Challenge: High degree of…

ERO number

019-8666

Comment ID

99977

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Challenge:
High degree of revenue uncertainty under current version of CPPA regulation due to
1. Fluctuating wholesale market prices in the future. Some of the IESO price forecast that we have seen which make projects feasible under this framework depend on certainty of the federal carbon price being in place along with CER. But a scenario where a framework such as that is not present leads to low wholesale market revenue for solar generators.
2. Chances of solar generation not being available during GA peaks leading to GA savings uncertainty.

Potential Solution:
Provide additional compensation to distribution connected projects/ICI participant for reduced loading on the transmission infrastructure while serving ICI participants under a CPPA if project located in the same or adjacent load zone. See NY's VDER framework i.e., DRV values.