EB CDM Exemption Hydro One Networks' Undertaking Responses ONLY HYDRO ONE UNDERTAKINGS Undertaking Description Filed Date Note

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1 CDM Exemption Hydro One Networks' s ONLY HYDRO ONE S Description Filed Date Note J. J. J. TO PROVIDE NUMBERS OF NON-COMPLIANT APPLICATIONS REQUIRING AND NOT REQUIRING SITE ASSESSMENTS TO PROVIDE STAFFING COUNTS TO PROCESS MICROFIT APPLICATIONS AS AT MAY 00, SEPTEMBER 00, NOVEMBER 00, FEBRUARY 0 AND AS CLOSE TO TODAY'S DATE AS POSSIBLE; AND PROVIDE A DESCRIPTION, WITHIN THE TIMELINE WHEN AUTOMATION WAS ADDED, AND WHAT IMPACT HYDRO ONE PERCEIVES IT TO HAVE HAD ON REQUIREMENTS FOR INCREASED STAFFING COUNTS. TO PROVIDE A BREAK-OUT OF NON-COMPLIANCE ASSOCIATED WITH CUSTOMER- DRIVEN ISSUES VERSUS NON-COMPLIANCE STRICTLY ON THE HYDRO ONE SIDE FOR.. SINCE MAY OF 0. August, 0 August, 0 August, 0 J. TO PROVIDE ASSESSMENT OF THE IMPACT OF AN ANNOUNCEMENT FOR CFIT LAUNCH ON THE NUMBER OF APPLICATIONS ANTICIPATED TO BE RECEIVED. TO PROVIDE DATES THAT EACH OF THE FOLLOWING MITIGATION MEASURES J. WERE IMPLEMENTED: SCREENING TOOL, CUSTOMER COMMUNICATION, WORK PROGRAM MANAGEMENT AND PRIORITIES TO PROVIDE COPY OF NOVEMBER, 00 LETTER TO THE OEB, DISCLOSING J. NON-COMPLIANCE. TO PROVIDE ANSWER AS TO, OF THE,00 OFFERS TO CONNECT, HOW MANY J. WERE indirect AND HOW MANY WERE DIRECT. J. TO PROVIDE DATE OF AUTOMATED IMPLEMENTATION OF SCREENING TOOL, AND INDICATE WHICH STAKEHOLDERS WERE CONSULTED BY HYDRO ONE. August, 0 August, 0 August, 0 August, 0 August, 0 J. TO PROVIDE PERCENTAGE OF APPLICATIONS TO HYDRO ONE THAT HAVE BEEN August, 0 REFUSED CONNECTION SINCE SCREENING TOOL WAS FIRST IMPLEMENTED. J.0 TO PROVIDE NUMBER OF PROJECTS RE-SCREENED SINCE THE PROCESS WAS IMPLEMENTED. August, 0 J. TO PROVIDE A BREAKDOWN OF THE, NUMBER BY DATES, HOW MANY RECEIVED REFUSAL AND HOW MANY RECEIVED AN OFFER TO CONNECT, BROKEN August, 0 DOWN BY PARALLEL AND STANDALONE J. TO PROVIDE DATE GROUPINGS OF LATE APPLICATIONS August, 0

2 Filed: August, 0 Exhibit J. Page of 0 Applications that require a site visit that were not issued an offer/rejection within the timelines (/0) days that: (a) required a site visit and (b) did not require a site visit. The total number of non-compliant projects as of July, 0 is 0. These projects are further broken down into those that:. Require a site visit. Do not require a site visit This breakdown is based on the most recent compliance snapshot with respect to Section.. of the Code, and is a reasonable proxy for the foreseeable future, assuming that the nature and configuration of generation connection requests remains consistent.

3 0 Filed: August, 0 Exhibit J. Page of TO PROVIDE STAFFING COUNTS TO PROCESS MICROFIT APPLICATIONS AS AT MAY 00, SEPTEMBER 00, NOVEMBER 00, FEBRUARY 0 AND AS CLOSE TO TODAY'S DATE AS POSSIBLE; AND PROVIDE A DESCRIPTION, WITHIN THE TIMELINE WHEN AUTOMATION WAS ADDED, AND WHAT IMPACT HYDRO ONE PERCEIVES IT TO HAVE HAD ON REQUIREMENTS FOR INCREASED STAFFING COUNTS. Business Customer Centre (BCC) Staff Count dedicated to microfit projects - BCC May Sep Nov Feb Apr July Date New Hires Full Time Part Time Total Staff BCC Overtime Hours Note: 0 Staff increase in May is based on number of staff of which portion is part-time with the ability to flex to full-time if required. The above staff count is based on month end numbers. Business Customer Centre Staff Count Number of Staff May (00) Sept (00) Nov (00) Feb (0) April (0) July (0) Month

4 Filed: August, 0 Exhibit J. Page of Business Customer Centre Overtime Hours Number of Hours May (00) Sept (00) Nov (00) Month Feb (0) Customer Care Distributed Generation Staff Count dedicated to microfit projects DG Team April (0) May Sep Nov Feb Apr July Date Staff 0 0 July (0) Customer Care Distributed Generation Staff Count Number of Staff May (00) Sept (00) Nov (00) Feb (0) April (0) July (0) Month

5 Filed: August, 0 Exhibit J. Page of Customer Operations Staff Count Customer Operations Date May 00 Sep 00 Nov 00 Feb 0 Apr 0 July 0 Staff 0 0 Overtime Hours 00 0 N/A Note: Casual Trades is comprised of Hiring Hall Line Maintainers, Data Collectors and Laborers Customer Operations,00 Staff Breakdown,000,00, Other Casual Trades Metering Tech TECH Union Trade Sup UTS Line Maintainer Area Dx Eng Tech ADET - January March May July September November January March May July Customer Operations Overtime Hours Number of Hours May (00) Sept (00) Nov (00) Feb (0) April (0) Month

6 Filed: August, 0 Exhibit J. Page of Key Automations: November 00: Automation of the release of projects to the field. Without this automation, an additional. regular full time staff would be required. June 0: the Capacity Calculator tool helped to streamline the processing of applications at the front end, and reduced the overall handle time. However, the specific impact it had on requirements for increased staffing counts cannot be determined as this would depend on the fluctuating nature of application volumes.

7 0 Filed: August, 0 Exhibit J. Page of A breakdown of non-compliance with section.., by customer requested delays and by outstanding service conditions. For the months of May, June and July 0. The total number of project that exceeded the day timeline to connect stipulated in section.., categorized as requested in the undertaking is as follows: May 0 June 0 July 0 Connected within Timelines Customer Requested Delay Outstanding Service Conditions Total Delayed Note : Service conditions could be an obligation on Hydro One or the Customer.

8 Filed: August, 0 Exhibit J. Page of 0 What is Hydro One s assessment of the volume of applications and the impact on Hydro One if the OPA were to launch the C-FIT program. In the first six months of C-FIT program launch Hydro One anticipates a larger volume and then forecasts the volume to subside. Therefore, Hydro One s forecast is 00 per month during the first six months and approximately per month thereafter.

9 Filed: August, 0 Exhibit J. Page of Provide the dates that each of the following mitigation measures were implemented:. Screening Tool. Customer Communication. Work Program Management and Priorities. Screening Tool In October 00, a manual but Excel-based screening tool was developed and implemented. The tool was a stand-alone application that required data input for each screening. Until then, the company did not have a standard screening tool for assessing micro-embedded generator connection proposals. Minor improvements were made to the stand-alone application in December 00. In June 0, the screening tool was further automated and integrated to retrieve information from the Hydro One databases containing the required information. In June 0, the screening tool was also made available online for customers to use themselves.. Customer Communication In December 00, Hydro One started proactively informing customers that there would be delays in processing their applications. A template of the letter is provided as Attachment to J... Work Program Management Priorities In November 00 Hydro One automated releasing work packages to the field. This was previously done manually by staff. In February 0 work program management instructed staff to prioritize DG connections above all other work other than power restoration and emergencies. In May 0, clarification was provided to field staff regarding compliance with section.. of the Distribution System Code, clarifying the distinctions between the requirements of section.. and.. which apply to load connections, and section.. for micro-embedded generation. In May 0, Hydro One made modifications to databases to improve tracking capabilities of projects through the connection process.

10 Filed: August, 0 Exhibit J. Attachment Re: IMPORTANT INFORMATION Processing of your microfit application Dear Valued Customer, Thank you for your interest in launching a microfit renewable energy project. The tremendous success of the Ontario Power Authority s (OPA) microfit program confirms that Ontarians clearly want to play an important role in connecting clean and renewable sources of power to the electricity grid. The number of project applications received to date by the OPA has far surpassed expectations. Your microfit project application is being processed by Hydro One staff, but due to application volume, we regret it is taking longer than expected. At this time, we are unable to provide you with a response to your application.we are working as quickly as we can and will provide you with a response, either yes or no, once we process your application. We remind all applicants to not purchase equipment for your project until you receive and accept an Offer to Connect from Hydro One. We will contact you directly when we have further information. We appreciate your patience. Sincerely, Business Customer Centre

11 Filed: August, 0 Exhibit J. Page of 0 TO PROVIDE THE NOVEMBER, 00 LETTER Please refer to Attachment

12 Toronto, Ontario MG P Cell: () - Susan.E.Frank@HydroOne.com Susan Frank Vice President and Chief Regulatory Officer Regulatory Affairs BY COURIER November, 00 Ms. Kirsten Walli Secretary Ontario Energy Board Suite 00, 00 Yonge Street P.O. Box Toronto, ON. MP E Dear Ms. Walli: Compliance with Section.. of the Distribution System Code Hydro One Networks Inc. ( Hydro One ) is informing the Board of the current status of its offers to connect under section.. of the Distribution System Code (DSC), and its plans to comply with those requirements. Section.. requires distributors, to, within days of receiving [an application for the connection of a micro-embedded generation facility to the distribution system], make an offer to connect or provide reasons for refusing to connect the proposed generation facility. Hydro One s understanding is that about,000 applications have been made to the Ontario Power Authority s ( OPA s ) MicroFIT program. Approximately,000 of these are expected to propose connections to Hydro One s Distribution system. About 000 generator proponents have already applied to Hydro One. About,00 applicants have valid offers to connect. Of the,000 applications, about,00 applications have been withdrawn, placed on hold by the customer, or have expired. About 00 proponents who have applied to Hydro One Distribution for connection have not been informed of their connection status within the required period and therefore Hydro One finds itself in non-compliance with section... Hydro One has recently implemented remediation plans, which involve process changes and a screening tool to more expeditiously assess those connections that can be accommodated at this time. These will help Hydro One identify any proposals that require upgrades to the distribution or transmission system in order to connect generators. Specifically, these measures will allow Hydro One

13 to process the large volume of connection requests by identifying those that are eligible to connect (no mitigation measures required) and those that are not, so that Hydro One can make offers to connect, or, if necessary, provide reasons for refusing to connect the facility. Accordingly, Hydro One expects to comply with section.. in the near future. Hydro One takes its regulatory obligations seriously, and remains committed to complying with them while supporting the connection of renewable energy generators in its service area. Hydro One will advise affected proponents of the status of application and will also keep the OEB apprised of any changes that may arise. Sincerely, ORIGINAL SIGNED BY SUSAN FRANK Susan Frank

14 Filed: August, 0 Exhibit J. Page of 0 0 Of the,0 total projects (Reference:, Exhibit K.) that have applied to Hydro One as of July, 0 please provide the number of projects by direct and indirect connection type with the following categorization:. Projects that received an offer to connect.. Projects that received a rejection.. Projects that are still being processed. Also, provide a breakdown of the number projects that received an offer or a rejection, by how many were completed within the prescribed timeline and how many were not completed within the prescribed timeline and by direct and in-direct connection type. In-direct ( days) Direct (0 days) Total Offer to Connect,, 0, Rejected,,, Being Processed 0,0 Total,,,0 Offer to Connect or Refusals Issued With timeline Issued Exceeded timeline Total In-direct 0, Direct 0 0,

15 Filed: August, 0 Exhibit J. Page of 0 0 TO PROVIDE DATE OF AUTOMATED IMPLEMENTATION OF SCREENING TOOL, AND INDICATE WHICH STAKEHOLDERS WERE CONSULTED BY HYDRO ONE. A portion of the response to Exhibit J. is repeated below for completeness. In October 00, an Excel-based screening tool was developed and implemented. The tool was a stand-alone application that required data input for each screening. Until then, the company did not have a tool for assessing micro-embedded generator connection proposals, however Hydro One did perform impact assessments. Minor improvements were made to the stand-alone application in December 00. In June 0, the screening tool was further automated and integrated to retrieve information from the Hydro One databases containing the required information. In June 0, the screening tool was also made available online for customers to use themselves. The screening criteria and the development, implementation and automation of screening tool were not stakeholdered. However, the development of criteria and the need for these criteria was brought to the attention of Ontario Energy Board Staff and the Ontario Power Authority.

16 Filed: August, 0 Exhibit J. Page of 0 The percentage of applications that have been refused a connection since the screening tool was implemented. The screening tool was first used in October 00. The percentage of applications that have received a refusal since then is %.

17 Filed: August, 0 Exhibit J.0 Page of 0 Of the projects that were initially screened and rejected. How many were rescreened and then provided an offer to connect? As of August, 0, there were, capacity constrained projects that were rescreened due to offers to connect expiring. Of that number, (0%) passed rescreening and received an offer to connect.

18 Filed: August, 0 Exhibit J. Page of Provide a breakdown of the, number (Reference:, Exhibit K.) by dates, how many received refusal and how many received an offer to connect, broken down by parallel (in-direct) and stand-alone (direct). 0 January, 0 Offer to Connect Refusal Total In-direct ( days) Direct (0 days) Total 0 February, 0 Offer to Connect Refusal Total In-direct ( days) Direct (0 days) Total 0 March, 0 Offer to Connect Refusal Total In-direct ( days) 0 Direct (0 days) Total April 0, 0 Offer to Connect Refusal Total In-direct ( days) 0 0 Direct (0 days) Total 0 May, 0 Offer to Connect Refusal Total In-direct ( days) 0 0 Direct (0 days) 0 Total 0 June 0, 0 Offer to Connect Refusal Total In-direct ( days) Direct (0 days) 0 Total 0 July, 0 Offer to Connect Refusal Total In-direct ( days) 0 0 Direct (0 days) 0 Total

19 Filed: August, 0 Exhibit J. Page of 0 0 TO PROVIDE DATE GROUPINGS OF LATE APPLICATIONS Hydro One has provided in Graphs and, the processing time distribution of noncompliant offers and refusals since the start of the MicroFIT program, for In-direct and Direct Connections, respectively. In early 0, Hydro One had already begun to implement many of its process efficiencies which resulted in a modest improvement in the number and degree of noncompliance with DSC section... In-direct and Direct Connects which applied to date in 0 are shown in Graphs and respectively. By May 0, Hydro One had dramatically reduced the volume and degree of noncompliance with section.. of the Distribution System Code. This is exemplified in Graphs and, for In-direct and Direct Connections respectively. In-direct Connect Non-Compliant Offers and Refusals Since Start of MicroFIT Program Number of Applications to to to to to to to to to 0 0 to to Processing Time (days) to to to to Graph : Processing Time of In-direct Connect Non-Compliant Offers/Refusals since Start of MicroFIT >

20 Filed: August, 0 Exhibit J. Page of Direct Connect Non-Compliant Offers and Refusals Since Start of MicroFIT Program Number of Applications to 0 to 0 to 0 to 00 0 to 0 to 0 to 0 to 0 to 0 to 0 Processing Time (Days) Graph : Processing Time of Direct Connect Non-Compliant Offers/Refusals since start of MicroFIT to 0 to 0 to 0 to 00 0 to 0 >0 In-direct Connect Non-Compliant Offers and Refusals Since January - 0 Number of Applications to to to to to to to Processing Time (Days) to to 0 0 to Graph : Processing Time of In-direct Connect Non-Compliant Offers/Refusals since January st, 0 to

21 Filed: August, 0 Exhibit J. Page of Direct Connect Non-Compliant Offers and Refusals Since January - 0 Number of Applications to 0 to 0 to 0 to 00 0 to 0 to 0 to 0 to 0 to 0 to 0 to 0 Processing Time (Days) Graph : Processing Time of Direct Connect Non-Compliant Offers/Refusals since January st, 0 In-direct Connect Non-Compliant Offers and Refusals Since May - 0 Number of Applications to to to to to to to Processing Time (Days) Graph : Processing Time of In-direct Connect Non-Compliant Offers/Refusals since May st, 0

22 Filed: August, 0 Exhibit J. Page of Direct Connect Non-Compliant Offers and Refusals Since May - 0 Number of Applications 0 to 0 to 0 Processing Time (Days) Graph : Processing Time of non-compliant Direct Connect Non-Compliant Offers/Refusals since May st, 0

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