AI-generated summary
· Application · 07/07/2026
Nova Scotia Power filed rebuttal evidence defending its $6.76 million Identity & Access Management capital project against Consumer Advocate and Small Business Advocate challenges on AFUDC, contingency, and asset accounting
AI summary
- NS Power rebuts the Consumer Advocate's recommendation to disallow AFUDC for April 2025–March 2026, arguing the cybersecurity incident caused only a brief project pause (May–June 2025, with only $3,804 of the total $85,258 AFUDC accruing during that period) and that cost increases were driven by NIST Cybersecurity Framework evolution and expanded scope, not the incident (Exhibit N-7, NS Power (CA) RIR-4; p. 7–8).
- NS Power defends its 15% contingency on the full project budget, contending the remaining IGA deployment phase—including enterprise-wide application onboarding, system integrations, and user lifecycle management—carries sufficient residual risk to warrant maintaining the full contingency, even though approximately 45% of the $6,756,522 budget has been spent and Decision Gate 6 has been reached (p. 9–10).
- On Accounting Standards, NS Power explains that predecessor PAM assets (CIs 49094 and C0054455) will not be retired early; under the amortization framework approved in the 2026–2027 GRA (M12451, Board Decision, March 25, 2026, p. 134), they will continue depreciating over approved service lives until fully amortized, leaving no unrecovered net book value and rendering Accounting Policy 6350 inapplicable (p. 6–7).
- NS Power addresses the transition from on-premises to SaaS-based PAM by noting that NERC-regulated data remains excluded from the SaaS environment, satisfying the original constraint, and that the on-premises CyberArk solution exited vendor support in 2025 and reaches end of life in 2026, making the SaaS migration a prudent lifecycle progression rather than a reversal of prior decision-making (p. 4–6).
- Against the Small Business Advocate's claim of an incomplete cost picture, NS Power confirms the total project cost of $6,756,522 covers all six planned releases, with Release 1 in service since February 2026 and full deployment forecast by August 2026; any future capabilities beyond current scope would be brought forward separately (p. 15–16).
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What was filed
Documents filed on this day
- N-8 Rebuttal Evidence - NSPI