The Green Energy and Green Economy Act is changing Ontario for the better. CH Four Biogas, a developer of anaerobic digesters and biogas technologies, is glad to be a part of this development by providing some feedback on the Draft FIT rules. While many issues around the biogas industry have improved in the last months, the biggest obstacle, which remains unchanged and is even in place to become worse under the proposed rules, is undoubtedly grid connection. CH Four Biogas very much encourages the OPA to revisit and rethink their transition to a new procedure. In the following, we provide comments and propositions on the aspects we deem most important:

1.CH Four Biogas would first and foremost like to thank and congratulate the OPA on the new FIT tariffs implemented just recently. These advancements in tariffs are encouraging and prove that the OPA is willing to help the biogas industry expand. CH Four Biogas would also like to recognize most of the efforts the OPA put into the Green Energy Act.

2.Seeing as anaerobic digestion systems are in fact local power for local farms built by local industries, CH Four Biogas would approve that the requirement for Provincial Content apply to anaerobic digesters. The local content of farm-based biogas plants comes naturally and should therefore be underlined.

3.With the new tariffs, the principal struggle for the implementation of biogas projects has moved away from the economical aspect and moved on to the historical battle for grid connection. Ontario is internationally recognized for its failure to get distributed generation on the distribution network. Clause 3.2 of the Draft FIT rules is raising serious concerns:

We painfully understand that the queue approach exercised until now is dysfunctional and a new system must be introduced. However, the proposed transition is just as dysfunctional. Hydro One is notoriously substantially behind schedule to comply with code timelines issuing CIA's. Suggesting to cancel all CIA's issued over the past few years and have all projects reapply will lead to chaos within the industry.

Rather than canceling everything, the projects having achieved maturity and those already under construction, or going into construction within 12 months from availability of the FIT program, should be allowed to move forward and get connected as soon as possible, based on the work already done. Anybody who did not sign RESOP must be legitimately entitled to proceed under FIT.

OPA should encourage project development to take place and consequently support the projects that did their homework and are at an advanced stage or are already under construction.

4.Biogas plants have the potential to generate environmental attributes:

a)Reduction of transportation by transporting the organic waste to the biogas project at, in example, 4 km away instead of a landfill over 100 km away.
b)Reduction of methane emissions from the landfill by diverting the organic waste to the biogas project, where the methane is used to produce electricity and therefore converted to CO2.
c)Recycling organic material to agriculture as soil amendment and therefore replacing chemical fertilizer for crop production. Replacement of ammonia nitrate, which is energy intensive to produce chemically, does have a strong potential to offset natural gas consumption for producing ammonia nitrate.
d)Reduction of methane emissions from the livestock operation in particular emissions from the manure storage.
e)Displacement or substitution of non-renewable energy from the grid by renewable energy, such as wind, photovoltaic or biogas.

The OPA's claim to 80% of all these attributes should be diminished to only certain specific products. Only the environmental benefit e) should be assigned to the OPA, the rest shall remain at the disposal of the developer respectively available to assign to other stakeholders, such as organic waste suppliers. This way, all involved stakeholders have an incentive to make the project economically viable.

These recommendations have been based on first hand experience and we believe that they would greatly help the biogas industry in Ontario. CH Four Biogas is not looking to denigrate the OPA's efforts, but to collaborate with them in order to develop a well organized, functional and satisfying program.

Sincerely

Benjamin Strehler
Vice-President