CFFO Submission on MicroFIT Programming
The Christian Farmers Federation of Ontario (CFFO) is taking the opportunity to provide comments on the future direction of the FIT and microFIT programs within the province on Ontario. The Christian Farmer’s Federation of Ontario represents the interests of 4,000 farmers across the province approaching farming and rural issues from a Christian perspective.
The Ontario Government has outlined five key focus areas for comment. The following CFFO recommendations deal with each of these key areas in turn.
1. FIT and microFIT price reductions. The CFFO supports strong reductions in FIT and microFIT pricing for solar and wind power.
Rationale: The price for FIT and microFIT solar projects must be reduced a significant amount for the next two years. World prices for solar panels have dropped by as much as 40% over the last year. Given that the long-term goal for the solar industry in Ontario is to be an export hub for North America, it is critical that the industry be streamlined to compete on the international stage. Strongly subsidizing new installations in this industry for another two years will not position Ontario-based companies to compete on the international stage in the medium to long-term.
Furthermore, the CFFO views the previous two years of FIT and MicroFIT pricing as seed money to jump start the industry. It is our expectation that the price will drop for the next two years and will eventually be brought into line with more conventional forms of energy production in the medium-term.
2. Ensuring the long-term Sustainability of clean energy procurement. The CFFO considers sustainability from a triple-bottom line perspective that considers economic, environmental, and social impacts.
Wind FIT Concerns: the FIT program for wind power is failing to be socially sustainable. Nothing short of a community-based approach is going to reduce the level of opposition to the presence of turbines in communities. The people that live in the shadow (at least a 2 Km radius) of these objects need to be involved in the process, and revenue-sharing instruments be adopted.
Solar FIT Concerns: There are growing concerns regarding FIT projects on Class 4 land or better in Ontario. There are reports that $500 per acre per year is being offered for this land for a 20 year period. The rental rates being offered for land go far beyond the competitive rate that can be offered by farmers for agricultural purposes. In the view of the Christian Farmers, this means that the pricing for FIT projects is far too high. The best place for these panels is on the rooftops of buildings, not in the rural country side.
3. Continuing to build on the success of Ontario-based manufacturing and clean energy job creation. The CFFO supports the continued existence and growth of Ontario-based manufacturing based on being able to compete on the international stage in the medium to long term. However, if an honest assessment of the future of the industry points toward it being unsustainable in the long-term in this province, then strong consideration must be given towards cutting our losses as a province now rather than later.
4. Consideration of new technologies and fuel sources. For agriculture, there is one opportunity under the Fit/microFIT program that is facing serious hurdles. Small-scale co-generation of heat and hydro using biomass and biogas is facing serious regulatory issues that must be addressed quickly. The social and environmental benefits of these projects are sufficient to warrant a focused effort on resolving these hurdles.
5. Local Consultations and the Renewable Energy Approval process (REA) Regarding local consultations, the CFFO believes that the balance of power has swung too strongly in favour of the province. However, a return to the haphazard regulatory development of the period leading up to the Green Energy Act is not desirable either. A balanced position is needed that allows the province to set the broad direction with local flexibility to reflect the will of communities as a whole is needed.
Further to that, the CFFO believes that open and transparent consultation rules are required for renewable developments. This includes the process by which wind power companies approach farmers and the tactics used to acquire contracts. Communities as a whole need to be approached together and treated as equals in the process.
Regarding REA, the CFFO supports efforts to reduce red tape for FIT and microFIT projects.
Thank you for your time and consideration of these important matters.
Lorne Small, President
Christian Farmers Federation of Ontario