Project Description


  • At its outset, the IESO CFF Programs were to have been delivered over a five-year period from 2015 through 2020. These programs were expected to generate 6.9 TWh of energy savings, with a total budget of $1.9 Billion.
  • The audit scope included review LDC wind-down activity for 9 separate CFF Programs which targeted a variety of sectors and conservation objectives.
  • Delivery for most CFF Programs was to be coordinated locally by LDCs operating in partnership with IESO.
  • Substantial differences in the size and scope of these LDCs required a flexible audit approach which could accommodate these differences and still deliver on related assurance objectives.
  • The IF Programs were to run from April 2019 through December 2020, with a total budget estimated at $353 Million and projected energy savings of 1.4 TWh.

“Bronson was retained by IESO to conduct compliance audits and to assess and identify audit risks for Local Distribution Companies and Service Providers involved in Interim Framework Conservation Programs.”

– Phil Cormier, CA, CPA, Senior Consultant, Bronson Consulting Group

Project Description

Bronson was retained by IESO to conduct compliance audits for Local Distribution Companies (LDCs) during their wind-down of Conservation First Framework (CFF) Programs. Bronson was also retained by IESO to conduct compliance audits for Service Providers involved in ongoing delivery of Interim Framework (IF) Conservation Programs.

Business Challenge

IESO’s CFF Programs were being delivered throughout Ontario by a network of 67 LDCs. These programs were discontinued in March 2019, and LDCs were subsequently responsible for ensuring an orderly wind down of related activities, including ongoing administration and review of incented projects which were in progress at the time that CFF was discontinued. Subsequent delays in wind-down activity were encountered with the onset of COVID-19 which required a flexible approach to compliance audit and assurance activities.

IESO’s IF Programs were introduced in April 2019 as a replacement for conservation programs which were previously offered by IESO under CFF. The compliance audit scope includes 21 separate contractual agreements with service providers for delivery of various IF Programs throughout Ontario. In addition, site visits were planned to verify installation details for selected projects from various IF Programs, though this activity has been delayed due to the onset of COVID-19.

Our Solution and Outcome

Bronson’s approach involved consultation with IESO representatives to review and assess identified audit risks for both CFF Wind Down and IF Program Delivery which were to be mitigated through these activities. Program requirements and parameters were reviewed in detail, leveraging Bronson’s previous experience in compliance audit engagements for IESO programs.

Detailed frameworks were then developed to provide a structured and consistent approach for implementation of subsequent compliance audit activities. Individual LDCs and Service Providers were then engaged and reviewed based on the approach defined in the frameworks.

Any issues identified through this process were reviewed in detail with counterparty representatives to ensure that audit findings were accurate and include all relevant considerations and context.