Mechanism: Inclusion in a "Less Red Tape, Stronger Ontario" omnibus bill
Bundle plug-in solar legalization into a Less Red Tape omnibus bill. This approach lets the Red Tape Reduction ministry coordinate the amendments to O. Reg. 541/05, O. Reg. 164/99, and related instruments as a single package, and frames the change in the government’s own language.
Legal basis: The Ford government has passed six "Less Red Tape" omnibus bills since 2019. These are legislative amendments bundling regulatory simplifications across ministries. Plug-in solar — a 1200W appliance currently regulated as a utility-scale generator — is a textbook candidate for inclusion.
Legislature required? Yes
Precedent: Bill 46 Less Red Tape, Stronger Ontario Act (2023), Bill 190 Working for Workers Five Act (2024), and multiple additional red-tape omnibus bills have all passed with comfortable majorities. This is an active and proven pipeline.
Mechanism: Amendment to Ontario Electrical Safety Code regulation
Create a plug-in generation class in the Ontario Electrical Safety Code for certified systems under 1200W. Certified equipment (UL 3700 or CSA equivalent) would meet the installation safety requirements without a licensed electrician or permit for cord-and-outlet connection only.
Legal basis: The Electricity Act, 1998 s.113.2 gives the Lieutenant Governor in Council authority to prescribe the Ontario Electrical Safety Code. The ministry responsible for the Electrical Safety Authority is Public and Business Service Delivery and Procurement. An amendment to O. Reg. 164/99 can create a cord-connected plug-in generation class with reduced permit and electrician requirements when certified equipment is used.
Legislature required? No
Precedent: O. Reg. 164/99 has been amended multiple times to keep pace with new equipment categories and the Canadian Electrical Code. The regulatory machinery is regularly exercised.
Mechanism: Regulation amendment under the Electricity Act, 1998
Create a plug-in generation category in O. Reg. 541/05 for certified systems under 1200W. Exempt from net metering application, interconnection agreement, and bi-directional meter requirement. On-site use only, anti-islanding required. The regulatory instrument already exists; the amendment is additive.
Legal basis: The Electricity Act, 1998 (S.O. 1998, c. 15, Sched A) gives the Lieutenant Governor in Council broad regulation-making authority respecting net metering, distributed generation, and LDC obligations (ss.113.4 and 114). In practice these regulations move through the Minister of Energy’s office. An amendment to O. Reg. 541/05 could define a "plug-in generation" category for certified systems up to 1200W exempt from the net metering application, LDC interconnection agreement, and meter upgrade.
Legislature required? No
Precedent: Ontario already uses regulation-level amendments to adjust net metering eligibility — most recently via O. Reg. 389/18 (amendments to simplify third-party net metering arrangements). The mechanism is well-used.