$500 idea · Pattern-breaking · Canada · Edition 020
Ontario’s only unlicensed wholesale electricity seat pays $171,319 a megawatt-year.
Ontario licenses every role in its wholesale power market. Generator, distributor, transmitter, retailer, wholesaler, wholesale consumer — each needs an Ontario Energy Board licence under section 57 of the Ontario Energy Board Act, 1998, and the wholesaler licence alone costs $1,000 to apply for and $800 a year to keep. One seat is exempt. The IESO’s own registration manual, Table 2-3, says flatly that “Capacity market participants participating using a demand response resource do not require an OEB licence.”
Ontario runs its electricity system through a single public agency, which operates the province’s wholesale market and has to make sure there is enough supply on the worst day of the year. Once a year it holds an auction — not for electricity, but for the promise that something will be there if the system gets tight: a generator that will run, an import that will arrive, or a factory that will switch off. Whoever wins is paid a fixed daily amount for six months whether or not they are ever called on, and is charged a penalty if they are called and cannot deliver. This edition is about the one kind of bidder in that auction that Ontario does not license at all — the one selling electricity it promises not to use.
The capital is CAD $709.05 (USD $500 at 1.4181, Bank of Canada daily average, 10 November 2026 — the most recent posted rate at the time of writing) and the target is CAD $7,090.50 a month (USD $5,000), or CAD $85,086.00 a year. The claim of this edition is that Ontario’s wholesale electricity market has exactly one unlicensed seat in it, that the seat is priced in dollars per megawatt-day by a published auction, that 0.7401 MW of it clears this series’ target — and that the two things standing between a reader and it are a deposit of CAD $3,817.31 and a qualification window that shut six weeks ago.
Start with how licensed the market is. Section 57(e) of the Ontario Energy Board Act, 1998 says no person may purchase electricity or ancillary services in the IESO-administered markets or directly from a generator without a licence; paragraph (f) does the same for selling. The Board’s own application page prices an electricity wholesaler licence at $1,000 for a new application, $200 to renew and $800 a year in registration fees — CAD $5,000 across a five-year licence term before a single megawatt changes hands. Distributors, transmitters, generators, retailers and wholesale consumers each need their own.
Now read Table 2-3 of the IESO’s Market Manual 1.5, the table that maps each authorization class to the OEB licence it requires. Against capacity auction participant: none. Against capacity market participant: “Capacity market participants participating using a demand response resource do not require an OEB licence.” Against every other class that sells or buys energy — generator, distributor, transmitter, retailer, energy trader, wholesale consumer — a named licence. The exemption is not an oversight. A demand response resource sells neither electricity nor ancillary services; it sells the absence of a withdrawal, and section 57 has nothing to say about that.
So price the seat. The capacity auction buys a capacity obligation for a commitment period of one year, split into two six-month obligation periods. For the auction being held this month the commitment period runs 1 May 2027 to 30 April 2028, with a summer obligation period of 1 May–31 October 2027 and a winter one of 1 November 2027–30 April 2028. The availability window is “business days from 12:00 to 21:00 EST” in summer and 16:00 to 21:00 in winter. The IESO’s pre-auction report for this auction, created 1 October 2026, sets a reference price of $678.63 per MW-day, a maximum clearing price of $1,017.95, and targets of 2,000 MW for summer and 1,400 MW for winter.
The last auction is the one with prices attached. The IESO’s post-auction report, read on 11 November 2026, puts the clearing price for summer 2026 at CAD $645.24 per MW-day and for winter 2026–27 at CAD $725.31, uniform across all ten electrical zones. The payment rule is Chapter 9, section 4.7J.1 of the Market Rules, charge type 1314: the capacity availability payment is the obligation summed over “all settlement hours within the availability window of all business days” in the period. Business days, not calendar days. At the 125 business days the IESO’s own deposit formula uses for an obligation period, one megawatt earns CAD $80,655.00 in summer and CAD $90,663.75 in winter: CAD $171,318.75 a year, or USD $120,808.65.
Then read what a virtual obligation is, because it is the part nobody expects. Market Manual 12, Table 3-1, says that for an hourly demand response resource, “if there is no registered facility, the zonal location of the potential demand response resource” is given instead. Section 5.2 then requires the resource to be registered “at least 45 business days prior to the beginning of the obligation period” — which is to say, you may sell the promise first and assemble the thing that keeps it afterwards, with roughly five months in hand. Generation, storage and import offers get no such latitude: they must name a registered facility at qualification.
The register says how much of the market works this way. Of the 1,748.7 MW of summer 2026 obligations outstanding, 638.9 MW are virtual — 36.54%; of the 1,125.3 MW of winter, 653.5 MW, or 58.07%. The holders are named in full. The aggregators are there as expected — Rodan Energy Solutions Inc with 257.5 MW across nine zones, Voltus Energy Canada Ltd with 83.6, Enel X Canada Ltd. with 81.8, Edgecom Energy Inc. with 52.6, En-Powered Inc. with 38.7. So are the people nobody puts in an electricity market: the University of Guelph at 3.3 MW summer, Hamilton Health Sciences Corporation at 8, Sanofi Pasteur Limited at 4, Dome Mine Ltd. at 1.4 summer and 6 winter, and Vine Fresh Acres Ltd. — a greenhouse — at 8.7 MW of winter obligation worth CAD $788,774.62 a year on the same arithmetic.
And here is where it turns. Netting CAD $7,090.50 a month as an Ontario sole proprietor at the 2026 rates needs CAD $126,797.30 of gross income a year. One megawatt of capacity obligation pays 135.11% of that. The quantity that exactly clears the target is 0.7401 MW — less than the one-megawatt minimum the auction will accept as an offer, and less than the smallest non-zero virtual obligation on the register, which is exactly 1.0 MW and is held by four participants including the University of Guelph. On a 50% revenue share with the sites whose load you curtail, the number is 1.4803 MW; at 25%, 2.9605 MW.
The catch is in two numbers and a date. Market Manual 12, section 3.4: “Capacity auction deposit = 3% * (total unforced capacity * maximum auction clearing price per MW-day) * 125 business days” — on a one-megawatt offer at this auction’s $1,017.95 cap, CAD $3,817.31, which is 5.38× the capital this series starts with. Charge type 1322, the capacity deficiency charge, is “(-1.5) x OCMW” times the clearing price: being deficient on one megawatt for one summer obligation period costs CAD $120,982.50, 170.63× the capital and 31.69× the deposit. And the capacity qualification window for the 25–26 November auction ran from 10 September to 9 October 2026. It is shut. A reader starting today qualifies in the 2027 cycle for an obligation period beginning 1 May 2028.
The non-consensus reading, then, is not that this is a $500 business. It is that Ontario’s wholesale electricity market — the most heavily licensed market in the province — contains one seat that needs no licence from anyone; that the seat is openly held by universities, hospitals and a greenhouse as well as by aggregators; that a single megawatt of it pays 135.11% of what this series is trying to reach; and that the barrier is not permission but a refundable deposit 5.38× the capital, a penalty 1.5× the revenue, and a door that closed on 9 October. The price is public, the register is public, and the queue is eighteen months long.
The evidence
8 findingsEvery wholesale seat in Ontario needs an OEB licence except the demand response one
Table 2-3 maps each IESO authorization class to the Ontario Energy Board licence it requires. Generator: electricity generator licence. Distributor: “Distributors must hold an electricity distributor OEB licence.” Transmitter: transmitter licence. Retailer: retailer licence. Energy trader and wholesale consumer: electricity wholesaler licence. Electricity storage participant: storage or generator licence.
Against the capacity classes, nothing. Capacity auction participant: no OEB licence. Capacity market participant: “Capacity market participants participating using a demand response resource do not require an OEB licence.” Table 2-2 adds that prospective market participants must hold an OEB licence for each participation type for which they will conduct market activities, citing Market Rules Ch. 2, s. 1.2.2.4 — which is what makes the blank row meaningful rather than accidental. The same table records that the IESO charges an application fee for authorization; the amount is not stated in the manual and was not established on this run. Market Manual 1.5
What the licence you do not need would have cost
Section 57(e): “no person is permitted to purchase electricity or ancillary services” in the IESO-administered markets or directly from a generator without a licence. Paragraph (f) applies the same bar to selling electricity or ancillary services through the IESO-administered markets or directly to anyone other than a consumer.
The Board’s published fees for that licence: $1,000 non-refundable on a new application, $200 to renew where the annual registration fee has been paid, and $800 for every year of the licence. Over a five-year term that is CAD $5,000 of pure permission cost, before any market activity, and it is the cost the demand response seat does not carry. OEB — electricity wholesaler licence
CAD $645.24 and $725.31 per MW-day, uniform across all ten zones
The 2025 Capacity Auction cleared summer 2026 at 645.24 and winter 2026–27 at 725.31, the same price in BRUCE, EAST, ESSA, NIAGARA, NORTHEAST, NORTHWEST, OTTAWA, SOUTHWEST, TORONTO and WEST. Province-wide obligations outstanding at the report date: summer 1,748.7 MW (1,109.8 physical, 638.9 virtual); winter 1,125.3 MW (471.8 physical, 653.5 virtual). The IESO’s own release of 4 December 2025 announced “1,833 megawatts (MW) of supply for summer 2026 and 1,125 MW for winter 2026-2027”; the difference in the summer figure is the register as it stands after transfers and buy-outs, which is why this edition quotes the report rather than the release.
Virtual obligations are therefore 36.54% of the summer book and 58.07% of the winter one. Post-Auction Report · IESO release, 4 December 2025
A greenhouse, a university, a hospital group and a vaccine plant are all in Ontario’s capacity market
The register names every holder. The aggregators: Rodan Energy Solutions Inc 257.5 MW summer and 259.2 winter across nine zones; Voltus Energy Canada Ltd 83.6 and 85.3; Enel X Canada Ltd. 81.8 and 95.1; Edgecom Energy Inc. 52.6 and 60.3; En-Powered Inc. 38.7 and 41.8; Alectra Microgrid Services Project (LNR) LP 24.3 and 24.5; GC Project LP 14.1 and 13.2; plus HCE Energy Inc., Stem Energy Canada Inc. and Great Circle Power Corporation at 1.3 to 4 MW.
And the end users holding obligations in their own name, with no aggregator between them and the market: Vine Fresh Acres Ltd., a greenhouse, 8.7 MW of winter obligation in the WEST zone; Hamilton Health Sciences Corporation 8 summer and 5 winter; the Governing Council of the University of Toronto 5.6 in both; Sanofi Pasteur Limited 4 in both; the University of Guelph 3.3 and 1.0; Dome Mine Ltd. 1.4 and 6; Linde Canada Inc., CRH Canada Group Inc., Cascades Canada ULC, Roseburg Forest Products Canada Ltd. and Stelco Inc. The smallest non-zero virtual obligation on the register is 1.0 MW. Post-Auction Report
The door for this month’s auction closed on 9 October 2026
The milestone table for the 2026 Capacity Auction: capacity qualification request submission 10 September to 9 October 2026; the IESO assesses unforced capacity 13–19 October; auction deposits are posted 20 October to 18 November 2026; offers are submitted 25–26 November 2026; the post-auction report publishes by 3 December 2026. Qualification precedes everything, and it is closed.
Auction parameters for both periods: reference price $678.63 per MW-day, minimum clearing price $0, maximum clearing price $1,017.95; target capacity 2,000 MW summer and 1,400 MW winter; maximum auction capacity limits 3,334 and 2,334 MW. The zonal caps on virtual obligation are the ceiling on this edition’s route and they are small: TORONTO 383.2 MW, SOUTHWEST 287, OTTAWA 126.9, WEST 69.8, NORTHEAST 63.2, NIAGARA 50.2, NORTHWEST 2.1 MW. Pre-Auction Report
Paid by the business day; charged at 1.5× for being short
The capacity availability payment, charge type 1314, is “CAAPmk = ΣH CCOmk,h x CACPz”, where “‘H’ is the set of all settlement hours within the availability window of all business days in the relevant energy market billing period.” CACP is the obligation-period clearing price divided by the number of settlement hours in that window, so the period total is simply the obligation in MW times the clearing price times the number of business days.
The charges run the other way. Availability charge (1315) for a demand response resource: “(-1) x Max( 0, (CCOmk,h - DREBQmk,h)) x CACPz h x CNPFtm”. Dispatch charge (1317): “(-1) x DRSQtymk,h x CACPz h x CNPFtm”. Buy-out charge (1319): “50% x ΣH CBOCmk x CACPz h x (1 - CNPFtm)”. And the capacity deficiency charge (1322) carries no mitigating factor at all: “(-1.5) x OCMWi k x CACPzh.” One and a half times the price you were paid. Ch. 9 settlements reference guide
Sell the promise first, register the resource within 45 business days of the period
Table 3-1: for an hourly demand response resource, “if there is no registered facility, the zonal location of the potential demand response resource” is supplied at qualification. Section 5.2: a participant with a virtual obligation “must register their demand response resource as a virtual hourly demand response resource”, virtual HDR resources may include third-party non-dispatchable loads as contributors, and the registration “must be completed at least 45 business days prior to the beginning of the obligation period.” A physical obligation, by contrast, requires the participant to “be the registered owner” of the facility.
The constraints that bite. Offers may be submitted for “any quantity between 1 MW and the unforced capacity” (s. 4.1). Contributors’ physical addresses must sit in the same electrical zone as the resource, and residential virtual HDR needs “at least 350 control group demand response contributors” a month (s. 5.2.1). The deposit (s. 3.4): “Capacity auction deposit = 3% * (total unforced capacity * maximum auction clearing price per MW-day) * 125 business days”, with the IESO free to demand more on creditworthiness. The annual test (Table 5-2) passes only if the resource “reduces its withdrawal of energy, on average for each hour of its 4 consecutive hour test duration, by at least 90% of its cleared ICAP.” Market Manual 12 (PDF)
CAD $171,318.75 a megawatt-year, 0.7401 MW to the target, and a deposit 5.38× the capital
Capital: 500 × 1.4181 = CAD $709.05. Target: 5,000 × 1.4181 = CAD $7,090.50 a month, CAD $85,086.00 a year. Gross business income needed to net that after federal and Ontario tax, the health premium and CPP: CAD $126,797.30.
Per megawatt: 645.24 × 125 = CAD $80,655.00 for summer; 725.31 × 125 = CAD $90,663.75 for winter; total CAD $171,318.75, or USD $120,808.65. Counting the actual calendar instead — weekdays less statutory holidays, 126 business days in summer 2026 and 125 in winter — gives CAD $171,963.99, 0.38% higher; this edition uses the 125 the IESO’s own deposit formula uses. One megawatt is therefore 135.11% of the required gross, and the target is cleared by 0.7401 MW at a 100% share, 1.4803 MW at 50% and 2.9605 MW at 25% — the three crossings plotted in the figure above, each coordinate being MW × 171,318.75 × share run through the tax model.
Entry and exposure: deposit 0.03 × 1 × 1,017.95 × 125 = CAD $3,817.31 (USD $2,691.85), 5.38× the capital, refundable. Deficiency on one megawatt: 1.5 × 645.24 × 125 = CAD $120,982.50 for a summer period and 1.5 × 725.31 × 125 = CAD $135,995.63 for a winter one, CAD $256,978.13 across the year — 1.5× the revenue, 170.63× the capital on the summer figure alone and 31.69× the deposit. At this auction’s $1,017.95 cap a megawatt would pay CAD $254,487.50 a year.
Market size: 1,748.7 × 80,655 + 1,125.3 × 90,663.75 = CAD $243,065,316.38 a year of capacity payments outstanding, of which the virtual book — 638.9 and 653.5 MW — is CAD $110,779,240.12. Rodan’s 257.5 and 259.2 MW are CAD $44,268,706.50; Vine Fresh Acres’ 8.7 MW of winter is CAD $788,774.62; Hamilton Health Sciences’ 8 and 5 MW are CAD $1,098,558.75; the University of Guelph’s 3.3 and 1.0 are CAD $356,825.25.
The ladder
From $500 to $5,000 a month · C$707 → C$7,068Section 57 of the Ontario Energy Board Act, 1998 licenses every way of buying or selling electricity in the IESO-administered markets, and an electricity wholesaler licence costs $1,000 to get and $800 a year to keep. Table 2-3 of IESO Market Manual 1.5 lists the licence each authorization class needs — and against capacity participation by demand response it says they “do not require an OEB licence.” You are not selling electricity. You are selling its absence.
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Find the one row in the licence table that is blank
Section 57 of the Ontario Energy Board Act, 1998 licenses every way of buying or selling electricity in the IESO-administered markets, and an electricity wholesaler licence costs $1,000 to get and $800 a year to keep. Table 2-3 of IESO Market Manual 1.5 lists the licence each authorization class needs — and against capacity participation by demand response it says they “do not require an OEB licence.” You are not selling electricity. You are selling its absence.
OEB Act s. 57(e)–(f) · MM1.5 Table 2-3 · $0 of licence -
Price the day, because Ontario prices the day
Chapter 9, s. 4.7J.1 pays the obligation over “all settlement hours within the availability window of all business days” — 12:00 to 21:00 EST in summer, 16:00 to 21:00 in winter. At the 2025 auction’s clearing prices and the 125 business days the IESO’s own deposit formula uses, a megawatt pays CAD $80,655.00 for the summer period and CAD $90,663.75 for the winter one, whether or not it is ever activated.
645.24 × 125 + 725.31 × 125 = CAD $171,318.75 -
Notice that the offer does not have to be backed by anything yet
Market Manual 12, Table 3-1: an hourly demand response offer gives “the zonal location of the potential demand response resource” where there is no registered facility. Section 5.2 then wants the resource registered “at least 45 business days prior to the beginning of the obligation period” — about five months after the auction. 638.9 MW of summer and 653.5 MW of winter obligations are held on exactly that basis. Generation and imports get no such latitude.
virtual: 36.54% of summer · 58.07% of winter -
Find the load, because the load is the entire business
Contributors must sit in the same electrical zone as the resource, and the zonal caps on virtual obligation are the real ceiling: TORONTO 383.2 MW, SOUTHWEST 287, OTTAWA 126.9 — NORTHWEST 2.1. The register shows who is already there: Rodan at 257.5 MW, and beside it a greenhouse at 8.7, a hospital group at 8 and a university at 3.3. Netting the target needs 1.4803 MW on a half-share, or 0.7401 MW if the load is your own.
0.7401 MW to target · 1 MW minimum offer -
Price the deposit and the deficiency before you price the revenue — and look at the calendar
The auction deposit on a one-megawatt offer is CAD $3,817.31, 5.38× this series’ capital, and charge type 1322 prices being short at “(-1.5) x OCMW” times the clearing price — CAD $120,982.50 on one megawatt for one summer. Then the date: capacity qualification for the 25–26 November 2026 auction closed on 9 October 2026. Starting today, the first obligation period you can reach begins 1 May 2028.
$3,817.31 deposit · −$120,982.50 exposure · 18 months
Sources
10 primary documents- IESO, Market Manual 1.5 — Market Registration Procedures — Tables 2-2 and 2-3, ss. 2.2.1–2.2.2. Read 11 November 2026.
- IESO, Market Manual 12: Capacity Auctions, MAN-44, Issue 17.0 — ss. 2.2, 2.4, 3.3.1, 3.4, 4.1, 5.2, 5.2.1, 5.3.3, 5.3.4. Read 11 November 2026.
- IESO, Capacity Auction: Pre-Auction Report — revision 1, created 1 October 2026; commitment period 1 May 2027–30 April 2028. Read 11 November 2026.
- IESO, Capacity Auction: Post-Auction Report — revision created 19 October 2026; clearing prices and participant-level obligations. Read 11 November 2026.
- IESO, IESO Secures Resources via 2025 Capacity Auction — 4 December 2025. Read 11 November 2026.
- IESO, Capacity Auction programme page — 2026 auction held 25–26 November 2026. Read 11 November 2026.
- IESO, Capacity Auction Settlements — Chapter 9 reference guide — charge types 1314, 1315, 1317, 1319, 1322. Read 11 November 2026.
- IESO, Guide to Capacity Auction Activities via Online IESO — June 2025. Read 11 November 2026.
- Ontario Energy Board, Electricity wholesaler licence — OEB Act ss. 57(e)–(f); $1,000 / $200 / $800. Read 11 November 2026.
- Bank of Canada Valet — FXUSDCAD — 10 November 2026 = 1.4181.
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