As the contracts under LRP I are being finalized, the IESO has begun a formal consultation process with stakeholders on the design and operation of LRP II (Large Renewable Procurement, round 2). Considering the breadth of recent experience with LRP I, and the significant procurement targets expected for LRP II, the consultation process is likely to generate significant interest.
Shawn Cronkwright, the IESO’s director of renewables procurement, says that the goal of the LRP II engagement plan is “to seek input and capture any learnings that could be taken into account for the planned LRP II process.” There will be three phases of engagement:
Phase I: Review of LRP I process
Phase II: Feedback on draft LRP II Request for Qualifications (LRP II RFQ)
Phase III: Feedback on draft LRP II Request for Proposals (LRP II RFP).
The IESO recently released its proposed Stakeholder Engagement Plan for LRP II and invited comments from all interested parties. The implementation of the Engagement Plan will be in accordance with the IESO’s approved engagement principles.
Based on the material released so far, Travis Lusney of Power Advisory LLC, a power system consultant who has advised APPrO and numerous generation companies on the LRP process, believes that significant improvements are possible, without affecting the overall timeline for procurement. In a memo to generator organizations, Mr. Lusney recommends that, “A series of meetings to engage on the key components of the draft LRP II RFP and draft LRP II contract should be scheduled, in order to best engage on complicated and technical components (e.g., connection assessment, mandatory requirements, application of rated criteria, proposal scoring methodology, voluntary termination, curtailment, etc.).”
In terms of timing, he notes that, “If the LRP II RFQ can be concluded in June 2016, and the draft LRP II RFP and draft LRP II contract are released in July 2016, the IESO can hold stakeholder consultations during July and August 2016, therefore stakeholders can provide comments on the LRP II RFP and draft LRP II contract no later than early September 2016 and the IESO can finalize the LRP II RFP and LRP II contract by October 2016.”
One of the key issues raised by Power Advisory is the uncertainty proponents often face with respect to connection capability. Although it is likely impractical to have full blown connection assessments prepared for every qualified applicant prior to proposal submission, he points out that the number of qualified applicants is relatively small, which means that the task of collecting relevant information for their use can be kept within manageable limits. Mr. Lusney suggests there are methods of providing information useful for preparing their proposals, without incurring the full cost of actual connection assessments. He says that, “During the consultations regarding the draft LRP II RFP and draft LRP II contract, the IESO should also explicitly consult on the connection assessment framework for LRP II.” For details, see Mr. Lusney’s commentary on the Connection Assessment process, elsewhere in this issue of IPPSO FACTO.
Mr. Lusney recommends further that:
• LRP II stakeholder engagement should be more formalized with set engagement dates that clearly articulate the scope and objectives of each engagement (e.g., webinars, in-person meetings, etc.).
• Phase III should include engagement on the draft LRP II contract.
• Industry association meetings and one-on-one meetings should be encouraged and not described as “possible” regarding one-on-one meetings within Phase II and Phase III.
Further information on Mr. Lusney’s recommendations is available from Power Advisory or APPrO.
All materials for this consultation will be posted on the IESO website at www.ieso.ca, > Participate > Stakeholder Engagement > Large Renewable Procurement (LRP) Engagement http://www.ieso.ca/Pages/Participate/Stakeholder-Engagement/Large-Renewable-Procurement-LRP-Engagement.aspx.
Inquiries and/or comments throughout the engagement process can be directed to