Photo by Al Oman
ORA is increasingly concerned by the cumulative financial burden being placed on Ontario electricity ratepayers through IESO procurement and contract design choices. Across recent engagements, ratepayers have been positioned as the default risk absorber for:
- Retention and monetization of environmental attributes and clean energy claims funded through ratepayer-supported contracts, even where those attributes are later used to meet industrial or policy objectives.
- Stacking of multiple compensation mechanisms—energy payments, capacity payments, environmental attributes, and risk-mitigation provisions—for the same facility, without commensurate accountability for performance under real-world operating and climate conditions
- Long-term fixed-price contracts for resources whose performance is declining under climate change.
- Settlement mechanisms that compensate for non-delivery rather than enforcing performance discipline.
- Escalating system costs associated with transmission expansion, deliverability constraints, and congestion management.
- Stranded or underperforming assets locked into multi-decade contracts.
- Policy-driven procurement volumes that exceed demonstrated domestic reliability needs.
ORA is concerned that ratepayers are financing the assets and contracts that generate those credits, only to be told the credits are “extra value”. Concerned that environmental benefits and clean energy attributes are being treated as additive system value even where the underlying resource is energy-limited, intermittently unavailable, or unable to perform during system stress events. When ratepayers fund long-term contracts, absorb hydrologic risk, and also underwrite environmental attributes for the same facility, the result is cost stacking rather than value creation. This approach obscures true system costs and further weakens the link between public expenditure and actual climate or reliability outcomes. Environmental attributes should not be used to mask or compensate for poor operational performance or climate vulnerability.