Thank you for the…

Thank you for the opportunity to comment on Ontario Integrated Resource Plan. We are at a crossroads in our province's energy future and Voltus believes that Demand Response and Distributed Energy Resources play a pivotal role in an affordable, sustainable and reliable grid. Taken together, enabling Demand Response and DERs to participate in all IESO and utility programs will assist our province in not only managing a cleaner, reliable and more cost effective grid, but also in protecting the competitiveness of Ontario’s Commercial and Industrial business sectors. Voltus looks forward to working with Ministry of Energy staff on these files in 2025.

Capacity
1. Demand Response continues to be the most cost-effective Capacity acquired by Ontario. For the 2025/2026 year, the IESO has procured almost 1,200 MW of Demand Response at a price of just $58,800 per MW-Year through the Capacity Auction. When compared to the Long-Term Procurement pricing of between $166,000 and $416,000 per MW-Year, Demand Response is incredibly cost-effective.
2. The Capacity Auction had a number of resources that did not clear, as a result it is pivotal to expand the Capacity Auction and maintain medium and long-term incentives for new resources to be made available through this mechanism.

Energy and Ancillary Services
1. Ontario is one of just 3 jurisdictions in North America that prevents aggregated Demand Response resources from being paid in the energy market and from participating in ancillary services.
2. Voltus manages gigawatts of ancillary services capacity throughout the United States and these resources are both cost effective and highly reliable.
3. In addition, Voltus has provided nearly 1,000 GWh of energy to the PJM grid through highly flexible loads that are dispatched through its day-ahead market. These resources are paid the energy price and would not be available without this payment.

Utility Programs
1. Over the past ten years, Ontario utilities have have demonstrated the capability of demand response in providing localized support for transmission and distribution system.
2. The time for pilots is over, now we must develop a standard Utility Non-Wires Alternative Program across the province. Ontario can look to New York's Commercial System Relief Program (CSRP) or New England's Connect Solutions program for inspiration.
3. These programs must have a way of coordinating dispatch with the Independent Electricity System Operator to enable program stacking.

Please find our full comments on how the province can enable these resources in its Integrated Resource Plan attached.

Best,

Michael Pohlod
Voltus, Inc.