IESO is seeking to reduce risks in its procurement of long lead-time (LLT) resources by reserving the right to reject proposals that are too expensive and allowing the ISO and generation developers to cancel deals in the first few years.
IESO created the LLT procurement in response to stakeholder feedback that energy storage resources such as compressed air and pumped hydro require longer planning cycles than the four-year lead times for resources offering in the pending Long Term 2 (LT2) procurement.
The ISO plans to seek 600 to 800 MW of capacity and up to 1 TWh of energy from resources requiring at least five years of lead time in a solicitation expected about Q4 2026. The first drafts of the capacity contract and request for proposal (RFP) were posted Oct. 20.
“It’s possible that there will be future [procurement] windows,” IESO’s Danielle D’Souza said in an engagement session Oct. 21, the fourth stakeholder meeting on the procurement. “I think that will depend on outcomes of this single procurement window, and … subject to [the Ministry of Energy and Mines’] direction.”
D’Souza said the ISO has not yet closed debate on any design issues in the procurement. “However, we do intend very soon to begin closing design elements” to focus on unresolved issues, she said.
Reserve Price
IESO proposes to use reserve prices — a confidential price threshold — to ensure it doesn’t pay too much for energy or capacity in the solicitation.
The ISO said the thresholds will be based on inputs including prices in the first window of the LT2 procurement and any differences in the obligations between LT2 and LLT resources.
Akira Yamamoto, director of regulatory and market policy for TransAlta, said he understood why IESO wouldn’t want to disclose the reserve prices but said it should provide guidance to help developers understand whether they should participate in the procurement.
“If you publish that methodology, that would actually give some insights without giving that true value. I think you need to give some indication to [whether your project has] no chance of actually getting procured,” he said. “Essentially, the ISO giving some indication that ‘Don’t waste your time if you’re too expensive.’”
Termination Provision
The ISO also proposes a termination option that could be exercised by IESO or the project developer in the first two or three years after the contract date.
If IESO exercises termination, it would return the developer’s completion and performance security ($20,000/MW of maximum contract capacity with a minimum of $350,000 and a maximum of $15 million) along with a fixed payment to cover a portion of development costs. If the developer chooses to terminate, IESO would retain a portion of the completion and security and there would be no payment for development costs.
If neither party terminates, the full completion and performance security of $35,000/MW would take effect.
Yamamoto questioned why IESO wouldn’t cover all of the development costs if it initiates the cancellation.
“I just think that that makes this a pretty unattractive type of procurement to be involved in if [IESO] changes their mind on the project and decides not to pay you for the cost that you’re actually incurring,” he said.
Dave Barreca, IESO’s supervisor of resource acquisition, said IESO is attempting to address “pitfalls that have been seen previously with similar arrangements in older procurements.”
“[We] absolutely recognize that that could be an issue,” he acknowledged, saying IESO wants a policy “that can work for developers, while … limiting the liability [to IESO] and the difficulty of assessing … costs that have been spent to date.”
Eligibility
IESO plans to use a 40-year contract for both energy and capacity procurements.
The capacity stream will be open to new electricity storage facilities of at least 50 MW — up from 1 MW in the LT2(c-1) RFP — that are able to deliver their contract capacity for at least eight hours and use an eligible long-duration energy storage (LDES) technology. The facility must begin commercial operations between five and eight years after the contract date.
100 MW Cap on Class 2 LDES Technologies
The draft RFP identifies as eligible “Class I” LDES technologies compressed air energy storage and pumped hydro storage, based on their technology readiness.
Two newer technologies were defined as “Class II” LDES technologies and will be limited to a maximum procurement of 100 MW:
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- liquid air energy storage, which uses electricity to compress air until it becomes a liquid, saving the released thermal energy in a high-grade thermal store; and
- pumped thermal energy storage, which converts electricity into heat, which is stored as thermal energy and later converted back into electricity through reversible thermodynamic cycles.
IESO said the 100-MW cap would “limit the risks related to procuring less proven technologies and encourage participation from a diverse set of eligible LDES technologies.”
The ISO also may require an independent engineering report detailing “project scope, permitting path, supply chain constraints/lead times, etc.”
The proposed 100-MW maximum is included — not in addition to — in the total capacity stream target of 600 to 800 MW. It is not a set-aside, meaning only the most cost-effective proposals will be chosen.
D’Souza said the 50-MW minimum size for eligibility reflected “projects around that size that are currently working towards commercial operation.”
“If … stakeholders think that projects less than that size should be considered, we’re happy to hear it,” she added. “But that threshold was … set based on our expectation of what is possible, and [to incentivize] projects of a commercial scale rather than a pilot scale.”
Hydro Refurbishments Under Consideration
Although the LLT RFP is intended for new build resources, IESO continues to consider whether hydro redevelopments should be eligible to participate.
The ISO said stakeholders told it that replacement equipment no longer is available for hydro facilities built in the early 1900s and that long-term contracts would be needed to make hydro rebuilds economic.
Regulation-Ready Resources
To help manage the increasing penetration of variable generation resources and industrial facilities with fluctuating loads, IESO also is considering requiring that LLT resources be equipped to provide regulation services.
“IESO is forecasting an increased need for regulation services in the future; both hydroelectric and LDES are ideal candidate technologies to provide regulation services,” IESO said in a presentation.
IESO would require only that LLT resources be “regulation ready” — a minimum ramp rate of 5 MW/min and the ability to follow regulation signals every four seconds or less. Regulation services would be procured and paid for separately.
The requirement would apply to all capacity resources and hydro resources that can provide a 20-MW range (±10 MW regulation) above their minimum loading point.
Mid-term Outage
In response to feedback following its Sept. 16 engagement session, IESO said it would consider allowing resource owners a “mid-term extended outage” of up to 12 months after the 20th anniversary of the contract — up from the six-month outage initially proposed. (See IESO Ups Capacity Target for Long Lead-Time Resources.)
IESO said the mid-term extended outage would allow suppliers to complete “small-scale work that may be required to allow the facility to continue to operate and is not intended to be a period over which major refurbishment work is completed.”
Must-Offer Obligations
As in the LT2(c-1) contract, LLT suppliers will be required to offer their facility’s output into the day-ahead market. But IESO proposes to expand the definition of “qualifying hours” for long lead-time resources to include weekends and holidays in addition to the 7 a.m. to 11 p.m. business day definition for the first LT2 capacity contract.
IESO also is considering a must-offer requirement for LLT capacity resources in the real-time market “to better align with operational needs.”
“We have seen some periods of need outside of the hours that are included in the qualifying hours,” D’Souza said. “Given that these are going to be 40-year contracts, we are looking to ensure that we’re getting the most benefit and flexibility out of these resources.”
IESO asked for feedback on how the expanded qualifying hours, and RT must-offer obligations, would affect the cost and operations of proposed projects.
Barreca said IESO is trying to address uncertainty about how system conditions will be in 40 years. “We recognize that none of these will likely be cost-free, and so we want to be able to — as always — take your feedback on these and make an informed decision as to whether the benefits that we may see from them would be worth the cost.”
“Our intuition is that expanding qualifying hours would not be such a huge burden, although maybe there’s some middle ground in there between what we have written on the slides here and what” suppliers want, he added. “The real-time offer is a bit more of an open question, in terms of both what the costs might be and what the benefits might be.”
Contract Length
IESO rejected requests that it consider contracts longer than 40 years. Some stakeholders said the 40-year term didn’t reflect compressed air and pumped storage mechanical components that have an expected life of more than 60 years.
Stakeholders also asked IESO to use an “open book process” regarding long-term debt for LDES that would allow price adjustments at the midpoint of their proposed 60-year contract term.
IESO said it is not considering a term longer than 40 years. “Proponents should consider expected costs (including those related to long term debt) over the contract term when establishing proposal prices,” it said.
IESO asked stakeholders to submit written feedback to engagement@ieso.ca by Nov. 4.











