To: Minister of Energy Bob Chiarelli CC: Premier Kathleen Wynne MPP John Gerretsen From: Tyson Champagne, Executive Director

of SWITCH Ontario Re: Changes to Feed-In Tariff Program Date: June 21, 2013

Dear Minister Chiarelli, Your recent directive to the Ontario Power Authority regarding changes to the feed-in tariff program touched on numerous areas that could significantly impact the success of clean, renewable energy in Ontario. SWITCH and its members applaud the Government of Ontario’s renewed commitment to microFIT and small FIT projects and the decision to address the need for increased engagement with municipalities when choosing locations for large FIT projects. We would like to offer some input that may help the directive be successfully implemented and increase support for renewable energy generation in Ontario. SWITCH has facilitated sustainable energy development in Southeastern Ontario for over ten years. SWITCH brings together urban and rural businesses, researchers and innovators, educational institutions, the public sector, and a variety of community-minded people working to create a green future. SWITCH also believes that widespread support for sustainable energy projects is an integral part of a truly sustainable energy future and we look forward to building that support in any way possible. Our members are engaged in designing, building, operating and researching renewable energy in Ontario. We have seen proof that this sector is creating thousands of new jobs and local benefits at prices that are highly cost-competitive with other new sources of electricity, all while helping Ontario build a stronger, cleaner and more affordable power system. SWITCH and our membership of over 100 businesses and individuals involved in the sustainable energy sector could play a valuable role in contributing to a workable implementation of the points you put forward in your directive. Our access to experts and resources in the sector could be of assistance in ensuring that well-informed decisions are made and that renewable energy continues to be an important part of Ontario’s energy mix. Some of the concerns already brought forward by our membership regarding the changes to the FIT program include:  A need to reassess renewable generation capacity limits o The largest provincial utility, Hydro One, currently limits renewable energy to no more than 7% of peak demand on its distribution feeders. This is an exceedingly low

number that should be raised to match other regions (Utilities in California generally agree that 15% distributed generation on a local distribution circuit is the threshold for any problems and Hawaii allows 23% of peak load). o SWITCH can provide you or your staff with access to experts on electricity distribution that can provide perspective on how this rule is perhaps applied more broadly in Ontario than technically necessary. Potential job loss due to reduction of the Small FIT Quota from 200MW to 150MW o Our membership has already faced job loss that was likely due to the small FIT category being reduced rather than increased. The difficulties small and medium sized companies will have participating in a competitive procurement process o Smaller developers do not have the deep pockets that will allow them to spend millions of dollars to participate in an RFP process that could see them walk away with nothing. Mechanisms should be added to the RFP process to make room for smaller Ontario companies. The need to remove MW caps and provide grid access and capacity building resources for community power projects o Integrating commercial know-how with community interest will assist in local acceptance, more rapid deployment, and the creation of local resiliency as well as financial resources. The exclusion of farmers from the microFIT program o The restrictions limiting ground mount microFITs on land adjacent to residential zoned land removes the option of a microFIT installation for many farmers (even if they own hundreds of acres of land). A 100 metre setback would be a preferable option. o Also, many farmers could place 5 microFITs where they do not impact Class 1-3 agricultural land or neighbours. If farmers with a current Farm Business Number were able to install up to 50kW of microFIT it would provide support to rural Ontario residents and local businesses.

The Ministry of Energy recently funded our GreenProfit Conference which included an expert panel discussing many of the very issues addressed in your directive (IMBY: Earning Social License for Renewable Energy Projects). I now feel that there is an opportunity for SWITCH to provide input and access to resources that could assist in the development of the next generation of renewable energy project best practices. I request a meeting between SWITCH and you or your staff so that we can make these resources available and participate in the implementation of the directive to ensure that Ontario continues to be a world leader in the generation of clean, renewable energy. Thank you for your consideration and I look forward to your response. Sincerely, Tyson Champagne Executive Director, SWITCH