Quick Summary

Bronson conducted compliance audits for two concurrent Independent Electricity System Operator (IESO) conservation programs in Ontario.

The first stream audited the wind-down of the Conservation First Framework (CFF), a $1.9 billion, 6.9 TWh program delivered through 67 Local Distribution Companies (LDCs).

The second stream audited the Interim Framework (IF), a $353 million, 1.4 TWh program delivered through 21 service provider agreements.

Bronson developed tailored audit frameworks that maintained consistent assurance standards across 88 counterparties of substantially different size and scope.

The engagement was delivered through the COVID-19 period, with audit methods adapted to remote engagement and delayed site verification constraints.

Project Overview

The Independent Electricity System Operator (IESO) manages Ontario’s electricity grid and oversees the delivery of conservation programs across the province. Bronson was engaged to conduct compliance audits for two distinct but concurrent IESO conservation program streams, each with its own audit scope, counterparty mix, and methodological demands.

The first stream covered the Conservation First Framework (CFF), a five-year conservation program delivered from 2015 through 2020. CFF was originally designed to generate 6.9 TWh of energy savings with a total program budget of $1.9 billion, targeting a variety of sectors and conservation objectives across nine separate program types. CFF programs were discontinued in March 2019, and the 67 Local Distribution Companies (LDCs) that delivered them became responsible for an orderly wind-down of activities, including ongoing administration and review of incented projects still in progress at the time of discontinuation.

The second stream covered the Interim Framework (IF), introduced in April 2019 as a replacement for CFF and running through December 2020. The IF had an estimated total budget of $353 million and projected savings of 1.4 TWh, delivered through 21 separate contractual agreements with service providers across Ontario.

Bronson’s role was to design and deliver audit programs that satisfied IESO’s compliance requirements for both streams while adapting to the unique characteristics of each: a massive multi-LDC wind-down on one side, and a tightly-scoped, multi-service-provider program on the other.

The Challenge

Auditing two concurrent multi-counterparty conservation programs at this scale is not a single methodology problem. Each stream had its own risk profile, counterparty mix, and operational context, and the engagement had to deliver consistent assurance across both.

The main challenges Bronson tackled:

  • Two parallel program audits. Bronson was running compliance audit activity across the CFF wind-down and IF delivery simultaneously, each with distinct program requirements and counterparty types.
  • 67 LDCs of vastly different scale. The Conservation First Framework was delivered through 67 LDCs ranging from small rural utilities to large urban distributors. A one-size-fits-all audit approach would have created disproportionate burden for smaller LDCs and risked incomplete findings for larger ones.
  • 21 service provider agreements. The Interim Framework involved 21 separate service provider agreements that each carried their own compliance considerations and required individualized engagement.
  • CFF wind-down complexity. Wind-down activities, including ongoing administration and review of incented projects that remained in progress at discontinuation, introduced audit considerations that go beyond standard in-flight program audits.
  • Nine separate CFF program types. CFF spanned nine program types across multiple sectors and conservation objectives, broadening the technical and contractual scope of the audit.
  • COVID-19 constraints. The pandemic introduced delays to CFF wind-down activities and disrupted planned site verification visits for selected IF projects. Audit methods had to adapt without compromising integrity.
  • Counterparty trust and accuracy. Audit findings had to be accurate, defensible, and reviewed with each counterparty to confirm that all relevant context had been captured before they were finalized.

IESO needed a structured, defensible audit program that could deliver consistent compliance assurance across 88 counterparties operating under two different conservation program frameworks, in a constrained operating environment.

Our Solution

Bronson designed and delivered the engagement as two parallel audit streams sharing a common methodology backbone. The work was organized into the following streams:

1. Audit Risk Consultation with IESO

Bronson began with structured consultation with IESO representatives to review and assess identified audit risks for both the CFF wind-down and IF program delivery. The consultation set the priorities for the audit program and ensured that risk areas of greatest concern to IESO were addressed first.

2. Program Requirements and Parameter Review

Bronson conducted a detailed review of program requirements and parameters for both CFF and IF, drawing on prior experience with IESO compliance audit engagements. This pre-engagement program knowledge reduced ramp-up time and improved audit precision.

3. CFF Audit Framework Development

Bronson developed a structured audit framework for the CFF wind-down covering 67 LDCs and 9 program types. The framework defined a core audit methodology with modular components adjustable to counterparty scale, maintaining consistent assurance standards across small rural utilities and large urban distributors alike.

4. IF Audit Framework Development

Bronson developed a separate audit framework tailored to the IF program structure, designed to support consistent compliance review across 21 service provider agreements while accounting for the differences between contractual arrangements.

5. Counterparty Audit Engagements

Individual LDCs and service providers were engaged and reviewed based on the respective audit frameworks. Audit activities were adapted to remote engagement where required by COVID-19 constraints, with flexible scheduling that preserved audit integrity through periods of disruption.

6. Findings Review and Counterparty Validation

Any issues identified during the audit were reviewed directly with counterparty representatives to ensure findings were accurate and reflected all relevant considerations and context. This counterparty-validation step was critical to producing defensible audit outcomes across 88 different organizations.

Key Deliverables

Audit Risk Assessment for CFF and IF – A documented audit risk assessment for both the Conservation First Framework wind-down and Interim Framework program delivery, developed in consultation with IESO and used to set audit priorities.

Program Requirements and Parameter Analysis – A detailed review of CFF and IF program requirements and parameters, leveraging prior IESO audit experience to inform the audit design.

CFF Audit Framework – A structured audit framework for the Conservation First Framework wind-down, covering 67 Local Distribution Companies and 9 separate program types within the $1.9 billion, 6.9 TWh program portfolio.

IF Audit Framework – A separate audit framework tailored to the Interim Framework, covering 21 service provider agreements within the $353 million, 1.4 TWh program portfolio.

LDC Audit Engagements and Findings (CFF) – Completed compliance audit engagements for 67 Local Distribution Companies under the CFF wind-down, with findings reviewed with each counterparty for accuracy and completeness.

Service Provider Audit Engagements and Findings (IF) – Completed compliance audit engagements for 21 service provider agreements under the Interim Framework, with findings reviewed with each counterparty for accuracy and completeness.

COVID-19 Adaptation Approach – Adapted audit and verification methods that preserved audit integrity through pandemic-driven delays to CFF wind-down activities and IF site verification visits.

Validated Audit Findings Across 88 Counterparties – Final, counterparty-validated audit findings delivered to IESO across the CFF and IF streams, providing structured, defensible assurance outcomes for both program portfolios.

The Impact

Bronson’s work gave IESO consistent, defensible compliance assurance across two concurrent conservation program streams, delivered across 88 counterparties of substantially different scale and operating context. Specifically, the engagement delivered:

  • Structured compliance audits of CFF wind-down activities across 67 Local Distribution Companies and 9 program types within a $1.9 billion, 6.9 TWh program portfolio.
  • Compliance audits of 21 service provider agreements under the $353 million, 1.4 TWh Interim Framework.
  • Tailored audit frameworks for both streams that accommodated substantial counterparty size and scope differences while maintaining consistent assurance standards.
  • Adapted audit and verification methods that preserved audit integrity through COVID-19 disruptions to in-program activities and site visits.
  • Counterparty-validated findings that gave IESO an accurate, complete, and defensible record of compliance outcomes across the full conservation program portfolio.

 

The result is a robust compliance picture for two of Ontario’s largest energy conservation program streams, supported by audit frameworks IESO can draw on for the design of future multi-counterparty conservation program reviews.

 

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