Port Hawkesbury Paper and NS Power filed reply evidence defending the proposed ELID Above-the-Line Tariff against intervenor challenges to demand allocation, interruptible credits, and the Dispatchable Rider framework

M12661 · Nova Scotia Power - Application for approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (PHP)Application for approval of the Extra Large Industrial Dispatchable (ELID) Tariff, an above-the-line- tariff available to Port Hawkesbury Paper

AI summary

Port Hawkesbury Paper witnesses Fitzhenry and Gorman (N-36) argued that the Industrial Group consultant Bowman's proposal to use PHP's 120 MW average demand as the 3-CP allocator — rather than its actual coincident peak contribution — is discriminatory because it applies exclusively to PHP while all other ATL classes retain the standard 3-CP methodology, adding an estimated $9.4 million to PHP's annual cost allocation (N-36, p. 5).
PHP witnesses contended that the Eliadc Tariff interruptible credit of $7.638–$7.667/kVA proposed by the Consumer Advocate's consultant InterGroup is inherently cost-discriminatory because it applies LIIR class billing determinants to a separate customer class; PHP argues the cost-based credit of $13.107/kVA (confirmed by NS Power in response to PHP IR-4(b)) should apply, with the difference costing PHP approximately $4.2 million annually (N-36, pp. 6–7; N-37, p. 10).
PHP's operational witnesses Lock and Esaiw (N-37) rebutted Bates White's Goose Harbour wind output assumptions, explaining that the SIS approval covers only 130.5 MW of installed capacity and that the correct P90 generation estimate for a full 168 MW facility is 528 GWh — not the 653 GWh used by Bates White — yielding a net NS Power load of approximately 246,000 MWh and eliminating the basis for Bates White's proposed true-up mechanism (N-37, pp. 2–4).
Nova Scotia Power reply evidence (N-38) confirmed its position that the GRA Settlement Agreement locked in the 65 MW demand determinant, LIIR-based interruptible credit, and revenue-to-cost ratios for 2026–2027, and that the Dispatchable Rider savings should flow 100% to PHP given PHP's transition to a full embedded-cost ATL framework; NS Power proposes using the same 65 MW determinant for both costing and billing to convert demand cost recovery into a fixed charge (N-38, pp. 8–10).
NS Power opposed Board approval of DR Operating Procedures as unnecessary given existing FAM Audit oversight, opposed a symmetrical true-up mechanism for energy charge variances, and recommended retaining Priority Interruptible service at approximately $500,000 per year pending a full reliability analysis in the next GRA, noting PHP experienced zero interruption events from 2022–2025 while remaining available as an interruptible resource (N-38, pp. 20–21).

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What was filed

Documents filed on this day

N-36 Reply Evidence of Colin Fitzhenry and Michael Gorman, on behalf of PHP exhibits
N-37 Reply Evidence of Bevan Lock and John Esaiw, on behalf of PHP exhibits
N-38 Reply Evidence - NS Power exhibits