The RFP: How the Procurement Works

A detailed analysis of the IESO Nova Scotia Fast-Acting Generation draft RFP (March 2026) - the procurement that will determine what Nova Scotia ratepayers pay for the next 20–27 years.

Update: A Better Path Forward - Technology-Neutral RFPs

The original analysis below was written in March 2026 when I first reviewed the draft RFP. The initial focus was on the issues and mitigation: the technology lock-in, the cost risks, the confidentiality barriers. That analysis stands, and it’s kept here for the record.

But as I learned more, my view shifted. Instead of mitigation, there's a chance to look at something different. Ontario’s IESO has already run a successful technology-neutral capacity procurement - LT1 (2023–2025) and is in the midst of it's second - LT2 (2025–2026) - using a similar IESO organizational structure that now operates in Nova Scotia. The results were striking: in LT1, 10 of 13 winning projects were battery storage, delivering 1,784 MW at prices 2.5 times cheaper than the gas bids. 9 of those 10 battery projects had 50–51% Indigenous equity ownership, likely a direct result of making Indigenous participation a scored criterion rather than a non-binding checkbox.

Nova Scotia is in a rare position. The ∼2-year delay caused by the IESO-NS transition pushed the procurement timeline into a window where grid-forming batteries - which didn’t exist at transmission scale when the IRP was modelled in 2023 - are now commercially proven. Two 200–300 MW grid-forming BESS projects are operating in Scotland, providing the same grid stability services this RFP requires. NRStor has proposed a 150 MW / 600 MWh Mi’kmaq-owned facility at Trenton, NS that they say could be expanded to 300 MW / 2400 MWh. The technology has arrived. These gas plants have not been built yet. There is still time to have another look before locking in fossil fuels for 25 years.

The downloadable proposal below shows how the current draft RFP can be made technology-neutral - preserving all of IESO Nova Scotia’s existing site work, the Tolling Agreement, and the Functional Specifications, while adding a parallel Capacity Contract option modelled on Ontario’s LT2. Nothing is deleted; the gas option remains available. The market can decide which technology delivers the best value.

This is the leapfrog opportunity: Nova Scotia can skip the gas peaker era entirely and go straight to the technology mix that Ontario discovered through competitive procurement. Same timeline. Same grid reliability. Lower long-term cost. No 25-year fossil fuel lock-in.

Read the Technology-Neutral RFP Proposal (PDF)    The Leapfrog Opportunity (1-page summary)

What Is a Tolling Agreement?

The RFP uses a tolling agreement - a contract structure where the plant operator receives a fixed monthly payment whether or not the plant generates any electricity. On top of that, every dollar spent on fuel is passed through to ratepayers at 100%. The operator bears no fuel price risk; ratepayers bear all of it.

Source
Draft Tolling Agreement v1.1, March 11, 2026, Articles 4 and 5. The payment formula appears in Section 4.1.

Under the tolling structure, the monthly payment to the plant operator consists of:

Source
Draft Tolling Agreement v1.1, Section 4.1 (Monthly Payment formula): Monthly Payment = Fixed Capacity Payment + Variable O&M + Synchronous Condenser Payment − Dispatch Non-Performance Charge + Gas Interconnection Adder. Fuel Reimbursement is separate under Section 5.

The Fixed Capacity Payment is partially indexed to inflation: 20% is adjusted annually by CPI, with the remaining 80% fixed. The contract term is 20 years from Commercial Operation Date, but IESO can unilaterally extend it to 26–27 years without the generator's consent.

Source
Draft Tolling Agreement v1.1, Section 1.1 (definitions of Fixed Capacity Price, CPI indexing), Section 9.1(b) (unilateral extension to 26th anniversary), Section 9.1(c) (further extension to 27th anniversary - automatic unless generator objects within 10 business days).
The operator's profit is guaranteed

The Fixed Capacity Payment covers the generator's capital recovery, return on equity, and fixed O&M - paid monthly regardless of dispatch. The generator gets paid whether the plant runs 0 hours or 8,760 hours in a year. The minimum availability threshold before a default is triggered is only 70% (12-month rolling average).

Source
Draft Tolling Agreement v1.1, Section 6.3 (availability requirements and default thresholds).

Cost Structure: What Ratepayers Will Pay

The actual bid prices will not be made available to the public. IESO members have stated that they don't want to influence the bid process by even suggesting how much it should cost, but this seems to be a deflection to keep the public reaction manageable. However, the cost structure and order of magnitude can be estimated from publicly available data on North American gas peaker capacity pricing. Ratepayers deserve to know the full costs before making decisions!

$12–21M
Estimated monthly capacity payments for both plants combined
Based on $20,700–34,500/MW-month (industry range for new NA peakers, converted from USD at 1.38)
$149–248M
Estimated annual capacity payments (both plants)
Monthly estimate × 12
$3.7–6.2B
Estimated capacity payments over 25-year contract
Before any fuel costs or interconnection charges

These capacity payments are what ratepayers owe before a single MWh is generated. Here is a list of costs that ratepayers will pay:

Cost Component Who Pays Details
Fixed Capacity Payment Ratepayers Paid monthly whether or not the plant runs. CPI-indexed (20%). Up to 27 years.
All Fuel Costs Ratepayers (100% pass-through) Natural gas and light fuel oil. If gas prices spike, ratepayers cover the increase.
Variable O&M Ratepayers Per-MWh charge when the plant generates electricity.
Electrical Interconnection Overruns Ratepayers Estimated at $12M per site; any cost above estimate passed through at $35/MW-month.
Gas Interconnection Ratepayers Regulated gas distribution connection costs, passed through via GIC Adder.
Carbon Pricing Ratepayers Fuel combustion carbon costs are embedded in fuel pass-through. As carbon price rises, costs increase.
Source
Draft Tolling Agreement v1.1: Section 4.1 (monthly payment formula), Section 5 (fuel reimbursement), Section 4.5 (Electrical Interconnection Cost Adjustment, $12M estimate, $35/MW-month pass-through), Section 4.4 (GIC Adder), Section 7.1 (Performance Security at $50,000/MW).
Ratepayers bear all the risk

Fuel price risk, carbon price risk, and construction cost overruns for interconnection are all borne by ratepayers. The generator's Fixed Capacity Payment guarantees its return regardless of how often the plant runs, how much fuel costs, or how high the carbon price goes.

Land Conveyance

The two sites have different land arrangements:

Source
Draft Tolling Agreement v1.1, Section 13.3(b): conveyance of IESO Owned Lands for $1.00 within 30 days of COD; assignment of Head Lease "[to be included only for Salt Springs]." Appendix C, Form of Lease, footnote 3: "Rent will be $1 for Marshdale and the amounts payable under the Coady lease for Salt Springs."

Pre-determined, Not Competitive

Unlike a typical energy procurement, this RFP does not invite proposals for the best available project. The key parameters are locked in advance.

Sites

Only Two Sites Allowed

The RFP names exactly two sites: Marshdale and Salt Springs. These are not suggested - they are the only permitted locations. The Proposal Workbook has columns pre-labelled "Marshdale Site" and "Salt Springs Site." No alternative sites may be proposed.

Bidders

One Bidder Can Take Both

The Economic Bid Statement allows three offer types: Single Project (one site), Independent Project (separate bids for each), or Combined Project (a package deal for both at a discount). One company can lock up all 600 MW of fossil fuel capacity.

Technology

Fossil Fuels Only

Only gas turbines (CT) or reciprocating internal combustion engines (RICE) are eligible. Natural gas is the primary fuel; light fuel oil is secondary. Battery storage, demand response, and renewable alternatives are not eligible.

Innovation

"Proven" Tech Requirement

Proponents must demonstrate 3+ North American examples of their proposed technology operating before January 1, 2021. This excludes newer clean energy technologies that could provide the same grid services.

Transition

Non-Binding "Clean Pathway"

Proponents must describe a "pathway to future operation without fossil fuels" but face no binding requirement, timeline, or penalty for never following through. NS Power's own IRP rejected hydrogen-enabled generation as uneconomic.

Consultation

Feedback for Bidders, Not Public

The draft RFP feedback period (March 11-30) was designed for prospective bidders, not the public. There is no formal mechanism in the RFP for community input to affect the procurement terms.

Source
Draft RFP v1.0, March 10, 2026: Section 2.1 (Identified Sites), Section 4.2 (Offer Types). Exhibit T Functional Specifications (Hatch Engineering, Rev. 2, Feb 2026): Section 1 (eligible technologies), Table 3-1 (performance requirements). Economic Bid Statement template (offer type options). Proposal Workbook template (pre-labelled site columns).

The RFP asks proponents to "Describe the Proposed Project's pathway to future operation without the use of fossil fuels." This sounds forward-looking, but it is purely descriptive - there is no binding requirement, timeline, or penalty for failing to transition away from fossil fuels. It is a narrative exercise embedded in a 25-year fossil fuel contract.

Source
Draft RFP v1.0, Proposal Description template (pathway question). No corresponding binding provision exists in the Draft Tolling Agreement v1.1.

Confidentiality: The $20,000 Paywall

The RFP creates multiple layers of information restriction that prevent the public from knowing what these plants will cost and what environmental data exists for the sites.

Three Barriers to Public Information

To access site-specific data - including aquifer investigation results, geotechnical reports, and land deal terms - a party must clear three barriers:

Barrier What It Requires Effect
1. Register as a Proponent Submit a Registration Form identifying the party as a prospective bidder Community groups, journalists, and environmental organizations cannot access the data unless they register as entities intending to bid
2. Pay $20,000 + HST Non-refundable payment by electronic funds transfer to IESO Nova Scotia Even if you pay and don't bid, you don't get the money back
3. Accept Binding Confidentiality All information received can only be used "for the purpose of replying to this RFP" and must not be disclosed Even if a community group registered and paid, they could not share the data with the community, media, or public
Source
Draft RFP v1.0: Section 3.4 (Registration and Proposal Package Fee of $20,000 + HST), Section 3.10 (confidentiality obligation - information "is not to be used for any purpose other than replying to this RFP" and "must not be disclosed without the prior written authorization of IESO Nova Scotia"), Section 3.6 (media gag - proponents must not communicate with media without written IESO permission).
No public interest carve-out

There is no provision anywhere in the RFP that allows non-proponent access, community access, freedom of information requests, or any other mechanism for the public to obtain the site data. The only path to the aquifer test results runs through registration as a bidder, $20,000, and a binding confidentiality obligation that prohibits sharing the information.

What Is Behind the Paywall

The Proposal Package Information (Appendix D of the RFP) includes, for each site:

Document Public Interest Accessible?
Aquifer investigation results Determines groundwater impact on neighbouring wells and watercourses Behind paywall
Geotechnical report (test pits, boreholes, lab results) Determines site suitability and foundation design Behind paywall
Option to Purchase/Lease agreements Terms of public land deals Behind paywall
Land control cost spreadsheet What public money has already been spent Behind paywall
Summary of community engagement What the community was told and when Behind paywall
Environmental Assessment Registration Documents Environmental impact analysis Public (NS Environment website)
Source
Draft RFP v1.0, Appendix D (Proposal Package Information list). The EARDs are noted in the RFP as "publicly available prior to this package."

The aquifer investigation results are directly relevant to community concerns about groundwater. The public EARDs contain only a desktop-level water resources assessment. Both EARDs state that "an aquifer test well and pump test will be completed in December 2025" - but whether those field results are behind the paywall, or whether the tests were never conducted, cannot be determined from public information.

Source
Marshdale EARD (Hatch, Appendix D): describes its groundwater analysis as "a high-level desktop study." Both EARDs reference planned December 2025 pump tests to "confirm yield."

Permanent Price Secrecy

Even after the contract is signed, the actual price ratepayers pay remains hidden. Exhibit B of the Tolling Agreement - titled "Contract Capacity, Fixed Capacity Payment, and Other Stated Variables" - is classified as Mutually Confidential Information. Article 8 protects it with confidentiality obligations that survive termination of the agreement, with injunctive relief available without proving damages.

Source
Draft Tolling Agreement v1.1: Exhibit B (Mutually Confidential Information), Article 8 (Confidentiality), Section 8.4 (injunctive relief). The agreement and lease may be published, but Exhibit B pricing terms are excluded.
Unusual in Canadian procurement

Ontario's IESO publishes individual contract prices for electricity procurements. Alberta and BC allow companies to propose their own sites competitively. The combination of pre-determined sites, a $20,000 paywall for site data, and permanent pricing confidentiality is unusual among Canadian electricity procurements.

Technology Lock-in: Fossil Fuels by Design

The RFP's functional specifications do not just require fossil fuels - they are calibrated to exclude the cheapest fossil fuel technology, steering the procurement toward more expensive options.

How the Specifications Eliminate the Cheapest Option

Three types of peaker technology exist worldwide. All three burn fossil fuels, but they differ substantially in cost and performance:

Metric Frame CT (Heavy-Duty) Aero CT (e.g., GE LM6000) RICE (e.g., Wartsila 50SG)
Typical 300 MW config 1–2 units 6 units at ~50 MW each 15–16 units at ~19 MW each
Capital cost ($/kW) ~$984 ~$1,622 ~$1,380–1,656
Cold start to full load 15–20 min ~10 min 2–5 min
Fuel efficiency ~37% ~40% ~45%
Min. stable load 40–50% 40% 10%
Meets <10 min start? No At the limit Yes
Source
Capital cost: US EIA Capital Cost and Performance Characteristics and Gas Turbine World 2025, converted to CAD at 1.38. RICE at scale: Power Engineering Magazine, AGL Barker Inlet 210 MW (Australia, 2019). Cold start times: industry standard for Frame CT; GE Vernova product specification for LM6000; Wartsila and Power Engineering for RICE.

The RFP's functional specifications (Exhibit T, Hatch Engineering) require cold start to full power in under 10 minutes. Frame CTs — the cheapest technology at ~$984/kW — require 15–20 minutes and cannot meet this requirement. The cheapest option is excluded.

The RFP does not explain why the cold start threshold was set at <10 minutes rather than <15 or <20 minutes. A 15-minute threshold would have included Frame CTs and given ratepayers access to the lowest-cost technology. No reference is made to any grid stability study or system operator requirement that mandates the specific 10-minute threshold.

Source
Exhibit T Functional Specifications (Hatch Engineering, Rev. 2, Feb 2026), Table 3-1: Cold Start and Ramp Up Time to Full Power <10 Minutes. No grid stability justification for this specific threshold appears in any published RFP document.

The 25-Year Lock-in

Whatever technology is chosen, it is locked in for the contract term. The timeline directly contradicts Canada's climate commitments:

Milestone Year
Estimated Commercial Operation Date 2029
Federal Clean Electricity Regulations target 2035
NS Environmental Goals and Climate Change Reduction Act target (80% below 2005) 2030
Initial contract term ends 2049
Canada net-zero target 2050
IESO unilateral extension limit 2055–2056
Lease renewal limit (four 5-year renewals) 2069
Source
Draft Tolling Agreement v1.1: Section 9.1(b)–(c) (contract extensions). Appendix C, Form of Lease, clause 6(a) (four 5-year automatic renewals). NS Environmental Goals and Climate Change Reduction Act, S.N.S. 2021, c. 20. Clean Electricity Regulations, SOR/2024-263.
Citing the clean electricity regulation to build fossil fuel plants

Section 10.2(f) of the Tolling Agreement explicitly references the Clean Electricity Regulations (SOR/2024-263) - the federal regulation requiring net-zero electricity - as justification for IESO to step in and build the plant itself if the generator delays construction. The regulation intended to drive clean electricity is being cited to accelerate fossil fuel construction.

Source
Draft Tolling Agreement v1.1, Section 10.2(f).

How Other Canadian Procurements Work

The IESO NS RFP is unusual among Canadian electricity procurements in several respects:

Feature IESO NS RFP Typical Canadian Practice
Price transparency Exhibit B is permanently confidential; pricing sealed even after contract signing Ontario IESO publishes individual contract prices for electricity procurements
Site selection Two sites pre-determined (Marshdale and Salt Springs); no alternatives allowed Alberta and BC allow companies to propose their own sites competitively
Technology eligibility Only gas turbines or RICE; no clean energy alternatives Many Canadian procurements are technology-neutral or include storage/renewables
Site data access $20,000 paywall with binding confidentiality; no public interest carve-out Environmental and site data typically accessible through provincial EA processes
Market concentration One bidder can win both 300 MW sites (600 MW total) Procurements typically limit single-bidder concentration to preserve competition
Source
Ontario IESO contract disclosure: IESO publishes contract details including pricing for large renewable and gas procurements. Alberta Utilities Commission and BC Hydro procurement processes allow proponent-selected sites. Comparisons based on publicly available procurement frameworks.

Summary

Nova Scotia ratepayers are being asked to sign an estimated $3–5 billion, 20–27 year contract to pay a private company for two fossil fuel plants that:

  1. Lock in fossil fuel dependency past Canada's 2050 net-zero target, with lease renewals extending to 2069
  2. Pass all fuel and carbon price risk to ratepayers while guaranteeing the operator's profit
  3. Were pre-determined at specific sites without a published competitive alternatives analysis
  4. Exclude all clean energy alternatives by design - only gas turbines and RICE engines are eligible
  5. Exclude the cheapest fossil fuel technology through a start-time specification with no published justification
  6. Transfer public land (Marshdale) to a private company for $1.00, and assign an existing lease (Salt Springs)
  7. Shield cost details from public scrutiny through permanent confidentiality provisions
  8. Lock public-funded environmental data behind a $20,000 paywall with binding non-disclosure
The RFP is still in draft

All documents analyzed here are dated March 10–11, 2026 and stamped "DRAFT." The Tolling Agreement contains numerous "[Note to Finalization]" markers showing it is still being negotiated. A feedback form was released alongside the draft. The terms are not yet final.

Source
All analysis on this page is based on the following publicly available draft documents: Draft RFP v1.0 (March 10, 2026), Draft Tolling Agreement v1.1 (March 11, 2026), Exhibit T Functional Specifications (Hatch Engineering, Rev. 2, Feb 2026), Appendix C Form of Lease, Economic Bid Statement template, and Proposal Workbook template. Cost estimates use US EIA AEO2020 capital cost data and typical North American peaker capacity pricing ranges.