Ontario Commercial Rooftop Solar Generation Projects: Looking Forward June 19, 2014 Power Advisory LLC Jason Chee-Aloy Tel: 416-303-8667 Email: jchee-aloy@poweradvisoryllc.com Today’s Discussion Ontario Power System Needs Procurement Processes IESO/OPA Merger Regulatory Policy and Net Metering Power Advisory LLC 2014 All Rights Reserved 2 Ontario’s Future Supply Gap Indication of requirement for additional capacity, beyond total resource commitment Power Advisory LLC 2014 All Rights Reserved 3 Ontario’s Future Supply Gap Underestimated in Long-Term Energy Plan The earlier removal of Pickering moves the need date for new resources forward to 2018 Disruption to the refurbishment schedule at Darlington and Bruce B increases the resource requirement beyond 2022 through to 2032 Power Advisory LLC 2014 All Rights Reserved 4 Procurement Processes OPA likely to re-start microFIT/FIT (< 500 kW) Processing applications FIT 3 OPA likely to re-start Large Renewable Procurement (LRP) I process (> 500 kW) Final RFQ Draft RFP Maybe draft contract IESO/OPA merger likely to not frustrate re-starting microFIT/FIT and LRP I LRP II and LRP III may be subject to change microFIT/FIT and LRP I are still objectives in LTEP, therefore will likely continue in parallel to merger and afterwards Power Advisory LLC 2014 All Rights Reserved 5 IESO/OPA Merger Unlike Bill 75, OPA is being folded into IESO IESO governed by the Market Rules and IESO Board of Directors (BOD) have rule making authority IESO will act more independently than OPA IESO BOD to determine protocols to ensure wholesale market operations and contract management do not present conflicts IESO/OPA merger may happen quicker than expected Annual Energy Outlook reports Scope? Could drive changes to LTEP and solar generation policies and procurement targets Power Advisory LLC 2014 All Rights Reserved 6 Changing Regulatory Policy – Distribution and Low Volume Customers In many jurisdictions, including Ontario, there is a growing paradox Utilities (e.g., LDCs) recover costs through fixed charges and variable rates Variable rates linked to volumetric consumption (i.e., energy draw), so when consumers decrease consumption LDCs lose revenue (i.e., losing revenue resulting from “sales”) Problematic for LDCs because less revenue means less cost recovery and less profitability This can provide disincentives for LDCs to administer and support CDM programs, distributed generation (e.g., solar, combined heat and power, etc.), and other technologies (e.g., storage, etc.) despite policy objectives OEB started consultation on “revenue decoupling”, proposing to drop variable rates for low volume electricity customers leaving only fixed charges (i.e., “decouples” revenues from sales) Arguably takes away above disincentives, therefore helpful for rooftop solar generation but controversial e.g., front page of June 17, 2014 Toronto Star and June 19, 2014 editorial in the Toronto Star Power Advisory LLC 2014 All Rights Reserved 7 Revenue Decoupling Across North America As of 2013, in the U.S., over 25 electric LDCs in over 13 states adopted some form of revenue decoupling (but different to OEB’s proposal) Power Advisory LLC 2014 All Rights Reserved 8 Why is Revenue Decoupling Important for Commercial Rooftop Solar Generation? LDCs may have disincentives to support rooftop solar generation without revenue decoupling, as solar energy production occurs when energy consumption is highest, therefore decreasing LDCs revenues Power Advisory LLC 2014 All Rights Reserved 9 Declining Solar Generation Costs and Rising Total Costs to Electricity Customers Ontario has a “perfect storm”, total electricity costs to customers are rapidly increasing while costs to install solar rooftop installations are declining, therefore commercial rooftop solar generation may become economical after 2020 Power Advisory LLC 2014 All Rights Reserved 10 Net Metering Projections of costs to customers and rooftop solar installation costs show that consumers may not require mechanisms like microFIT and FIT after 2020 to install rooftop solar generation Therefore, mechanisms like net metering will likely be more effective in the future to incentivize uptake of rooftop solar generation Less transaction costs, clarity in rate structure, less administration, etc. However, net metering will only work effectively if LDCs do not have disincentives to administer and support rooftop solar generation LDCs need to recover costs to serve their customers and maintain their assets Customer classes need to be effectively determined Costs need to be efficiently allocated across customer classes Effective design of rates and charges per customer classes are essential Net metering factors into rate design Therefore, pending on the final OEB revenue decoupling decision, net metering may be much easier or much harder to design and implement Power Advisory LLC 2014 All Rights Reserved 11 Going Forward CanSIA has a decision to make in Ontario – given that the LTEP supports development of net metering, how much effort should be given to present issues with microFIT/FIT versus development and implementation of net metering? e.g., scope of DG Task Force? If sufficient effort is to go to development and implementation of net metering, heavy participation in developing and changing applicable regulatory policies will be required before the OEB Regulatory economics Rate design Integrated resource planning (i.e., costs-benefits of rooftop solar generation, etc.) LDC capital plans Power Advisory LLC 2014 All Rights Reserved 12