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ERCOT Winter Capacity RFP seeks up to 3,000 MW through generation and demand response to bolster Texas grid reliability during peak load, leveraging Reliability Must-Run, incentive factors, and EEA risk mitigation for the 2023-24 season.

Key Points

An ERCOT initiative to procure 3,000 MW of generation and demand response to reduce EEA risk and improve reliability.

✅ Targets 3,000 MW from generation and demand response

✅ Uses RMR-style contracts with flexible incentive factors

✅ Aims to lower EEA probability below 10% this winter

The Electric Reliability Council of Texas (ERCOT) issued a request for proposals to stakeholders to procure up to 3,000 MW of generation or demand response capacity to meet load and reserve requirements during the winter 2023-24 peak load season (Dec. 1, 2023, through Feb. 29, 2024), amid ongoing Texas power grid challenges across the region.

ERCOT cited “several factors, including significant peak load growth since last winter, recent and proposed retirements of dispatchable Generation Resources, and recent extreme winter weather events, including Winter Storm Elliott in December 2022, Winter Storm Uri in February 2021, and the 2018 and 2011 winter storms, each of which resulted in abnormally high demand during winter weather.” It now seeks additional capacity under its “authority to prevent an anticipated Emergency Condition,” reflecting nationwide blackout risks identified by grid experts.

In its notice regarding the RFP, ERCOT identified a number of mothballed and recently decommissioned generation resources that may be eligible to offer capacity under the RFP. It further stated that offers must comport with the format of its “Reliability Must-Run” agreement but could include a proposed “Incentive Factor” that reflects the revenues the unit owners determine would be necessary to bring the unit back to operation. It added that the Incentive Factor is not necessarily limited to 10%. Providers of eligible demand response can submit offers based on similar principles that are not necessarily constrained by cost. The notice identifies potential acceptable sources of demand response, describes certain parameters for the kinds of demand response that are permitted to respond to the RFP, and outlines the time periods during which ERCOT must be able to deploy the demand response resources to improve electricity reliability across the system.

To meet the Dec. 1, 2023, service start date, ERCOT developed an aggressive timeline to solicit and evaluate proposals through the RFP. Responses to the RFP are due Nov. 6, 2023. ERCOT’s schedule provides that it will notify market participants that obtain awards on Nov. 23, 2023. Expect contracts to be executed by Nov. 30, 2023.

Unlike Regional Transmission Organizations in the Northeastern United States, ERCOT does not have a capacity market. Instead, ERCOT relies on a high price cap of $5,000 per MWh for its energy market (decreased from the $9,000 per MWh cap in effect during Winter Storm Uri) and an Operating Reserve Demand Curve adder that pays additional funds to generators supplying power and ancillary services, an area recently scrutinized for improper payments when supply conditions are tight. In the wake of Winter Storm Uri, some calls were made to have ERCOT adopt a capacity market for reliability reasons, and a number of legal battles continue to play out in the wake of Winter Storm Uri. (See recent McGuireWoods legal alert “Winter Storm Uri Power Dispute Reaches the Supreme Court of Texas.”) Though a capacity market was not adopted, the Texas Legislature approved a $7.2 billion loan program, widely described as an electricity market bailout for generators, to build up to 10,000 MW of dispatchable generation. The legislature also approved a version of the Public Utility Commission of Texas’ proposal to establish a “Performance Credit Mechanism,” but with a cost cap of $1 billion.

The loss of life and economic impacts of Winter Storm Uri in 2021, along with the energy crunches and calls for conservation this past summer, are driving changes to ERCOT’s “energy-only” market, including electricity market reforms under consideration. Texas policymakers are providing multiple financial incentives to promote investment in dispatchable on-demand generation, and voters will consider funding to modernize generation measures this year to make the Texas grid more reliable and able to deal with power demand from a growing economy and increased demand for electricity driven by weather. In the meantime, ERCOT’s plan to procure 3,000 MW through this RFP process is a stopgap measure intended to bolster reliability for the upcoming winter season and lower the probability of load shed in the event of severe winter weather.

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Hourly Electricity Emissions Tracking maps grid balancing areas, embodied emissions, and imports/exports, revealing carbon intensity shifts across PJM, ERCOT, and California ISO, and clarifying renewable energy versus coal impacts on health and climate.

Key Points

An hourly method tracing generation, flows, and embodied emissions to quantify carbon intensity across US balancing areas.

✅ Hourly traces of imports/exports and generation mix

✅ Consumption-based carbon intensity by balancing area

✅ Policy insights for renewables, coal, health costs

In the United States, electricity generation accounts for nearly 30% of our carbon emissions. Some states have responded to that by setting aggressive renewable energy standards; others are hoping to see coal propped up even as its economics get worse. Complicating matters further is the fact that many regional grids are integrated, and as America goes electric the stakes grow, meaning power generated in one location may be exported and used in a different state entirely.

Tracking these electricity exports is critical for understanding how to lower our national carbon emissions. In addition, power from a dirty source like coal has health and environment impacts where it's produced, and the costs of these aren't always paid by the parties using the electricity. Unfortunately, getting reliable figures on how electricity is produced and where it's used is challenging, even for consumers trying to find where their electricity comes from in the first place, leaving some of the best estimates with a time resolution of only a month.

Now, three Stanford researchers—Jacques A. de Chalendar, John Taggart, and Sally M. Benson—have greatly improved on that standard, and they have managed to track power generation and use on an hourly basis. The researchers found that, of the 66 grid balancing areas within the United States, only three have carbon emissions equivalent to our national average, and they have found that imports and exports of electricity have both seasonal and daily changes. de Chalendar et al. discovered that the net results can be substantial, with imported electricity increasing California's emissions/power by 20%.

Hour by hour
To figure out the US energy trading landscape, the researchers obtained 2016 data for grid features called balancing areas. The continental US has 66 of these, providing much better spatial resolution on the data than the larger grid subdivisions. This doesn't cover everything—several balancing areas in Canada and Mexico are tied in to the US grid—and some of these balancing areas are much larger than others. The PJM grid, serving Pennsylvania, New Jersey, and Maryland, for example, is more than twice as large as Texas' ERCOT, in a state that produces and consumes the most electricity in the US.

Despite these limitations, it's possible to get hourly figures on how much electricity was generated, what was used to produce it, and whether it was used locally or exported to another balancing area. Information on the generating sources allowed the researchers to attach an emissions figure to each unit of electricity produced. Coal, for example, produces double the emissions of natural gas, which in turn produces more than an order of magnitude more carbon dioxide than the manufacturing of solar, wind, or hydro facilities. These figures were turned into what the authors call "embodied emissions" that can be traced to where they're eventually used.

Similar figures were also generated for sulfur dioxide and nitrogen oxides. Released by the burning of fossil fuels, these can both influence the global climate and produce local health problems.

Huge variation
The results were striking. "The consumption-based carbon intensity of electricity varies by almost an order of magnitude across the different regions in the US electricity system," the authors conclude. The low is the Bonneville Power grid region, which is largely supplied by hydropower; it has typical emissions below 100kg of carbon dioxide per megawatt-hour. The highest emissions come in the Ohio Valley Electric region, where emissions clear 900kg/MW-hr. Only three regional grids match the overall grid emissions intensity, although that includes the very large PJM (where capacity auction payouts recently fell), ERCOT, and Southern Co balancing areas.

Most of the low-emissions power that's exported comes from the Pacific Northwest's abundant hydropower, while the Rocky Mountains area exports electricity with the highest associated emissions. That leads to some striking asymmetries. Local generation in the hydro-rich Idaho Power Company has embodied emissions of only 71kg/MW-hr, while its imports, coming primarily from Rocky Mountain states, have a carbon content of 625kg/MW-hr.

The reliance on hydropower also makes the asymmetry seasonal. Local generation is highest in the spring as snow melts, but imports become a larger source outside this time of year. As solar and wind can also have pronounced seasonal shifts, similar changes will likely be seen as these become larger contributors to many of these regional grids. Similar things occur daily, as both demand and solar production (and, to a lesser extent, wind) have distinct daily profiles.

The Golden State
California's CISO provides another instructive case. Imports represent less than 30% of its total electric use in 2016, yet California electricity imports provided 40% of its embodied emissions. Some of these, however, come internally from California, provided by the Los Angeles Department of Water and Power. The state itself, however, has only had limited tracking of imported emissions, lumping many of its sources as "other," and has been exporting its energy policies to Western states in ways that shape regional markets.

Overall, the 2016 inventory provides a narrow picture of the US grid, as plenty of trends are rapidly changing our country's emissions profile, including the rise of renewables and the widespread adoption of efficiency measures and other utility trends in 2017 that continue to evolve. The method developed here can, however, allow for annual updates, providing us with a much better picture of trends. That could be quite valuable to track things like how the rapid rise in solar power is altering the daily production of clean power.

More significantly, it provides a basis for more informed policymaking. States that wish to promote low-emissions power can use the information here to either alter the source of their imports or to encourage the sites where they're produced to adopt more renewable power. And those states that are exporting electricity produced primarily through fossil fuels could ensure that the locations where the power is used pay a price that includes the health costs of its production.

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Lebanon Electricity Sector Reform aims to overhaul tariffs, modernize the grid, cut fuel oil subsidies, unlock donor loans, and deliver 24-hour power, restructuring EDL governance, boosting generation capacity, and reducing the budget deficit.

Key Points

A plan to restructure EDL, adjust tariffs, add capacity, and cut subsidies to deliver 24-hour power and reduce deficits.

✅ New tariffs and phased cost recovery

✅ Added generation capacity and grid modernization

✅ Governance reform of EDL and loss reduction

Lebanon’s Cabinet has approved a much-anticipated plan to restructure the country’s dysfunctional electricity sector, as Beirut power challenges continue to underscore chronic gaps, which hasn’t been developed since the time of the country’s civil war, decades ago.

The Lebanese depend on a network of private generator providers and decrepit power plants that rely on expensive fuel oil, while Israeli power supply competition seeks to lower consumer prices in a nearby market. Subsidies to the state electricity company cost nearly $2 billion a year.

For years, reform of the electricity sector, echoed by EU electricity market revamp, has been a major demand of Lebanon’s population of over 5 million. But frequent political stalemates, corruption and infighting among politicians, entrenched since the civil war that began in 1975, often derailed reforms.

International donors have called for reforms, including in the electricity sector, to unlock $11 billion in soft loans and grants pledged last year, as regional initiatives like the Jordan-Saudi electricity linkage move ahead to strengthen interconnections. Prime Minister Saad Hariri said Monday that the new plan will eventually provide 24-hour electricity.

Energy Minister Nada Boustani said that if there were no obstacles, residents could start feeling the difference next year, as an electricity market overhaul advances alongside the plan.

The plan, which is expected to get parliament approval, will reform the state electricity company, introduce new pricing policies, with international examples like France's electricity pricing scheme, and boost power production.

“This plan will also reduce the budget deficit,” Hariri told reporters. “This is positive and all international ratings companies will see … that Lebanon is taking real steps to reform in this sector.”

Lebanon’s soaring debt prompted rating agencies to downgrade the country’s credit ratings in January over concerns the government may not be able to pay its debts. Unemployment is believed to be at 36 per cent and more than 1 million Syrian refugees have overwhelmed the already aging infrastructure, while policy debates like Alberta electricity market changes illustrate different approaches to balancing cost and reliability.

Boustani told the Al-Manar TV that the electricity sector should be spared political bickering and populist approaches.

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Ukraine Winter Energy Strategy strengthens the power grid through infrastructure repairs, electricity imports, renewable integration, nuclear output, and conservation to ensure reliable heating, blackout mitigation, and grid resilience with international aid, generators, and transmission lines.

Key Points

A wartime plan to stabilize Ukraine's grid via repairs, imports, renewables, and nuclear to deliver reliable electricity.

✅ Repairs, imports, and demand management stabilize the grid.

✅ Renewables and nuclear reduce outage risks in winter.

✅ International aid supplies transformers, generators, expertise.

As Ukraine braces for the winter months, the question of how the country will keep the lights on has become a pressing concern, as the country fights to keep the lights on amid ongoing strikes. The ongoing war with Russia has severely disrupted Ukraine's energy infrastructure, leading to widespread damage to power plants, transmission lines, and other critical energy facilities. Despite these challenges, Ukraine has been working tirelessly to maintain its energy supply during the cold winter months, which are essential not only for heating but also for the functioning of homes, businesses, hospitals, and schools. Here's a closer look at the steps Ukraine is taking to keep the lights on this winter and ensure that its people have access to reliable electricity.

1. Repairing Damaged Infrastructure

One of the most immediate concerns for Ukraine's energy sector is the extensive damage inflicted on its power infrastructure by Russian missile and drone attacks. Since the war began in 2022, Ukraine has faced repeated attacks targeting power plants, substations, and power lines, including strikes on western regions that caused widespread outages across communities. These attacks have left parts of the country with intermittent or no electricity, and repairing the damage has been a monumental task.

However, Ukraine has made significant progress in restoring its energy infrastructure. Government agencies and energy companies have been working around the clock to repair power plants and transmission networks. Teams of technicians and engineers have been deployed to restore power to areas that have been hardest hit by Russian attacks, often under difficult and dangerous conditions. While some areas may continue to face outages, efforts to rebuild the energy grid are ongoing, with the government prioritizing critical infrastructure to ensure that hospitals, military facilities, and essential services have access to power.

2. Energy Efficiency and Conservation Measures

To cope with reduced energy availability and avoid overloading the grid, Ukrainian authorities have been encouraging energy efficiency and conservation measures. These efforts are particularly important during the winter when demand for electricity and heating is at its peak.

The government has implemented energy-saving programs, urging citizens and businesses to reduce their consumption and adopt new energy solutions that can be deployed quickly. Measures include limiting electricity use during peak hours, setting thermostats lower in homes and businesses, and encouraging the use of energy-efficient appliances. Ukrainian officials have also been promoting public awareness campaigns to educate people about the importance of energy conservation, which is crucial to avoid grid overload and ensure the distribution of power across the country.

3. Importing Energy from Abroad

To supplement domestic energy production, Ukraine has been working to secure electricity imports from neighboring countries. Ukraine has long been interconnected with energy grids in countries such as Poland, Slovakia, and Hungary, which allows it to import electricity during times of shortage. In recent months, Ukraine has ramped up efforts to strengthen these connections, ensuring that it can import electricity when domestic production is insufficient to meet demand, and in a notable instance, helped Spain during blackouts through coordinated cross-border support.

While electricity imports from neighboring countries provide a temporary solution, this is not without its challenges. The cost of importing electricity can be high, and the country’s ability to import large amounts of power depends on the availability of energy in neighboring nations; officials say there are electricity reserves and no scheduled outages if strikes do not resume. Ukraine has been actively seeking new energy partnerships and working with international organizations to secure access to electricity, including exploring the potential for importing energy from the European Union.

4. Harnessing Renewable Energy Sources

Another key part of Ukraine's strategy to keep the lights on this winter is tapping into renewable energy sources, particularly wind and solar power. While Ukraine’s energy sector has historically been dependent on fossil fuels, the country has been making strides in integrating renewable energy into its grid. Solar and wind energy are particularly useful in supplementing the national grid, especially during the winter months when demand is high.

Renewable energy sources are less vulnerable to missile strikes compared to traditional power plants, making them an attractive option for Ukraine's energy strategy. Although renewable energy currently represents a smaller portion of Ukraine’s overall energy mix, its contribution is expected to increase as the country invests more in clean energy infrastructure. In addition to reducing dependence on fossil fuels, this shift is aligned with Ukraine’s broader environmental goals and will be important for the long-term sustainability of its energy sector.

5. International Aid and Support

International support has been crucial in helping Ukraine keep the lights on during the war. Western allies, including the European Union and the United States, have provided financial assistance, technical expertise, and equipment to help restore the energy infrastructure, though Washington recently ended some grid restoration support as priorities shifted. In addition to rebuilding power plants and transmission lines, Ukraine has received advanced energy technologies and materials to strengthen its energy security.

The U.S. has sent electrical transformers, backup generators, and other essential equipment to help Ukraine restore its energy grid. The European Union has also provided both financial and technical assistance, supporting Ukraine’s efforts to integrate more renewable energy into its grid and enhancing the country’s ability to import electricity from neighboring states.

6. The Role of Nuclear Energy

Ukraine’s nuclear energy plants play a critical role in the country’s electricity supply. Before the war, nuclear power accounted for around 50% of Ukraine’s total electricity generation, and for communities near the front line, electricity is civilization that depends on reliable baseload. Despite the ongoing conflict, Ukrainian nuclear plants have remained operational, though they face heightened security risks due to the proximity of active combat zones.

In the winter months, nuclear plants are expected to continue providing a significant portion of Ukraine's electricity, which is essential for meeting the country's heating and power needs. The government has made efforts to ensure the safety and security of these plants, which remain a vital part of the country's energy strategy.

Keeping the lights on in Ukraine during the winter of 2024 is no small feat, given the war-related damage to energy infrastructure, rising energy demands, and ongoing security risks. However, the Ukrainian government has taken proactive steps to address these challenges, including repairing critical infrastructure, importing energy from neighboring countries, promoting energy efficiency, and expanding renewable energy sources. International aid and the continued operation of nuclear plants also play a vital role in ensuring a reliable energy supply. While challenges remain, Ukraine’s resilience and determination to overcome its energy crisis are clear, and the country is doing everything it can to keep the lights on through this difficult winter.

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Canada Clean Electricity drives a net-zero grid by 2035, scaling renewables like wind, solar, and hydro, with storage, smart grids, interprovincial transmission, and electrification of vehicles, buildings, and industry to cut emissions and costs.

Key Points

Canada Clean Electricity is a shift to a net-zero grid by 2035 using renewables, storage, and smart grids to decarbonize

✅ Doubles non-emitting generation for electrified transport and heating

✅ Expands wind, solar, hydro with storage and smart-grid balancing

✅ Builds interprovincial lines and faster permitting with Indigenous partners

By Merran Smith and Mark Zacharias

Canada is an electricity heavyweight. In addition to being the world’s sixth-largest electricity producer and third-largest electricity exporter in the global electricity market today, Canada can boast an electricity grid that is now 83 per cent emission-free, not to mention residential electricity rates that are the cheapest in the Group of Seven countries.

Indeed, on the face of it, the country’s clean electricity system appears poised for success. With an abundance of sunshine and blustery plains, Alberta and Saskatchewan, the Prairie provinces most often cited for wind and solar, have wind- and solar-power potential that rivals the best on the continent. Meanwhile, British Columbia, Manitoba, Quebec, and Newfoundland and Labrador have long excelled at generating low-cost hydro power.

So it would only be natural to assume that Canada, with this solid head start and its generous geography, is already positioned to provide enough affordable clean electricity to power our much-touted net-zero and economic ambitions.

But the reality is that Canada, like most countries, is not yet prepared for a world increasingly committed to carbon neutrality, in part because demand for solar electricity has lagged, even as overall momentum grows.

The federal government’s forthcoming Clean Electricity Standard – a policy promised by the governing Liberals during the most recent election campaign and restated for an international audience by Prime Minister Justin Trudeau at the United Nations’ COP26 climate summit – would require all electricity in the country to be net zero by 2035 nationwide, setting a new benchmark. But while that’s an encouraging start, it is by no means the end goal. Electrification – that is, hooking up our vehicles, heating systems and industry to a clean electricity grid – will require Canada to produce roughly twice as much non-emitting electricity as it does today in just under three decades.

This massive ramp-up in clean electricity will require significant investment from governments and utilities, along with their co-operation on measures and projects such as interprovincial power lines to build an electric, connected and clean system that can deliver benefits nationwide. It will require energy storage solutions, smart grids to balance supply and demand, and energy-efficient buildings and appliances to cut energy waste.

While Canada has mostly relied on large-scale hydroelectric and nuclear power in the past, newer sources of electricity such as solar, wind, geothermal, and biomass with carbon capture and storage will, in many cases, be the superior option going forward, thanks to the rapidly falling costs of such technology and shorter construction times. And yet Canada added less solar and wind generation in the past five years than all but three G20 countries – Indonesia, Russia and Saudi Arabia, with some experts calling it a solar power laggard in recent years. That will need to change, quickly.

In addition, Canada’s Constitution places electricity policy under provincial jurisdiction, which has produced a patchwork of electricity systems across the country that use different energy sources, regulatory models, and approaches to trade and collaboration. While this model has worked to date, given our low consumer rates and high power reliability, collaborative action and a cohesive vision will be needed – not just for a 100-per-cent clean grid by 2035, but for a net-zero-enabling one by 2050.

Right now, it takes too long to move a clean power project from the proposal stage to operation – and far too long if we hope to attain a clean grid by 2035 and a net-zero-enabling one by 2050. This means that federal, provincial, territorial and Indigenous governments must work with rural communities and industry stakeholders to accelerate the approvals, financing and construction of clean energy projects and provide investor certainty.

In doing so, Canada can set a course to carbon neutrality while driving job creation and economic competitiveness, a transition many analyses deem practical and profitable in the long run. Our closest trading partners and many of the world’s largest companies and investors are demanding cleaner goods. A clean grid underpins clean production, just as it underpins our climate goals.

The International Energy Agency estimates that, for the world to reach net zero by 2050, clean electricity generation worldwide must increase by more than 2.5 times between today and 2050. Countries are already plotting their energy pathways, and there is much to learn from each other.

Consider South Australia. The state currently gets 62 per cent of its electricity from wind and solar and, combined with grid-scale battery storage, has not lost a single hour of electricity in the past five years. South Australia expects 100 per cent of its electricity to come from renewable sources before 2030. An added bonus given today’s high energy prices: Annual household electricity costs have declined there by 303 Australian dollars ($276) since 2018.

The transition to clean energy is not about sacrificing our way of life – it’s about improving it. But we’ll need the power to make it happen. That work needs to start now.

Merran Smith is the executive director of Clean Energy Canada, a program at the Morris J. Wosk Centre for Dialogue at Simon Fraser University in Vancouver. Mark Zacharias is a special adviser at Clean Energy Canada and visiting professor at the Simon Fraser University School of Public Policy.

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Ontario Global Adjustment and ICI balance hydro rates, renewable cost shift, and peak demand. Class A and Class B customers face demand response decisions amid pandemic occupancy uncertainty and volatile GA charges through 2022.

Key Points

A pricing model where GA costs and ICI peak allocation shape Class A/B bills, driven by renewables cost shifts.

✅ Renewable cost shift trims GA; larger Class A savings expected.

✅ Class A peak strategy returns; occupancy uncertainty persists.

✅ Class B faces volatile GA; limited levers beyond efficiency.

Ontario’s large commercial electricity customers can approach the looming annual decision about their billing structure for the 12 months beginning July 1 with the assurance of long-term relief on a portion of their costs, amid changes coming for electricity consumers that could affect planning. That’s to be weighed against uncertainties around energy demand and whether a locked-in cost allocation formula that looked favourable in pre-pandemic times will remain so until June 30, 2022.

“The biggest unknown is we just don’t know when the people are coming back,” Jon Douglas, director of sustainability with Menkes Property Management Services, reflected during a webinar sponsored by the Building Owners and Managers Association (BOMA) of Greater Toronto last week. “The occupancy in our office buildings this fall, and going into the new year, could really impact the outcome of the decision.”

After a year of operational upheaval and more modifications to provincial electricity pricing policies, BOMA Toronto’s regularly scheduled workshop ahead of the June 15 deadline for eligible customers to opt into the Industrial Conservation Initiative (ICI) program had a lot of ground to cover. Notably, beginning in January, all commercial customers have seen a reduction in the global adjustment (GA) component of their monthly hydro bills after the Ontario government shifted costs associated with contracted non-hydroelectric renewable supply to reduce the burden on industrial ratepayers from electricity rates to the general provincial account — a move that trims approximately $258 million per month from the total GA charged to industrial and commercial customers. However, they won’t garner the full benefit of that until 2022 since they’re currently repaying about $333 million in GA costs that were deferred in April, May and June of 2020.

Renewable cost shift pares the global adjustment
For now, Ontario government officials estimate the renewable cost shift equates to a 12 per cent discount relative to 2020 prices, even as typical bills may rise about 2% as fixed pricing ends in some cases. Once last year’s GA deferral is repaid at the end of 2021, they project the average Class A customer participating in the ICI program should realize a 16 per cent saving on the total hydro bill, while Class B customers paying the GA on a volumetric per kilowatt-hour (kWh) basis will see a slightly more moderate 15 per cent decrease.

“This is the biggest change to electricity pricing that’s happened since the introduction of ICI,” Tim Christie, director of electricity policy, economics and system planning for Ontario’s Ministry of Energy, Northern Development and Mines, told online workshop attendees. “The government is funding the out-of-market costs of renewables. It does tail off into the 2030s as those contracts (for wind, solar and biomass generation) expire, but over the next eight-ish years, it’s pretty steady at around just over $3 billion per year.”

Extrapolating from 2020 costs, he pegged average electricity costs at roughly 9.1 cents/kWh for Class A commercial customers and 13.2 cents/kWh for Class B, a point of concern for Ontario manufacturers facing high rates as well. However, energy management specialists suggest actual 2021 numbers haven’t proved that out.

“In commercial buildings, we’re averaging 10 to 12 cents for Class A in 2021, and we’re seeing more than that for about 14, 15 cents for Class B,” reported Scott Rouse, managing partner with the consulting firm, Energy@Work.

GA costs for Class B customers dropped nearly 30 per cent in the first four months of 2021 compared to the last four months of 2020, when they averaged 11.8 cents/kWh. Thus far, though, there have been significant month-to-month fluctuations, with a low of 5.04 cents/kWh in February and a high of 10.9 cents/kWh in April contributing to the four-month average of 8.3 cents/kWh.

“In 2020, system-wide GA very often averaged more than $1 billion per month,” Rouse said. “This February it dropped to $500 million, which was really quite surprising. So it is a very volatile cost.”

Although welcome, the renewable cost shift does alter the payback on energy-saving investments, particularly for demand response mechanisms like energy storage. When combined with pandemic-related uncertainty and a series of policy and program reversals alongside calls to clean up Ontario’s hydro policy in recent years, the industry’s appetite for some more capital-intensive technologies appears to be flagging.

“Volatility puts a pause on some of the innovation,” said Terry Flynn, general manager with BentallGreenOak and chair of BOMA Toronto’s energy committee. “It could be a leading edge, but it might be a bleeding edge that won’t bear any fruit because the way the commodity costs are structured will change.”

“There’s kind of a wait-and-see approach on some of these bigger investments,” Douglas concurred.

Industrial Conservation Initiative underpins commercial class divide
Turning to the ICI, Class A customers — defined as those with average monthly energy demand of at least 1 megawatt (MW) — encountered some unexpected changes to the program rules during 2020. Meanwhile, Class B customers — encompassing the vast share of commercial properties smaller than about 350,000 square feet — confront the persistent reality of electricity cost allocation that offloads the burden from larger players onto them.

Through the ICI, participating Class A customers pay a share of the global adjustment that’s prorated to their energy use during the five hours of the period from May 1 to April 30 when the highest overall system demand is recorded. This gives Class A customers the opportunity to lock in a favourable factor for calculating their share of monthly system-wide global adjustment costs if they can successful project and curtail energy loads during those five hours of peak demand. On the flipside, Class B customers pay the remainder of those system-wide costs, on a straightforward per-kWh basis, once Class A payments have been reconciled.

“Class B has sometimes been regarded as the forgotten middle child of the customer classes in Ontario where all the shifted costs in the system kind of pile up,” acknowledged Mark Olsheski, vice president, energy and environment, with Sussex Strategy Group. “Likewise, there can be big unpredictable and uncontrollable swings in the global adjustment rate from month to month and, outside of pure energy efficiency, there really is precious little opportunity or empowerment for a Class B customer to take actions to lower their bills.”

Nevertheless, COVID-19 presents a few extra hiccups for Class A customers this year. Conventionally, late May is when they receive notification of the cost allocation factor that would be used to determine their GA for the upcoming July 1 to June 30 period. This year, though, all current ICI participants will retain the factor they secured by responding to the five hours of peak demand during the 12 months from May 1, 2019 to April 30, 2020 after the Ontario government placed a temporary halt on the peak demand response aspect of the program last summer. Regardless, eligible ICI participants must formally opt into the program by June 15 or they will be billed as Class B customers.

Peak chasing resumes for summer 2021
Since peak demand hours conventionally occur from June to September, Class A customers will once again be studying forecasts intently and preparing to respond via Peak Perks as the heat wave season sets in. That should help alleviate some of the system stresses that arose last summer — prompting policy-makers to reject lobbying for a continued pause on peak demand response.

“The policy rationale was to allow consumers to focus on their operations when recovering from COVID as opposed to reducing peaks. The other issue was that we did not expect the peaks to be high last summer given COVID shutdowns,” Christie recounted. “But due to some hot weather, more people at home and also the lack of ICI response, we saw peaks we haven’t seen in many, many years come up last summer. So the peak hiatus has ended and this summer we’ll be back to responding to ICI as per normal.”

Among Class A customers, owners/managers of office and retail facilities generally have the most to lose from a billing formula tied to the energy demand of more densely occupied buildings in the summer of 2019. However, they could be much more competitively positioned for 2022-23 if their buildings remain below full occupancy and energy demand stays lower than usual this summer.

“Where we can improve is the IESO (Independent Electricity System Operator) and the LDCs (local distribution companies) need to help customers get their real-time data, especially in light of the phantom demand issue, interpret their bills and their Class A versus B scenarios much more easily and comprehensively,” urged Lee Hodgkinson, vice president, technical services, sustainability and ESG, with Dream Unlimited. “ I look for APIs (application programming interface) and direct data flow from the LDCs to the building owners so that we can access that data really easily.”

Given Class A’s historic advantages, few eligible ICI participants are expected to migrate out to Class B. From a sustainability perspective, there’s perhaps more cause to question how the ICI’s 1-MW threshold encourages strategies to move in the other direction.

“You could jack up demand in some buildings and get them into Class A basically by firing up the chillers on the weekend and then pouring cooling outside to get rid of it,” Douglas noted. “That has nothing to do with climate change strategy or sustainability, but it’s a cost- saving strategy, and, sometimes, when you look at the math, it’s hundreds of thousands of dollars you can save.”

Brian Hewson, vice president, consumer protection and industry performance with the Ontario Energy Board (OEB), confirmed the OEB is currently scrutinizing the discrepancy that leaves Class B as the only consumer group with no flexibility to curtail energy load during higher-priced periods, and will be providing advice to the Ministry of Energy. In the interim, that status does, at least, simplify tactics.

“Just reduce your kWh and it doesn’t matter what time of day because you’re paying that fixed rate for 24 hours a day. So if you can curb your demand at night, you get a big bang for your dollar,” Rouse advised.

“We do talk about rates a lot, but if you’re not using it, you’re not paying for it,” Flynn agreed. “A lot of our focus is still on really to try to reduce the number of kilowatts that we use. That seems to be the best thing to do.”

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