Quebec Issues Follow-Up Regulations and Details to its Announcement of a 2300 MW of Renewable Energy RFPs
Last April, the Government of Quebec and Hydro-Québec announced the launch of two new RFPs for a total block of 2,300 MW of renewable energy, which effectively kicked off the largest wind and renewable energy procurement project in the Province’s history. This is in parallel to the recent two RFPs for 780 MW of renewable energy (where submissions were received last July by Hydro-Québec) as well as the announced three wind projects totalling 1,200 MW to be jointly developed by Boralex, Énergir and Hydro-Québec.
In our previous publication, we indicated that the two RFPs would be led by Hydro-Québec, and that the Government implied that the new RFPs will have a structure similar to that of the current 300 MW and 480 MW RFPs: the 1,000 MW block would be reserved for wind energy, the slightly larger block of 1,300 MW would be open to all forms of renewable energy electricity production, such as solar, biomass, hydroelectric, and wind.
The Government of Québec initially published on April 27 two draft regulations in support of the two RFPs. These regulations have since been officially enacted on August 3, 2022, pursuant to the Act respecting the Régie de l’énergie (c. R-6.01) as Orders in Council 1451-2022 and 1452-2022 (together, the “Regulations”). Under the two Regulations, both RFPs will have to be initiated by Hydro-Québec at the latest by December 31, 2022.
Of particular note regarding the 1,000 MW RFP - the Regulation respecting a 1,000-megawatt block of wind energy - are plans for the 1,000 MW block of wind energy to be segmented into three distinct deadlines for connecting to Hydro-Québec’s main transmission lines:
- 400 megawatts should be available and connected by December 1, 2027;
- 300 megawatts should be available and connected by December 1, 2028; and
- 300 megawatts should be available and connected by December 1, 2029.
There are no similar provisions in the Regulation for the 1,300 MW general renewable energy RFP (the Regulation respecting a 1,300-megawatt block of renewable energy).
In previous RFPs, the Government of Québec had required that projects submitted meet certain guidelines relating to social, economic and environmental concerns. This was the case in the recent 2021 RFPs, where Orders in Council 906-2021 and 1442-2021 had integrated these objectives from Hydro-Québec's Electricity Supply Plan for 2020-2029 and clarified local community benefit requirements.
For the upcoming RFPs, neither Regulation has provided details on possible social, economic and environmental objectives, nor other substantive details. With a number of these objectives already integrated into Hydro-Québec's current Electricity Supply Plan, it is foreseeable that previous requirements for regional economic development, promotion of community participation, and collaboration with Indigenous peoples could be features of these two upcoming RFPs. It remains to be seen, however, if these will take the same form as in the past or if new guidelines will be introduced.
Given that the Government has indicated to media its intention to also include a “buy local” component for at least one of the two RFPs, in order to encourage local spending, especially in the Gaspésie, Magdalen Islands and the Matanie regions of Québec, it is likely that more information on the particularities of each RFP will be made available prior to their official launch in December. We will continue to be on the lookout for and provide updates on all new orders in council on this topic as they become available.
Our team at McCarthy Tétrault continues to closely follow the development of the Quebec RFPs, as well as the Quebec energy developments generally. If you would like more information about renewable energy RFPs, including project development, financing or regulatory aspects, we are here to help. Please contact Louis-Nicolas Boulanger, Mathieu Leblanc, Jacob Stone or any other member of the Power Group at McCarthy Tétrault with any questions or for assistance.
 See Gazette N° 17 of the Gazette Officielle du Québec.
 See Gazette N° 33 of the Gazette Officielle du Québec.
clean energy renewable energy Energy RFP Wind RFP Submission public infrastructure projects