Sand in the Vaseline – Part I

Vaseline_Opened
Image courtesy Med Chaos, Wikimedia Commons

I haven’t experienced Germany’s Feed-In Tariff program directly, but I’ve heard all about it. It’s easy. If you decide you want to participate, you go through a perfunctory application process and you’re in. You get whatever rate is in effect when you apply. Painless.

In a perfect world, the Ontario FIT program would be just as simple. The most obvious case crying out for simplicity would be the small-scale residential part of the program, called MicroFIT.

If you wanted to take part, you would register online – that always makes life easier, right? If, like my company, you work on behalf of a customer, you would only have to register once for yourself, and once for each customer, and you would have one place to go to see the status of every one of your projects. Your customer would have their own account that would let them see just their own project.

Of course, there is a 20-year contract involved, and it relates to a piece of real estate. There would have to be a way to ensure that everyone registered as an owner of the property in question was a party to the MicroFIT contract. But since the Ministry of Natural Resources already has a database which contains exactly the required information, it would be a piece of cake to use the free interface available to other provincial ministries to look up the property and return the names of the owners – and even to make an automatic correction if you hadn’t entered the legal name that is on file. Then the system would simply require that each owner give consent, and that’s that.

However, in the real world, things are very different. The process is fiendishly complicated, and there are reams of seemingly arbitrary rules. You’d almost – almost – think that someone was doing their level best to limit participation to the lowest level possible.

The online tool that the OPA has provided is so much less than it could be. As a contractor, I do not get my own account. Instead, I have to create a new one each time I have a new prospective customer (including collecting and then inputting sensitive personal information that I’d rather not have to handle, and that they are perfectly able to enter themselves), enter my own contact information every such time, and share the login and password information with the customer. If the customer neglects to click the confirmation link in an automated email, or decides to change their password, it can stop up the whole application for days.

This is to say nothing of the fact that sharing passwords is the Single Deadly Sin of information security. It simply isn’t done. The designers have put those annoying “captcha” tests in at every opportunity, but left the most glaringly obvious security hole right in the middle of everything. It is astounding that any self-respecting web developer would have put their name to this beast.

If I want to see how each of my potentially dozens of applications are doing, I have to log in to each one individually – no bird’s eye view for me. It is incredibly simple to lose track of where a particular application is in the process, and to miss the window of opportunity to complete the next step. Then it’s back to square one.

If there is more than one person on title, you have to enter their first name, last name, and date of birth on the web page, and then you have to enter that all over again – along with their address, phone number, and email address – on a PDF that you then attach to your application. An OPA employee must open that form to confirm everything is correct, since the web site can’t do that automatically.

To make sure you haven’t missed anyone that’s on title for the property, you have to visit your local Land Registry Office and pay for a Parcel Registry form (or pay an additional $20 plus HST to get it online). Then you have to upload this document to the OPA website. After you submit your application, an OPA employee has to open the document and manually check that there is contact information in the application for each person on title. They also check that the name on the parcel form is an exact match to the name on the online application. If you goofed by omitting a middle name, or using a married name instead of the registered maiden name, or using a commonly used name instead of the legal name, the OPA will gleefully toss your application back at you or just terminate it outright.

And after all that effort, how does the system ensure every party that is on title for the property has agreed to take part? You check a box on a web page. That’s it.

Again, if you’re a contractor, you have to get each person on title to sign a form giving you permission to act on his or her behalf.  If the name on that form is not an exact match with the name on the Parcel Registry form, the OPA will once again kick it back at you or terminate the application. Oh, and to make life interesting, they sometimes issue a new version of the form, forcing you to re-do every form for every application that is still in progress. Nice.

The OPA’s only real concern in this process is to ensure that this contract will not be the one that pushes them over their self-imposed Annual Procurement Cap. That and to ensure their contract will be legally binding. With a decently designed web application including an interface to the Land Information Ontario database, they could make the application process simple, automatic, fast, and foolproof.

Instead, they’ve made it byzantine, labour-intensive, glacially slow, and massively error-prone.

That’s to say nothing of the total lack of decent flow-through of information to the other parties further along in the process. I’ll take a dive into that quagmire next week.

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5 thoughts on “Sand in the Vaseline – Part I”

  1. A mostly accurate article. The one positive side of all of this is that the process limits companies that simply want to bog down the application process to limit competition. When the process was simpler, it was easy for companies to get non-confidential information from a client and submit a microfit application without the client consenting or sometimes even knowing about the application. Since the government is paying about 4x what Germany is paying per kWh, it is a lot more lucrative for Ontario residents and Ontario businesses to participate, and obviously the shortsightedness of greed gets in the way of progress. The new application process is actually much faster if you are accurate in every step of the process, and it is a GOOD thing that a fee is required, or time spent to get the parcel register so that there will be less applications from companies for people who don’t actually want to apply. The new application process restricts the companies that submit applications because “it is free, so if you don’t want to install it, you don’t have to”. The new microfit process is an improvement over the old process because the applications that are submitted correctly are turned around a lot quicker. I just received a microfit approval after 9 calendar days. That must be a record for the OPA! Now on to the Hydro One application, which is usually quick and easy. If everything goes at it is, we could be installing in 3 weeks time! Not bad.

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    1. Thank you for the feedback, Stuart. Sometimes my past life as an IT business analyst and project manager tends to colour my judgement. My frustration is mostly with the poor design of the application, the redundant data entry, the many opportunities for errors – or, as I call them when explaining to a client why its better for us to apply on their behalf, the “gotchas” – all of which make it look like someone deliberately designed it not to be efficient. I agree that the cost of the parcel registry form, while minimal, is sufficient to stave off frivolous applications. They could have as easily kept the revenue in the OPA’s hands and pay down the cost of the application by employing my data interface idea and charging a service fee for each application.

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      1. I agree with you on many levels Alex, a simple $50 fee for microfit application would have been a smart approach. The next improvement will be when the OPA consolidates all applications into one…. Building permit, LDC app, etc. That would eliminate a lot of red tape. Please check out a small article I wrote about SaskPower’s net metering program. http://paid4power.ca/saskpower-net-metering-worth-looking-into/ I believe net metering to be a better program than the FIT, both socially and economically. It is what drives the US solar industry today.

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      2. I read your article and liked it (I also shared it on LinkedIn). Net metering combined with a partial capex rebate is attractive because the level of investment by the utility tracks the declining cost of installation directly. Very elegant. However, it doesn’t address the fact that solar is more valuable power because its peak production coincides exactly with peak demand, when other purchased power (from neighbouring states and provinces, for example) is at its most expensive. A friend in need is a friend indeed, and the price should reflect that. Ontario already has one foot in the door with Time Of Use billing, so all that need happen is the addition of the capex incentive to the existing net metering program already in place in the province, and Bob’s your uncle.

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