Topic:"2025 Ace Plan" in M11927

Reason for Variance - ATO The increase of approximately $8.2 million compared to the approved 2019 ACE Plan budget of $7,244,422 is due to increased environmental permitting requirements, extended construction timeline, and costs associate...

AI summary The increase of approximately $8.2 million in the 2019 ACE Plan budget is attributed to increased environmental permitting requirements, extended construction timelines, and costs related to Mi'kmaq engagement. Additional costs include studies, design, and construction for fish passage and an environmental offsetting program.

REDACTED 1 Request IR-3: 2 3 Reference: "The increase of approximately $8.2 million compared to the approved 2019 ACE 4 Plan budget of $7,244,422 is due to increased environmental permitting requirements, 5 extended construction timeline,...

AI summary The text outlines a request for information regarding the increase in the 2019 ACE Plan budget by approximately $8.2 million, attributed to environmental permitting requirements, extended construction timelines, and Mi'kmaq Engagement costs. It asks NS Power to explain the process and sources used in developing original timelines and budgets, and to provide comparative tables and figures.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO (NSUARB M11927) NSPI Responses to The Industrial Group Information Requests 1 Request IR-3: 5 6 Preamble: This capital project, CI 50518 was approved by the Board as part of the 2019 7...

AI summary The document outlines responses from Nova Scotia Power Inc. (NSPI) to information requests regarding the Ruth Falls Main Dam Refurbishment project, which was approved as part of the 2019 ACE Plan. NSPI confirms that the project has been updated and clarifies details about the dam's construction and capacity.

REDACTED 1 (v) Please identify the cost of additional site supervision resulting from delays in 2 project execution. 3 4 (a) Please explain why these costs are required beyond those that were 5 envisioned in the 2019 ACE Plan Application....

AI summary The text presents a series of questions regarding additional costs related to the Ruth Falls Main Dam Refurbishment project, including site supervision, freight, equipment rental, and Mi'kmaw engagement, with a response indicating a 93% increase in material costs due to extended timelines and permitting requirements.

2 (ii) Table below summarizes the cost of materials from the table in (a) (i) associated 3 with new scope items that were not included in the 2019 ACE Plan Application:

AI summary The text references a table summarizing the cost of materials associated with new scope items not included in the 2019 ACE Plan Application.

2 (ii) Table below summarizes the cost of contracts associated with new scope itemsfrom 3 the table in (b) (i) that were not included in the 2019 ACE Plan Application: 4 2 Totals may be off due to rounding of individual line items. CI 5051...

AI summary The text refers to a table summarizing the cost of contracts for new scope items not included in the 2019 ACE Plan Application, along with a reference to a specific regulatory matter related to the Ruth Falls Main Dam Refurbishment.

- 4 extended construction timeline: Table 10: Yearly Breakdown – Labour Variance[49](#page-28-5) Year Regular Labour ($k) Term Labour ($k) 2017-2020 ($19) $3 2021 $85 $0 2022 $124 $1 2023 $56 - 2024 $47 $1 2025 $104 $30 2026 $47 $60 TOTAL:...

AI summary The text provides a yearly breakdown of labour costs, including regular and term labour expenses from 2017 to 2026, and references specific regulatory matters and exhibits related to the 2019 ACE Plan and other filings.

- 3 NS Power attributes the increase in contracting costs, totalling $2,595,802, to new scope items that were not - 4 included in the 2019 ACE Plan Application. These costs are driven by additional project requirements such as - 5 fish pas...

AI summary NS Power attributes an increase in contracting costs of $2,595,802 to new scope items not included in the 2019 ACE Plan Application, such as fish passage upgrades, construction supervision, and archaeological mitigation efforts. The costs are detailed in Table 17.

at the time of the 2019 ACE Plan submission, NS Power should have been aware that archaeological costs for the Project would be several orders of magnitude higher than its estimated figure of $2,256. [24] As it relates to estimated Mi'kmaq...

AI summary The text discusses NS Power's 2019 ACE Plan submission, highlighting that archaeological and Mi'kmaq engagement costs were underestimated. Midgard acknowledges the underestimation but suggests it likely did not affect the original decision. Midgard also supports NS Power's contingency measures and validates the chosen project option.

Request IR-1: - With reference to Page 2 of the Application: - a) Please provide the original engineering drawings (e.g., general arrangement drawings) of the preferred alternative from the earliest design stage available (e.g., on which t...

AI summary Request IR-1 asks for original and updated engineering drawings of the preferred alternative (Option 4), including a description of key design modifications related to DFO and permitting requirements.

Request IR-4: - In Undertaking U-6 submitted by NS Power as part of the 2019 ACE Plan proceeding (Matter - M08984), NS Power stated: - (a) Riprap work is not included in the scope of this project. The riprap on the embankments remains in g...

AI summary The document requests confirmation of NS Power's statements regarding the scope of a project from the 2019 ACE Plan proceeding. NS Power previously stated that riprap work, minimum freeboard work, and concrete erosion work were not required or were included in the project scope. The request seeks confirmation or clarification on whether these statements still apply.

Request IR-6: In response to NSUARB IR-65f) in the 2019 ACE Plan Proceeding (M08994), NS Power stated: Potential geotechnical issues were reviewed as part of the design phase of the project. Since the existing dam is founded on bedrock and...

AI summary NS Power responded to NSUARB IR-65f) in the 2019 ACE Plan Proceeding (M08994), stating that no geotechnical issues are anticipated for the new dam, as it will be constructed on the same footprint as the existing dam. The NSUARB is requesting confirmation, details on any changes, and information on whether a detailed geotechnical investigation was completed.

Request IR-7: - Given the new (as compared to the 2019 ACE Plan Submission) project requirements and costs for environmental permitting, fish passage, environmental offsetting, temporary lowering of the reservoir, and additional archaeolog...

AI summary The document requests NS Power to re-evaluate project options for the ACE Plan, considering new requirements such as environmental permitting and Mi'kmaw engagement, and to explain why Option 4 remains the lowest cost option or provide analysis if other options were considered.

Request IR-10: - Regarding the Account Variance Sheet on pages 5 and 6 of the current Application: - a) For the "Materials" Line Item: - i. Please identify the percentage increase in materials cost that NS Power has allowed for since the 2...

AI summary The document requests detailed explanations and justifications for various cost increases and exclusions in the Account Variance Sheet related to the 2019 ACE Plan Application, including materials, contracts, consulting, and Mi'kmaw Engagement costs.

lain how the cost was developed. - k) Please explain the significant increase in Consulting "Conceptual/Detailed design of refurb" cost as compared to the 2019 ACE Plan Application "Design" cost and explain how the cost was developed.

AI summary The text requests an explanation for the significant increase in the cost of 'Consulting Conceptual/Detailed design of refurb' compared to the 2019 ACE Plan Application 'Design' cost and how this cost was developed.

16 Question: 17 18 (a) Given that the amendments to the Fisheries Act had passed third reading in the house of 19 commons by the end of June 2018 and that NSPI filed its ACE plan in November 2018, in 20 Midgard's view would it have been pr...

AI summary The question asks whether NSPI should have consulted with DFO on the implications of the Fisheries Act amendments for projects like the Ruth Falls Dam Refurbishment, given that the amendments had passed third reading and NSPI filed its ACE plan in 2018.

VIA EMAIL Crystal Henwood Regulatory Affairs Officer/Clerk of the Board Nova Scotia Utility and Review Board 3rd Floor Summit Place 1601 Lower Water Street Halifax NS B3J 3S3 Dear Ms. Henwood: RE: M11927 – NSPI – CI 50518 – HYD Ruth Falls...

AI summary The Consumer Advocate submits comments on Nova Scotia Power's application to overspend on the Ruth Falls Main Dam refurbishment project. The project was initially approved under the 2019 ACE Plan with a budget of approximately $7.2 million, but the application now seeks authorization to increase the budget by $8.2 million, primarily due to increased permitting requirements, archaeological resource management, and engagement with the Mi'kmaq community. Midgard Consulting found most of the cost increases to be valid, except those related to archaeological resources.

uth Falls ATO are not overstated , "Midgard considers that there remains a risk of future significant increases to archaeological costs, as noted in Section 6.2.3 of Midgard's report."[32](#page-6-8) The Industrial Group would further note...

AI summary The text discusses concerns about the Ruth Falls ATO and the potential for increased archaeological costs, referencing the Hydro Asset Study and the Boreas Costing Report. It notes that NSPI was not aware of the high potential for archaeological impacts prior to the original application.

at the time of the 2019 ACE Plan submission, NS Power should have been aware that archaeological costs for the Project would be several orders of magnitude higher than its estimated figure of $2,256. [24] As it relates to estimated Mi'kmaq...

AI summary The text discusses the 2019 ACE Plan submission by NS Power, highlighting that archaeological and Mi'kmaq engagement costs were underestimated. Midgard supports NS Power's inclusion of a contingency fund and validates administrative overheads. NS Power continued to support Option 4 for the Ruth Falls dam refurbishment in the current ATO application.

3.2 Preferred Refurbishment Option [65] In approving NS Power's 2019 ACE Plan, the Board agreed with NS Power that Option 4 was the preferred and most economic refurbishment alternative for the project. As noted above, NS Power's CEJC expl...

AI summary The Board approved NS Power's 2019 ACE Plan, recognizing Option 4 as the preferred and most economic refurbishment alternative. NS Power did not update its 2019 economic analysis, citing similar cost increases across all options and constructability/safety concerns. Midgard found NS Power's reasoning reasonable, and the Board accepts this, reaffirming Option 4 as the preferred option.