Industrial Group and Small Business Advocate request conversion of ELID tariff proceeding to oral hearing, citing competing expert opinions, unresolved factual disputes, and novel tariff complexity

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

The Industrial Group, represented by Stewart McKelvey, filed a letter (Exhibit 102802) on July 16, 2026 requesting the Board convert Matter M12661 from a written to an oral hearing process, citing at least five distinct expert perspectives — from NSPI, Port Hawkesbury Paper, Bates White Economic Consulting, Synapse Energy Economics, Bowman Economic Consulting, and Intergroup Consultants — that remain unresolved on the written record.
Key contested issues include: the demand determinant (NSPI proposes 65 MW per Exhibit N-1; PHP proposes 8 MW per Exhibit N-2; Bowman recommends 120 MW per Exhibit N-25); the Dispatchable Rider (DR) credit and Customer Baseline Load methodology; Goose Harbour Lake Wind Farm output assumptions (Bates White flagged a 130.5 MW vs. 168 MW capacity discrepancy in Exhibit N-20, raising the risk that PHP could pay zero Energy Charge); and the Interruptible Rider credit value (NSPI: ~$7.64–7.67/kVA per Exhibit N-1; PHP: $13.107/kVA per Exhibit N-2; Bowman: little to no value per Exhibit N-25).
The Industrial Group further flagged that NSPI's Reply Evidence (Exhibit N-38, p. 23) introduced a new Active Demand Control (ADC) valuation methodology discussed at a Q2 2026 FAM Small Working Group meeting after the close of Information Requests, leaving intervenors unable to examine or assess its financial implications for above-the-line ratepayers.
Bowman's evidence (Exhibit N-25, p. 3) describes the proposed Eliadc Tariff-successor ELID rate as "complicated and unusual in utility rate regulation" with no comparable Canadian precedent, and Synapse evidence (Exhibit N-21, p. 4) notes PHP accounts for up to 25% of total NSPI system load, making the outcome material to all ratepayers.
The Small Business Advocate filed a concurring letter (Exhibit 102804) on the same date, endorsing the Industrial Group's request on the basis that the application's complexity requires cross-examination.

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What was filed

Documents filed on this day

102802 Letter IG re: Request oral hearing other_documents
102804 Letter SBA re: Request oral hearing other_documents