OEB issues updated Filing Requirements for OPG's payment amounts applications

Today, the OEB has issued updated Filing Requirements for OPG’s payment amounts applications. These updates include revisions to the 2011 guidelines, informed by stakeholder comments and discussions. The Filing Requirements aim to address the evolving regulatory landscape, incorporate lessons learned from past proceedings, and remain evergreen.

The draft update released by OEB staff on April 23, 2024, for stakeholder comment did not propose wholesale changes but rather more targeted revisions. These include:

  • Aligning language and terminology for consistency with other OEB filing requirements
  • Revising exhibit titles
  • Removing references to specific years and specific facilities
  • Renaming the Filing Guidelines to Filing Requirements

The above changes elicited broad support from stakeholders and have been incorporated into the updated Filing Requirements.

Other notable changes to the Filing Requirements include:

  • Updated cost thresholds for capital projects: These thresholds better reflect inflationary increases and enhance regulatory efficiency by focusing on more substantial projects while ensuring that evidence is available for a comprehensive review. Tier 1 Capital Projects are now set at $30 million, with corresponding adjustments to Tier 2 and 3 cost thresholds.
  • Term-over-term variance analysis: This will replace year-over-year variance analysis for capital costs and project operating, maintenance, and administration costs (OM&A). However, OPG is still required to provide a year-over-year variance analysis for base OM&A costs.
  • Historical Years: To ensure that the application evidence focuses on the most relevant data, the updated Filing Requirements require OPG to provide the five most recent historic years. If OPG is unable to provide certain historical data, it should clearly set out the reasons for this. Specific guidance has also been provided in the cover letter for the historical data applicable to the next OPG hydroelectric application.
  • Capitalization policies: The final Filing Requirements include the requirement for OPG to file a plan for transitioning away from capitalizing indirect overheads or provide a justification for maintaining its current practice. (At this time, OPG is required by regulation to do its financial reporting under United States Generally Accepted Accounting Principles.)


The OEB extends its gratitude to all stakeholders who participated in the consultation process.