We feel there are a few key points that will ensure corprorate participation, that will stimulate program growth and installed renewable capacity in the Province of Ontario.

First, the point of connection to the grid is very important to us. We employ many initiatives to reduce our energy consumption and emissions. We are presently building and operating LEED certified manufacturing plants in North America. Integrating a renewable energy component into our buildings facilitates our qualification under this certification. If our point of connection is in series it will help with LEED certification, reduce our energy drain on the utlity grid, in turn reducing associated line losses and transmission congestion to our facility. This will free up that grid power for others closer to the source of generation. We feel that despite our point of connection there are still clear benefits to the Ontario electrical system, that justify qualification for 100% of the suggested FIT, while still permiting our facility to use the green energy created at our facility.

Second, we are committed to CO2e emissions reductions. Is there certainty that any CO2e offsets created from the installation of a renewable energy generator at one of our locations will either be retired, or under our control.

Third, the application process must clearly identify a time line for application approvals. For example, our understanding of the Green Energy Act is that if we build a renewable energy facility we will be provided a connection to the utility, provided we meet the relevant technical and environmental requirements. Our business requires greater certainty in timelines for project implementation. If we apply for a contract and meet all of the criteria identified in the Draft FIT rules, will we be given a 30 day turn around or a 60 day turnaround for the FIT contract? The COD concept is confusing, greater certainty in contract approval would help.

Respectfully submitted,
NWC