Topic:"Community Feed In Tariff" in M03632

Summary & Overview St. Francis Xavier University (STFX) is a leading Canadian undergraduate university located at Antigonish, Nova Scotia. The STFX campus is heated by a central heating plant which is located at the center of the lower cam...

AI summary St. Francis Xavier University (STFX) seeks to replace its aging central heating plant with a Combined Heat and Power Biomass (CH&PB) facility. The current 90-year-old plant uses bunker C and fish oil, while the proposed CH&PB requires a Comfit rate of 21.3 cents/kWh to achieve a 13% return on equity. STFX cites a 2009 CBCL analysis and adjusted Synapse's 2011 assumptions to support this rate, aiming to leverage a Community Feed-in Tariff for feasibility.

5.0 Two Tier Pricing Model - 5.1. For purposes of this discussion we are referring to 1.2 (d). The COMFIT price setting process and subsequent programs in Ontario recognized the necessity for a multi-tiered approach to ensure that the Onta...

AI summary The text discusses the Two Tier Pricing Model, emphasizing the need for a multi-tiered approach to enable Mi'kmaq participation in COMFIT programs, similar to initiatives in Ontario. It highlights challenges faced by the Mi'kmaq, including regulatory obstacles preventing partnerships with Nova Scotia Power, and the potential of a Mi'kmaq price adder to facilitate participation.

1.1.3 Two Tier System With regard to the unique economic circumstances facing the Mi'kmaq, the Renewable Energy Regulations have implications that must be recognized and addressed so that the Mi'kmaq are neither unduly impacted nor constra...

AI summary The document discusses the need for a two-tier system in the Renewable Energy Regulations to address the unique economic circumstances of the Mi'kmaq, ensuring they are not unduly impacted and can participate in renewable energy development. It proposes a Community Feed-in-Tariff (ComFIT) system and a special purchase agreement formula to support Mi'kmaq communities in accessing capital markets.

Dear Mr. Christmas: We understand that you are making a submission to the Nova Scotia Utility and Review Board (UARB) on behalf of the Assembly of Nova Scotia Mi'kmaq Chiefs in relation to the hearing to determine Renewable Energy Communit...

AI summary The submission to the UARB by the Assembly of Nova Scotia Mi'kmaq Chiefs seeks comments on the proposed capital structure for wind projects on reserve lands. The consultants suggest a 50% debt to 50% equity ratio, but the Indian Act's regulations on First Nation property may affect the ability to secure financing on these lands.

Operation and Maintenance Scotian WindFields Inc believes that the operation and maintenance costs assumed for small wind are too low. While the figures included in the models may be accurate for the physical maintenance required on the tu...

AI summary Scotian WindFields Inc. argues that the operation and maintenance (O&M) costs for small wind projects in the COMFIT program are underestimated, as they do not include site maintenance, land leases, and administrative costs. They recommend increasing O&M costs to 1.8% of capital costs, which is still below the standard range of 2%-4%.

s who do. The existence of these many (often overlapping) incentives in the U.S. makes comparisons between the availability of equity in the U.S. and Canadian renewable energy markets tenuous at best. This highlights the importance of ensu...

AI summary The text discusses the importance of ensuring COMFIT projects in Nova Scotia can achieve a reasonable return on investment, highlighting the challenges of securing debt financing post-financial crisis and the need for appropriate rates. It also notes that the 8% debt rate assumed by Synapse is reasonable, though some projects may achieve lower rates.

Reply Submission May 6, 2011 1 Please accept this submission on behalf of Nova Scotia Power Inc. with respect to the 2 Utility and Review Board's proceeding to set community feed-in tariffs (COMFIT) 3 pursuant to the Renewable Electricity...

AI summary Nova Scotia Power Inc. submitted a reply to the Utility and Review Board's proceeding regarding the setting of community feed-in tariffs (COMFIT) under the Renewable Electricity Regulation and the amended Electricity Act. The submission responds to recommendations made by the Ecology Action Centre, including the need for a distribution grid assessment and an access guarantee for COMFIT projects.

- Community Feed-in Tariff? Page 36 NSUARB-BRD-E-R.10 1 MR. RICKERSON: Not with the exact 2 characteristics, no. 3 MR. MERRICK: Do you know of any 4 COMFIT errors? 5 MR. RICKERSON: Again, I think it 6 depends on how you define COMFIT. 7 Co...

AI summary The discussion revolves around the Community Feed-in Tariff and whether there are existing examples of tariffs that limit ownership to specific groups. The conversation highlights that while some legislative proposals have been made, none have been passed into law. The term COMFIT is also referenced in the context of defining errors.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS set by the Board; is that possible the way you see it? 1 NSUARB-BRD-E-R.10 Page 549 MR. TRAVIS: Well, no. I mean, we 9 has suggested. So by that it would be a and like a 10 reopener, as an ex...

AI summary The discussion revolves around the Community Feed-in Tariff (COMFIT) and the suggestion to adjust rates based on market conditions, such as changes in the price of wood fibre and biomass, during reopener events every two years.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS power project at the university to supply heat to the 1 campus, so I would suggest that there are other 2 opportunities and that sawmills are only one. 3 We're not advocating that we're the 4...

AI summary The discussion highlights the potential for various entities, including sawmills and municipalities, to participate in the COMFIT program, while addressing concerns about risks associated with variable process heat and efficiency thresholds.

- grouped together a bunch of like-minded sawmills that had - kind of a similar interest and maybe similar opportunity - and we agreed to, you know, put a submission in together - for this community feed-in tariff rate. - It could have inc...

AI summary A group of sawmills, not officially associated, collaborated on a community feed-in tariff rate submission. They selected the largest three out of six sawmills due to economies of scale, with operations around 18,000 pounds per hour.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS Christmas' point, it is in our budget today, a Mi'kmaq 1 ecological knowledge study. Not particularly relevant to 19 We believe there'll be no debt 20 available to tidal energy projects at th...

AI summary The discussion involves the financial structure and funding challenges for tidal energy projects, noting the lack of available debt and the reliance on equity. The COMFIT application process is mentioned as a way to provide data to banks for project support, and the importance of having a clear business case and financing plan is emphasized.

DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS ultimately comes from the manufacturer who'd be using the 1 NSUARB-BRD-E-R.10 Page 927 COMFIT structure as a way of testing and demonstrating the 2 technology and being able to say we've instal...

AI summary The discussion revolves around the COMFIT structure as a method for testing and demonstrating renewable energy technology, with a focus on community partnerships and commercial viability. The conversation also touches on ownership and financing arrangements for renewable energy projects.

Nova Scotia Power. Page 930 NSUARB-BRD-E-R.10 22 projects that responded to the RFP and were awarded DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS 1 NSUARB-BRD-E-R.10 Page 937 contracts were flukes, then that would be different. 2 But thes...

AI summary The text discusses the capacity factor of wind energy projects and its impact on cost, referencing the COMFIT program. It notes that lower capacity factors lead to higher costs and that the average capacity factor for projects is 37 percent. The discussion highlights that capacity factor is a significant but not the only driver of cost.

- that kind at that kind of level. 1 Page 942 NSUARB-BRD-E-R.10 When something outside of their core 2 interests pops up that's an opportunity to save energy, 3 improve the environment, do something that their 4 constituents want to have h...

AI summary The discussion highlights that municipalities may become involved in COMFIT projects in the future, but their current non-involvement does not preclude future participation. The conversation also addresses the challenge of determining appropriate rates for COMFIT projects, emphasizing the need to avoid unfair disadvantages to other participants.

- Street as we are in Canada. - MR. CHERNICK : You may get your money - from Germany. You may get it from China. - MR. TOWSE : I'm not getting the money - from anywhere, Mr. Chernick. - MR. CHERNICK : By you, I meant, you, - the Province o...

AI summary Mr. Chernick argues that the Province of Nova Scotia's COMFIT programs may be coercing communities into developing renewable energy projects without genuine community participation, with funding coming from external sources. Mr. Towse responds by asking if Mr. Chernick has finished speaking.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS MR. TOWSE : Thank you. Thank you for 1 Page 950 NSUARB-BRD-E-R.10 MR. CHERNICK: Yes. 2 MR. TOWSE: We will go on to look at 3 the amount of equity that you that would be required. 4 The assumi...

AI summary The discussion centers on the equity required for COMFIT projects and the ability of communities to invest in wind projects through CEDIFS. Mr. Chernick admits he is not aware of the amount of money CEDIFS has raised, and Mr. Towse offers to provide a link to relevant government websites.

report back. 1 If NSPI is prepared to undertake to 2 produce it, that would be the more direct way, I would 3 think. 4 THE CHAIR: Why don't you and 5 Ms. Godbout chat about it and see how we might most 6 effectively do it? NSPI hasn't prod...

AI summary The discussion revolves around NSPI's production of a witness and confidentiality concerns, as well as a question regarding community eligibility requirements for feed-in tariffs in other jurisdictions, specifically referencing Ontario's provisions.

- the community and being re-spent in the community, I can't - see a major difference, although possibly a community- - owned enterprise would be more likely to hire a local - contractor to do some work rather than bring somebody in - from...

AI summary The discussion centers on the economic benefits of community-owned renewable energy projects, emphasizing long-term profitability and local job creation in construction, operation, and maintenance phases. Ownership is highlighted as a key factor for sustained economic development.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS large wind farm, if you've got 20 to 30 turbines, you're 1 going to have somebody nearby to take care of the routine 8 other than the interest or dividend payments going back to 9 local peopl...

AI summary The discussion revolves around the economic development benefits of community-owned renewable energy projects, with concerns raised about whether these projects are extracting money from ratepayers and redistributing it to non-local investors, potentially undermining economic development in Nova Scotia.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS difference, but there may be some, depending upon how you 2 MR. PYNN: Okay, that's all I have. 3 Thanks. 4 THE CHAIR: Thanks very much. 5 St. F.X. I don't see Mr. Coady here. 6 Wind Prospect...

AI summary The text includes a portion of a regulatory proceeding where Mr. Outhouse references the Renewable Electricity Plan and the Community Feed-in Tariff (COMFIT), asking Mr. Chernick about his interpretation of the plan and Synapse's analysis, specifically regarding the 100 megawatts target.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS be clear. Six percent is debt, 11 percent is equity on 1 small wind, large wind and hydro; on biomass and tidal, 19 me to be a pretty good deal for a testing facility. 20 MR. DEVEAU: And in r...

AI summary The discussion revolves around Nova Scotia's position in tidal energy development, with reference to the COMFIT program. The conversation highlights Nova Scotia's potential leadership in tidal energy and explores other jurisdictions with similar initiatives.

- of if we had this much flowing back what would happen. - And the distinction that I believe is - intended here is that the COMFIT is not projects are - not eligible for the COMFIT if they would get into that - situation and require that...

AI summary The discussion focuses on the eligibility criteria for the COMFIT program, particularly regarding the 200 megawatt limit on the distribution system and the need for the Board to explicitly state this in the tariff. The speaker highlights the importance of clarifying these limitations to avoid potential issues.

- And so I subtracted that value, - whether it's the avoided fuel or avoided renewables, from - the total payments under the COMFIT and got those two - lines, the dollars saved per year if avoiding either base - fuel or the RFP renewables....

AI summary The speaker discusses calculating the financial impact of the COMFIT program by subtracting avoided fuel and renewable costs from total payments, resulting in percentage increases in costs for NSPI. The Chair clarifies that these percentages are not simply additive.

- percent. NSUARB-BRD-E-R.10 Page 1029 5 I think LaHave is next. THE CHAIR: 6 Did you have a question? 7 FURTHER CROSS-EXAMINATION BY MR. TOWSE 8 MR. TOWSE: Yes. Mr. Chair, just a 9 point of clarification regarding the potential for COMFIT...

AI summary The discussion revolves around the COMFIT program and the requirement for transmission inter-connection studies for projects proposing to feed energy back into the transmission system. The participant argues that requiring such studies would make projects ineligible for COMFIT and is seen as superfluous.

- comment on those, no. Page 1062 NSUARB-BRD-E-R.10 10 that they could determine a rate? 11 MR. LEVY: I would speak with the 12 people who are active in this region. I would also 13 consider input from people who have experience in other 1...

AI summary The discussion involves Mr. Levy and Mr. Barry discussing the acceptance of input from organizations like Scotian WindFields and Seaforth Energy, and Mr. Outhouse cross-examining Mr. Levy on his recommendation regarding COMFIT project pricing.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS MR. LEVY: I could also I'd be very NSUARB-BRD-E-R.10 Page 1073 1 happy to provide that presentation insofar as the Board 2 wishes to for your review. 3 MR. DEVEAU: Sure, okay. Yes, that 4 wil...

AI summary The discussion revolves around the data collection process for capacity factors by Natural Resources Canada, the source of data from Heli-Max, and the use of assumptions from a Quebec study for determining an appropriate FIT rate. The participants are confirming data sources and the scope of the data collection.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS Upon resuming at 2:03 p.m. 1 NSUARB-BRD-E-R.10 Page 1077 MR. OUTHOUSE: Mr. Chair, during the 2 lunch break Mr. Levy approached me and he indicated that 3 he had been able to confirm a point o...

AI summary Mr. Levy clarifies that in Quebec, community wind projects under 25 megawatts have a starting price of $12.5 cents per kilowatt hour, fully indexed to CPI. The Ecology Action Centre calls Toby Couture of E3 Analytics to provide opinion evidence on COMFIT and feed-in tariffs.

I guess what I would dispute is that that is a material impact on the levelized cost of energy production from community based projects. I don't think the impact is substantive enough and there are or that it's even substantive at all. Pag...

AI summary The speaker disputes the claim that there is a material impact on the levelized cost of energy production from community-based projects. They reference Ontario's feed-in tariff policy, which includes an adder for community-based projects, and highlight the disparity in tariffs between small (under 50 kW) and larger projects in Nova Scotia.

DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS MR. COUTURE: Clearly there are other 1 NSUARB-BRD-E-R.10 Page 1091 small advantages but I suppose I would answer the question 2 more generally by saying that they're by and large I've 3 not enc...

AI summary The discussion centers on the cost differences between community-owned and commercial energy projects, noting that while community projects may face fewer opposition challenges, they often incur higher costs due to less efficient development processes. Environmental assessments remain equally rigorous for both types of projects.

supply chain system. Page 1096 NSUARB-BRD-E-R.10 1 So in those countries, the typical 2 rate of return targeted under the feed-in tariff ranges 3 from 5 to 9 percent. 4 So there is some MR. MERRICK: 5 advantage. 6 MR. COUTURE: In mature we...

AI summary The discussion focuses on the expected rate of return for renewable energy projects in Nova Scotia, contrasting it with rates in more developed markets like Germany. The speakers note that Nova Scotia lacks the mature supplier chain and experience to achieve lower rates of return, and there is uncertainty about the profitability of CEDIF projects.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS Now, as the market matures, the risk 1 NSUARB-BRD-E-R.10 Page 1099 of developing projects goes down because you get more 10 printed out just before the hearing began and it's stated 11 to be...

AI summary The text discusses incentives for biomass CHP and biogas production in Vermont, including production incentives and feed-in tariffs, as part of a regulatory proceeding involving Nova Scotia utility and review board matters.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS MR. COUTURE : Yes. 1 NSUARB-BRD-E-R.10 Page 1119 (SHORT PAUSE) 2 MS. RUBIN: Mr. Chair, may we have 3 this marked as the next exhibit? 4 THE CHAIR: It's Exhibit B-28. 5 EXHIBIT NO. B-28: 6 Exc...

AI summary The document discusses a section from a paper titled 'The Policymaker's Guide to Feed-in Tariff Policy Design' by the National Renewable Energy Laboratory, focusing on fuel price adjustments for renewable energy resources dependent on fuel such as biomass. The discussion references Spain's approach to adjusting fuel prices every three months.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS encourage small wind. Under a feed-in tariff the only one 1 NSUARB-BRD-E-R.10 Page 1151 that comes readily to mind is Switzerland. They have a 2 markedly higher tariff for that wind class. 3...

AI summary The discussion revolves around the comparative cost efficiencies of feed-in tariffs and RFPs, with a mention of a report by the Lawrence Berkeley National Laboratory that found high failure rates for RFPs. The conversation takes place during a cross-examination involving the NSUARB.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS So there's significantly higher risk, 1 and that risk means that the investors that are investing 12 jurisdictions have encountered that same problem and have 13 tried to find different solut...

AI summary The text discusses the higher risk associated with investments in certain jurisdictions and suggests exploring solutions like grants to encourage diverse models for tidal energy. It also mentions the limitation of community-based projects in Nova Scotia as a public policy decision.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS Allen study, given the assumption I think you raise a 1 NSUARB-BRD-E-R.10 Page 1181 good point, that based on the assumption that they were 8 happens, and provided it's capped as the Regulati...

AI summary The discussion revolves around biomass feed-in tariffs and their fuel escalator mechanisms. The speaker notes that biomass feed-in tariffs typically do not include long-term contracts and instead use shorter terms with periodic tariff revisions. The Vermont tariff is referenced as a potential example.

make the cut or not. And I think that remains the case in - all small capped feed-in tariff policies. - The cap is also sometimes more - objective in that it's based on the strength of the grid. - So you can have a cap based on how - much...

AI summary The discussion highlights the challenges associated with small capped feed-in tariff policies, emphasizing that caps based on grid capacity are more objective, while others are politically motivated. Caps near their limit create market uncertainty, discourage new applications, and can lead to competitive issues among developers.

- on the amount of a given technology that can be - introduced. - So you could say maximum 50 percent of - the COMFIT will be taken up by wind and that could provide - an alternative to the strict cap only on small wind. - I suspect you're...

AI summary The discussion explores the potential adjustment of the COMFIT program to allow up to 50% of its capacity to be allocated to wind energy, potentially replacing the current cap on small wind projects. The speaker suggests capping the total gigawatt hours of wind energy eligible for the program, considering the higher tariff for small wind projects.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS government's discretion, what they wish to do with the NSUARB-BRD-E-R.10 Page 1217 small wind cap. 2 As it currently stands, I wouldn't 3 interpret it to mean that projects 50 and below would...

AI summary The discussion revolves around the interpretation of a small wind cap in the COMFIT program. There is a distinction made between capping projects below 50 kW and those above, with concerns about overburdening ratepayers and encouraging different technologies. The discussion highlights potential policy implications and the need for clarification.

have to understand that. 1 Page 1246 NSUARB-BRD-E-R.10 These are prospectuses for what's 2 million but they only invest a million. When lesser 3 amounts are raised, the costs of those fees bears more 4 heavily upon the net that can be inve...

AI summary The text discusses the challenges of forming a CEDIF, highlighting the need for a minimum of 25 shareholders and a minimum investment threshold of $100,000. It also mentions the financial implications of raising lesser amounts and the need to reserve funds for operational purposes.

and equity. Page 1252 NSUARB-BRD-E-R.10 1 MR. MERRICK: Last area, 2 Mr. Livingston, that I want to explore with you is whether 3 you intend or your company intends to avail itself of 4 whatever COMFIT rate comes out of these hearings? 5 MR...

AI summary Mr. Livingston argues that the COMFIT rate policy creates ethical challenges and risks for small shareholders, particularly in community projects. He criticizes the government for not addressing these concerns and highlights the difficulty of forming a CEDIF without sufficient initial funding.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS and an outside equity comes in with the rest of the money, 1 how do I ever, as that high risk first person, get 2 rewarded. Because my experience is that there isn't 3 enough territory to do...

AI summary The discussion revolves around the COMFIT rate and its intended use for community organizations rather than economic or commercial entities. Concerns are raised about the model's effectiveness and the lack of proper consideration for local expertise in project success. The COMFIT rate is questioned as being no higher than what a utility would offer in a small RFP.

- between $6,000 and $12,000 annually for projects and - turbines in the 50 kilowatt range, and suggest that even - though the processes may and standards involved in the - COMFIT program will likely be higher than that metering, - that we...

AI summary The text discusses the COMFIT program, noting that operational and maintenance (O&M) costs are in the lower range despite higher standards. It also highlights the lack of a commercial debt market for community projects and the expectation that debt availability will improve, influencing the suggested interest rate changes for wind classes.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS The projects have yet to be financed, 1 NSUARB-BRD-E-R.10 Page 1291 so, generally it involves some form of scenario of a group 11 MR. ROSCOE: Yes, we are still 12 proceeding with the project,...

AI summary The discussion revolves around a project that has yet to be financed and the company's approach to organizing itself in relation to the COMFIT tariff and CEDIFs. The company is not eligible for COMFIT but is collaborating with CEDIFs to develop projects on behalf of community organizations.

- However, that has not yet to trickle its way down. - MR. CHRISTMAS Okay. - MR. ROSCOE : And secondly, I would - suggest that one of the main reasons that their - investments have only been in sort of operating companies - rather than pro...

AI summary The discussion highlights the limited participation of CEDIF groups in large-scale projects like the Digby Wind Farm, due to the high capital requirements. The speaker suggests that COMFIT offers a more accessible opportunity for equity investment in revenue-generating assets.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS good segue to my next question, was that obviously the 1 NSUARB-BRD-E-R.10 Page 1307 Mi'kmaq are interested in the COMFIT process, and 2 specifically large and the small wind in that. 3 Do yo...

AI summary The discussion focuses on the feasibility of returns for CEDIFs under proposed rates and the potential restructuring of CEDIFs to function more like a venture capital pool. Mr. Roscoe suggests that rates in the 13% range are feasible but notes that financial arrangements depend on rate-setting decisions.

- invest it with different opportunities as they are - approached with it. - MR. DEVEAU : Okay. And your answer in - relation to once you get a COMFIT rate - MR. ROSCOE : Yeah. - MR. DEVEAU : then you look at - these projects. - Do you ant...

AI summary The discussion focuses on the potential benefits of setting a COMFIT rate in easing financing pressures for projects, particularly in terms of debt/equity breakdown and returns on equity. The speaker acknowledges the assistance it would provide but expresses concerns about the conditions and timeline for implementation.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS will, yes. I think that it will help. I think that it 1 NSUARB-BRD-E-R.10 Page 1317 I think that the COMFIT program will be essentially a 2 catalyst for community-based renewable energy devel...

AI summary The discussion revolves around the COMFIT program and its potential to catalyze community-based renewable energy development. The speaker acknowledges minor adjustments are needed but believes the program will succeed in meeting its mandate. The Chair asks about electrical losses and availability differences between COMFIT and net metering.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS But we would have financed every 1 single one of the ones that were issued; we would have 2 built every single one of them. 3 Even today, we would be quite happy to 4 say to the Board, to the...

AI summary The speaker discusses the willingness to finance and build resources if given the opportunity, referencing the COMFIT program and Synapse's recommendations for biomass indices. The Chair redirects the discussion to focus on COMFIT, emphasizing its role in allowing eligible participants to access resources through a tariff-based process.

- through the RFP process, and I guess we you could say - that in some senses I was I didn't reach a comfort - level that I was willing go back and get local investors - to invest. - On that issue for a second, I did a - trial run through...

AI summary The speaker discusses a trial run through the RFP process for the Broad River project, highlighting the feasibility of reversing a transformer to supply local demand and feed back into the transmission system. The project involved a 1.2 megawatt substation and a nearby dam located just two kilometers away.