Power Advisory Commentary on IESO Annual Acquisition Report

July 29, 2021
Brady Yauch, Travis Lusney, Sarah Simmons, Michael Killeavy, Jason Chee-Aloy

The  Independent Electricity System Operator (IESO) released its first Annual  Acquisition Report (AAR)[1]  on July 19, specifying Ontario’s future supply needs and plans for the use of  procurement contracts and other mechanisms to meet capacity and energy needs  forecast to materialize over the next decade.  The AAR supports IESO’s  on-going resource adequacy stakeholder engagement where IESO plans to utilize  sole-sourced bilateral contracts and Request for Proposals (RFP)/contracts in  addition to capacity auctions to procure capacity to meet forecast needs.   The combination of procurement mechanisms will be administered by IESO to  meet capacity needs forecast for different timeframes – short-, medium- and  long-term mechanisms.  Figures 1 and 2 at the end of this commentary  note provide an overview of IESO’s proposed procurement process.  

For  short-term capacity needs, IESO will continue to rely on annual capacity  auctions, but will now include a minimum winter capacity target of 500 MW and  a minimum summer capacity target of 500 MW, although the actual need for  summer capacity is expected to increase to 1,800 MW by 2026 – up from 1,000 MW  in 2022.

For  medium-term capacity needs, IESO will introduce multi-year commitments  ranging from three to five years.  These procurements are expected to be  done through a “competitive procurement such as an RFP, or an enhanced  capacity auction,” although the details around the process remain unclear at  this time.  IESO expects to procure 750 MW on a medium-term basis  starting in the fall of 2021, with the obligation to deliver procured  capacity beginning in 2026 via contracts with expected terms of three to five  years.

Regarding  long-term capacity needs, IESO is expecting to procure a particular resource  for “at least seven years” (our emphasis) via contracts.  According to  its “acquisition strategy”, IESO is now planning to procure up to 1,000 MW of  capacity on a long-term basis to meet needs in the 2026 to 2029 timeframe.   This is the first time that IESO has been explicit in the forecast  amount of capacity that will be procured to meet long-term needs (see figures  at the end this note).

The AAR  also lays out sole-sourced bilateral contracts that IESO plans to execute  over the next decade as well as recommendations for transmission development.   The two bilateral contracts are both for gas-fired generators – the  Brighton Beach generating station (GS) near Windsor and the Lennox GS near  Kingston.  For Brighton Beach GS, the contract term is expected to run  until 2028, while for Lennox GS the contract term is expected to run until  2029.  Due to the potential for limited capacity on the Flow East to  Toronto (FETT) interface due to planned retirements of generation resources  (e.g., Pickering Nuclear GS (NGS)) and refurbishments (e.g., Darlington NGS)  in eastern Greater Toronto Area (GTA), IESO has recommended that Hydro One  upgrade transmission lines from Trafalgar transformer station (TS) to  Richview TS by 2026.  Even with these transmission system upgrades, IESO  expects there may be a need for supply resources in eastern GTA.

And  finally, IESO reiterated its plan to procure resources on an unforced  capacity (UCAP) basis, which reduces the amount of a capacity a resource can  offer based on historical outages and other capabilities and constraints  given its statistical ability to produce energy during peak demand periods.   The details around how IESO will define resource-specific UCAP is still  being discussed with stakeholders but appears to directionally being  leveraged from calculations of UCAP used in the northeast U.S. wholesale  electricity markets that administer capacity markets (i.e., NYISO, ISO-NE,  PJM).

Power Advisory Commentary

Both the release and the details of the AAR mark a pivotal moment for the  IESO-Administered Market (IAM).  While the previous decade was defined by  capacity and energy surpluses and the signing of a multitude of long-term  contracts for both system needs and policy objectives, the next decade is  expected to be one of capacity shortfalls (and potential energy shortfalls)  coinciding with the end of current contracts for a variety of resource types.   While IESO has maintained that it will focus on competition to enhance  market efficiency and address future capacity needs – in rationalization with  the IAM redesign through the Market Renewal Program (MRP) and adoption of the  Resource Adequacy Framework – the application of the AAR and identified  procurement mechanisms may at times be challenged to ensure effective  competition to procure resources and drive competitive outcomes within IAM.

While  the AAR is the first ‘kick at the can’ at such a report and likely to evolve  significantly over time, it raises important points for needed discussion  amongst IAM market participants and broader stakeholders.

1.        Process Matters

At a  high level, IESO-led process underpinning their capacity procurement plans  laid out in the AAR will be of a vital importance to maintaining effective  competition, market confidence, and economic efficiency within IAM over the  next decade.  For example, governance and oversight of designing  procurement mechanisms that potentially target specific resource types (e.g.,  baseload, flexible, small, large, etc.) with specific supply attributes must  be clearly articulated to prospective procurement participants.  The  process for how IESO designs the long-term procurement mechanism compared to  the medium-term procurement mechanism – including which resources are  eligible to participate – will also need to be clear.  While  stakeholders may accept IESO’s forecast for needed capacity (as does Power  Advisory), more details about IESO’s process to address these needs will be  required.  If stakeholders do not support the process, the result will  be reduced competition – as certain resource types refuse to participate –  and the likelihood of higher costs for Ontario’s electricity ratepayers over  the long-term.  It may also worsen the forecast capacity need, as  certain capacity suppliers may exit Ontario – leaving ratepayers on the hook  for higher cost capacity procurements. 

2.        Time for a Robust Integrated Resource Plan

The  combination of IESO’s Annual Planning Outlook (APO) and the AAR should mark  the beginning of a move towards IESO launching a full-blown and robust  Integrated Resource Plan (IRP).  A detailed IRP would provide  stakeholders and policymakers with an in-depth look at the details behind  forecast capacity needs, resource options considered to meet these needs, and  clear linkages to plans to procure capacity to meet forecast needs.  The  APO and the AAR would be annual updates to the IRP, including updates to  demand forecasts, supply mix projections, capacity forecasts, policy updates,  etc.  Most importantly, the IRP should be thoroughly consulted and  vetted with stakeholders and, as such, would also include the views from  stakeholders that are growing in number within Ontario representing emerging  resources (e.g., distribution energy resources (DERs), storage, other  behind-the-meter (BTM) resources, etc.).  The grid of the future is a  (at times delicate) combination of front-of-the meter (FTM) and BTM  resources.  By including the entire range of resource types that  currently – or are expected to – participate in Ontario’s electricity sector,  by way of connection, technology, fuel-type, etc., IESO can provide  stakeholders and policymakers with a macro view of the sector over the coming  decade – and reach beyond IAM as defined today.

3.        Need for Greater Regulatory Oversight

IESO’s  procurement activities have over the last decade and a half operated outside  of independent regulatory review.  With the significant amounts of  needed procurements that the AAR identifies for IESO to undertake over the  next decade, an independent review will be more important now than ever.   How IESO designs various procurement processes and mechanisms, who is able  to participate, and what assumptions are underpinning the procurements will  all need to be thoroughly discussed and analyzed in an independent forum  overseen by the Ontario Energy Board (OEB).  The most efficient  oversight would see OEB hold an annual hearing to review the AAR to ensure it  aligns with the IRP and results in procurements that cost-effectively meets  forecast supply needs.  The AAR provides a clear example for why  regulatory oversight is needed.  The AAR lays out IESO’s plan for  sole-sourced bilateral contracts (Brighton Beach GS, Lennox GS), although the  details on those contracts – and the justification for their length – are  limited (given information stakeholders have today).  The bilateral  contracts may be necessary from a reliability perspective and may provide  good value to ratepayers, but neither of these concepts have been clearly  articulated or adequately analyzed in a transparent manner for all  stakeholders to understand.  We note as well that the Ontario government  had previously commenced consultation related to long-term planning in  Ontario, including roles for government directives and potential new roles  for OEB oversight.[2]

4.       Increased Competition Neededto More Effectively Meet Future Capacity  Requirements

Power  Advisory has long argued for the introduction of Load Serving Entities (LSEs)  in Ontario as means to increase competition and to increase buy-side  liquidity.  The release of the AAR simply solidifies this view.   The AAR provides IESO’s view on what resources will be required to meet  future capacity needs – mainly via large-scale, transmission-connected  resources.  It provides a limited view on what other resource types  could reduce the need for AAR’s procurement forecast.  Using the LSE model  as a reference point, the provincial-wide capacity needs could be mitigated –  potentially to a significant extent – by unlocking competition at all levels  within Ontario’s electricity market and mostly through a more active and  participatory buy-side.  Additionally, IESO needs to move as quickly as  possible to fully enable exiting resources and emerging resource types –  ranging from ‘hybrids’ (e.g., renewables plus energy storage, etc.), energy  storage, DERs, etc. – as they become increasingly more cost-effective as well  as increasingly customer and investor preferred (i.e., policy reasons (e.g.,  decarbonization, etc.), capital market drivers (e.g., environmental, social,  governance (ESG), etc.).

5.        Need for Greater Definition of Ontario Power Generation’s Role in  Ontario’s Electricity Market

The role of Ontario Power  Generation (OPG) within IESO’s procurement framework – and within IAM overall  – needs to be addressed.  No other wholesale electricity market has the  same level of supply-side concentration as OPG presently holds within IAM.   When the wholesale and retail electricity markets were launched in May  2002 there was a clear policy to limit (and reduce) OPG’s market power.   However, that policy appears to have mostly been abandoned, even though by  way of licence conditions OPG ‘must-offer’ supply within IAM.  If OPG is  allowed to participate in future procurements, clarity is needed regarding  how OPG may participate.  Overall, additional to present licence  conditions, there needs to be general consideration of applying some type of  specific market power mitigation to OPG broadly within IAM and specifically  regarding future procurements administered by IESO.    

Figure 1 – IESO Resource Adequacy Framework

Figure 2 – IESO Capacity Auction Forward Guidance

[1] See https://www.ieso.ca/en/Sector-Participants/Planning-and-Forecasting/Annual-Acquisition-Report