The microFIT contract and rules were released on August 14th and their content appears to be pretty much as expected. The microFIT program was developed by the LDCs who will also be responsible for handling the future administration of the program. The OPA is handling the dissemination of program information to stakeholders and of course the resulting public consultations until the program goes live. The application process will be quite simple, with just two sets of online "fill in the blanks" questions (contact information, LDC account number, technology type, system size, etc.), one to the LDC for an application to connect, and one to the OPA for a FIT contract. In both cases that actual contract is prepared by them for the applicant using the information supplied.
A number of questions arose from the information presented, however, and the following are the questions that have been raised and since answered. The OPA has scheduled a microFIT Web conference for Monday, August 31 at 1:30pm for a public consultation.
Q: Will a MicroFIT system size be determined by panel nameplates or inverter?
A: For microFIT, the 10kW size refers to the sum of all gross nameplate ratings of the generating equipment, and not the inverter. The OPA has checked with the Electrical Safety Authority and during the inspection of the renewable energy generating facility, the inverter will be checked to ensure that the inverter is sized larger than the generator's equipment to avoid overheating and any safety hazards. UPDATE: It will be deemed to be the smaller of the nameplate ratingsof the inverter(s) or panels.
Q: What is the purpose of the 30 day delay in applying for a connection agreement after applying for a MicroFIT contract?
A: The OPA will be sharing some information with the LDCs with respect to interested micro-scale generators. This period of time is to allow the LDCs to prepare for incoming MicroFIT applicants (e.g. preparation of resources). LDCs would be permitted to waive this time requirement. The OPA is presently considering reducing this from the 30 day period stated or possibly waving it all together.
Q: Under what conditions would an LDC request a CIA? I thought that all micro fits were Capacity Allocation Exempt Facilities.
A: If there are two micro-scale projects located at one point of connection (e.g. a 10 kW solar PV system and a 10 kW wind turbine). Under the OEBs codes, if a project is under 10 kW then they are exempt from a CIA. However, in this example, even though both projects are micro-scale, they are seen by the LDC as being a `non-micro-scale' projects à e.g. a 20 kW facility. The LDCs are not required to complete a CIA for projects greater than 10 kW - they could waive this requirement if they felt there would be minimal impact on their system. So, if in this example, if the LDC decided that the second project would trigger a CIA, then only one project would be permitted in the microFIT program. The second 10 kW project would have to apply through the FIT program. If the LDC decided that a CIA was not required for the second project, then both projects could apply through the microFIT program. The other potential circumstance which might trigger the need for a CIA, would be if a number of projects were being connected to a portion of the grid with a somewhat fragile rural line, particularly if they are approaching the 10 kW size.
Q: "Supplier shall not modify the Facility to increase the nameplate rated capacity" has an unclear meaning. Is this intended to mean that the supplier may never increase the system size under any circumstances or rather that if/when more capacity is later to be added to the system, an incremental system application must be made?
A: The Supplier cannot amend the contract to add more capacity, however, they could apply for an `incremental project' at a later date which would be under a separate agreement.
Q.: Since settlement is made by LDCs, why would it be OPA that would pay sales taxes?
A: The OPA pays sales tax on the generation payments to contract holders who indicate that they are required to collect and remit sale tax (e.g. GST). The LDC makes generation payments to the contract holder, and on the behalf of the OPA. Therefore, if the contract holder is a GST registrant, then the LDC would pay the contract holder GST.
Q: Will the OPA or OEB be setting out a fee schedule limiting what LDCs will be permitted to charge for meter installation?
The OPA cannot control what the LDCs charge for meter installations, however we do recognize that this is an important issue to address. At this time, we don't believe the OEB is reviewing the amount LDCs charge for meters. SEE HERE WHY THIS WARRANTS CONCERN.
Q: What arrangements will likely be in place before monthly metering costs of a microFIT system?
A: Presently there are two distinct methods for connecting to the grid and in 2007, the OEB directed that for one of them, no monthly account fees may be charged by the LDC. Soon, however, due to proposed changes being made by the OEB to the Distribution System Code, it has apparently been decided that all generation facilities must have their own LDC account regardless of whether or not a load account presently exists. The OPA is presently considering what might be a reasonable fee to charge for the separate account and is thinking that it will be a reduced fee from what residential load customers normally would be charged.
Q: In the basic eligibility requirements, it is stated that "the Supplier must be the same person or entity as the LDC account holder associated with the microFIT project". Why is this? What if a private company, municipality, or LDC wish to offer PV systems to homeowners, on either a rental or lease to rent type of an arrangement, does this not preclude them from doing so?
A: This requirement is to ensure that there is a `direct settlement relationship' with the Supplier. The LDCs make contract payments to Suppliers on behalf of the OPA. Based on the OEB's proposed Distribution System Code amendments, the "microFIT generator account" will always be different than the "load customer account". The Supplier must be the owner of the "microFIT generator account". There should be no problem in developing a project on a property you did not own. The only requirement is that you must own the "microFIT generator account". You would work with the appropriate LDC to set up this new account - which is a process that would be similar to setting up an LDC account for "tenant" on a property.
Q: Will the microFIT program be launched in advance of the bigger FIT program?
A: The OPA has repeatedly stated that both programs will be announced and launched simultaneously.
In case anybody is interested in some proposed minutia, here are changes that I proposed to the text of the microFIT agreement and rules:
Micro FIT agreement notes
4.1 Might better to read as "Initial Contract Price" since escalation will modify future prices.
4.2 It would be helpful to include in Schedule B, what the escalation percentages are by technology.
4.4.4 After "is not a Sales Tax registrant" it might be helpful to insert something like "(check here for a residential system with no business affiliation)"
6.2.3 I see notes in the Rules about more work to be done re: battery backup systems, but here, rewording is needed since I would assume that a battery backup system would be permitted so long as it is doesn't interfere with the generation system and any readings related to it's production.
7.3.1 The meaning of this definition is not straightforward. Could you not just substitute "The Facility's metering configuration must be as laid out in the micro fit rules and regulations"?
8.1 Rather than "reasonable notice" it would be preferable to state a set number of business days. I suggest five.
8.2 "seller" is not elsewhere used or defined.
8.3.2. In some cases, it is difficult to arrange for someone to be home on as little as two days notice. Five days would be better.
Appendix B "TCP-BD" needs to be defined on the escalation calculation page
Micro Fit Rule Notes
1.2 Par 1: If I am correct and for greater clarity, it should be stated that the micro fit application is made to the OPA and that it is the OPA who will submit this information to the LDC.
6.1 Par b: substitute" insuring" for "insure"
MicroFIT Questions Asked and Answered Mike Brigham August 24, 2009