This document provides comments from iSolara Solar Power in response to proposed amendments to Ontario's net metering regulation. Key points include: - The credit carryover period should be extended to 60 months to account for annual variations in solar production and energy consumption. - The maximum system size limit should be removed to allow more large customers to participate and size systems to meet energy needs. - Single-entity virtual net metering distance restrictions should be based on IESO geographical zones rather than an arbitrary distance. - Existing generators should have the option to opt-in to the new net metering agreements.

1. 30 Capital Drive, Ottawa, Ontario, K2G 0E9
Office: 613.738.2646 / 1.877.978.2646
Fax: 613.738.9939
www.iSolara.com
@iSolaraSolar
"We get the Sun working for You!"
30 September 2016
Dear Emma Schwab-Pflug,
Re: iSolara Solar Power’s comments on EBR Registry Number: 012-8435 Proposed
Amendments to Ontario’s Net Metering Regulation
iSolara Solar Power is Eastern Ontario's first choice for residential, commercial, agricultural and
institutional solar systems with over 500 completed projects including numerous net-metering projects
ranging in size from a 6 kW residential system to 100 kW agricultural system. This document presents
the commentary and recommendations from iSolara Solar Power to Ontario Ministry of Energy’s
Conservation and Renewable Energy Division’s proposed amendments to the 2005 Net Metering
Regulation posted on Ontario’s Environmental Registry and Regulatory Registry on August 19th
, 2016.
iSolara applauds the Ministry’s efforts to modernize the current net metering billing arrangements and
welcomes the consultation process for comments on the proposed amendments. We believe it is in the
province’s best interest to transition from the contract based Feed-In-Tariff program to a simpler net
metering billing arrangement. iSolara’s staff reviewed the program concept proposal, watched the
background webinar, attended an in-person session and submitted written feedback to the Ministry.
For ease of reading, our comments are sectioned by amendment below. The Ministry’s proposed
amendments are listed first in italics. iSolara’s comments are provided in bold afterwards. Followed by
a detailed explanation of the comment.
Account Billing
1. Continue to compensate generators on the same basis as they are charged for
consumption of electricity as consumers (i.e. volumetric electricity charges). Simplify
(put in plain language) the description of the method used to calculate credits.
Exported and consumed electricity should be credited/charged in the same manner. Allowing
generators to be compensated for exported electricity in the same manner that they are charged for
their consumption of electricity permits rate payers to easily understand net-metering as a billing
arrangement. The Ministry should continue to ensure that this principal is maintained. A complicated
calculation method for credits will be a barrier for adoption of net-metering.

2. 30 Capital Drive, Ottawa, Ontario, K2G 0E9
Office: 613.738.2646 / 1.877.978.2646
Fax: 613.738.9939
www.iSolara.com
@iSolaraSolar
"We get the Sun working for You!"
2. Require electricity distributors to carry forward positive bill credits for net-metered
accounts for a consecutive 12-month period. This would extend the credit carryover
period from 11 months to 12 months.
The credit carryover period should be extended to 60 months. Limiting the carryover period to 12
month discourages generators to size the system to meet 100% of their current load. Allowing bill
credits to be carried forward for a consecutive 12-month period allows for seasonal variances in solar
energy production and energy consumption to be accounted for but does not allow for annual
deviations. For example, annual solar energy production can vary from year to year based on annual
differences in solar irradiance, if a generator consumes a typical amount of energy over a year but their
system produces an above average amount of energy they will lose the credit they have accumulated.
Similarly, if a production facility is planning a major shutdown during a certain year to remove aging
equipment and install a high efficiency replacement which results in a significant reduction in energy
consumption, and their annual solar energy generation is the expected amount for a year. They will over
produce and lose out on a significant amount of credits gained over the year.
Eligibility
3. Remove the requirement that the equipment used to generate electricity be no
greater than 500 kilowatts (kW), based on the rated maximum output capacity of the
equipment. The intent is to enable larger customers to right-size renewable energy
systems to their load. Larger customers tend to self-consume a higher proportion of
generated electricity due to higher daytime loads, aligning with the objective to
match generation to local demand, which can help reduce local load and related
infrastructure needs. The requirement that the generator must generate power
primarily for their own use and the proposed 12-month credit reset period will
encourage right-sizing for all customers.
The maximum output capacity limit of a system should be based on the technical limits of the site and
utility interconnection. Removing the 500 kW limit will allow more large customers to participate in the
net-metering program and size a system to meet their energy needs as well as take advantage of the
economies of scale associated with a larger system.

3. 30 Capital Drive, Ottawa, Ontario, K2G 0E9
Office: 613.738.2646 / 1.877.978.2646
Fax: 613.738.9939
www.iSolara.com
@iSolaraSolar
"We get the Sun working for You!"
4. Establish a billing method for Single-Entity Virtual Net Metering (credit transfers
between multiple electricity accounts held by the same person or corporation),
subject to: account meters being located within the same electricity distributor
service territory and within a maximum distance (e.g. a 3 kilometer radius). The
Ministry of Energy is seeking feedback regarding limitations on the use of the
electricity distribution system for Single-Entity Virtual Net Metering projects.
The maximum distance for Single-Entity Virtual Net Metering should be based on the IESO’s
Geographical Zones. Single-Entity Virtual Net Metering will allow customers to take advantage of the
property that is ideal for installing a net-metering solar system and apply the credits earned to their
larger bill that may not have a suitable location to install a solar system. This billing method will vastly
increase the amount of eligible projects for this program. Placing a restriction that the accounts must be
within the same electricity distributor service territory will reduce the complications involved with
applying these credits to different accounts managed by different distributors. A restriction based on
distance is not a fair restriction as the benefit to the grid is not limited by distance. We acknowledge
that the full grid benefit of a net-metering system cannot be transferred equally across the province,
which is why we believe the restriction should be based on a technical grouping of the grid such as
IESO’s Geographical Zones.
5. Allow for the use of energy storage when paired with renewable energy
generation. In other words, storage and remittance of electricity from the electricity
distribution system and from a renewable energy system would be permitted.
The introduction of energy storage paired with renewable energy generation should be encouraged.
Currently, generators with a net-metering billing arrangement are moved off of time-of-use billing which
eliminates the benefit of installing a storage system with a renewable energy generation system. To
encourage the use of energy storage net-metering generators should not be moved off of time-of-use
rates.

4. 30 Capital Drive, Ottawa, Ontario, K2G 0E9
Office: 613.738.2646 / 1.877.978.2646
Fax: 613.738.9939
www.iSolara.com
@iSolaraSolar
"We get the Sun working for You!"
Agreements
6. Allow participants who have existing net metering agreements prior to the
effective date of the proposed updated Regulation the option of entering into new
agreements which reflect the updated provisions, or of maintaining their existing
agreements.
Existing generators should be provided with the opportunity to opt-in to the new agreements. Early
adopters of net-metering should not be punished by the new amendments to the regulation, they
should be allowed to opt-in to the new program if they chose. They should not be automatically enrolled
into the new system and provided an opportunity to opt-out afterwards. A detailed explanation of how
the new amendments will affect how their generation credits are treated should be provided to all of
the province’s existing net-metering customers. This explanation should include a side-by-side
comparison of the billing statement before and after the amendments.
The amendments are proposed to be in force by July 1, 2017.
Information on the finalized amendments should be provided by May 1, 2017. The date these
amendments will be in force provides for an adequate overlap between the current microFIT program
and the amended net-metering regulation. Well in advance of this amendment taking effect existing
net-metering generators should be informed of the changes and how they could affect their operation if
they choose to opt-in.
Future Proposed Work
In addition to the proposed regulatory amendments, the Ministry of Energy is
proposing to:
• Undertake a cost-benefit evaluation of the program every three years, if required,
coinciding with the Long-Term Energy Plan cycle.
An ongoing cost-benefit evaluation of net-metering should be included in every Long-Term Energy
Plan. This evaluation will provide rate payers with sound information on the benefit that net-metering
systems provide to the electrical grid. A detailed and transparent cost-benefit evaluation will encourage
additional rate payers to participate as generators in the net-metering program while promoting
distributed generation.

5. 30 Capital Drive, Ottawa, Ontario, K2G 0E9
Office: 613.738.2646 / 1.877.978.2646
Fax: 613.738.9939
www.iSolara.com
@iSolaraSolar
"We get the Sun working for You!"
• Improve the availability of net metering program information.
Net-Metering program information should be available and advertised through the local distribution
company. Many LDCs do not have any information available for customers interested in connecting a
net-metering system. Most rate payers are unaware that there is a net-metering program in Ontario,
few are aware that there was a Feed-In-Tariff program and even less are aware that the microFIT
program still exists. The net-metering program should be widely advertised and promoted through LDCs
on par with the current Save on Energy program.
• Undertake a cost-benefit analysis to determine whether investments in Ontario’s
Meter Data Management and Repository should be made to enable province-
wide time-of-use billing for residential and general service (<50 kW) net metered
customers.
A cost-benefit analysis should be conducted immediately to transition residential and <50 kW net
metered customers to time-of-use billing. The introduction of time-of-use billing has helped reduce the
summer time peak in the province which has helped improve the efficiency of our power system. Net-
metered solar power systems primarily produce energy during on and mid peak times when the
province requires the energy. When a net metering generator is connected the account holder is
transitioned from time-of-use to tiered billing which is not dependent on the time when the energy was
produced. The excess energy that net metering generators are exported during peak times are not being
fairly compensated for. As well, since the customer’s load bill has transitioned to tiered they no longer
have any incentive to change their habits to reduce their energy consumption during peak times.
Maintaining net-metering generators on time-of-use billing encourages rate payers to reduce their load
during peak times and properly compensates generators for the energy they produce during peak times.
The OEB will be exploring steps that it may take to facilitate the implementation of
the updated net metering program, such as:
• Developing a standardized net metering application and agreement, with
consideration for streamlining processes;
Hydro One’s net metering application process should be used as a starting point for preparing a
province wide net metering application and agreement standard. Through iSolara’s experience with
connecting net-metering projects through many LDCs in the province, Hydro One’s application and
process is the most streamlined. For example, Hydro One no longer charges a Connection Impact
Assessment fee for small three phase customers. Their existing process should be improved upon and
standardized across the process to reduce the deployment time of a net-metering generator.

6. 30 Capital Drive, Ottawa, Ontario, K2G 0E9
Office: 613.738.2646 / 1.877.978.2646
Fax: 613.738.9939
www.iSolara.com
@iSolaraSolar
"We get the Sun working for You!"
BC Hydro’s net-metering application process should be considered when developing a province wide
standard. BC Hydro has a simple and straight forward net-metering application process that a typical
homeowner can complete. The OEB should review their process when developing a standard for
Ontario.
• Collecting net metering information from electricity distributors at more frequent
intervals to monitor implementation of the initiative; and
Electricity distributors should provide a summary of distributed generation projects connected on a
quarterly basis. Rate payers should be aware of the popularity of net-metering projects in their
communities and this can be accomplished by an annual report produced by the distributor detailed the
current state of distributed generation in their service territory, including: current generators operating,
generators connected in the last year, generators planned/anticipated to be connected in the following
year. This report can be used by the OEB to gauge which distributors are facilitating distributed
generation. These reports should be summarized and included in the IESO existing Quarterly Progress
Report on Contracted Electricity Supply.
Net-Metering projects should count towards an LDC’s Conservation and Demand Management
targets. Net-metering projects that operate as a load-displacement project (i.e. no excess energy is
exported to the grid) at the meter are no different than energy efficiency projects to reduce a
customer’s load. If these projects counted towards Conservation and Demand Management targets they
would be provided with a mechanism to promote and incentivize these projects through channels they
are already familiar with.
• Improving the availability of net metering program information.
Net-Metering program information should be available and advertised through the local distribution
company. Many LDCs do not have any information available for customers interested in connecting a
net-metering system. Most rate payers are unaware that there is a net-metering program in Ontario,
few are aware that there was a Feed-In-Tariff program and even less are aware that the microFIT
program still exists. The net-metering program should be widely advertised and promoted through LDCs
on par with the current Save on Energy program.

7. 30 Capital Drive, Ottawa, Ontario, K2G 0E9
Office: 613.738.2646 / 1.877.978.2646
Fax: 613.738.9939
www.iSolara.com
@iSolaraSolar
"We get the Sun working for You!"
New Design Elements
The Ministry of Energy plans to begin consultations in Fall 2016 on additional net
metering program design elements that may require legislative amendments
(amendments to the Ontario Energy Board Act, 1998). These design elements include:
• Third-Party Ownership: The eligibility of third-party companies to own and operate
renewable energy systems and sell power to net metered customers.
Third-Party Ownership will encourage the adoption of net-metering projects by reducing the barriers
associated with access to financing and capital. The Ministry of Energy should investigate what would
be required to allow Third-Party Ownership of net-metering projects as this will increase the adoption of
the program and allow low-income families to participate. The Ministry should put in place safe guards
to ensure rate payers are not being deceived or taken advantage of companies offering Third-Party
Ownership. An example would be to require all Third-Party Ownership providers to abide by the
Canadian Solar Industries’ Solar Business Code of Conduct and register with the OEB as electricity
retailers currently have to.
• Community Net Metering: The allowance of credit transfers from a shared
generation facility to the billing accounts of multiple entities.
Community Net Metering will allow renewable energy co-operatives a vehicle to continue procuring
and construct renewable energy generation facilities. Renewable energy co-ops allow those who do
not have the facility or electrical load to economically participate in the net-metering program an
avenue to invest in renewable energy generation after the Feed-In-Tariff program has ended. Co-ops are
very popular with rate payers as they are making an active contribution to changing the power supply
mix in the province.
Thank you for your consideration and please do not hesitate to contact me with any further comments
or questions.
Best Regards,
Mitchell Niles
iSolara Solar Power
W: 613.738.2646 x105 C: 613.325.3545
E: mniles@isolara.com
Follow me on Twitter @MitchellNiles