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Pouya LajevardiandClaude Opus 5 6aaf089b05 feat: rule Q62 by stating the truth; strike the /med-arb/ gloss; re-stamp R18 
Pouya's four rulings of 2026-09-01, applied 2026-09-02.

Q62 — RULED "state the truth", not "remove the access". /legal/privacy/
now says two people can read the intake table, names their role, and adds
the two stronger facts the false sentence had crowded out: the handler
role holds PutItem only, and adr-sml-deploy is implicitDeny on all seven
read and write actions. Wording is subject to Pouya's read-through —
Q63(a), with a TODO(pouya) beside the copy.

The ruling named one sentence; a vocabulary sweep found the falsehood in
three places, and the audit then found two more. Five paragraphs now
answer "who can see it" and change together.

The tripwire stays permanently, per ruling, and grew from two
alternatives to five. Every alternative is one string that reached dist/.
Proven both ways against the pre-correction page rebuilt from bd282aa:
exit 1 with 5 matches at dist/legal/privacy/index.html:54,67,67,68,72;
exit 0 on the corrected page, self-test 12 patterns / 36 approved
strings.

/med-arb/ — the gloss is struck with no replacement, per ruling. The
strike left "the section above" pointing at the ADRIC rule set and "the
agreement" with no antecedent; both fixed. The bare designations line
sitting under ADRIC's quoted competence requirement is also struck, which
goes beyond the ruling and is flagged for Pouya.

R18 — re-stamped, two-tier: (a)(c)(d) re-verified against a source,
(b)(e)(f)(g) held on a cadence judgement. All seven hold, no shipped
sentence changed. R18's trigger had NO cutover checklist item and had
stamped five extracts of seven; both fixed. Candidate limb (h) flagged.

R10 — fired and unsatisfied; left open on instruction.

The evidence behind the new privacy sentence was weaker than the
sentence. Re-measured: 33 of 33 roles simulated (23 of 26 carried inline
policies nobody had read; the two CDK lookup roles can read the table),
four trust policies, the CloudFormation escalation path for all five
users, 0 federated providers, root recorded. Every read path terminates
at the same two people.

Two review rounds, 36 findings. 35 fixed, 1 declined. Five of round 2's
were defects in round 1's own fixes; stopped at two per D19.

Co-Authored-By: Claude Opus 5 (1M context) <noreply@anthropic.com>
Claude-Session: https://claude.ai/code/session_01Md3GndFqWPzK78xAoebsg5
2026-09-02 07:59:50 -04:00

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# Ontario energy — OEB leave to construct, IESO connection assessment, Bill 40 and the data-centre regime
Committed under AGENTS.md R14 and the CLAUDE.md rule it encodes: **anything a
spec makes a claim about must be reachable from the repository.** Every fact
the six `/practice/*` pages state about the world is checkable here or it is
not published.
**Retrieved 2026-08-29.** Fetched from the primary sources listed below and
extracted with quotations pasted verbatim. This file is the artefact; the pages
cite it. Do not paraphrase a fact into a page that is not stated here.
> ⚠️ **A statute, a regulation and a tribunal page all move.** Every consolidation
> date and effective date below is as at the retrieval date and nothing more.
> Re-check before cutover, and before any republish that turns on one of them.
> ### R18 re-check — cutover pass, 2026-09-01
>
> The trigger fired. `AGENTS.md` §12 R18 holds the per-limb findings and
> the sources; this stamp does not restate them. **The quoted bytes below
> are still the original retrieval and were not re-fetched** — what was
> re-checked is whether the *facts* they support have moved.
>
> - **(c) ERO 026-0853 — RE-VERIFIED UNMOVED** `[re-checked 2026-09-01 —
> Pouya]`. The comment period to 2026-09-12 is still open.
> - **(b) the regulation under `Electricity Act` s. 28.1 — NOT RE-RETRIEVED.**
> Held unchanged on a cadence judgement rather than a fresh retrieval
> `[assumed 2026-09-01 — Pouya: unchanged by its nature at this cadence]`.
> That is a weaker stamp than (c) and is written weaker on purpose.
**Topic as researched:** Ontario electricity/energy regulatory processes that generate disputes: OEB leave to construct (OEB Act, 1998 ss. 90/92/95/96), the IESO and market participation, the IESO connection assessment process (SIA/CIA), large-load and data-centre grid connection (Electricity Act, 1998 s. 28.1), and Ontario Bill 40
---
## Sources
| Kind | Source | URL |
|---|---|---|
| statute | Ontario Energy Board Act, 1998, S.O. 1998, c. 15, Sched. B — e-Laws (ontario.ca), Government of Ontario | <https://www.ontario.ca/laws/statute/98o15> |
| statute | Electricity Act, 1998, S.O. 1998, c. 15, Sched. A — e-Laws (ontario.ca), Government of Ontario | <https://www.ontario.ca/laws/statute/98e15> |
| regulation | O. Reg. 161/99: DEFINITIONS AND EXEMPTIONS, under the Ontario Energy Board Act, 1998 — e-Laws (ontario.ca) | <https://www.ontario.ca/laws/regulation/990161> |
| regulator | Leave to construct applications for priority transmission projects — Ontario Energy Board | <https://www.oeb.ca/applications/applications-oeb/leave-construct-applications-priority-transmission-projects> |
| regulator | Natural Gas Facilities Handbook — Ontario Energy Board | <https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/natural-gas-facilities-handbook> |
| institution | Managing the Power System — IESO (Independent Electricity System Operator). Requested as https://www.ieso.ca/en/Learn/About-the-IESO/What-We-Do, which redirects here. | <https://ieso.ca/Learn/Ontario-Electricity-Grid/Managing-the-Power-System> |
| institution | Overview of the Connection Process — IESO | <https://www.ieso.ca/Sector-Participants/Connection-Process/Overview> |
| institution | Stage 2 – Obtain conditional approval to connect — IESO | <https://www.ieso.ca/Sector-Participants/Connection-Process/Obtain-Approval> |
| institution | Stage 4 – Authorize market and program participation — IESO | <https://www.ieso.ca/en/Sector-Participants/Connection-Process/Authorize-Market-and-Program-Participation> |
| institution | Frequently Asked Questions - Connection Process — IESO | <https://www.ieso.ca/Sector-Participants/Connection-Process/Frequently-Asked-Questions> |
| statute | Bill 40, Protect Ontario by Securing Affordable Energy for Generations Act, 2025 — Legislative Assembly of Ontario | <https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40> |
| statute | Bill 40 (44th Parliament, 1st Session) — Status — Legislative Assembly of Ontario | <https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40/status> |
| statute | Bill 40, Moving Ontarians Safely Act, 2023 — Legislative Assembly of Ontario | <https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-40> |
| statute | Bill 40, Support for Adults in Need of Assistance Act, 2021 — Legislative Assembly of Ontario | <https://www.ola.org/en/legislative-business/bills/parliament-42/session-2/bill-40> |
| regulator | Economic and Strategic Assessment Framework for New Data Centres — Environmental Registry of Ontario (ERO 026-0853), Ministry of Energy and Mines | <https://ero.ontario.ca/notice/026-0853> |
| regulator | New Requirements for Data Centres Seeking to Connect to the Electricity Grid in Ontario — Environmental Registry of Ontario (ERO 025-1001), Ministry of Energy and Mines | <https://ero.ontario.ca/notice/025-1001> |
| regulator | Distribution System Code (DSC) — Ontario Energy Board | <https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/distribution-system-code-dsc> |
---
## Verbatim quotations
### Ontario Energy Board Act, 1998, S.O. 1998, c. 15, Sched. B — e-Laws (ontario.ca), Government of Ontario
<https://www.ontario.ca/laws/statute/98o15> — retrieved 2026-08-29
> Ontario Energy Board Act, 1998 / S.O. 1998, CHAPTER 15 / Schedule B
> Consolidation Period: From December 11, 2025 to the e-Laws currency date.
> Last amendment: 2025, c. 22, Sched. 3.
> PART VI — TRANSMISSION AND DISTRIBUTION LINES
> Definitions, Part VI — 89 In this Part, "electricity distribution line" means a line, transformers, plant or equipment used for conveying electricity at voltages of 50 kilovolts or less; ("ligne de distribution d'électricité")
> "electricity transmission line" means a line, transformers, plant or equipment used for conveying electricity at voltages higher than 50 kilovolts; ("ligne de transport d'électricité")
> "hydrocarbon line" means a pipe line carrying any hydrocarbon, other than a pipe line within an oil refinery, oil or petroleum storage depot, chemical processing plant or pipe line terminal or station; ("ligne pour hydrocarbures")
> "work" means a hydrocarbon line, electricity distribution line, electricity transmission line, interconnection or station. ("ouvrage") 1998, c. 15, Sched. B, s. 89; 2003, c. 3, s. 62.
> Leave to construct hydrocarbon line — 90 (1) No person shall construct a hydrocarbon line without first obtaining from the Board an order granting leave to construct the hydrocarbon line if, (a) the proposed hydrocarbon line is more than 20 kilometres in length; (b) the proposed hydrocarbon line is projected to cost more than the amount prescribed by the regulations; (c) any part of the proposed hydrocarbon line, (i) uses pipe that has a nominal pipe size of 12 inches or more, and (ii) has an operating pressure of 2,000 kilopascals or more; or (d) criteria prescribed by the regulations are met. 2003, c. 3, s. 63 (1).
> Exception — 90 (2) Subsection (1) applies to the relocation or reconstruction of a hydrocarbon line only if the conditions prescribed by the regulations are met. 2024, c. 16, Sched. 11, s. 1.
> Application for leave to construct hydrocarbon line or station — 91 (1) Any person may, before constructing a hydrocarbon line to which subsection 90 (1) does not apply or a station, apply to the Board for an order granting leave to construct the hydrocarbon line or station. 2024, c. 10, s. 6.
> Leave to construct, etc., electricity transmission or distribution line — 92 (1) No person shall construct, expand or reinforce an electricity transmission line or an electricity distribution line or make an interconnection without first obtaining from the Board an order granting leave to construct, expand or reinforce such line or interconnection. 1998, c. 15, Sched. B, s. 92 (1).
> Exception — 92 (2) Subsection (1) applies to the relocation or reconstruction of an existing electricity transmission line or electricity distribution line or interconnection where no expansion or reinforcement is involved only if the acquisition of additional land or authority to use additional land is necessary. 2024, c. 16, Sched. 11, s. 2.
> Route map — 94 An applicant for an order granting leave under this Part shall file with the application a map showing the general location of the proposed work and the municipalities, highways, railways, utility lines and navigable waters through, under, over, upon or across which the proposed work is to pass. 1998, c. 15, Sched. B, s. 94.
> Exemption, subs. 90 (1) or 92 (1) — 95 (1) The Board may, if in its opinion special circumstances of a particular case so require, make an order exempting any person from the requirements of subsection 90 (1) or 92 (1) without a hearing. 2024, c. 10, s. 7.
> Same, prescribed circumstances — 95 (2) The Board shall, with or without a hearing, make an order exempting a person from the requirements of subsection 90 (1) or 92 (1) if the Board is satisfied that the circumstances prescribed by the regulations have been met. 2024, c. 10, s. 7.
> Order allowing work to be carried out — 96 (1) If, after considering an application under section 90, 91 or 92 the Board is of the opinion that the construction, expansion or reinforcement of the proposed work is in the public interest, it shall make an order granting leave to carry out the work. 1998, c. 15, Sched. B, s. 96.
> Applications under s. 92 — 96 (2) In an application under section 92, the Board shall only consider the following when, under subsection (1), it considers whether the construction, expansion or reinforcement of the electricity transmission line or electricity distribution line, or the making of the interconnection, is in the public interest: 1. The interests of consumers with respect to prices and the reliability and quality of electricity service. 2. Supporting economic growth in a manner consistent with the policies of the Government of Ontario. 2009, c. 12, Sched. D, s. 16; 2021, c. 25, Sched. 19, s. 2; 2025, c. 22, Sched. 3, s. 9 (1).
> Same — 96 (3) In an application under section 92, the Board shall consider such reports, documents or other information as may be prescribed by the regulations. 2025, c. 22, Sched. 3, s. 9 (2).
> Section Amendments with date in force (d/m/y) — 2025, c. 22, Sched. 3, s. 9 (1, 2) - 11/12/2025
> Lieutenant Governor in Council, order re electricity transmission line — 96.1 (1) The Lieutenant Governor in Council may make an order declaring that the construction, expansion or reinforcement of an electricity transmission line specified in the order is needed as a priority project. 2015, c. 29, s. 16.
### Electricity Act, 1998, S.O. 1998, c. 15, Sched. A — e-Laws (ontario.ca), Government of Ontario
<https://www.ontario.ca/laws/statute/98e15> — retrieved 2026-08-29
> Electricity Act, 1998 / S.O. 1998, CHAPTER 15 / Schedule A
> Consolidation Period: From April 24, 2026 to the e-Laws currency date.
> Last amendment: 2026, c. 2, Sched. 5, s. 9.
> "market participant" means a person who is authorized by the market rules to participate in the IESO-administered markets or to cause or permit electricity to be conveyed into, through or out of the IESO-controlled grid; ("intervenant du marché")
> "market rules" means the rules made under section 32; ("règles du marché")
> Objects — 6 (1) The objects of the IESO are, (a) to exercise the powers and perform the duties assigned to it under this Act, the regulations, directions, the market rules and its licence;
> (c) to direct the operation and maintain the reliability of the IESO-controlled grid to promote the purposes of this Act;
> (g) to operate the IESO-administered markets to promote the purposes of this Act;
> (l) to conduct independent planning for electricity generation, demand management, conservation and transmission;
> (l.1) to support economic growth in a manner that protects the interests of consumers;
> Prohibition — (5) The IESO shall not conduct the operations of the IESO-administered markets in any manner that, (a) unjustly advantages or disadvantages any market participant or class of market participants; or (b) is inconsistent with this Act. 2014, c. 7, Sched. 7, s. 3 (1).
> Exceptions for specified load facilities — 28.1 (1) In this section, "specified connection requirements" means, in relation to a specified load facility, (a) any conditions, requirements or limitations that the regulations specify must be met for the specified load facility to be connected or reconnected to a transmission system or distribution system, as applicable, (b) any approvals that the regulations specify must be obtained for the specified load facility to be connected or reconnected to a transmission system or distribution system, as applicable, and (c) any conditions, requirements or limitations of an approval described in clause (b); ("exigences précisées en matière de raccordement")
> "specified load facility" means a facility or class of facilities, (a) that is a data centre and that meets any criteria that may be set out in the regulations, or (b) that, (i) withdraws or would, if it were connected to a transmission system or distribution system, be expected to withdraw electricity from the IESO-controlled grid or from the distribution system of a distributor who is licensed under Part V of the Ontario Energy Board Act, 1998, (ii) has or would, if it were connected to a transmission system or distribution system, be expected to have a demand for electricity at the point of connection to the transmission system or distribution system, as applicable, that exceeds the amount prescribed by the regulations, and (iii) meets any other criteria that may be set out in the regulations. ("installation de charge précisée") 2025, c. 22, Sched. 1, s. 7.
> Connection or reconnection of specified load facilities — (2) Unless a transmitter or distributor is satisfied that the specified connection requirements have been complied with, the transmitter or distributor shall not, (a) connect a specified load facility to its transmission system or distribution system, as applicable; or (b) reconnect a specified load facility to the transmission or distribution system after the specified load facility was disconnected, in accordance with the regulations, as a result of the nonfulfillment or breach of any of the specified connection requirements. 2025, c. 22, Sched. 1, s. 7.
> Transition — (6) This section does not apply to a specified load facility in respect of which a connection request made in accordance with the Transmission System Code or the Distribution System Code issued under the Ontario Energy Board Act, 1998 was submitted to a transmitter or distributor, as applicable, before June 3, 2025. 2025, c. 22, Sched. 1, s. 7.
> Section Amendments with date in force (d/m/y) — 2025, c. 22, Sched. 1, s. 7 - 11/12/2025
> (f.0.1) defining "data centre" for the purposes of section 28.1;
> (f.0.2) prescribing criteria for the purposes of the definition of "specified load facility" in section 28.1, which may include, but are not limited to, criteria related to, (i) the geographic area in which the specified load facility is or may be located, (ii) the maximum volume of electricity that the specified load facility may withdraw at the point of connection to the transmission system or have distributed to it at the point of connection to the distribution system, as applicable, or (iii) the maximum demand for electricity that the specified load facility may have at the point of connection to the transmission system or distribution system, as applicable;
### O. Reg. 161/99: DEFINITIONS AND EXEMPTIONS, under the Ontario Energy Board Act, 1998 — e-Laws (ontario.ca)
<https://www.ontario.ca/laws/regulation/990161> — retrieved 2026-08-29
> O. Reg. 161/99: DEFINITIONS AND EXEMPTIONS, Under: Ontario Energy Board Act, 1998, S.O. 1998, c. 15, Sched. B
> ONTARIO REGULATION 161/99 — DEFINITIONS AND EXEMPTIONS — Consolidation Period: From January 1, 2024 to the e-Laws currency date. Last amendment: 376/23.
> 6.2 (1) Subsection 92 (1) of the Act does not apply to, (a) a person that constructs, expands or reinforces an electricity distribution line; (b) a person that makes an interconnection linking a distribution system with an adjacent distribution system; (c) a person that constructs or reinforces an electricity transmission line that is two kilometres or less in length; (d) a person that expands an electricity transmission line in length by two kilometres or less;
> (e) a person, other than a licensed transmitter or licensed distributor, that constructs, expands or reinforces an electricity transmission line, if the cost of the construction, expansion or reinforcement of the line is to be exclusively paid for by the person;
> (f) a person that makes an interconnection linking a transmission system with an adjacent transmission system in Ontario; or (g) a person that makes an interconnection linking a distribution system with an adjacent transmission system. O. Reg. 365/00, s. 4; O. Reg. 72/02, s. 6; O. Reg. 511/22, s. 1 (1).
### Leave to construct applications for priority transmission projects — Ontario Energy Board
<https://www.oeb.ca/applications/applications-oeb/leave-construct-applications-priority-transmission-projects> — retrieved 2026-08-29
> Section 92 of the Ontario Energy Board Act, 1998 (Act) requires transmitters and distributors to obtain approval from the OEB for the construction, expansion, or reinforcement of electricity transmission and distribution lines or interconnections.
> Section 96 (1) of the Act sets out that after the OEB considers an application under section 92, if it is of the opinion that the construction, expansion or reinforcement of the proposed work is in the public interest, it shall make an order granting leave to carry out the work.
> Under section 96.1 (1) of the Act, the Lieutenant Governor in Council may make an order declaring that the construction, expansion or reinforcement of an electricity transmission line specified in the order is needed as a priority project. Even if a transmission line is declared to be a priority project, OEB approval to build the line under section 92 of the Act is still required. However, in these cases the OEB must accept that the project is needed when forming its opinion under section 96 of the Act.
> This page identifies any leave to construct applications for priority transmission projects currently in process at the OEB.
> There are currently no leave to construct applications before the OEB for approval to build a transmission line that has been declared to be a priority project under section 96.1 of the Act.
### Natural Gas Facilities Handbook — Ontario Energy Board
<https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/natural-gas-facilities-handbook> — retrieved 2026-08-29
> The Natural Gas Facilities Handbook provides guidance related to the following application types:
> 2. Under the Ontario Energy Board Act — Section 38, Designated Storage Area Applications; Section 40, DSA Well Drilling Licence Application Referrals; Section 90 and 91, Leave to Construct Applications; Section 95, Exemption from the Requirements of Section 90 Applications; Section 99, Expropriation Applications related to Leave to Construct Approvals
> On September 24, 2024, the OEB issued new Filing Requirements applicable to applications for exemption from leave to construct applications contemplated in sections 90(2) and 95(2) of the Ontario Energy Board Act, 1998.
> On April 3, 2024, the OEB issued a letter to natural gas distributors regarding minor revisions that it has made to the standard conditions of approval typically attached to the OEB's decisions approving natural gas leave to construct applications.
### Managing the Power System — IESO (Independent Electricity System Operator). Requested as https://www.ieso.ca/en/Learn/About-the-IESO/What-We-Do, which redirects here.
<https://ieso.ca/Learn/Ontario-Electricity-Grid/Managing-the-Power-System> — retrieved 2026-08-29
> The IESO is the coordinator and integrator of Ontario's electricity system. Our system operators monitor the energy needs of the province in real time – 24 hours a day, 7 days a week – balancing supply and demand and directing the flow of electricity across Ontario's transmission lines.
> The IESO works with our partners in the electricity sector, as well as our Canadian and U.S. neighbours, to ensure that Ontario's grid operates reliably and that everyone in Ontario has access to the energy they need, when and where they need it.
> The IESO is responsible for ensuring these five pillars of electricity system reliability are met: Capacity: The ability to produce enough electricity to meet demand; Energy: The ability to produce electricity consistently over time; Transmission: The ability to distribute and deliver electricity; Operability: The ability to respond to changes in demand; Ancillary Services: Technical support that fine-tunes the electricity grid to adapt to second-by-second changes in demand.
> Because the IESO controls all dispatch instructions for the province, our system operators can ensure that Ontario's electricity suppliers are not over or under producing at any given time and that the system is running as efficiently and cost-effectively as possible.
> Copyright © 2026 Independent Electricity System Operator
### Overview of the Connection Process — IESO
<https://www.ieso.ca/Sector-Participants/Connection-Process/Overview> — retrieved 2026-08-29
> The process to connect a new facility or to modify an existing facility involves up to six stages as described below.
> New or modified connections to a transmitter's system are generally subject to all six stages, while new or modified connections to a distributor's system may only be subject to the first three.
> You are required to successfully complete all applicable stages to receive final approval to connect your new or modified facility to the electricity system and begin commercial operation.
> The entire process can take anywhere from a few months for small modifications to existing facilities, to more than three years for major modifications or to connect new facilities.
> 1. Prepare application — Planned connection of new facilities and modifications to existing facilities must be assessed to identify and mitigate any potential adverse effect on the reliability of the electricity grid and its existing customers. To ensure that the applicable processes are initiated, as a first step, please contact your transmitter or distributor.
> 2. Obtain conditional approval to connect — Your organization is required to obtain conditional approval for new or modified connections through the appropriate processes. Successful completion of the connection assessment process results in a conditional approval to connect. This stage typically takes one year.
> Transmission system connections — New connections or modifications to facilities connected to a transmitter's system are subject to the IESO's system impact assessment (SIA) and the transmitter's customer impact assessment (CIA).
> Distribution system connections — New connections or modifications to facilities connected to a distributor's system must participate in the distributor's connection assessment process. As part of this process, distributors may need to participate in the IESO's and transmitter's connection assessment processes to obtain their conditional approval to connect on your behalf.
> 4. Authorize market and program participation — To participate in the IESO-controlled grid, IESO-administered markets or programs, you must register your organization with the IESO to authorize it as a market or program participant. This stage typically takes about one month.
> 5. Register equipment — The equipment, telemetry, and metering installed at your facility must be registered and tested with the IESO. The IESO uses the data provided by market participants for the systems and models that are necessary to maintain the reliability of the IESO-controlled grid and to operate the IESO-administered markets. This stage takes at least three months.
> Successful completion of all six stages, to the satisfaction of the IESO, is required to obtain final approval to connect to the IESO-controlled grid, and start commercial operation in the IESO-administered markets.
> If you're exploring connection options and aren't ready to submit a formal request, start with our Major Projects Identification Committees (MPIC) process.
> Whether your organization is an existing or potential market participant, you can explore options for a new or modified connection with the IESO's technical feasibility study (TFS). This optional, confidential service is provided on a cost-recovery basis to identify and mitigate potential issues with various connection options, and help participants select a final connection option.
### Stage 2 – Obtain conditional approval to connect — IESO
<https://www.ieso.ca/Sector-Participants/Connection-Process/Obtain-Approval> — retrieved 2026-08-29
> If you determined during the previous stage that your organization is required to participate in the IESO's and transmitter's connection assessment and approval (CAA) process, please contact the IESO for a pre-application meeting.
> Upon receipt, the IESO will determine if the application qualifies for a system impact assessment (SIA) or an expedited system impact assessment (ESIA) and will assign a unique CAA ID.
> Step 2 – Execute the system impact assessment (SIA) agreement — After receiving your application and associated deposit for a connection assessment, the IESO will prepare an SIA agreement in accordance with section 6.1.15.3 of chapter 0.4 of the Market Rules for execution by your authorized representative.
> Step 3 – IESO completes SIA studies and produces draft report — Once you have provided all of the required information, the IESO will assess the impact of your proposed new or modified connection on the reliability of the integrated power system and issue a draft SIA report to your organization and the transmitter for review and comments.
> The transmitter generally initiates the customer impact assessment (CIA) after the draft SIA report from the IESO. A CIA agreement between the connection applicant and transmitter is also needed as part of the transmitter's CIA process.
> Step 4 – IESO issues final SIA report — After addressing comments received from your organization and the transmitter on the draft or revised draft SIA report, the IESO sends the final SIA report and one of the following to both parties: Notification of conditional approval (NoCA); Notification of disapproval with reasons (NoDR)
> The final SIA report will be published on the IESO website in the Application Status table at the end of the month in which it was finalized.
### Stage 4 – Authorize market and program participation — IESO
<https://www.ieso.ca/en/Sector-Participants/Connection-Process/Authorize-Market-and-Program-Participation> — retrieved 2026-08-29
> Your organization must be authorized by the IESO to participate in the IESO-administered markets or programs, or to connect a physical facility to the IESO-controlled grid.
> Step 1 – Register organization — If your organization is new to the IESO, you must register prior to receiving authorization. To register, your organization must submit company information and appoint mandatory contact roles using the IESO's online application form... It may take up to three weeks to complete the registration process.
> Step 2 - Authorize as a market participant — The authorized representative appoints other roles, including the applicant representative, who will be responsible for authorizing your newly registered organization as a market participant using Online IESO (the IESO's web-based registration system).
> Paying the market registration application fee $1,130 ($1,000 + 13% HST)
> Providing the following: Ontario Energy Board (OEB) licence; National Energy Permit (for energy trader – exporter only); Prudential support if your organization plans to participate in the real-time IESO-administered markets
> Step 4 – IESO issues registration approval notification — Once the above authorization tasks are completed, the IESO will issue a registration approval notification (RAN) confirming that your organization has been approved by the IESO to participate in the IESO-administered markets and programs.
### Frequently Asked Questions - Connection Process — IESO
<https://www.ieso.ca/Sector-Participants/Connection-Process/Frequently-Asked-Questions> — retrieved 2026-08-29
> FAQ - Connection Assessments — What tools and models do the IESO use for System Impact Assessments (SIAs)? The IESO uses DSA and PSSE tools to conduct SIA studies.
> Is there an expedited process available in Ontario to skip the interconnection queue, similar to the US market? The IESO is not using an "interconnection queue", instead it adopted the concept of "committed projects" that is defined in Section 3.3 of Market Manual 1.4: Connection Assessment and Approval. As such, there is no option to "skip the interconnection queue", each assessment follows the timelines described in Section 5.8 of Market Manual 1.4: Connection Assessment and Approval.
> The treatment of new renewable generation facilities is no different than any other new facility, the normal System Impact Assessment (SIA) process applies to the connection of all generation facilities, renewable or non-renewable, equally.
> Where can I find the required application forms and data requirements for submitting a connection application to the IESO? You'll need to complete Form 128 and send it via email to connection.assessments@ieso.ca to initiate the SIA process.
### Bill 40, Protect Ontario by Securing Affordable Energy for Generations Act, 2025 — Legislative Assembly of Ontario
<https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40> — retrieved 2026-08-29
> Bill 40, Protect Ontario by Securing Affordable Energy for Generations Act, 2025
> Lecce, Hon. Stephen (Minister of Energy and Mines)
> Current status: Royal Assent received. Statutes of Ontario 2025, chapter 22
> Bill 40 has been enacted as Chapter 22 of the Statutes of Ontario, 2025.
> Bill 40 2025 — An Act to amend various statutes with respect to energy, the electrical sector and public utilities
> CONTENTS — Preamble; 1. Contents of this Act; 2. Commencement; 3. Short title; Schedule 1 Electricity Act, 1998; Schedule 2 Municipal Franchises Act; Schedule 3 Ontario Energy Board Act, 1998
> Preamble — The Government of Ontario is committed to: Building an affordable, secure, reliable and clean energy system to power the strongest economy in the G7. Prioritizing economic growth, job creation and strong governance as objectives of Ontario's energy system. Supporting the responsible growth of energy-intensive industries like data centres that align with Ontario's economic priorities and benefit local communities. Keeping our energy supply secure by supporting the sector with the implementation of limitations on foreign participation in Ontario's energy sector. Delivering affordable and clean energy for generations to power our economy and peoples' lives.
> Short title — 3 The short title of this Act is the Protect Ontario by Securing Affordable Energy for Generations Act, 2025.
> SCHEDULE 1 ELECTRICITY ACT, 1998 ... 4. New section 28.1 is added to the Act. It provides that transmitters or distributors shall not connect or reconnect certain load facilities from its transmission system or distribution system unless connection requirements that are specified in the regulations are met. Complementary amendments are made to the regulation-making authority in section 114.
> SCHEDULE 3 ONTARIO ENERGY BOARD ACT, 1998 ... 5. Section 96 of the Act is amended in respect of applications under section 92 of the Act (leave to construct, etc., electricity transmission or distribution line). Economic growth is added to the list of matters the Board is permitted to consider when deciding whether granting leave is in the public interest. As well, the Board is required to consider reports, documents or other information that may be specified by the regulations made under the Act in considering an application under section 92.
> SCHEDULE 3 ... 1. Subsection 1 (1) of the Act is amended to add a new objective of the Ontario Energy Board respecting economic growth in relation to the regulation of the electricity sector. 2. A new section 13.1 of the Act authorizes the Board's chief executive officer to issue internal policies respecting various procedural matters in relation to hearings and determinations.
> SCHEDULE 2 MUNICIPAL FRANCHISES ACT — ... Section 3 is re-enacted to remove the requirement for the municipal electors to assent to such a by-law and instead to require that a municipality pass a by-law setting out the terms and conditions.
### Bill 40 (44th Parliament, 1st Session) — Status — Legislative Assembly of Ontario
<https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40/status> — retrieved 2026-08-29
> Date | Bill stage | Event | Outcome | Committee
> December 11, 2025 | Royal Assent | Royal Assent received | - | -
> December 8, 2025 | Third Reading | Vote | Carried on division | -
> December 3, 2025 | Second Reading | Reported as amended | - | Standing Committee on the Interior
> November 17, 2025 | Second Reading | Ordered referred to Standing Committee pursuant to the Order of the House | - | Standing Committee on the Interior
> June 3, 2025 | First Reading | Ordered for Second Reading | - | -
> June 3, 2025 | First Reading | Vote | Carried | -
### Bill 40, Moving Ontarians Safely Act, 2023 — Legislative Assembly of Ontario
<https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-40> — retrieved 2026-08-29
> Parliament 43, Session 1 — Bill 40, Moving Ontarians Safely Act, 2023
> The Bill amends the Highway Traffic Act. It is about the legal consequences of a collision that seriously injures or kills a pedestrian, a cyclist, a mobility device user, a roadway worker, an emergency responder outside their motor vehicle or another individual listed in the Bill.
### Bill 40, Support for Adults in Need of Assistance Act, 2021 — Legislative Assembly of Ontario
<https://www.ola.org/en/legislative-business/bills/parliament-42/session-2/bill-40> — retrieved 2026-08-29
> Parliament 42, Session 2 — Bill 40, Support for Adults in Need of Assistance Act, 2021
> The Bill enacts the Support for Adults in Need of Assistance Act, 2021. The Act requires regulated health professionals to report to a board of health if they have reasonable suspicion that an individual who is 16 years of age or older is being abused or neglected.
### Economic and Strategic Assessment Framework for New Data Centres — Environmental Registry of Ontario (ERO 026-0853), Ministry of Energy and Mines
<https://ero.ontario.ca/notice/026-0853> — retrieved 2026-08-29
> Economic and Strategic Assessment Framework for New Data Centres — ERO number 026-0853 — Notice type: Regulation — Posted by: Ministry of Energy and Mines — Notice stage: Proposal — Proposal posted: August 13, 2026 — Comment period: August 13, 2026 - September 12, 2026 (30 days) Open — Last updated: August 13, 2026
> This consultation closes at 11:59 p.m. on: September 12, 2026
> To ensure responsible data centre growth, the government introduced legislative amendments to the Electricity Act, 1998 that provide the Lieutenant Governor in Council the authority to set out in regulation requirements that data centres covered by the regulation must meet before connecting or re-connecting to the electricity grid.
> Data centres that do not meet these requirements would not be able to connect (or re-connect) to the electricity grid. The province is considering drafting a proposed regulation that, if approved, would require new large data centres to obtain the approval of the government to connect or reconnect to the electricity grid.
> To guide such approvals and attract the best data centre investments that drive economic growth, ensure Canadians' data remains in Canada and deliver significant and meaningful benefits to local communities, Ontario is proposing a Data Centre Playbook.
> Assessing proposed data centres against these pillars could form part of the broader proposed regulatory data centre connection process requiring connection approval by the government, alongside other considerations related to electricity system reliability, technical feasibility and cost responsibility.
> Pillar 1: Advance Economic Development ... Pillar 2: Protect Data Security and Digital Sovereignty ... Pillar 3: Invest in Communities and Earn Public Trust
> The government is therefore exploring amendments to Ontario Regulation 429/04 under the Electricity Act, 1998 that would establish a new separate rate Class (e.g., Class C) for new data centres above a specific demand threshold (e.g., 1 MW). Facilities in this rate class would not be eligible to participate in the Industrial Conservation Initiative (ICI), a demand response program for large electricity customers.
> In addition, there are a significant number of data centres that have applied for connections. MEM estimates these proposals could total more than 10,000 MW cumulatively.
### New Requirements for Data Centres Seeking to Connect to the Electricity Grid in Ontario — Environmental Registry of Ontario (ERO 025-1001), Ministry of Energy and Mines
<https://ero.ontario.ca/notice/025-1001> — retrieved 2026-08-29
> New Requirements for Data Centres Seeking to Connect to the Electricity Grid in Ontario — ERO number 025-1001 — Notice type: Regulation — Posted by: Ministry of Energy and Mines — Notice stage: Proposal Updated — Proposal posted: September 5, 2025 — Comment period: September 5, 2025 - November 4, 2025 (60 days) Closed — Last updated: September 8, 2025
> The Ministry of Energy and Mines (MEM) introduced amendments to the Electricity Act, 1998 as part of Bill 40. If passed, the government is proposing to set out in regulation a process that will allow the Minister of Energy and Mines to prioritize and approve connection requests from data centre projects that serve the province's economic interests.
> The proposal contemplates implementing an approval process for connection requests of data centres covered by the proposed regulation.
> If the legislation passes, the proposed regulation will require covered data centre projects to receive approval from the Minister of Energy and Mines to connect to the provincial electricity grid.
> The data centre sector is forecast to represent about 13 per cent of new electricity demand in the province by 2035.
> The government is seeking input on the types of data centres that would be subject to the proposed requirement, including the electrica[l]
### Distribution System Code (DSC) — Ontario Energy Board
<https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/distribution-system-code-dsc> — retrieved 2026-08-29
> Distribution System Code (DSC) — Sets out the minimum obligations that a licensed electricity distributor must meet in carrying out its obligations to distribute electricity within its service area under its licence.
> Last revised August 1, 2026
> Appendix I - Methodology for Implementing a Capacity Allocation Model (pdf)
> 40. Amendment to introduce Capacity Allocation Model (CAM) to facilitate housing development connections and to create Appendix I to set out the CAM methodology. This change came into force on September 16, 2025 (EB- 2024-0092).
> DER Connection Procedures (DERCP) - Version 3.0 (issued December 18, 2025, came into force on May 1, 2026)
> Electric Vehicle Charging Connection Procedures (EVCCP)
---
## What this establishes
Each item names the source it rests on. An item here that no quotation above
supports is a defect in this file, not a fact.
- LEAVE TO CONSTRUCT — electricity: s. 92 (1) of the Ontario Energy Board Act, 1998 is the leave-to-construct provision for electricity lines. Operative words: "No person shall construct, expand or reinforce an electricity transmission line or an electricity distribution line or make an interconnection without first obtaining from the Board an order granting leave to construct, expand or reinforce such line or interconnection."
*Source:* <https://www.ontario.ca/laws/statute/98o15>
- LEAVE TO CONSTRUCT — hydrocarbon pipeline: s. 90 (1) is the separate leave-to-construct provision for hydrocarbon lines. Operative words: "No person shall construct a hydrocarbon line without first obtaining from the Board an order granting leave to construct the hydrocarbon line if," followed by four triggers — more than 20 km in length; projected cost above the prescribed amount; any part using pipe of nominal size 12 inches or more AND operating at 2,000 kilopascals or more; or criteria prescribed by the regulations. So s. 90 is threshold-based while s. 92 is not.
*Source:* <https://www.ontario.ca/laws/statute/98o15>
- Both provisions sit in Part VI of the Act ("TRANSMISSION AND DISTRIBUTION LINES"). Section 89 defines "electricity transmission line" as conveying electricity above 50 kilovolts, "electricity distribution line" as 50 kilovolts or less, and "hydrocarbon line" as a pipe line carrying any hydrocarbon other than one within a refinery, storage depot, chemical processing plant or pipe line terminal or station.
*Source:* <https://www.ontario.ca/laws/statute/98o15>
- The public-interest test is in s. 96 (1): if the Board "is of the opinion that the construction, expansion or reinforcement of the proposed work is in the public interest, it shall make an order granting leave to carry out the work." For s. 92 applications, s. 96 (2) confines what "public interest" may mean to two enumerated matters: "1. The interests of consumers with respect to prices and the reliability and quality of electricity service. 2. Supporting economic growth in a manner consistent with the policies of the Government of Ontario."
*Source:* <https://www.ontario.ca/laws/statute/98o15>
- The second branch of the s. 96 (2) test — "Supporting economic growth in a manner consistent with the policies of the Government of Ontario" — and the new s. 96 (3) duty to consider prescribed reports were added by 2025, c. 22, Sched. 3, s. 9, in force 11/12/2025. The e-Laws consolidation period for the Act begins December 11, 2025 and its last amendment is 2025, c. 22, Sched. 3.
*Source:* <https://www.ontario.ca/laws/statute/98o15>
- Exemptions from leave to construct are available under s. 95: the Board "may, if in its opinion special circumstances of a particular case so require, make an order exempting any person from the requirements of subsection 90 (1) or 92 (1) without a hearing" (s. 95 (1)), and "shall" exempt where prescribed circumstances are met (s. 95 (2)). Section 94 requires a route map to be filed with the application.
*Source:* <https://www.ontario.ca/laws/statute/98o15>
- Section 96.1 (1) lets the Lieutenant Governor in Council declare a transmission line a "priority project". The OEB's own page states that even then, "OEB approval to build the line under section 92 of the Act is still required. However, in these cases the OEB must accept that the project is needed when forming its opinion under section 96 of the Act."
*Source:* <https://www.oeb.ca/applications/applications-oeb/leave-construct-applications-priority-transmission-projects>
- OEB's own description of the s. 92 process: "Section 92 of the Ontario Energy Board Act, 1998 (Act) requires transmitters and distributors to obtain approval from the OEB for the construction, expansion, or reinforcement of electricity transmission and distribution lines or interconnections."
*Source:* <https://www.oeb.ca/applications/applications-oeb/leave-construct-applications-priority-transmission-projects>
- As of retrieval on 2026-08-29, the OEB's priority-transmission page states: "There are currently no leave to construct applications before the OEB for approval to build a transmission line that has been declared to be a priority project under section 96.1 of the Act." (This is a point-in-time statement and will change.)
*Source:* <https://www.oeb.ca/applications/applications-oeb/leave-construct-applications-priority-transmission-projects>
- On the natural-gas side, the OEB publishes a Natural Gas Facilities Handbook giving guidance on, among others, "Section 90 and 91, Leave to Construct Applications", "Section 95, Exemption from the Requirements of Section 90 Applications", and "Section 99, Expropriation Applications related to Leave to Construct Approvals". On September 24, 2024 the OEB issued new filing requirements for exemption applications under ss. 90(2) and 95(2).
*Source:* <https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/natural-gas-facilities-handbook>
- O. Reg. 161/99 (Definitions and Exemptions) under the OEB Act, s. 6.2 (1), exempts several categories from s. 92 (1) — including "a person that constructs, expands or reinforces an electricity distribution line" and "a person that constructs or reinforces an electricity transmission line that is two kilometres or less in length". This is the source of the commonly cited 2 km transmission threshold; distribution lines are exempt outright by regulation notwithstanding their inclusion in s. 92 (1).
*Source:* <https://www.ontario.ca/laws/regulation/990161>
- THE IESO, in its own words: "The IESO is the coordinator and integrator of Ontario's electricity system. Our system operators monitor the energy needs of the province in real time – 24 hours a day, 7 days a week – balancing supply and demand and directing the flow of electricity across Ontario's transmission lines." It names five reliability pillars: Capacity, Energy, Transmission, Operability and Ancillary Services.
*Source:* <https://ieso.ca/Learn/Ontario-Electricity-Grid/Managing-the-Power-System>
- The IESO's statutory objects are in s. 6 (1) of the Electricity Act, 1998 and include directing the operation and maintaining the reliability of the IESO-controlled grid (cl. c), operating the IESO-administered markets (cl. g), conducting independent planning (cl. l), and — added by Bill 40 — "to support economic growth in a manner that protects the interests of consumers" (cl. l.1).
*Source:* <https://www.ontario.ca/laws/statute/98e15>
- MARKET PARTICIPATION — statutory definition: "market participant" means "a person who is authorized by the market rules to participate in the IESO-administered markets or to cause or permit electricity to be conveyed into, through or out of the IESO-controlled grid" (Electricity Act, 1998, s. 2 definitions). Section 6 (5) forbids the IESO from operating the markets in a way that "unjustly advantages or disadvantages any market participant or class of market participants".
*Source:* <https://www.ontario.ca/laws/statute/98e15>
- MARKET PARTICIPATION — operationally, per the IESO: "To participate in the IESO-controlled grid, IESO-administered markets or programs, you must register your organization with the IESO to authorize it as a market or program participant." Registration runs through Online IESO, requires an OEB licence, prudential support for real-time market participation, and a market registration application fee of $1,130; it ends with the IESO issuing a "registration approval notification (RAN)".
*Source:* <https://www.ieso.ca/en/Sector-Participants/Connection-Process/Authorize-Market-and-Program-Participation>
- CONNECTION PROCESS — the IESO runs a six-stage connection process: (1) Prepare application; (2) Obtain conditional approval to connect; (3) Design and build; (4) Authorize market and program participation; (5) Register equipment; (6) Commission equipment and validate performance. "New or modified connections to a transmitter's system are generally subject to all six stages, while new or modified connections to a distributor's system may only be subject to the first three."
*Source:* <https://www.ieso.ca/Sector-Participants/Connection-Process/Overview>
- "System Impact Assessment" IS the IESO's real term, confirmed on multiple IESO pages. The IESO: "New connections or modifications to facilities connected to a transmitter's system are subject to the IESO's system impact assessment (SIA) and the transmitter's customer impact assessment (CIA)." The IESO conducts the SIA; the transmitter conducts the CIA.
*Source:* <https://www.ieso.ca/Sector-Participants/Connection-Process/Overview>
- The umbrella name for the process is the "connection assessment and approval (CAA)" process. On application the IESO "will determine if the application qualifies for a system impact assessment (SIA) or an expedited system impact assessment (ESIA) and will assign a unique CAA ID". The SIA agreement is prepared "in accordance with section 6.1.15.3 of chapter 0.4 of the Market Rules". The IESO then "will assess the impact of your proposed new or modified connection on the reliability of the integrated power system" and issues a draft, then final, SIA report accompanied by either a "Notification of conditional approval (NoCA)" or a "Notification of disapproval with reasons (NoDR)".
*Source:* <https://www.ieso.ca/Sector-Participants/Connection-Process/Obtain-Approval>
- The transmitter "generally initiates the customer impact assessment (CIA) after the draft SIA report from the IESO", and a CIA agreement between the connection applicant and the transmitter is required as part of the transmitter's CIA process.
*Source:* <https://www.ieso.ca/Sector-Participants/Connection-Process/Obtain-Approval>
- Ontario does NOT operate an "interconnection queue". The IESO: "The IESO is not using an 'interconnection queue', instead it adopted the concept of 'committed projects' that is defined in Section 3.3 of Market Manual 1.4: Connection Assessment and Approval. As such, there is no option to 'skip the interconnection queue'."
*Source:* <https://www.ieso.ca/Sector-Participants/Connection-Process/Frequently-Asked-Questions>
- Connection timelines, per the IESO: stage 2 (conditional approval) "typically takes one year"; stage 4 "typically takes about one month"; stage 5 "takes at least three months"; and the whole process "can take anywhere from a few months for small modifications to existing facilities, to more than three years for major modifications or to connect new facilities."
*Source:* <https://www.ieso.ca/Sector-Participants/Connection-Process/Overview>
- LARGE LOADS / DATA CENTRES — there IS a real, in-force Ontario statutory process. Section 28.1 of the Electricity Act, 1998 ("Exceptions for specified load facilities") came into force 11/12/2025 (added by 2025, c. 22, Sched. 1, s. 7). It provides: "Unless a transmitter or distributor is satisfied that the specified connection requirements have been complied with, the transmitter or distributor shall not, (a) connect a specified load facility to its transmission system or distribution system... or (b) reconnect a specified load facility..."
*Source:* <https://www.ontario.ca/laws/statute/98e15>
- "Specified load facility" is defined in s. 28.1 (1) as a facility or class of facilities "(a) that is a data centre and that meets any criteria that may be set out in the regulations", OR (b) one that withdraws electricity from the IESO-controlled grid or a licensed distributor's system, has demand at the point of connection "that exceeds the amount prescribed by the regulations", and meets any other prescribed criteria. So the section is expressly aimed at data centres and at large loads defined by a regulated demand threshold.
*Source:* <https://www.ontario.ca/laws/statute/98e15>
- Section 28.1 (6) is a transition rule: the section "does not apply to a specified load facility in respect of which a connection request made in accordance with the Transmission System Code or the Distribution System Code issued under the Ontario Energy Board Act, 1998 was submitted to a transmitter or distributor, as applicable, before June 3, 2025" — i.e. the date Bill 40 received First Reading.
*Source:* <https://www.ontario.ca/laws/statute/98e15>
- ⚠️ **CORRECTED 2026-08-29 — "two LIVE consultations" was wrong, and the quoted notice data three sections above says so.** ERO 025-1001's comment period ran 5 September – **4 November 2025** and the notice reads **"Closed"**; only ERO 026-0853 (13 August – 12 September 2026) was open on the retrieval date. The overreach reached `src/data/practice-pages.ts` and was caught on a self-audit against this file before it shipped. The original wording of this item follows.
- ~~There are two live Ontario government consultations specifically about connecting data centres to the grid.~~ There are two Ontario government consultations specifically about connecting data centres to the grid, **one of them closed.** ERO 025-1001, "New Requirements for Data Centres Seeking to Connect to the Electricity Grid in Ontario" (Ministry of Energy and Mines, Regulation notice, Proposal, posted September 5, 2025, comment period closed November 4, 2025): "the proposed regulation will require covered data centre projects to receive approval from the Minister of Energy and Mines to connect to the provincial electricity grid."
*Source:* <https://ero.ontario.ca/notice/025-1001>
- ERO 026-0853, "Economic and Strategic Assessment Framework for New Data Centres" (Ministry of Energy and Mines, Regulation notice, Proposal, posted August 13, 2026, comment period August 13 – September 12, 2026, OPEN as at 2026-08-29). It proposes a "Data Centre Playbook" and a three-pillar assessment (Advance Economic Development; Protect Data Security and Digital Sovereignty; Invest in Communities and Earn Public Trust), and separately proposes "amendments to Ontario Regulation 429/04 under the Electricity Act, 1998 that would establish a new separate rate Class (e.g., Class C) for new data centres above a specific demand threshold (e.g., 1 MW)", whose facilities "would not be eligible to participate in the Industrial Conservation Initiative (ICI)".
*Source:* <https://ero.ontario.ca/notice/026-0853>
- As at August 13, 2026 the connection-approval regulation under s. 28.1 was still prospective in the Ministry's own words: "The province is considering drafting a proposed regulation that, if approved, would require new large data centres to obtain the approval of the government to connect or reconnect to the electricity grid."
*Source:* <https://ero.ontario.ca/notice/026-0853>
- BILL 40 — the energy Bill 40 is Bill 40 of the 44th Parliament, 1st Session: "Protect Ontario by Securing Affordable Energy for Generations Act, 2025", sponsored by Hon. Stephen Lecce (Minister of Energy and Mines). Long title: "An Act to amend various statutes with respect to energy, the electrical sector and public utilities". Status: "Royal Assent received. Statutes of Ontario 2025, chapter 22". It has three schedules: Electricity Act, 1998; Municipal Franchises Act; Ontario Energy Board Act, 1998.
*Source:* <https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40>
- Bill 40 (44-1) timeline: First Reading June 3, 2025; referred to the Standing Committee on the Interior November 17, 2025; reported as amended December 3, 2025; Third Reading vote carried on division December 8, 2025; Royal Assent December 11, 2025.
*Source:* <https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40/status>
- Bill 40's preamble names data centres expressly: the Government of Ontario is committed to "Supporting the responsible growth of energy-intensive industries like data centres that align with Ontario's economic priorities and benefit local communities."
*Source:* <https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40>
- Bill 40 is the direct link between the two topics above: its Schedule 1 added Electricity Act s. 28.1 (data centre / large load connection requirements) and its Schedule 3 amended OEB Act s. 96 so that "Economic growth is added to the list of matters the Board is permitted to consider when deciding whether granting leave is in the public interest" on a s. 92 leave-to-construct application, and required the Board to consider prescribed reports and documents.
*Source:* <https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40>
- THE TRAP CONFIRMED — "Bill 40" is reused every parliament and most Bill 40s are unrelated to energy. Two verified non-energy examples: Bill 40 of the 43rd Parliament, 1st Session is the "Moving Ontarians Safely Act, 2023", amending the Highway Traffic Act; and Bill 40 of the 42nd Parliament, 2nd Session is the "Support for Adults in Need of Assistance Act, 2021", on reporting abuse or neglect of adults. Only the 44-1 Bill 40 is the energy bill. Any reference to "Bill 40" in an Ontario energy context must be cited as Bill 40, 44th Parliament, 1st Session / S.O. 2025, c. 22.
*Source:* <https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-40>
- A real Ontario term adjacent to "connection allocation" is the OEB's "Capacity Allocation Model (CAM)" in the Distribution System Code: DSC amendment 40 "introduce[d] Capacity Allocation Model (CAM) to facilitate housing development connections and to create Appendix I to set out the CAM methodology. This change came into force on September 16, 2025 (EB- 2024-0092)." The DSC also carries DER Connection Procedures (DERCP) and Electric Vehicle Charging Connection Procedures (EVCCP).
*Source:* <https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/distribution-system-code-dsc>
---
## What this does NOT establish
**Read this section before writing copy.** It is the half that keeps a page
honest, and on this project it is the half that has twice been skipped.
- **Is "connection allocation" an actual Ontario term of art for the process by which a generator or large load gets grid access?**
- *Searched:* Full-text grep for "allocation" and "connection allocation" across all four IESO pages fetched (Connection Process Overview, Stage 2 Obtain Approval, Stage 4 Authorize Participation, Connection Process FAQ); plus WebSearch for '"connection allocation" Ontario electricity IESO OEB'.
- *Outcome:* NOT ESTABLISHED — zero hits for "allocation" of any kind in the IESO connection-process pages. Do not use "connection allocation" as an Ontario term. The correct terms, all verified above, are: connection assessment and approval (CAA), System Impact Assessment (SIA, by the IESO), Customer Impact Assessment (CIA, by the transmitter), and Notification of Conditional Approval (NoCA). A distinct and real OEB term is "Capacity Allocation Model (CAM)" in the Distribution System Code, but it is about distribution capacity for housing developments, not transmission connection generally.
- **Has the implementing regulation under Electricity Act s. 28.1 (defining "data centre", the demand threshold for a "specified load facility", and the "specified connection requirements") actually been made?**
- *Searched:* e-Laws act-reg API listing of current regulations under the Electricity Act, 1998 (returned 50 current regulations, none titled for data centres or specified load facilities); ERO notices 025-1001 and 026-0853 fetched in full; WebSearch for '"O. Reg." Ontario "data centre" Electricity Act 1998 connection regulation'.
- *Outcome:* NOT ESTABLISHED either way, and DO NOT ASSERT ITS ABSENCE. What IS established is that as at August 13, 2026 the Ministry of Energy and Mines described the connection-approval regulation as something "the province is considering drafting". The 50-item regulation list may have been truncated by a page cap, and criteria could in principle be added to an existing regulation rather than a new one. Safe wording: "the enabling section is in force since 11 December 2025; the Ministry's August 2026 consultation still described the connection-approval regulation as under consideration." Re-verify before publishing anything about the regulation's status.
- **Is there a dedicated IESO connection process, page, or queue specifically for large loads or data centres (as distinct from the general six-stage process)?**
- *Searched:* WebSearch restricted to ieso.ca for '"data centre" OR "large load" connection IESO Ontario'; plus review of the four IESO connection-process pages fetched.
- *Outcome:* NOT ESTABLISHED — no IESO page describing a data-centre- or large-load-specific connection process was found. The general six-stage CAA/SIA/CIA process appears to apply to load facilities as it does to generation (the IESO's CAA application form has a "Load Facilities" variant). An IESO planning paper titled "Demand & Conservation Planning Technical Paper: Large Step Loads" appeared in search results but was NOT fetched and is a planning/forecasting document, not a connection process. Note that several search results for "large load connection process" were about the AESO in Alberta, not Ontario — do not confuse the two.
- **Does the OEB publish a general (non-priority-project) explainer page for the electricity leave-to-construct process?**
- *Searched:* WebSearch on oeb.ca for leave-to-construct application/filing-requirements pages; fetched the OEB priority-transmission leave-to-construct page and the Natural Gas Facilities Handbook page.
- *Outcome:* PARTIALLY ESTABLISHED. The OEB page fetched and quoted is specifically the priority-transmission-projects page, though its text describes ss. 92, 96(1) and 96.1(1) generally. An 'OEB-Electricity-Leave-to-Construct-Filing-Requirements-20230316.pdf' and an 'issues-list-LTC-electricity.pdf' appeared in search results but were NOT fetched, and the 2023 filing requirements would predate the 2024 and 2025 statutory amendments verified above. Do not cite them.
- **Typical duration or cost of an OEB section 92 leave-to-construct hearing.**
- *Searched:* WebSearch for the OEB section 92 application process (a snippet asserted 'several months'); no primary OEB page fetched that states a timeline.
- *Outcome:* NOT ESTABLISHED — the 'several months' figure came only from a search-result snippet, not from a fetched OEB source. Do not publish any duration or cost figure for a leave-to-construct proceeding. The only timeline figures verified in this research are the IESO connection-process stage timings, which are a different process.
---
## Searches run
- `WebSearch: IESO "System Impact Assessment" connection assessment procedure ieso.ca`
- `WebSearch: Ontario Energy Board "leave to construct" section 92 application process oeb.ca`
- `WebSearch: Ontario Bill 40 site:ola.org`
- `WebSearch: Ontario regulation "specified load facility" data centre connection Electricity Act 28.1 consultation`
- `WebSearch: "O. Reg." Ontario "data centre" Electricity Act 1998 connection regulation ontario.ca/laws 2026`
- `WebSearch: IESO large load data centre connection process ieso.ca`
- `WebSearch: oeb.ca "leave to construct" natural gas pipeline application filing requirements process page`
- `WebSearch: IESO "market registration" become a market participant registration process ieso.ca overview`
- `WebSearch (allowed_domains restricted to ieso.ca): "data centre" OR "large load" connection IESO Ontario`
- `WebSearch: "connection allocation" Ontario electricity IESO OEB`
- `WebFetch: https://www.ontario.ca/laws/statute/98e15 — FAILED, returned only the SPA shell with no statute text`
- `WebFetch: https://www.canlii.org/en/on/laws/stat/so-1998-c-15-sch-b/latest/so-1998-c-15-sch-b.html — FAILED, HTTP 403 (CanLII blocks both WebFetch and curl)`
- `e-Laws API: GET https://www.ontario.ca/laws/api/v2/laws/autocomplete?term=Ontario%20Energy%20Board%20Act — used to establish the correct e-Laws alias`
- `e-Laws API: GET https://www.ontario.ca/laws/api/v2/laws/autocomplete?term=Definitions%20and%20Exemptions — used to find the alias for O. Reg. 161/99`
- `e-Laws API: GET https://www.ontario.ca/laws/api/v2/legislation/en/act-reg/statute?title=electricity%20act,%201998&sort=citation — listed 50 current regulations under the Electricity Act, 1998`
- `curl (Googlebot UA, required for e-Laws prerender): https://www.ontario.ca/laws/statute/98o15 — Ontario Energy Board Act, 1998`
- `curl (Googlebot UA): https://www.ontario.ca/laws/statute/98e15 — Electricity Act, 1998`
- `curl (Googlebot UA): https://www.ontario.ca/laws/regulation/990161 — O. Reg. 161/99`
- `curl: https://www.oeb.ca/applications/applications-oeb/leave-construct-applications-priority-transmission-projects`
- `curl: https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/natural-gas-facilities-handbook`
- `curl: https://www.oeb.ca/regulatory-rules-and-documents/rules-codes-and-requirements/distribution-system-code-dsc`
- `curl: https://www.ieso.ca/en/Learn/About-the-IESO/What-We-Do (redirects to https://ieso.ca/Learn/Ontario-Electricity-Grid/Managing-the-Power-System)`
- `curl: https://www.ieso.ca/Sector-Participants/Connection-Process/Overview`
- `curl: https://www.ieso.ca/Sector-Participants/Connection-Process/Obtain-Approval`
- `curl: https://www.ieso.ca/en/Sector-Participants/Connection-Process/Authorize-Market-and-Program-Participation`
- `curl: https://www.ieso.ca/Sector-Participants/Connection-Process/Frequently-Asked-Questions`
- `curl: https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-40 and /status`
- `curl: https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-40`
- `curl: https://www.ola.org/en/legislative-business/bills/parliament-42/session-2/bill-40`
- `curl: https://ero.ontario.ca/notice/026-0853`
- `curl: https://ero.ontario.ca/notice/025-1001`
- `METHOD NOTE 1 — e-Laws (ontario.ca/laws) is a React SPA. A normal fetch returns a 54 KB shell containing ZERO statute text and no error. Fetching with a Googlebot user-agent returns the full prerendered HTML (672 KB for the OEB Act, 909 KB for the Electricity Act). Anyone re-verifying these quotes must use the bot UA or the quotes will appear unverifiable.`
- `METHOD NOTE 2 — the e-Laws alias for the Ontario Energy Board Act, 1998 is 98o15 (S.O. 1998, c. 15, Sched. B). 98e15 is the Electricity Act, 1998 (Sched. A). My first fetch used 98e15 for the OEB Act and would have sourced the wrong statute; the autocomplete API caught it. Both statutes are needed here and they are easy to transpose.`
- `ARTEFACTS — all fetched HTML and extracted text saved under /private/tmp/claude-501/-Users-pouya-Dev-Websites-adr-sml/2e628a52-3cc2-46e4-a4c9-dc1e5273a175/scratchpad/ : g.html + g.txt (OEB Act), ea.html + ea.txt (Electricity Act), r161.html + r161.txt (O. Reg. 161/99), oeb_ltc.*, oeb_ngfh.*, oeb_dsc.*, ieso_Overview.*, ieso_Obtain-Approval.*, ieso_stage4.*, ieso_faq.*, ieso_What-We-Do.*, bill40.*, b40status.*, b40_43.html, b40_42.html, ero_026-0853.*, ero_025-1001.*. These are in a scratchpad, NOT in the repo — under the project's own rule that a claim's supporting artefact must be reachable from the repository, they must be committed (or a faithful extract with provenance committed) before any of these facts goes on a public page.`
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