Distribution System Plans / Comment Letters and Process for Submission to the OPA

On March 28, 2013, the Ontario Energy Board (“OEB”) issued Chapter 5 of the Board’s Filing Requirements for Electricity Transmission and Distribution Rate Applications, entitled Consolidated Distribution System Plan Filing Requirements. Chapter 5 implements the Board’s policy direction on ‘an integrated approach to distribution network planning’, set out in the Board’s October 18, 2012 Report of the Board - A Renewed Regulatory Framework for Electricity Distributors: A Performance Based Approach.

Under the Filing Requirements all distributors are required to file a Distribution System Plan (“DS Plan”) when filing a cost of service application with the OEB for the rebasing of their electricity rates. Distributors are also required to submit their DS Plan to the OPA for comment and to include the OPA’s comments as part of the evidentiary portion of an OEB rate application.

In 2013 OPA provided comments to the following distributors:

  1. Burlington Hydro Inc. (pdf )
  2. Cambridge and North Dumfries Hydro Inc. (pdf )
  3. Festival Hydro Inc. (pdf )      
  4. Fort Frances Power Corporation (pdf )     
  5. Haldimand County (pdf )     
  6. Kitchener-Wilmot Hydro Inc. (pdf )     
  7. Niagara-on-the-Lake Hydro Inc. (pdf )     
  8. Oakville Hydro Electricity Distribution Inc. (pdf )     
  9. Orangeville Hydro Limited (pdf )     
  10. Veridian Connections Inc. (pdf )      

In 2014 OPA provided comments to the following distributors:

  1. Algoma Power Inc. (pdf )
  2. EnWin Utilities Ltd. (pdf )
  3. Horizon Utilities Corporation (pdf )
  4. Hydro One Brampton Networks Inc. (pdf )
  5. Hydro One Networks Inc. (pdf )
  6. Oshawa PUC Networks Inc. (pdf )
  7. St. Thomas Energy Inc. (pdf )
  8. Woodstock Hydro Services Inc. (pdf )
  9. North Bay Hydro Distribution Limited (pdf )
  10. Hearst Power Distribution Company Limited (pdf )
  11. Toronto Hydro-Electric System Limited (pdf )
  12. Niagara Peninsula Energy Inc. (pdf )
  13. Whitby Hydro Electric Corporation (pdf )

 Process for an LDC to submit a DS Plan to the Ontario Power Authority
Filing Requirements Section 5.1.4.2 Renewable energy generation investments states:

 Prior to filing a DS Plan, a distributor must:

1.    Not less than 60 days (where REG investments are contemplated; 30 days otherwise) in advance of the date the distributor needs to receive the OPA letter for inclusion in an application, a distributor must submit information to the OPA in relation to the REG investments identified in their DS Plan and request in writing that the OPA provide a letter commenting on the information by a date that conforms to the distributor’s filing timetable.

Please use this email address - Regulatory.Affairs@ieso.ca - when submitting a DS Plan or information relating to your renewable energy generation investments to the OPA.  Please include any specific instructions, including the name of the person to be contacted if OPA staff has questions about the content of your information during the review period and the date that you require a response. 

Once your DS Plan has been submitted to the OPA, it will be reviewed by the appropriate electricity system planners and FIT program administrators.

The OPA comments, to be included with your Ontario Energy Board applications, will be returned to you through email on or before the timelines specified by the LDC that conforms to the distributor’s filing timetable.

Section 5.1.4.2 states that [t]he Board expects that the OPA comment letter will include:

  • the applications it has received from renewable generators through the FIT program for connection in the distributor’s service area;
  • whether the distributor has consulted with the OPA, or participated in planning meetings with the OPA;
  • the potential need for co-ordination with other distributors and/or transmitters or others on implementing elements of the REG investments; and
  • whether the REG investments proposed in the DS Plan are consistent with any Regional Infrastructure Plan.


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OPA Contact Information

The OPA encourages LDCs to get in touch with the OPA for further assistance with respect to the preparation of Distribution System Plans or about the information required and the review process in general. For further assistance please contact:

Regulatory Affairs
Ms. Miriam Heinz, Regulatory Coordinator
416 969-6045
miriam.heinz@ieso.ca

Ms. Nancy Marconi, Manager, Regulatory Proceedings
416 969-6046
miriam.heinz@ieso.ca