AI-generated summary
· Application · 09/08/2023
Board consultants Bates White and Synapse filed substantive comments on NSPI's 2023 Evergreen IRP Action Plan, raising concerns about Atlantic Loop cost escalation, competitive procurement practices, and battery storage capacity valuation methodology.
AI summary
- Bates White (Exhibit N-2) recommended NSPI maximize use of best-practices competitive procurement — including all-source RFPs with binding offers — to manage cost and risk across identified near-term resource needs of up to 1,500 MW of wind, 200 MW of solar, 300–600 MW of fast-acting resources, and 100 MW of battery storage by 2030.
- Bates White flagged the Atlantic Loop as carrying "extraordinary costs and risks," noting total project cost estimates have escalated from $2.9 billion (2020) to $7.5 billion (2023), a 159% increase, while NSPI's modeling still uses the 2019 assumption of $1.7 billion in ratepayer costs; NB Power's own 2023 IRP concluded the Atlantic Loop is not its least-cost alternative.
- Synapse (Exhibit N-3) confirmed the No Atlantic Loop scenario (CE1-E1-R2) is $130 million lower in 26-year NPVRR than the base Atlantic Loop run, and that NSPI's 10-year System Outlook relies on the No Atlantic Loop scenario as its resource portfolio basis.
- Synapse identified a critical methodological concern: the battery energy storage ELCC values used in the IRP update are too low because they do not fully capture portfolio diversity effects among wind, solar, battery storage, and demand response in combination, potentially producing sub-optimal capacity expansion results.
- Both consultants supported expedited development of the NS–NB Reliability Tie as a high-priority item required under all scenarios to integrate the roughly 600 MW of additional wind needed by 2028, and recommended NSPI pursue robust regional integration alternatives beyond the Atlantic Loop, including full joint dispatch with New Brunswick.
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What was filed
Documents filed on this day
- N-2 Comments - Bates White
- N-3 Comments - Synapse