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IESO Fictitious Demand Error inflated HOEP in the Ontario electricity market, after embedded generation was mis-modeled; the OEB says double-counted load lifted wholesale prices and shifted costs via the Global Adjustment.

Key Points

An IESO modeling flaw that double-counted load, inflating HOEP and charges in Ontario's wholesale market.

✅ Double-counted unmetered load from embedded generation

✅ Inflated HOEP; shifted costs via Global Adjustment

✅ OEB flagged transparency; exporters paid more

For almost a year, the operator of Ontario’s electricity system erroneously counted enough phantom demand to power a small city, causing prices to spike and hundreds of millions of dollars in extra charges to consumers, according to the provincial energy regulator.

The Independent Electricity System Operator (IESO) also failed to tell anyone about the error once it noticed and fixed it.

The error likely added between $450 million and $560 million to hourly rates and other charges before it was fixed in April 2017, according to a report released this month by the Ontario Energy Board’s Market Surveillance Panel.

It did this by adding as much as 220 MW of “fictitious demand” to the market starting in May 2016, when the IESO started paying consumers who reduced their demand for power during peak periods. This involved the integration of small-scale embedded generation (largely made up of solar) into its wholesale model for the first time.

The mistake assumed maximum consumption at such sites without meters, and double-counted that consumption.

The OEB said the mistake particularly hurt exporters and some end-users, who did not benefit from a related reduction of a global adjustment rate applicable to other customers.

“The most direct impact of the increase in HOEP (Hourly Ontario Energy Price) was felt by Ontario consumers and exporters of electricity, who paid an artificially high HOEP, to the benefit of generators and importers,” the OEB said.

The mix-up did not result in an equivalent increase in total system costs, because changes to the HOEP are offset by inverse changes to a electricity cost allocation mechanism such as the Global Adjustment rate, the OEB noted.

A chart from the OEB's report shows the time of day when fictitious demand was added to the system, and its influence on hourly rates.

Peak time spikes
The OEB said that the fictitious demand “regularly inflated” the hourly price of energy and other costs calculated as a direct function of it.

For almost a year, Ontario's electricity system operator @IESO_Tweets erroneously counted enough phantom demand to power a small city, causing price spikes and hundreds of millions in charges to consumers, @OntEnergyBoard says. @5thEstate reports.

It estimated the average increase to the HOEP was as much as $4.50/MWh, but that price spikes, compounded by scheduled OEB rate changes, would have been much higher during busier times, such as the mid-morning and early evening.

“In times of tight supply, the addition of fictitious demand often had a dramatic inflationary impact on the HOEP,” the report said.

That meant on one summer evening in 2016 the hourly rate jumped to $1,619/MWh, it said, which was the fourth highest in the history of the Ontario wholesale electricity market.

“Additional demand is met by scheduling increasingly expensive supply, thus increasing the market price. In instances where supply is tight and the supply stack is steep, small increases in demand can cause significant increases in the market price.

The OEB questioned why, as of September this year, the IESO had failed to notify its customers or the broader public, amid a broader auditor-regulator dispute that drew political attention, about the mistake and its effect on prices.

“It's time for greater transparency on where electricity costs are really coming from,” said Sarah Buchanan, clean energy program manager at Environmental Defence.

“Ontario will be making big decisions in the coming years about whether to keep our electricity grid clean, or burn more fossil fuels to keep the lights on,” she added. “These decisions need to be informed by the best possible evidence, and that can't happen if critical information is hidden.”

In a response to the OEB report on Monday, the IESO said its own initial analysis found that the error likely pushed wholesale electricity payments up by $225 million. That calculation assumed that the higher prices would have changed consumer behaviour, while upcoming electricity auctions were cited as a way to lower costs, it said.

In response to questions, a spokesperson said residential and small commercial consumers would have saved $11 million in electricity costs over the 11-month period, even as a typical bill increase loomed province-wide, while larger consumers would have paid an extra $14 million.

That is because residential and small commercial customers pay some costs via time-of-use rates, including a temporary recovery rate framework, the IESO said, while larger customers pay them in a way that reflects their share of overall electricity use during the five highest demand hours of the year.

The IESO said it could not compensate those that had paid too much, given the complexity of the system, and that the modelling error did not have a significant impact on ratepayers.

While acknowledging the effects of the mistake would vary among its customers, the IESO said the net market impact was less than $10 million, amid ongoing legislation to lower electricity rates in Ontario.

It said it would improve testing of its processes prior to deployment and agreed to publicly disclose errors that significantly affect the wholesale market in the future.

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Manitoba Hydro Interim Rate Increase faces PUB scrutiny as consumers coalition challenges a 5% electricity rate hike, citing drought planning, retained earnings, affordability, transparency, and impacts on fixed incomes and northern communities.

Key Points

A proposed 5% electricity rate hike under PUB review, opposed by consumers citing drought planning and affordability.

✅ Coalition backs 2% hike; 5% seen as undue burden

✅ PUB review sought; interim process lacks transparency

✅ Retained earnings, efficiencies cited to offset drought

The Consumers Coalition is urging the Public Utilities Board (PUB) to reject Manitoba Hydro’s current interim rate increase application, amid ongoing debates about Hydro governance and policy.

Hydro is requesting a five per cent jump in electricity rates starting on January 1, claiming drought conditions warrant the increase but the coalition disagrees, saying a two per cent increase would be sufficient.

The coalition, which includes Harvest Manitoba, the Consumers’ Association of Canada-Manitoba, and the Aboriginal Council of Winnipeg, said a 5 per cent rate increase would put an unnecessary strain on consumer budgets, especially for those on fixed incomes or living up north.

"We feel that, in many ways, Manitobans have already paid for this drought," said Gloria Desorcy, executive director of the Consumers’ Association of Canada - Manitoba.

The coalition argues that hydroelectric companies already plan for droughts and that hydro should be using past earnings to mitigate any losses.

The group claims drought conditions would have added about 0.8 per cent to Hydro’s bottom line. They said remaining revenues from a two per cent increase could then be used to offset the increased costs of major projects like the Keeyask generating station and service its growing debt obligations.

The group also said Hydro is financially secure and is projecting a positive net income of $112 million next year without rate increases, even as utility profits can swing with market conditions, assuming the drought doesn’t continue.

They argue Hydro can use retained earnings as a tool to mitigate losses, rather than relying on deferral accounting that shifts costs, and find further efficiencies within the corporation.

"So we said two per cent, which is much more palatable for consumers especially at the time when so many consumers are struggling with so many higher bills,” said Desorcy.

According to the coalition’s calculations, that works out to a $2-4 increase per month, and debates such as ending off-peak pricing in Ontario show how design affects bills, depending on whether electricity is used for heating, but it could be higher.

The coalition said their proposed two per cent rate increase should be applied to all Manitoba Hydro customers and have a set expiration date of January 1, 2023.

Another issue, according to the coalition, is the process of an interim rate application does not provide any meaningful transparency and accountability, whereas recent OEB decisions in Ontario have outlined more robust public processes.

Desorcy said the next step is up to the PUB, though board upheaval at Hydro One in Ontario shows how governance shifts can influence outcomes.

The board is expected to decide on the proposed increase in the next couple of weeks.

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Washington-Led Lawsuit Against Energy Emergency challenges President Trump's executive order, citing state rights, environmental reviews, permitting, and federal overreach; coalition argues record energy output undermines emergency claims in Seattle federal court.

Key Points

Multistate suit to void Trump's energy emergency, alleging federal overreach and weakened environmental safeguards.

✅ Challenges executive order's legal basis and scope

✅ Claims expedited permitting skirts environmental reviews

✅ Seeks to halt emergency permits for non-emergencies

In a significant legal move, Washington State Attorney General Nick Brown has spearheaded a coalition of 15 states in filing a lawsuit against President Donald Trump's executive order declaring a national energy emergency. The lawsuit, filed in federal court in Seattle on May 9, 2025, challenges the legality of the emergency declaration, which aims to expedite permitting processes for fossil fuel projects in pursuit of an energy dominance vision by bypassing key environmental reviews.

Background of the Energy Emergency Declaration

President Trump's executive order, issued on January 20, 2025, asserts that the United States faces an inadequate and unreliable energy grid, particularly affecting the Northeast and West Coast regions. The order directs federal agencies, including the Army Corps of Engineers and the Department of the Interior, to utilize "any lawful emergency authorities" to facilitate the development of domestic energy resources, with a focus on oil, gas, and coal projects. This includes expediting reviews under the Clean Water Act, Endangered Species Act, the National Environmental Policy Act, and the National Historic Preservation Act, potentially reducing public input and environmental oversight.

Legal Grounds for the Lawsuit

The coalition of states, led by Washington and California, argues that the emergency declaration is an overreach of presidential authority, echoing disputes over the Affordable Clean Energy rule in federal courts. They contend that U.S. energy production is already at record levels, and the declaration undermines state rights and environmental protections. The lawsuit seeks to have the executive order declared unlawful and to halt the issuance of emergency permits for non-emergency projects. 

Implications for Environmental Protections

Critics of the energy emergency declaration express concern that it could lead to significant environmental degradation. By expediting permitting processes, including geothermal permitting, and reducing public participation, the order may allow projects to proceed without adequate consideration of their impact on water quality, wildlife habitats, and cultural resources. Environmental advocates argue that such actions could set a dangerous precedent, enabling future administrations to bypass essential environmental safeguards under the guise of national emergencies, even as the EPA advances new pollution limits for coal and gas plants to address the climate crisis.

Political and Legal Reactions

The Trump administration defends the executive order, asserting that the president has the authority to declare national emergencies and that the energy emergency is necessary to address perceived deficiencies in the nation's energy infrastructure and potential electricity pricing changes debated by industry groups. However, legal experts suggest that the broad application of emergency powers in this context may face challenges in court. The outcome of the lawsuit could have significant implications for the balance of power between state and federal authorities, as well as the future of environmental regulations in the United States.

The legal challenge led by Washington State Attorney General Nick Brown represents a critical juncture in the ongoing debate over energy policy and environmental protection. As the lawsuit progresses through the courts, it will likely serve as a bellwether for future conflicts between state and federal governments regarding the scope of executive authority and the preservation of environmental standards, amid ongoing efforts to expand uranium and nuclear energy programs nationwide. The outcome may set a precedent for how national emergencies are declared and managed, particularly concerning their impact on state governance and environmental laws.

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OEB Disconnection Ban shields Ontario residential customers under the stay-at-home order, pausing electricity distributor shutoffs for non-payment and linking COVID-19 Energy Assistance Program credits for small businesses, charities, and overdue utility bills.

Key Points

A pause on electricity shutoff notices during Ontario's stay-at-home order, with COVID-19 bill credits for customers.

✅ Distributors cannot issue residential disconnection notices.

✅ Applies through the stay-at-home order timeline.

✅ CEAP credits: $750 residential; $1,500 small biz and charities.

With Ontario now into the third province-wide lockdown, the Ontario Energy Board (OEB) has promised residents won't have to worry about their power being shut off.

On April 8, the Province issued the third stay-at-home order in the last 13 months which is scheduled to last for 28 days until at least May 6, as electricity rates and policies continue to shift.

On April 30, the annual winter disconnection ban is set to expire, meaning electricity distributors like Hydro One would normally be permitted to issue disconnection notices for non-payment as early as 14 days before the end of the ban.

However, the OEB has announced changes for electricity consumers that prohibit electricity distributors from issuing disconnection notices to residential customers for the entirety of the stay-at-home order.

Additionally, the COVID-19 Energy Assistance Program is available for residential, small business, and registered charity customers who have overdue amounts on their electricity or gas bills as a result of the pandemic, complementing support for electric bills introduced during COVID-19, and the fixed COVID-19 hydro rate that helped stabilize costs.

Those who meet these criteria are eligible for credits up to a maximum of $750 for residential customers and $1,500 for small businesses and charities, alongside earlier moves to set an off-peak price to ease costs.

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Atlin Hydro and Transmission Project delivers First Nation-led clean energy via hydropower to the Yukon grid, replacing diesel, cutting emissions, and creating jobs, with a 69-kV line from Atlin, B.C., supplying about 35 GWh annually.

Key Points

A First Nation-led 8.5 MW hydropower and 69-kV line supplying clean energy to the Yukon, reducing diesel use.

✅ 8.5 MW capacity; ~35 GWh annually to Yukon grid

✅ 69-kV, 92 km line links Atlin to Jakes Corner

✅ Creates 176 construction jobs; cuts diesel and emissions

A First Nation-led clean-power generation project for British Columbia’s Northwest will provide a significant economic boost and good jobs for people in the area, as well as ongoing revenue from clean energy sold to the Yukon.

“This clean-energy project has the potential to be a win-win: creating opportunities for people, revenue for the community and cleaner air for everyone across the Northwest,” said Premier John Horgan. “That’s why our government is proud to be working in partnership with the Taku River Tlingit First Nation and other levels of government to make this promising project a reality. Together, we can build a stronger, cleaner future by producing more clean hydropower to replace fossil fuels – just as they have done here in Atlin.”

The Province is contributing $20 million toward a hydroelectric generation and transmission project being developed by the Taku River Tlingit First Nation (TRTFN) to replace diesel electricity generation in the Yukon, which is also supported by the Government of Yukon and the Government of Canada, and comes as BC Hydro demand fell during COVID-19 across the province.

“Renewable-energy projects are helping remote communities reduce the use of diesel for electricity generation, which reduces air pollution, improves environmental outcomes and creates local jobs,” said Bruce Ralston, Minister of Energy, Mines and Low Carbon Innovation. “This project will advance reconciliation with TRTFN, foster economic development in Atlin and support intergovernmental efforts to reduce greenhouse gas emissions.”

TRTFN is based in Atlin with territory in B.C., the Yukon, and Alaska. TRTFN is an active participant in clean-energy development and, since 2009, has successfully replaced diesel-generated electricity in Atlin with a 2.1-megawatt (MW) hydro facility amid oversight issues such as BC Hydro misled regulator elsewhere in the province today.

TRTFN owns the Tlingit Homeland Energy Limited Partnership (THELP), which promotes economic development through clean energy. THELP plans to expand its hydro portfolio by constructing the Atlin Hydro and Transmission Project and selling electricity to the Yukon via a new transmission line, in a landscape shaped by T&D rates decisions in jurisdictions like Ontario for cost recovery.

The Government of Yukon is requiring its Yukon Energy Corporation (YEC) to generate 97% of its electricity from renewable resources by 2030. This project provides an opportunity for the Yukon government to reduce reliance on diesel generators and to meet future load growth, at a time when Manitoba Hydro's debt pressures highlight utility cost challenges.

The new transmission line between Atlin and the Yukon grid will include a fibre-optic data cable to support facility operations, with surplus capacity that can be used to bring high-speed internet connectivity to Atlin residents for the first time.

“Opportunities like this hydroelectricity project led by the Taku River Tlingit First Nation is a great example of identifying and then supporting First Nations-led clean-energy opportunities that will support resilient communities and provide clean economic opportunities in the region for years to come. We all have a responsibility to invest in projects that benefit our shared climate goals while advancing economic reconciliation.” said George Heyman, Minister of Environment and Climate Change Strategy.

“Thank you to the Government of British Columbia for investing in this important project, which will further strengthen the connection between the Yukon and Atlin. This ambitious initiative will expand renewable energy capacity in the North in partnership with the Taku River Tlingit First Nation while reducing the Yukon’s emissions and ensuring energy remains affordable for Yukoners.“ said Sandy Silver, Premier of Yukon.

“The Atlin Hydro Project represents an important step toward meeting the Yukon’s growing electricity needs and the renewable energy targets in the Our Clean Future strategy. Our government is proud to contribute to the development of this project and we thank the Government of British Columbia and all partners for their contributions and commitment to renewable energy initiatives. This project demonstrates what can be accomplished when communities, First Nations and federal, provincial and territorial governments come together to plan for a greener economy and future.” said John Streicker, Minister Responsible for the Yukon Development Corporation. 

“Atlin has enjoyed clean and renewable energy since 2009 because of our hydroelectric project. Over its lifespan, Atlin’s hydro opportunity will prevent more than one million tonnes of greenhouse gases from being created to power the southern Yukon. We are looking forward to the continuation of this project. Our collective dream is to meet our environmental and economic goals for the region and our local community within the next 10 years. We are so grateful to all our partners involved for their financial support, as we continue onward in creating an energy efficient and sustainable North.” said Charmaine Thom, Taku River Tlingit First Nation spokesperson.

Quick Facts:

• The 8.5-MW project is expected to provide an average of 35 gigawatt hours of energy annually to the Yukon. To accomplish this, TRTFN plans to leverage the existing water storage capability of Surprise Lake, add new infrastructure, and send power 92 km north to Jakes Corner, Yukon, along a new 69-kilovolt transmission line.
• The project is expected to cost $253 - 308.5 million, the higher number reflecting recently estimated impacts of inflation and supply chain cost escalation, alongside sector accounting concerns such as deferred BC Hydro costs noted in recent reports.
• The project is expected to have a positive impact on local and provincial economic development in the form of, even as governance debates like Manitoba Hydro board changes draw attention elsewhere:
• 176 full-time positions during construction;
• six to eight full-time positions in operations and maintenance over 40 years; and
• increased business for B.C. contractors.
• Territorial and federal funders have committed $151.1 million to support the project, most recently the $32.2 million committed in the 2022 federal bdget.

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Ontario Industrial Electricity Pricing Reforms aim to cut regulatory burden for industrial ratepayers through an energy concierge service, IESO billing reviews, GA estimation enhancements, clearer peak demand data, and contract cost savings.

Key Points

Measures to reduce industrial power costs via an energy concierge, IESO and GA reviews, and better peak demand data.

✅ Energy concierge eases pricing and connection inquiries

✅ IESO to simplify bills and refine GA estimation

✅ Real-time peak data and contract savings under review

Ontario's government is pursuing burden reduction measures for industrial electricity ratepayers, including legislation to lower rates to help businesses compete, and stimulate growth and investment.

Over the next year, Ontario will help industrial electricity ratepayers focus on their businesses instead of their electricity management practices by establishing an energy concierge service to provide businesses with better customer service and easier access to information about electricity pricing and changes for electricity consumers as well as connection processes.

Ontario is also tasking the Independent Electricity System Operator (IESO) to review and report back on its billing, settlement and customer service processes, building on initiatives such as electricity auctions that aim to reduce costs.

Improve and simplify industrial electricity bills, including clarifying the recovery rate that affects charges;

Review how the monthly Global Adjustment (GA) charge is estimated and identify potential enhancements related to cost allocation across classes; and,

Improve peak demand data publication processes and assess the feasibility of using real-time data to determine the factors that allocate GA costs to consumers.

Further, as part of the government's continued effort to finding efficiencies in the electricity system, Ontario is also directing IESO to review generation contracts to find opportunities for cost savings.

These measures are based on industry feedback received during extensive industrial electricity price consultations held between April and July 2019, which underscored how high electricity rates have impacted factories across the province.

"Our government is focused on finding workable electricity pricing solutions that will provide the greatest benefit to Ontario," said Greg Rickford, Minister of Energy, Northern Development and Mines. "Reducing regulatory burden on businesses can free up resources that can then be invested in areas such as training, new equipment and job creation."

The government is also in the process of developing further changes to industrial electricity pricing policy, amid planned rate increases announced by the OEB, informed by what was heard during the industrial electricity price consultations.

"It's important that we get this right the first time," said Minister Rickford. "That's why we're taking a thoughtful approach and listening carefully to what businesses in Ontario have to say."

Helping industrial ratepayers is part of the government's balanced and prudent plan to build Ontario together through ensuring our province is open for business and building a more transparent and accountable electricity system.

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