.
After a Contract is issued, the environmental assessment process must include the ability to reject a renewable energy project. A "no
outcome" must be possible.
#7 - in the off-chance that a municipality's proposed project does not get an OPA contract in the future, it would be great if municipalities
could have a "Plan B" option to "wheel power" within the LDC distribution system to offset electricity use at another municipal facility
(e.g., use LFG power at City Hall and other municipal facilities)
When communicating the amount of power to be generated the actual power estimated to be generated must be included - not just
Installed Capacity.
The Ministry may review its earlier proposal at the onset of the GEA wherein "spur feeders" would have connected RE projects and
potentially permit sharing of transformers, dispatchable energy storage and other power engineering devices to implement "smart grid"
distribution of power.
Q 7 an RFP process will not work for communities. Too expensive and too complicated for evolving community groups. Exclude community
groups and use FIT and contract set aside for over 500 kw for community groups
7. Push the LDCs to allow more renewables on each transmission or distribution station.
1. Will you place copies of written submissions and one-one-one meetings online (like was done in the OPA/IESO sitting report)? 2. Will
your one-on-one meetings with industry associations, landowners, stakeholders etc include consumer groups?
7) Tough question - how do we ensure the supply chain settled in Ontario stays in Ontario. Does the WTO ruling allow any degree of
favouritism towards ON produced goods in the context of a competitive tender?
Ensure existing power generation has had upgrades and efficiencies before new generation is contracted.
How can the large upfront pre-application costs that were incurred in Small FIT be avoided??
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Question 7: More broadly, is the goal for the OPA to eventually bring renewables to the same price levels as other energy sources, perhaps
at grid-parity? If so, there should be an open window for small, medium, and large renewables if they are able to sell power at retail rates
without needing to go through a complicated procurement process. The procurement process should be for projects that would like to sell
power at above retail rates. What is the long-term vision for the OPA with regards to renewables?
Look to liquid thorium for future power generation rather than nuclear.
Power should not be purchased unless power is needed. Contracts must never include payment for all power generated whether it's
needed or not.
Reference to previous the WTO ruling question/suggestion, another suggestion: Ontario might like to consider the domestic content
equivalent legislation in place in other markets, which have survived a WTO enquiry. Examples include France, where individual projects
require to have a carbon footprint below a certain level, which effectively requires a certain level of components to be manufactured
within the country.
Is it safe to assume the additional consultation/engagement will follow the release of a newly defined LTEP?
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Appendix C: List of Meeting Participants
In-person meetings were held with municipal associations, industry associations, FIT
stakeholders, a Métis community and individual proponents who requested meetings. In
general, meeting participants used the sessions to obtain additional clarity on the possible
future LRP process as well as a supplement to their written submissions.

Association of Municipalities of Ontario

Biogas Association

Boralex Inc.

Canadian Solar Industries Association

Canadian Wind Energy Association

EDF EN Canada Inc.

EDP Renewables

EffiSolar Energy Corporation

Federation of Northern Ontario Municipalities

Innergex Renewable Energy Inc.

Kruger Energy

Leader Resources

Métis Nation of Ontario

NextEra Energy Canada

Northland Power Inc.

Northwestern Ontario Municipal Association

Recurrent Energy

REpower Systems Inc.

RES Canada

Rural Ontario Municipal Association

Solray Energy Corporation

Suncor Energy

SunEdison

Sussex Strategy Group

Teeswater Community Power Co-operative Inc.

TransAlta

Vestas Wind Systems
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