REQUEST FOR FEEDBACK ON DRAFT INTERPRETATIONS

To submit comments on a draft interpretation, please send them to Submissions@powerauthority.on.ca and include the text "Submission on Domestic
Content - Designated Activity X".

Please note that questions on a particular designated activity should continue to be
sent to FIT@powerauthority.on.ca. The OPA will not respond directly to questions on
domestic compliance.

________________________________________________________________________

PAST REQUESTS

Posted: June 29, 2010

Comment Closing Date: July 19, 2010

The MEI and the OPA were seeking comments on a proposal for possible changes to the Domestic Content Grid – Wind Power Projects > 10 kW, Exhibit D. Please see FIT Contract Exhibits.

These possible changes are:

1. Table 1 – Grid Cell No. 4 “Hub and hub casing”, where an alternative activity is proposed for hub assembly.
2. Table 1 – Grid Cell No. 19 – a new activity for manufacturing nacelle components that are not listed in Grid Cells 1 to 15.

These possible changes would only be offered to proponents having a domestic content requirement of 50 percent.

These changes will provide added flexibility to wind project developers to meet their domestic content requirements of 50 percent.

In particular, the MEI and the OPA was seeking comments on:

 - Cost and labour hour data of:

o manufacturing the hub
o hub pre-assembly
o hub assembly
o total turbine costs including construction and consulting but excluding sub-station costs
o total project (including sub-station costs)

- Which components, if any, are assembled to the hub in Ontario presently, other than blades, drive shaft and nacelle?

- If the MEI and the OPA proceeded with the possible change to Grid Cell No. 4, which components in the hub should be considered sub-assemblies which may be imported into Ontario? The interpretation would look similar to the one for solar inverters larger than 10 kW. Please see Table of final interpretations.

- If the MEI and the OPA proceeded with the possible addition of Grid Cell No. 19, what Qualifying Percentage would be attainable presently?

- For the possible Designated Activity 19, as with all other designated activities, the OPA shall use its best efforts and endeavour to provide clarity to equipment suppliers in a timely manner regarding the interpretation of the proposed Designated Activity prior to those suppliers initiating investment in Ontario.

Click here for more information about possible changes to Grid Cell 4 and 19 (Wind Power Projects > 10 kW, Exhibit D)

 ________________________________________________________________________

Posted: March 11, 2010

Comment Closing Date: March 18, 2010

The OPA and the MEI have proposed changes to amend the FIT Contract, Exhibit D.

This proposal includes the following designated activities in Exhibit D:

1. Table 1 - Grid Cell No. 2 "Gearless Pitch System"
2. Table 1 - Grid Cell No. 5 "Drives"
3. Table 1 - Grid Cell No. 6 "Generator and Brake"
4. Table 1 - Grid Cell No. 10 "Towers"
5. Table 1 - Grid Cell No. 11 "Materials and Processing for Towers"

Please click here to view the proposed changes to Exhibit D.

 ________________________________________________________________________

Posted: March 3, 2010

Comment Closing Date: March 10, 2010 

Designated Activity "Inverter". 
(See FIT contract, Exhibit D, Table 2, Grid Cell No. 5; Table 3, Grid Cell No. 3; Table 4, Grid Cell No. 5)

"Inverter, where the assembly, final wiring and testing have been done in Ontario."

The OPA has received a number of questions relating to the requirements for inverters. It is now proposing the following interpretations for micro-inverters (Table 4, item 5, less than or equal to 10 kilowatts), and non-micro inverters (Table 3, item 3, or Table 2, item 5, larger than 10 kilowatts). Note that these interpretations are provided as assistance only and are specific to the specially listed table items. These interpretations do not waive any contractual terms regarding Domestic Content and Designated Activities.

For inverters 10 kW or smaller:

1. In order to qualify as “assembly, final wiring and testing”, including as clarified below, all components must be assembled and finally wired into the final inverter in Ontario. All final testing, certification and software installation and configuration must be entirely performed in Ontario.

The following are considered to be components that may be fabricated outside Ontario but must be assembled and integrated into the inverter in Ontario, with the noted qualifications:

a.  printed circuit boards (PCBs)

i. PCBs that are to be assembled and integrated into the inverter in Ontario are not required to be populated with components (e.g., capacitors, resistors, microchips or similar components) in Ontario.

ii. stacked PCBs: each PCB is considered a separate component. Multiple PCBs may not be assembled together outside of Ontario but must be connected together (structurally and electrically) in Ontario.

iii. wiring connecting one part of a PCB to another part of the same PCB is considered integral to the PCB component, whatever the type of wiring connection
used, and is not considered “final wiring” or “assembly” necessary to be performed in Ontario.

iv. other than wiring as set out in (iii) above, wiring connected to a PCB using a screw terminal must be assembled and finally wired in Ontario.

v. other than wiring as set out in (iii) above, for wiring connected to a PCB using soldering, only one end of the wiring may be soldered to the PCB and is thereafter considered integral to the PCB. The unsoldered end must be assembled and finally wired in Ontario.

 b. cables/cable harnesses

i. cables/cable harnesses may be fabricated outside Ontario to the extent they do not constitute final wiring outside of Ontario.

ii. a component on a cable/cable harness is considered integral to the cable/cable harness only if it cannot be easily pulled off and/or cannot slide off the cable or cable harness without damaging the component or the cable/cable harness itself. Tie wraps and similar components normally used to hold together a cable harness are considered integral to the cable harness.

c. enclosure/enclosure lid

i. the entire inverter enclosure and its lid may be fabricated outside Ontario to the extent that, except as set out herein, it is assembled and finally wired in Ontario. The enclosure and its lid must be assembled together in Ontario.

ii. parts required to operate the inverter, e.g., fuses, switches or comparable items, are not considered part of the enclosure or enclosure lid.

iii. other types of parts (e.g., ground lugs, racking or comparable items inessential to operate the inverter) that are normally welded to the enclosure are considered integral to the enclosure/enclosure lid and are not considered final wiring or assembly of the enclosure.

d. housings

i. the housings for housing PCBs, other electronics equipment, or other components, may be fabricated outside Ontario to the extent that, except as set out herein, it is assembled and finally wired in Ontario.

e. whether it or is not part of a PCB, a fan/blower/heatsink component.

i. a fan, blower or heatsink component may be fabricated outside Ontario to the extent that, except as set out herein, the component is integrated into the inverter and finally wired in Ontario.

For inverters larger than 10 kW:

1. In order to qualify as “assembly, final wiring and testing”, including as clarified below, all components must be assembled and finally wired into the final inverter in Ontario. All final testing, certification and software installation and configuration must be entirely performed in Ontario.

Other than those listed in e. to k., the following are considered to be components that may be fabricated outside Ontario but that must be assembled and integrated into the inverter in Ontario:

a. printed circuit boards (PCBs)

i. PCBs that are to be assembled and integrated into the inverter in Ontario are not required to be populated with components (e.g., capacitors, resistors, microchips or similar components) in Ontario.

ii. stacked PCBs: each PCB is considered a separate component. Multiple PCBs may not be assembled together outside of Ontario but must be connected together (structurally and electrically) in Ontario.

iii. wiring connecting one part of a PCB to another part of the same PCB is considered to integral to the PCB component, whatever the type of wiring connection used, and is not considered “final wiring” or “assembly” necessary to be performed in Ontario.

iv. other than wiring as set out in (iii) above, wiring connected to a PCB using a screw terminal must be assembled and finally wired in Ontario.

v. other than wiring as set out in (iii) above, for wiring connected to a PCB using soldering, only one end of the wiring may be soldered to the PCB and is thereafter considered integral to the PCB. The unsoldered end must be assembled and finally wired in Ontario.

b. cables/cable harnesses

i. cables/cable harnesses may be fabricated outside Ontario to the extent they do not constitute final wiring outside of Ontario.

ii. a component on a cable/cable harness is considered integral to the cable/cable harness only if it cannot be easily pulled off and/or cannot slide off the cable or cable harness without damaging the component or the cable/cable harness itself. Tie wraps and similar components normally used to hold together a cable harness are considered integral to the cable harness.

c. enclosure/enclosure lid

i. the entire inverter enclosure and its lid may be fabricated outside Ontario to the extent that, except as set out herein, it is assembled and finally wired in Ontario. They may be attached together outside of Ontario.

ii. parts required to operate the inverter, e.g., fuses, switches or comparable items, are not considered part of the enclosure or enclosure lid.

iii. other types of parts (e.g., ground lugs, racking or comparable items inessential to operate the inverter) that are normally welded to the enclosure are considered integral to the enclosure/enclosure lid and are not considered final wiring or assembly of the enclosure.

d. fan/blower/heatsink components (component cooling)

i. a fan, blower or heatsink component whose purpose is to specifically cool an inverter component (e.g. a PCB heatsink) and not a fan or blower whose purpose is to cool the entire inverter may be fabricated outside Ontario to the extent that, except as set out herein, the component is integrated into the inverter and finally wired in Ontario.

The following are considered to be components that may be fabricated and/or mounted into the enclosure outside of Ontario:

e. fan/blower components (inverter cooling)

i. fan and blower components whose purpose is to cool the entire inverter may be mounted to the enclosure outside of Ontario. Final wiring and assembly must be performed in Ontario.

f. 3-phase AC inductor/reactor/choke components

i. the 3-phase alternating current inductors, reactors and choke components may be mounted into the enclosure outside of Ontario. Final wiring and assembly must be performed in Ontario.

g. DC capacitor banks and their heatsinks and metal work

i. direct current capacitor banks, their heatsinks and associated metal work may be mounted
into the enclosure outside of Ontario. Final wiring and assembly must be performed in Ontario.

 h. 3-phase AC transformer i. 3-phase alternating current transformers may be mounted
      into the enclosure outside of Ontario. Final wiring and assembly must be performed in
      Ontario.

i. power transistors i. power transistors, (e.g., insulated-gate bipolar transistors), the PCBs directly controlling them, and their heatsinks may be mounted into the enclosure outside of Ontario.
Final wiring and assembly must be performed in Ontario.

j. control, monitoring and communications electronics

i. the PCBs, power supplies, fuses, wiring, terminal blocks and housings for control, monitoring and communication electronics may be mounted into the enclosure outside of Ontario. Final wiring and assembly must be
performed in Ontario.

k. wiring and cabling between items ‘e’ through ‘j’

i. wiring and cabling as between items ‘e’ through ‘j’ may be performed outside Ontario, although final wiring of the inverter must be performed in Ontario.