Conservation First Framework LDC Tool Kit
Final v2.0 – May 1, 2016
CDM Plan Submission and Review Criteria
Rules
1)
Purpose and definitions
1.1
These Rules set out:
a)
the roles, responsibilities and timing for CDM Plan submission; and
b)
the criteria applied to approve a CDM Plan, and apply both to initial CDM Plans
and to amendments to CDM Plans.
Note: The process for completing the CDM Plan template is not included in these Rules.
1.2
All capitalized terms not defined in this CDM Plan Submission and Review Criteria
Rules have the definitions given to them in the Energy Conservation Agreement between
the LDC and the IESO.
2)
Timelines for review and decision making on CDM
Plans
2.1
The IESO will review and provide the LDC with a decision regarding approval of their
CDM Plan in accordance with the timelines in Table 1. The IESO will endeavour to
expedite approvals of CDM Plans that are submitted jointly by the LDC with other
distribution companies in order to encourage collaborative planning.
Table 1: Timelines for LDC CDM Plan review and notice of decision
Number of LDCs included in CDM
Plan
Number of calendar days from date of submission
that the IESO will notify the LDC of decision
(Approve/Approve with conditions/Not approve)*
LDC alone
60 days
LDC and one or more other
distirbution companies
30 days
*Where a calendar day falls on a weekend or holiday, the review completion date will be the
next business day.
** Subject to section 2(g) of Schedule B of the ECA.
Page 1 of 7
Conservation First Framework LDC Tool Kit
Final v2.0 – May 1, 2016
2.2
Any request by the IESO for additional information during the review period will cause
the remaining period for decision to be paused and the review period shall resume at such
time as the IESO considers that the request has been satisfied by the LDC.
3)
CDM Plan submission and review process
3.1
The CDM Plan review process is set out in Appendix A: LDC CDM Plan Review
Process.
3.2
Once an Energy Conservation Agreement has been executed, the LDC will submit its
first proposed CDM Plan to: CDMPlans@ieso.ca (or such other email address as the
IESO may notify the LDC) between November 1, 2014 and on or before May 1, 2015.
The LDC may request amendments to its CDM Plan in accordance with the provisions of
the Energy Conservation Agreement and, other than as indicated in section 3.3 below,
such amendments will follow the same process as set out in these Rules except for the
timelines set out in Table 1 of these Rules. The IESO will confirm receipt of the CDM
Plan to LDC’s CDM Plan contact.
3.3
CDM Plan amendments that have been designated by the IESO as minor pursuant to
Section 2 of Schedule B to the Energy Conservation Agreement may be undertaken in
accordance with the minor amendment process, if any, outlined by the IESO for such
minor amendments from time to time.
3.4
All CDM Plans will use the CDM Plan Template approved by the IESO.
4)
LDC responses to IESO requests for additional
information
4.1
The IESO will use reasonable efforts to provide the LDC with all requests for
clarifications in a single batch in order to streamline the review process.
5)
Key contact for communications throughout CDM Plan
review process
5.1
Each of the IESO and the LDC will designate a contact person with whom the IESO or
LDC, as applicable, can communicate with throughout the CDM Plan review process.
5.2
Where the LDC is submitting a CDM Plan jointly with other distribution companies, and,
in accordance with Section 19.2 of the Energy Conservation Agreement, the participating
distribution companies have appointed one amongst themselves to act as agent and have
identified an individual representative of the agent, the LDC will provide evidence of the
Page 2 of 7
Conservation First Framework LDC Tool Kit
Final v2.0 – May 1, 2016
appointment of the agent and the IESO will treat the representative of the agent as the
designated contact person. The designated contact will communicate with the IESO for
the purpose of the CDM Plan review on behalf of the parties that have submitted a single
CDM Plan. Among other things, the designated contact will be responsible for obtaining
and providing information requested by the IESO on behalf of the multiple distribution
companies that jointly submitted a CDM Plan.
5.3
The IESO will provide copies of any decisions regarding approval of the CDM Plan to
the designated contact and the contact person for the LDC (if different from the
designated contact).
6)
CDM Plan review criteria
The IESO will approve a CDM Plan that meets all of the criteria set out in Table 2 to the
satisfaction of the IESO.
Table 2: CDM Plan review criteria
Criteria
CDM Plan Approval Threshold(s)
1. Total budget

The total CDM Plan Budget is consistent with budget
allocated to the LDC by the IESO.

The reasonableness of the annual allocation of the CDM Plan
Budget as determined by the LDC.

The reasonableness of the portion of CDM Plan Budget used
for FCR and P4P annually and for the full term of the CDM
Plan.

See ECA definition of Eligible Expenses and the “Eligible
Program Delivery Expense Guidelines” for eligible CDM Plan
Budget items.

Budget for each Program includes costs of IESO Value Added
Services (see [Central Services Strategy and Rate Guideline]
for price list).

Budget for only projects which have been initiated under the
new 2015-2020 CDM framework (e.g., does not include
budget associated with projects initiated in the 20112014/2015 extension framework which may be in-service
between January 1, 2015 and December 31, 2015).

If applicable, the target gap, being the portion of the CDM
Plan Target that the LDC reasonably expects, based on
qualified independent advice per an independently completed
achievable potential study initiated (i.e., a signed contract is in
place between the vendor and the LDC) on or before
November 1, 2014 and as accepted by the IESO, could only
be achieved with funding in addition to the CDM Plan Budget.
Page 3 of 7
Conservation First Framework LDC Tool Kit
Final v2.0 – May 1, 2016
Criteria
CDM Plan Approval Threshold(s)
2. Total MWh to be achieved by
2020

100% of CDM Plan Target allocated to the LDC is planned to
be achieved.

No less than incremental annual savings of 8.3% of total 2020
savings target is to be achieved in any year.

Reasonableness of the forecasted savings by sector in
relation to the Achievable Potential savings available in the
LDC’s service area by sector per the Achievable Potential
Tool provided as part of the LDC’s CDM Plan Submission.

1.0 for each year of CDM Plan unless otherwise justified by
the LDC.

1.0 for overall CDM Plan (the LDC may submit a CDM Plan
where cost effectiveness is not demonstrated if the LDC can
reasonably demonstrate that it is unable to develop a CDM
Plan that is cost effective due to its size, location, the nature
of its customer base or other unusual circumstances).

Note: CDM Plans with benefit:cost ratio less than 1.3 will be
subject to further review to determine potential risk of
decrease to <1.0.

Note: costs of IESO Value Added Services, the LDC
administrative and delivery costs and Programs for Low
Income, Education and First Nation customers will be
included in the evaluation of whether a CDM Plan is cost
effective.

1.0 for overall plan and estimated additional funding where a
qualified target gap has been identified (Note: IESO’s
approval of a CDM Plan does not imply any additional funding
above the CDM Plan budget allocated by the IESO, additional
funding is indicated for future reference only).

The cost effectiveness of a joint CDM Plan will be determined
on an aggregated basis.
General

The assumptions made in the CDM Plan regarding cost
effectiveness and measure-level savings are per the
Measures & Assumptions List, the most recent M&V results
provided by the IESO and/or an approved business case.
Exceptions - due to
the LDC’s size,
location, nature of
customer base or
other unusual
circumstance

A CDM Plan that is not cost effective due to a noted exception
may be accepted where the CDM Plan demonstrates that (a)
the LDC has made reasonable efforts to determine if a CDM
Plan could be delivered cost effectively in its service area by
another distirbution company; and (b) the CDM Plan will be
delivered in as cost effective a manner as is reasonably
possible. In evaluating the CDM Plan to assess whether it has
met the tests in (a) and (b) above, the IESO will consider
factors such as cost efficiencies derived from collaboration
3. CDM Plan
cost
effectiveness
Total Resource
Cost (TRC) and
PAC Test (Program
Administrator Cost
Test)
Page 4 of 7
Conservation First Framework LDC Tool Kit
Criteria
Final v2.0 – May 1, 2016
CDM Plan Approval Threshold(s)
with other distribution comanies and/or gas utilities that result
in delivery cost/MWh that is lower than the LDC’s historic
cost/MWh.
4. Programs

The CDM Plan may include (a) Programs that have been
approved by the IESO or (b) regional or local Programs or
pilots that are being proposed or planned by the LDC or other
distribution companies. For clarity, the IESO’s approval of a
CDM Plan that includes proposed regional and local
Programs or pilots does not constitute the IESO’s approval of
those Programs or pilots. Regional and local Programs or
pilots are subject to review and approval by the IESO in
accordance with the ECA before expenses incurred in respect
of such Programs will be Eligible Expenses under the ECA or
such Programs will qualify for pay-for-performance funding, as
applicable. Costs incurred in respect of the pilots are not
Eligible Expenses under the ECA.
5. Customer coverage

CDM Plan must include Programs for all of the following
customer segments which are found in the LDC’s service
area:
o
Residential;
o
Low income;
o
Small business;
o
Commercial (including multi-family);
o
Agricultural;
o
Institutional; and
o
Industrial.
6. Proposed Pilot and Program
identification

All proposed pilot and proposed local and/or regional
Programs included in the CDM Plan include an, outline of the
proposed pilot or Program name, type (pilot, local, regional),
customer segments served by the proposed program,
participating LDCs (if applicable), expected date of business
case submission, and brief overview of the proposed pilot or
Program.
7. Regional LDC collaboration

Includes an explanation of collaboration with distribution
companies in region. The LDC will indicate whether or not
collaboration will occurand if it will occur, what activities will be
included. If collaboration will not occur, the LDC will indicate
why it will not.
8. Gas collaboration

Includes an explanation of collaboration with gas utility
programs offered in the LDC’s service area (if applicable).
The LDC will indicate whether or not collaboration will occur
Page 5 of 7
Conservation First Framework LDC Tool Kit
Criteria
Final v2.0 – May 1, 2016
CDM Plan Approval Threshold(s)
and if it will occur, what activities will be included.
9. Funding mechanism
10. CDM contribution to regional
planning


Where the CDM Plan proposes a funding mechanism for a
new Program, or where the LDC is proposing to switch a
Program from one funding mechanism to another, the
following criteria must be met:
o
the LDC has not previously delivered that Program
through the funding mechanism that the LDC would now
like to apply to the Program;
o
the LDC has delivered Program through the previously
approved funding mechanism for a minimum of one year;
o
there is no potential for duplication of funding for costs
that have already been recovered by LDC;
o
where an LDC switches a Program from pay-forperformance to full cost recovery, FCR funding is not
used to cover costs incurred while the Program was
funded through pay-for-performance;
o
it is reasonable that the balance of target can be achieved
under the new mechanism in the time remaining in the
CDM Plan; and
o
the LDC and the IESO settle any expenses/financial
matters under the current mechanism before the new
mechanism is approved.
CDM Plan must include description of how the CDM Plan
considers the electricity needs and investments identified in
other plans or planned activitities, completed or underway
withing the LDC’s service area or region.This may include:
o
Integrated Regional Resource Plan;
o
Distribution Network Plan; and
o
Municipal or Community Energy Plans.
[Note to Reader: Additional criteria may be required for funding under the pay-forperformance mechanism.]
7)
Conditional approval
Where the IESO approves a CDM Plan with conditions and those conditions are accepted by the
LDC, those conditions will be attached as an addendum to, and form part of, the approved CDM
Plan.
Page 6 of 7
Draft v2.0 – February 25, 2016
Conservation First Framework LDC Tool Kit
Appendix A: LDC CDM Plan Review Process
LDC
LDC CDM Plan Review Process
1) LDC submits
CDM Plan to IESO
5) LDC provides IESO
with clarifying
information in written
form
(with meeting to
discuss if necessary)
2) IESO receives
CDM Plan and
confirms with LDC
3) IESO assigns a CDM Plan
Coordinator; CDM Plan
Coordinator reviews CDM
Plan to determine if:
IESO
a) Single LDC CDM Plan; or
b) Multi-LDC CDM Plan;
and notifies LDC of Business
Development contact
information and review
timeline/
4) IESO notifies LDC
that clarifying
information is
required to complete
review and outlines
information required
9) LDC returns
signed copy of
CDM Plan
Approval Letter to
IESO
6) IESO reviews
clarifying information
provided
Yes
Clarification on
CDM Plan content
required?
8a) IESO sends LDC
letter confirming
approved plan
Yes
No
7) IESO notfies LDC of CDM
Plan review decision:
a)approved;
b) approved with conditions; or
c) not approved;
CDM Plan
Approved
?
No
Yes,
With
conditions
8b) IESO sends LDC
letter containing
approved plan with
Schedule to ECA
indicating conditions of
approval
8c) IESO sends LDC
letter confirming plan
has not been approved
and reasons approval
not provided
Page 7 of 7