Ontario’s electricity rules need clearer technical standards

Ontario’s renewed electricity-market rules give the IESO essential authority to protect reliability, validate market data, and mitigate market power. But some of the rules lean too heavily on open-ended discretion at precisely the points where participants need clear technical instructions.

Consider the requirement that market participants provide information and supporting documentation the IESO “may reasonably require” to establish reference levels. Flexibility has a purpose: generators, storage resources, and dispatchable loads are not identical. Yet a broad reasonableness standard can become an operational problem when a participant does not know exactly what information is expected, how it will be evaluated, or what will be accepted as sufficient.

That uncertainty has consequences. A resource may be unable to proceed with normal market participation until its reference levels are determined. For non-financial parameters, missing information can result in default values that may be commercially and operationally restrictive. The cost of ambiguity is not shared equally: large organizations can devote legal, technical, and compliance teams to interpreting requests, while smaller participants may simply face delay, rejected data, or missed market opportunities.

The issue is even sharper when timing is tight. The IESO may reject an independent expert’s determination within 15 business days for a material manifest error or a conflict with the rules. A rejection issued at the end of that window remains valid, and challenging it does not halt the replacement-expert process. In practical terms, the participant may be pushed into another administrative cycle while the relevant interim values continue to affect its market position.

The answer is not to remove IESO discretion or turn every technical rule into a rigid one-size-fits-all formula. It is to make discretion auditable and usable.

The rules should require a clear technical specification for each information request: the required data fields, accepted formats, validation criteria, evidentiary purpose, and deadline. Rejection notices should identify the precise failed field, parameter, threshold, or document, not merely state that a submission was inadequate. Participants should be able to correct a defined defect quickly, rather than spend days interpreting a general conclusion.

The same principle applies to participant workstations and cybersecurity compliance. A promise to complete testing or permit inspection “as required” is not a substitute for published baseline controls, regular machine-verifiable checks, and a predictable vulnerability-testing schedule.

Electricity markets depend on speed, accuracy, and trust. A rulebook that asks analysts to guess what will satisfy the regulator does not create resilience. It creates delay, uneven compliance costs, and avoidable disputes.

Ontario does not need less oversight. It needs oversight that gives every participant the same technical map before the clock starts running.