To submit comments on a draft interpretation, please send them to Submissions@powerauthority.on.ca and include the text “Submission on Domestic Content – Designated Activity X”.

Please note that questions on a particular designated activity should continue to be sent to microFIT@powerauthority.on.ca. The OPA will not respond directly to questions on domestic content compliance.

REQUEST FOR FEEDBACK ON DRAFT INTERPRETATIONS
 

Designated activity "Inverter"
(See microFIT contract, Appendix C, Grid Cell No. 5)

Posted March 3, 2010

Closed for comments as of March 10, 2010

“Inverter, where the assembly, final wiring and testing have been done in Ontario.”

The OPA has received a number of questions relating to the requirements for inverters. It is now proposing the following interpretations for micro-inverters (Table 4, item 5, less than or equal to 10 kilowatts). Note that these interpretations are provided as assistance only and are specific to the specially listed table items. These interpretations do not waive any contractual terms regarding Domestic Content and Designated Activities.

For inverters 10 kW or smaller:

1. In order to qualify as “assembly, final wiring and testing”, including as clarified below, all components must be assembled and finally wired into the final inverter in Ontario. All final testing, certification and software installation and configuration must be entirely performed in Ontario.

The following are considered to be components that may be fabricated outside Ontario but must be assembled and integrated into the inverter in Ontario, with the noted qualifications:

1. printed circuit boards (PCBs)
   1. PCBs that are to be assembled and integrated into the inverter in Ontario are not required to be populated with components (e.g., capacitors, resistors, microchips or similar components) in Ontario.
   2. stacked PCBs: each PCB is considered a separate component. Multiple PCBs may not be assembled together outside of Ontario but must be connected together (structurally and electrically) in Ontario.
   3. wiring connecting one part of a PCB to another part of the same PCB is considered integral to the PCB component, whatever the type of wiring connection used, and is not considered “final wiring” or “assembly” necessary to be performed in Ontario.
   4. other than wiring as set out in (iii) above, wiring connected to a PCB using a screw terminal must be assembled and finally wired in Ontario.
   5. other than wiring as set out in (iii) above, for wiring connected to a PCB using soldering, only one end of the wiring may be soldered to the PCB and is thereafter considered integral to the PCB.  The unsoldered end must be assembled and finally wired in Ontario.

    

2. cables/cable harnesses
   1. cables/cable harnesses may be fabricated outside Ontario to the extent they do not constitute final wiring outside of Ontario.
   2. a component on a cable/cable harness is considered integral to the cable/cable harness only if it cannot be easily pulled off and/or cannot slide off the cable or cable harness without damaging the component or the cable/cable harness itself.  Tie wraps and similar components normally used to hold together a cable harness are considered integral to the cable harness.

    

3. enclosure/enclosure lid
   1. the entire inverter enclosure and its lid may be fabricated outside Ontario to the extent that, except as set out herein, it is assembled and finally wired in Ontario.  The enclosure and its lid must be assembled together in Ontario.
   2. parts required to operate the inverter, e.g., fuses, switches or comparable items, are not considered part of the enclosure or enclosure lid.
   3. other types of parts (e.g., ground lugs, racking or comparable items inessential to operate the inverter) that are normally welded to the enclosure are considered integral to the enclosure/enclosure lid and are not considered final wiring or assembly of the enclosure.

    

4. housings
   1. the housings for housing PCBs, other electronics equipment, or other components, may be fabricated outside Ontario to the extent that, except as set out herein, it is assembled and finally wired in Ontario.

    

5. whether it or is not part of a PCB, a fan/blower/heatsink component.
   1. a fan, blower or heatsink component may be fabricated outside Ontario to the extent that, except as set out herein, the component is integrated into the inverter and finally wired in Ontario.