Topic:"Capacity Costs" in M12854

APRIL 17 STAKEHOLDER SESSION QUESTIONS Question/Comment Response Are capacity cost considerations to be included in the ELCC study? In 2019 there was separate information on capacity costs in addition to ELCC information. No, capacity cost...

AI summary The stakeholder session addressed whether capacity costs should be included in the ELCC study. The response clarified that capacity costs are not part of the ELCC study, but will be reviewed with stakeholders during sessions on assumptions. In 2019, E3 conducted an ELCC study and a Supply Options study as part of pre-IRP work.

Capacity value of demand response resources Demand response can displace supply at peak, but its capacity value is often overstated when planning models rely on enrolled/nameplate capability without accounting for operational constraints....

AI summary Demand response (DR) capacity is often overstated in planning models that ignore operational constraints. The ToR should require IRP to use effective capacity metrics, including design-day conditions, net capacity post-snapback, availability rates, and duration limits. Overestimating DR as firm capacity risks misjudging supply-side needs, as highlighted by Dunsky's emphasis on plan robustness.

Dear Registrar, Marine Renewables Canada (MRC) is the national association for tidal, offshore wind, wave, and river current energy, representing a membership of over 215+ technology and project developers, suppliers, utilities, Indigenous...

AI summary Marine Renewables Canada (MRC) criticizes the 2026 Integrated Resource Plan (IRP) Terms of Reference for underestimating future electricity demand from industrial growth and electrification, arguing this risks inadequate long-term procurement signals for clean energy development.

Least-Cost Framework MRC notes that cost is weighted heavily in the evaluation framework, accounting for 70% of the assessment. While we recognize the importance of affordability, we encourage a broader interpretation of cost beyond simple...

AI summary MRC emphasizes that the Least-Cost Framework should consider system-level factors like ELCC and capacity factors, not just LCOE. Offshore wind's higher capacity factor reduces required generation capacity compared to onshore alternatives, while diversification lowers system costs by improving resilience and reducing fuel price risks. The 25-year NPV methodology is critical for capturing these benefits.

1701 HOLLIS ST. 12th FLOOR, HALIFAX, NS B3J 3M8 (902) 422-9663 NATURALFORCES.CA IESO Nova Scotia April 24, 2026 1791 Barrington St. Suite 1010 Halifax, NS B3J 3K9 RE: IESO's Draft Terms of Reference To whom it may concern; On behalf of Nat...

AI summary Natural Forces submits comments on the IESO's draft Terms of Reference for the 2026 Integrated Resource Plan, emphasizing that cost assessments should align with asset lifespans, sustainability must be prioritized, and risk evaluation should include factors like fuel price variability and geopolitical risks. It also advocates for broader environmental impact assessments, local economic considerations, and explicit energy security measures.

• Process - o Operating Costs : NRStor is encouraged by IESO-NS's proposal in the draft ToR to include operating and maintenance costs in addition to capital costs when evaluating existing and candidate resources, as directed by M12412. -...

AI summary NRStor recommends including operating costs in resource evaluations, advocating for technology-neutral grid service criteria, enhanced stakeholder transparency, targeted outreach to energy storage developers, and adopting a Societal Cost Test (SCT) to align with provincial climate goals. These proposals aim to improve the Integrated Resource Plan (IRP) process and ensure alignment with the Clean Power Plan and More Access to Energy Act.

o Demand-Side and Non-Wires : - NRStor welcomes the IESO-NS's proposed approach to better assess energy efficiency and non-wires solutions alongside supply-side resources, including working with E1 and the Demand Side Management Advisory G...

AI summary NRStor supports the IESO-NS's approach to evaluate energy efficiency and non-wires solutions alongside supply-side resources, emphasizing collaboration with E1 and the Demand Side Management Advisory Group. NRStor also highlights updated costing data on grid-scale and residential storage to inform non-wires strategies and infrastructure deferral.

IRP should include robust consideration of risks The Draft TOR does not include explicit discussion of risk analysis, aside from the "Technology Risk" factor included in the draft score card description provided in Appendix A. The IRP shou...

AI summary The Draft TOR lacks explicit risk analysis beyond 'Technology Risk' in Appendix A. The IRP should incorporate considerations of load forecast, resource capital costs, policy changes, fuel prices, and other risks early in the process to define appropriate risk assessment methodologies.