Mr. Jason Chee-Aloy
Director, Generation Procurement
Ontario Power Authority
120 Adelaide Street West, Ste. 1600
Toronto, Ontario M5H 1T1

SUBJECT: Feed-In-Tariff Program Draft Program Rules

As a company consisting of taxpaying and electricity rate paying individuals, Rooftop Kilowatts Solar Inc. believes that every Ontario resident and business should have the opportunity to produce power using the available roof space on current buildings and to design future buildings to have this capability. We applaud the Ontario Power Authority and Ontario government in moving forward with this FIT initiative.
We have recently heard that the OPA expects to receive FIT contract applications that exceed transmission capabilities, which tell us that the FIT rate for large scale commercial projects has been set too high and should perhaps be adjusted in favour of small scale projects.
In our view, any FIT program should achieve a number of objectives, one of which is to increase the renewable energy capabilities of the province. But this is also an opportunity to put money and jobs into local economies, and it would be wrong to offer a FIT that benefitted only large corporations rather than allowing every rate paying citizen the opportunity to feed the grid they have long supported and will support for generations to come.
A FIT can create jobs by developing an economy that didn't already exist while making the power grid more efficient and residents more in tune with the power they use because they are also able to create this power.
As part of the FIT program, there should be a well-worked plan to bring manufacturing and installation jobs to the province, and to offer willing investors benefits for creating these opportunities. A poorly constructed provincial content mandate could hamper the adoption of renewable technologies and greatly hinder any FIT objectives.
FIT's should only offer a reasonable return for rooftop installations and definitely not be sufficient to displace scarce farmland. The FIT program should exhaust all available and currently unused rooftops -- a vast untapped resource compared to other more solar advanced jurisdictions -- before any incentive is given to develop on otherwise productive land. That being said, we are pleased that the OPA is allowing small scale ground mount projects which levels the playing field for small scale participants.
There should also be a more specific definition around what will happen at the end of the 20 year FIT contract, as solar systems for example will still be producing 80% of their original output. This would greatly improve the comfort level of citizens looking to make an investment.
Furthermore, there should be predictable and transparent rules around when the FIT program could end and under what exact parameters it could be adjusted, either upward or downward. Is this a race to "get your FIT before it disappears" or can we temper the build-out, and therefore build at a reasonable price and not at a price reverse engineered by suppliers.
We respectfully submit these suggestions on behalf of Rooftop Kilowatts Solar Inc.

Best Regards