IESO officials held firm on excluding hydro redevelopment projects from the ISO’s Long Lead-Time (LLT) procurement despite objections from potential bidders at a Jan. 28 engagement session.
Officials also attempted to assuage concerns about the use of confidential reserve prices to control costs.
The ISO created the LLT procurement for resources that require longer planning cycles than the four-year lead times in the pending Long Term 2 (LT2) procurement. IESO plans to seek 600 to 800 MW of capacity from storage resources and up to 1 TWh of energy from hydro resources requiring at least five years of lead time. (See IESO Drops Termination Option for Long Lead-time RFP.)
The energy stream of the LLT request for proposals will be open to new-build hydroelectric facilities with a nameplate capacity of at least 1 MW that do not include pumped storage. The ISO said it will not permit bids from hydro redevelopment or expansion projects, despite proponents’ claims that such additions may also require longer design and construction cycles.
Stephane Boyer, of FirstLight Power, said he did not understand the ISO’s rationale for excluding hydro expansions, which he said would be unable to compete against wind and solar projects in IESO’s long-term procurements.
“Why not give the opportunity to bid in [and] get the most cost-competitive hydro you can get in the earlier window that is currently open?” he asked.
IESO officials said hydro expansions and redevelopments should seek 20-year contracts under the upcoming LT2 procurement because they can be developed in less than five years and don’t require the 40-year contracts in the LLT solicitation.
Boyer and Paul Norris, president of the Ontario Waterpower Association, said ratepayers would benefit from the longer contract terms. “We’re artificially eliminating … the participation of some hydro projects in the ISO procurements because they take longer than five years and they’re not greenfield,” Norris said.
John Wynsma, formerly of Peterborough Utilities, said that between 2008 and 2016, the company built one new hydro project while completing one expansion and one redevelopment, each of which took more than five years.
“The new-build was the cheapest of the three, and that’s because of logistics: It’s a clean site,” he said. “The redevelopment cost 40% more than the new-build. The expansion cost more than 50% more than the new-build.”
He suggested IESO allow redevelopments and expansions to submit prices for 20-, 30- and 40-year contracts in the LLT solicitation, with the ISO choosing any it finds attractive. “I think you’re missing an opportunity here,” he said.
IESO’s Ben Weir said ISO officials are still deciding how they will treat hydro redevelopments under LT2. “It’s a bigger piece of work that’s just not going to be done by the time that LLT has to launch,” he said.
“We do want to get a terawatt-hour worth of energy out of new-build hydro facilities in the province,” he continued. “I understand that the timelines for LT2 have not been made public yet, but we do expect to make those public at the end of an engagement in February.
“Whether or not those expansions are going to take five years is a site-specific question,” Weir added. “When we’re talking about upgrades and expansions to existing facility, it’s our position that a 40-year contract … shouldn’t be required in order to recover the investment that’s being made.”
On Jan. 29, IESO held an engagement on its Northern Hydro Program (NHP), which will allow existing hydro facilities of at least 10 MW to win new 20-year contracts. NHP will begin accepting applications on March 31.
Concern over Reserve Prices
Boyer also raised concerns over IESO’s plan to use reserve prices — a confidential price threshold — to ensure it doesn’t pay too much in the LLT solicitation. The ISO said the thresholds will be based in part on prices in the first window of the LT2 procurement and differences in the obligations of LT2 and LLT resources.
Boyer said LT2 “is for different technology with different attributes, which is very different from the baseload hydro that you’re looking at now to procure.”
The reserve price and limited guidance over interconnection timelines is requiring bidders to make “a lot of investment … with a lot of unknowns and uncertainties,” Boyer said.
Weir said the ISO will adjust the reserve price to acknowledge the differences between the LLT and LT2 procurements. “In no way, shape or form is it just the LT2 price,” he said.
‘Buy Local’ Provisions not Final
ISO officials said they hope to complete the LLT RFP and contract by the end of the first quarter — with the bidding commencing in the fourth quarter — but are still waiting for the Ministry of Energy and Mines’ directive on how to apply “buy local” requirements.
Bidders will be required to provide a “local supply plan” identifying their major goods, services and workforce suppliers, an attestation that the proponent plans to source at least 50% from Ontario or other Canadian provinces, and an explanation for what cannot be obtained domestically.
“The feedback that we’re seeking is whether proponents were already planning to source at least 50% of the project spend from Ontario or Canada,” Weir said. “If they weren’t planning on doing that — but could, because there are domestic sources of those good services and workforce — what the cost implications would be to bring that level up to 50%.”
Team Experience
The ISO also rejected requests that it allow proponents’ consultants to help them meet the RFP’s experience requirements.
All bidders will be required to have at least two team members with experience in planning, developing, financing, constructing and operating at least one “qualifying project” — an electric generation or storage facility that has reached commercial operation in the last 15 years in Canada or the U.S.
Proponents of Class II long-duration energy storage (LDES) technologies will be required to have at least two team members with experience on a project of the same technology (at least 1 MW) expected to reach commercial operation by the end of 2029.
IESO said consultants cannot count toward experience requirements because “they may not be enduring members of the project team” and could leave before the project reaches commercial operation.
Tariff Protections
Stakeholders also contended that the ISO should not have absolute discretion to cancel a contract if a developer seeks additional payments to compensate for tariff changes imposed after the deal is signed.
The ISO said developers should only submit tariff adjustment notices if the price change is “absolutely critical to maintain [the] viability” of the project “and should not be used … as a negotiating mechanism.”
Other Issues
In other developments, IESO said it is:
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- updating resource eligibility rules for storage to require that the instantaneous maximum withdrawal capability of the facility be equal to or greater than the project’s nameplate capacity. For example, a 200-MW nameplate project must be able to withdraw 200 MW during its charging cycle.
- removing a requirement for obtaining municipal support confirmations by Aug. 21.
- seeking feedback on how to define hydro project sites to reflect impacts on adjacent properties, such as lands that may be flooded.
- adjusting its compensation formula to protect hydro suppliers’ revenues during droughts that reduce production. IESO’s Jasdeep Kahlon called it a “tradeoff” that will also reduce hydro projects’ revenue “upside.”
Stakeholder feedback on the Jan. 28 session is due Feb. 12.



