Under the Feed-in Tariff and microFIT programs (the “FIT/micro-FIT Programs”) administered by the Ontario Power Authority (the “OPA”), a participant contracts with the OPA to supply the electricity generated from approved renewable energy project to the provincial electricity distribution system at a charge for each kWh of electricity generated regardless of whether electricity is subsequently consumed by the participant. CRA stated:
Generally, costs associated with the purchase and installation of renewable energy property eligible for the FIT/microFIT Programs are considered to be the capital cost of depreciable property. A participant would include the capital cost of a renewable energy property in Class 43.1 or 43.2 for CCA purposes, provided that the property meets all of the requirements of these classes.
Essentially the same conclusion applied to renewable energy property acquired for use in the Ontario Net Metering Program provided that the electricity generated was not used for personal consumption.