Topic:"Affordability" in M11927

r n a os CI # 50518 - HYD Ruth Falls Main Dam Refurbishment Consulting 246,562 1,877,234 1,630,672 Offsetting costs as dictated by the Fisheries Act Authorization. Additional costs for studies associated with confirmation of the improvemen...

AI summary The document outlines the consulting costs associated with the Ruth Falls Main Dam Refurbishment project, including expenses related to environmental permits, fish passage upgrades, archaeological assessments, and mitigation efforts with the Mi'kmaq. These costs are dictated by the Fisheries Act Authorization and environmental permits.

Note: A legend must be supplied for all mapping describing symbols used, scale and north orientation. Description Submitted Waiver requested Reason for Waiver 6A - Attach for all applicable Water Applications Proof of Ownership/Agreement/L...

AI summary The document outlines the required submissions for different types of water applications, including proof of ownership, site plans, and environmental assessments. It emphasizes the importance of complete and high-quality documentation to avoid delays or rejections in the application process.

CI 50518 CA IR-5 Attachment 19 Page 174 of 423 REDACTED (CONFIDENTIAL INFORMATION REMOVED) 3 # Indicators Condition Choices Data Definitions/Explanations Protection and off road vehicles appear to effectively exclude or divert visitors and...

AI summary The text outlines various indicators and condition choices related to environmental protection, consumptive uses, domestic wells, and calcareous fen within a specific area. It includes data on wildlife disturbance, sustainable consumptive uses, proximity of domestic wells, and calcareous fen identification.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO (NSUARB M11927) NSPI Responses to The Consumer Advocate Information Requests REDACTED 1 2 Request IR-13: 3 Reference: NS Power states that costs for Mi'kmaq Engagement are $ , whereas...

AI summary The document discusses responses to information requests regarding the Ruth Falls Main Dam Refurbishment ATO, including a breakdown of Mi'kmaq engagement costs, reasons for initial underbudgeting, and discrepancies in cost figures referenced in the application.

18 Year Total Contract Costs Contractor Administrative Overhead Rate Applied Total Contractor Administrative Overhead 2017 $2,256 10.76% $243 2018 $8,028 9.71% $780 2019 $1,027 12.02% $123 2020 $22,269 9.75% $2,172 2021 $641,718 10.08% $64...

AI summary The table presents contractor administrative overhead costs and rates applied from 2017 to 2023, with notable fluctuations in both total contract costs and overhead rates. The text also references a specific proceeding (CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO) and a related information request by the Consumer Advocate.

REDACTED 1 (b) Please refer to CA IR-13, part (c). 2 3 (c) In the original submission KMKNO Capacity Payments were budgeted and added to the 4 "Consulting" cost code in the amount of $ instead of a dedicated "Mi'kmaq 5 Engagement" cost cod...

AI summary The document discusses the budgeting of KMKNO Capacity Payments under the 'Consulting' cost code rather than a dedicated 'Mi'kmaq Engagement' code. It also addresses archaeological costs for the Ruth Falls Project and legislative requirements for the sale of hydro assets, including approvals from the Public Utilities Act and federal legislation.

REDACTED 1 Request IR-2: 2 3 With reference to Page 3 & 5-6 of the Application: 4 5 (a) Please provide the original estimated costs for archaeological investigation and 6 Mi'kmaq engagement prior to the additional $400,000 noted on Page 3....

AI summary The document contains a request for clarification regarding additional costs for archaeological investigation and Mi'kmaq engagement, specifically asking for breakdowns of original and additional costs, and the distribution of the additional funds.

REDACTED 1 Request IR-10: 2 3 Regarding the Account Variance Sheet on pages 5 and 6 of the current Application: 4 5 (a) For the "Materials" Line Item: 6 7 (i) Please identify the percentage increase in materials cost that NS Power has 8 al...

AI summary The text outlines an information request (IR-10) directed at NS Power concerning cost variances in the Account Variance Sheet related to the 2019 ACE Plan Application, specifically focusing on materials, contracts, and additional costs such as archaeological site security and pumping expenses.

REDACTED Description Increase in costs (in Thousands) ADDITIONAL SCOPE: NEW PERMITTING REQUIREMENTS Fish Passage upgrades $1,630 Engineering support for environmental permit $15 application Barn Swallow nest removal $11 Pre-tree clearing n...

AI summary The text outlines various cost increases associated with a project, including fish passage upgrades, archaeological engagement, and extended construction timelines. The table details specific line items with associated costs, such as engineering support, environmental permits, and construction-related expenses.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO (NSUARB M11927) NSPI Responses to NSUARB Information Requests 1 (f) The following scope of work was included as part of the Limited Notice to Proceed: 27 by NS Power at the time of the...

AI summary NSPI provided responses to NSUARB information requests regarding the Ruth Falls Main Dam Refurbishment ATO. Key points include the need for pre-clearing nesting bird surveys, unaccounted concrete testing costs, and escalation costs due to execution deferral caused by environmental permitting delays.

1.0 Introduction The Elliot Group of Companies is implementing the following Pandemic Preparedness Plan. This plan has been developed as a result of the current Covid-19 Pandemic but will be maintained as a "go forward" plan for all Elliot...

AI summary The Elliot Group of Companies is implementing a Pandemic Preparedness Plan, developed in response to the Covid-19 pandemic, to be used for future pandemic prevention. Scott and Dale Haverstock are responsible for its development and implementation. Nova Scotia Power's pandemic information will be shared and followed by employees.

CI 50518 NSUARB IR-12 Attachment 4 Page 9 of 57 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Ruth Falls Dam Refurbishment S 35(2)(b) Fisheries Act Authorization Supporting Information #1 Monitoring Activities personnel. The system will be m...

AI summary The document outlines NS Power's plan for water management during the Ruth Falls Dam refurbishment, including continuous downstream discharge to maintain fish passage and comply with regulatory requirements. The proposed system has been used successfully by the Halifax Regional Municipality, and NS Power intends to seek a variance from ECC for modifications to flow releases.

Year 1 Category Description Amount Salaries and Wages (The CMM) Project Manager (35 hrs @ $80/hr = $ 2,800) Project Lead (105 hrs @ $70/hr = $7,350) $10,150.00 Salaries and Wages (Millbrook) Amount to reimburse Millbrook community members...

AI summary The document outlines the costs associated with a project involving the CMM, Millbrook, and NSSA, including salaries, travel, and administrative expenses, totaling approximately $36,442.50.

Year 2 Category Description Amount Salaries and Wages (The CMM) Project Manager (35 hrs @ $80/hr = $ 2,800) Project Lead (105 hrs @ $70/hr = $7,350) $10,150.00 Allotment for Millbrook (Salaries, training, and equipment) Amount to reimburse...

AI summary The document outlines a detailed breakdown of costs associated with a project involving the CMM and Millbrook community, including salaries, travel, restoration machinery, and administrative expenses, with a total cost of approximately $224,135.50.

6.0 CLOSURE This plan has been prepared for the sole benefit of Nova Scotia Power Incorporated (NS Power). This report may not be relied upon by any other person or entity without the express written consent of Stantec Consulting Ltd. Any...

AI summary The Closure section of the document outlines that the report is prepared exclusively for Nova Scotia Power Incorporated and disclaims any liability for third-party reliance. It emphasizes that additional information should be brought to the attention of Stantec Consulting Ltd. for reassessment and invites questions regarding the Fish Entrainment Study Field Plan.

Pre – Offset Table 2 Year 1 (2022) Budget Category Description Amount Salaries and Wages (the CMM) Project Manager (70 hrs @ $80/hr = $ 5,600) Field technicians (3 x technicians for 21 hrs @ $45/hr = $2,835) $8,435.00 Training Environmenta...

AI summary The document outlines the Year 1 (2022) budget for a project involving the CMM and NSSA, detailing expenses for salaries, training, travel, professional services, and administrative costs, with a total of $21,520.59.

Offset Table 4 Year 3 (2024) Budget Category Description Amount Salaries and Wages (The CMM) Project Manager (35 hrs @ $80/hr = $ 2,800) Project Lead (105 hrs @ $70/hr = $7,350) $10,150.00 Allotment for Millbrook (Salaries, training, and e...

AI summary This table outlines the budget for Year 3 (2024) of a project involving the CMM, Millbrook community, NSSA, and other entities. It includes costs for salaries, travel, equipment, and professional services, with a total budget of approximately $255,544.12.

CI 50518 NSUARB IR-12 Attachment 10 Page 555 of 591 REDACTED (CONFIDENTIAL INFORMATION REMOVED) APPENDIX P – ACCDC REPORT

AI summary The document presents Appendix P of the ACCDC report, which is part of a regulatory proceeding in Nova Scotia. The content is redacted, indicating that it contains confidential information.

Pre – Offset Table 2 Year 1 (2022) Budget Category Description Amount Salaries and Wages (the CMM) Project Manager (70 hrs @ $80/hr = $ 5,600) Field technicians (3 x technicians for 21 hrs @ $45/hr = $2,835) $8,435.00 Training Environmenta...

AI summary The document outlines the Year 1 (2022) budget for a project managed by the Community Management Corporation (CMM), including expenses for salaries, training, travel, professional services, and administrative costs, totaling approximately $21,520.59.

Offset Table 4 Year 3 (2024) Budget Category Description Amount Salaries and Wages (The CMM) Project Manager (35 hrs @ $80/hr = $ 2,800) Project Lead (105 hrs @ $70/hr = $7,350) $10,150.00 Allotment for Millbrook (Salaries, training, and e...

AI summary The table outlines the budget for Year 3 (2024) of a project involving the CMM, NSSA, and a freshwater biologist, covering salaries, travel, allotments, and professional services. The total budget is listed as approximately $196,517.03, with administrative costs at 15% of the total.

CI 50518 NSUIARB IR-12 Attachment 12 Page 539 of 576 REDACTED (CONFIDENTIAL INFORMATION REMOVED) APPENDIX P – ACCDC REPORT

AI summary The document includes Appendix P of the ACCDC report, which is part of a regulatory proceeding in Nova Scotia. The content is redacted, indicating that confidential information has been removed.

2.2.3 Conclusion - In Midgard's opinion NS Power was acting reasonably in its interactions with NSECC. The delays associated - with the watercourse alteration permit issuance appear to stem from issues that originally initiated with the -...

AI summary Midgard concludes that NS Power acted reasonably in its interactions with NSECC, with delays in watercourse permit issuance primarily attributed to DFO's FAA process. NS Power has not detailed the breakdown of its cost overages related to environmental permitting, but the root cause appears to be DFO requirements.

5 11 - 7 The Consumer Price Index (" CPI ") is a measure of the average change in prices over time for a basket of - 8 goods and services commonly purchased by households. It serves as a general indicator of inflation and helps - 9 track p...

AI summary The text defines the Consumer Price Index (CPI) as a measure of average price changes over time for goods and services purchased by households, and notes that Table 4 outlines CPI trends in Nova Scotia from May 2019 to October 2024.

3.3.1 NS Power Submission - In the ATO Application, NS Power attributed the labour cost increase to the extended construction timeline, - required to secure environmental permits and meet their conditions. The increase was broken down as -...

AI summary NS Power attributes increased labor costs in their ATO Application to extended construction timelines caused by delays in securing environmental permits and meeting conditions. The breakdown includes regular, term, and overtime labor costs, with significant expenses incurred in 2025 for project execution and environmental studies.

Table 10: Ruth Falls Mi'kmaq Engagement Costs[43](#page-27-1) Description UARB Approved Original Submission ATO Submission Variance Additional KMKNO Capacity Payments: To provide the KMKNO with necessary resources to meaningfully engage wi...

AI summary The table outlines engagement costs related to the Ruth Falls Mi'kmaq community's involvement with NS Power, including observer payments and capacity payments. NS Power states these costs are necessary to cover additional monthly KMKNO capacity payments.

6.2.3 Labour Cost Increases - The increased labour and material costs reported by NS Power stem from updated environmental permitting - requirements and an extended timeline to meet regulatory conditions. Midgard concludes that the reporte...

AI summary NS Power reports increased labour and material costs due to updated environmental permitting requirements and an extended timeline to meet regulatory conditions. Midgard concludes that these increases are reasonable.

6.3.2 Mi'kmaq Engagement - Midgard concludes that the "Additional KMKNO Capacity Payments" increased costs are reasonable, as NS - Power was required to continue consultation with KMKNO as the Project changed. - With respect to the Mi'kmaq...

AI summary Midgard concludes that the Additional KMKNO Capacity Payments are reasonable given NS Power's requirement to continue consultation with KMKNO due to project changes. The costs for Mi'kmaq observers during archaeological work are considered reasonable, though their magnitude is unlikely to have significantly impacted the original decision.

Table 3: Nova Scotia CPI Trend19 Table 4: Canada IPPI Trend20 Table 5: Ruth Falls Archaeological Costs24 Table 6: Comparison of Recent Project Archaeological Costs25 Table 7: Ruth Falls Main Dam Refurbishment Variance Summary28 Table 8: 20...

AI summary The document presents a series of tables detailing various cost-related data, including archaeological costs, labour costs, materials costs, administrative overhead, and other expenses associated with projects such as the Ruth Falls Main Dam Refurbishment and the 2019 ACE and ATO applications.

2.2.3 Conclusion - In Midgard's opinion NS Power was acting reasonably in its interactions with NSECC. The delays associated - with the watercourse alteration permit issuance appear to stem from issues that originally initiated with the -...

AI summary Midgard concludes that NS Power acted reasonably in its interactions with NSECC, with delays in watercourse permits attributed to DFO's FAA process. The cost overages of $4.4 million are primarily linked to DFO delays, and this is considered a valid reason for the variance.

5.4.2 Analysis - NS Power attributes the $1,630,672 in consulting cost increase to compliance with the Fisheries Act - Authorization, including:[66](#page-41-0) - Fish ladder, louvres, and eel ramp improvements verification - Post-construc...

AI summary NS Power attributes increased consulting costs to compliance with the Fisheries Act, including fish passage improvements and environmental monitoring. Midgard notes that most costs are related to environmental and fish-related requirements, particularly due to DFO mandates.

5.4.3 Analysis – Archaeology - As discussed in Section [4.1,](#page-22-2) Midgard is of the opinion NS Power should have been aware that archaeological - costs for the Project would be several orders of magnitude higher than its estimate i...

AI summary Midgard argues that NS Power underestimated archaeological costs for the Project, which were significantly higher than estimated in the 2019 ACE. These costs were not categorized as first-level costs in the ACE or ATO Application, and there is ambiguity regarding how consulting costs under 'Archaeological Reconnaissance' align with NS Power's stated archaeology costs.

5 5.5.1 NS Power Submission - 6 NS Power did not report "Mi'kmaw Engagement" as a separate cost category in the 2019 ACE, however it did - 7 include XXXXXXX for "KMKNO Capacity Payments". The Mi'kmaw engagement costs given in the ATO - 8 A...

AI summary NS Power did not report 'Mi'kmaw Engagement' as a separate cost category in the 2019 ACE but included 'KMKNO Capacity Payments' instead. The Mi'kmaw engagement costs in the ATO Application are detailed in Table 21.

5 5.5.3 Conclusion - 6 It is Midgard's view that the "Additional KMKNO Capacity Payments" increased costs are reasonable, as NS - 7 Power was required to continue consultation with KMKNO as the Project changed. - 8 With respect to the Mi'k...

AI summary Midgard concludes that the increased costs related to Mi'kmaw engagement and Additional KMKNO Capacity Payments are reasonable, based on the need for continued consultation and the unforeseen archaeological costs associated with the ACE Project.

15 5.6.1 NS Power Submission - 16 NS Power reported AO cost increases from the 2019 ACE to the ATO Application as detailed i[n Table 23](#page-43-0) and - 17 [Table 24,](#page-43-1) which resulted in administrative overhead expense overspe...

AI summary NS Power reported increased administrative overhead expenses due to cost increases from the 2019 ACE to the ATO Application, resulting in an overspending of $627,515.

Table 23: 2019 ACE Administrative Overhead Costs[69](#page-43-2) Description Total Estimate ($) Labour AO $72,085 Contractor AO $438,973 TOTAL: $511,058 Table 24: ATO Application Administrative Overhead Costs[70](#page-43-3) Description To...

AI summary The text presents two tables detailing administrative overhead costs for the 2019 ACE and ATO application processes, including labour and contractor costs. The tables are referenced by matter numbers and exhibits from regulatory proceedings.

NS Power states that contingency was expanded to address uncertainties surrounding the potential variability of Environmental Offsetting Program costs required by DFO. NS Power confirmed that the additional contingency is exclusively alloc...

AI summary NS Power expanded contingency costs to address uncertainties in the Environmental Offsetting Program required by DFO. It estimated offsetting costs based on updated feedback, using an average of $25/m² and adding a $500,000 contingency. Midgard supports this contingency as a prudent measure to address regulatory uncertainty.

6.2.3 Analysis – Archaeological Costs Midgard notes the examples of the Tusket and Gaspereau projects identified in [Table 6.](#page-24-0) For these projects archaeological costs were originally estimated at amounts that are comparable to...

AI summary Midgard notes that archaeological costs for the Tusket and Gaspereau projects were initially estimated but later increased significantly in ATO applications, with the Tusket project increasing by 5.8x. NS Power has adjusted costs in this ATO application, but there remains a risk of further increases based on past experience.

7.1 Reasons for Variance - 1 Midgard makes the following conclusions on the three reasons for variance presented by NS Power see - 2 Sections [2,](#page-9-0) [3,](#page-18-1) and [4](#page-22-0) for additional detail: - 3 Environmental Per...

AI summary The text discusses three reasons for variance in the ACE project: environmental permitting requirements, extended construction timelines, and archaeology and Mi'kmaq engagement. While the first two are considered valid, Midgard questions the validity of the third due to NS Power's underestimation of archaeological costs.

7.3.2 Potential Additional Cost Increases - Midgard is concerned that the Project remains exposed to several risk areas (environmental compensation - costs, archaeological costs, and geotechnical risks) that have the potential to cause add...

AI summary Midgard is concerned that the Project may face additional cost increases due to environmental compensation, archaeological, and geotechnical risks. These risks could lead to cost overages beyond current contingency allowances and Class 1 error bounds. Midgard suggests that an analysis of a decommissioning option could provide more clarity on potential cost overruns.

- b) Midgard's assessment is that the identified scope changes in Table 1 stem from requirements set by the Department of Fisheries and Oceans (DFO). - Midgard differentiates between two types of scope changes: (1) cases where project plan...

AI summary Midgard Consulting Inc. explains that scope changes in the project stem from requirements set by the Department of Fisheries and Oceans (DFO). They differentiate between changes that introduce new elements and those that are adjustments to maintain project execution. Midgard also disputes the IR's characterization of the FAA application process, stating that each application follows a unique path depending on the nature of the impact and the individual assigned to the review.

CI 50518 – HYD Ruth Falls Main Dam Refurbishment - $15,445,508 (ATO) (NSUARB M10632) Midgard Consulting Inc. Responses to Industrial Group Information Requests 1 Request IR-4: 11 Midgard's report? 12 (d) Please provide a copy of any notes...

AI summary Midgard Consulting Inc. responded to information requests regarding the site visit for the Ruth Falls Main Dam refurbishment project. The visit aimed to understand project conditions and clarify NS Power's positions on the ATO application and ACE timeline. Photos and evidence were provided as part of the response.

NON-CONFIDENTIAL - a) As stated in the quoted passage, Midgard has not made any assumptions regarding how much of the - b) See IR Response 14(b). Response IR-15: - c) Yes. Regardless of whether the costs were incurred in responding to DFO...

AI summary Midgard acknowledges that the $4.4 million in cost overages is attributed to interactions with DFO or NSECC, primarily due to delays caused by DFO requirements. These delays were exacerbated by NS Power's inability to provide finalized design drawings and contractor documentation, resulting from shifting project designs and schedules.

- However, Midgard observes that the vast majority of the consulting costs in the ATO - Application are directly attributable to environmental and fish related costs. Such - increases can be considered to stem directly from the increased r...

AI summary Midgard notes that most consulting costs in the ATO application are due to environmental and fish-related costs driven by DFO requirements. It is asked to clarify what costs are not related to these factors, and Midgard responds that it has not analyzed all costs but suggests archaeological costs should have been identified during the 2019 ACE process.

Response IR-23: - a) Inasmuch as Mi'kmaq observer costs can be considered to be a part of "archaeological costs" more - generally, yes, since Midgard has concluded in its report that archaeological costs were underestimated - in the 2019 A...

AI summary Midgard Consulting Inc. responds to information requests regarding the Ruth Falls Main Dam Refurbishment project. It addresses Mi'kmaq observer costs, stating they are part of archaeological costs but not directly linked to the Fisheries Act. Midgard also explains that the increase in AO rate from 39.29% to 77.70% is based on NS Power's adherence to NSUARB-approved accounting policies.

NON-CONFIDENTIAL 1 2 drawdown, the duration of the drawdown, and an average cost of $25/m 2 of offsetting to impact area using other NS Power projects which have undergone offsetting. 3 4 5 However, NS Power does not expect this high end e...

AI summary NS Power estimates the cost of compensatory fish habitat offsetting at 20,000 m², based on past experience and feedback from DFO. Midgard supports this estimate as reasonable, aligning with DFO recommendations and similar projects. However, there is uncertainty about whether this estimate will be sufficient if higher offsetting requirements are mandated.

CI 50518 – HYD – Ruth Falls Main Dam Refurbishment ATO – Reply Evidence Redacted 1 5.0 POTENTIAL ADDITIONAL COST INCREASES 2 3 Midgard states that it is concerned that there are several areas where the project remains exposed 4 to risk for...

AI summary Midgard raises concerns about potential additional cost increases due to environmental, archaeological, and geotechnical risks beyond contingency allowances. NS Power responds by stating they have been working with the Confederacy of Mainland Mi'kmaq and DFO to address these concerns, including submitting an updated Fisheries Act Authorization with a revised offsetting plan.

10. Mi'kmaq Engagement Item Current Execution Cost Source of costs / Assumptions Sipekne'katik First Nation capacity payments Costs for 2026-2031 First Nation monitors / security during Costs for 2029-2033 archaeological reconnaissance C03...

AI summary The document outlines various financial and administrative costs associated with the Mi'kmaq engagement, contingency reserves, and administrative overheads. It includes specific items such as capacity payments to First Nations, contingency and management reserves derived from simulations, and historical overhead costs related to engineering work for dam redevelopment.

f baseline fish habitat indicators both physical (HSI surveys) biological (electrofishing and redd counts) as described in Appendix O of Supporting Information Application For Authorization Fisheries Act Ruth Falls Dam Refurbishment Sheet...

AI summary The document outlines requirements for baseline fish habitat indicators as part of the Ruth Falls Dam refurbishment project, including physical and biological surveys to be completed by December 31, 2025 and submitted to DFO.

ro capital refurbishment projects that included an extended drawdown. [36] In response to Midgard's evidence related to further potential cost increases for the project, NS Power noted the following: - The revised habitat offsetting plan a...

AI summary NS Power responded to Midgard's concerns regarding potential cost increases, habitat offsetting plans, archaeological considerations, and geotechnical issues for the project. NS Power also addressed the lack of consideration for decommissioning the Ruth Falls main dam, referencing a 2018 Hydro Asset Study that outlined decommissioning costs.

t increase in archeological costs, the Industrial Group underscored the need for an economic assessment and perhaps even an alternative that is more cost-effective while offering longer-term benefits. [48] The Industrial Group also agreed...

AI summary The Industrial Group emphasized the need for an economic assessment of archaeological costs and questioned the cost-effectiveness of the proposed refurbishment project. They recommended delaying approval of the ATO until a more thorough analysis of alternatives is conducted, citing insufficient evidence of the project's benefit to ratepayers and the lack of a FAA permit.

Submissions/Comments The SBA had no further comments beyond those noted in its March 25, 2025, closing submissions from the original ATO application. Nonetheless, the SBA continued to request that the Board require NS Power to provide regu...

AI summary The SBA reiterated its previous comments and requested regular updates from NS Power. Midgard commented on the finalized FAA, noting that it reduced project risk and adjusted cost estimates. Midgard recommended additional detail from NS Power on the updated offsetting cost estimates.

Request IR-3: - With reference to Page 5 of the Application: - a) Please provide a detailed breakdown of the approximate $1.4 million increase in materials costs, specifying how much is attributable to the additional scope (modifications t...

AI summary The request asks for a detailed breakdown of a $1.4 million increase in materials costs, specifying the portions attributable to additional scope modifications, inflation, market fluctuations, and other factors.

- l) Please describe the scope of "Offsetting (West River Project)" costs and explain how the cost was developed. m) Please provide documentation from DFO confirming the scope of the required Offsetting work. n) What is the Class level and...

AI summary The document contains a series of requests related to the West River Project and the Ruth Falls project, including inquiries about cost estimation, documentation from DFO, changes in project scope, procurement processes, and response timelines to DFO's information requests.

15 Request IR-4: 17 Reference: "Subsequent to the approval of the original filing, NS Power was required to obtain a 18 Fisheries Act Authorization (FAA) for the work from DFO, which was not required at the time of 19 original filing. This...

AI summary The document discusses the need for NS Power to obtain a Fisheries Act Authorization (FAA) after the original filing, which introduced new conditions related to fish passage and an Environmental Offsetting Program, resulting in additional costs. The questions seek clarification on the timeline and policy changes behind these requirements.

Date Filed: November 12, 2024 CA (NSPI) Page 4 of 7 1 associated with the lowering of the Ruth Falls Reservoir 18 feet below the minimum operating 2 level. This has led to additional costs of approximately $400,000." (ATO, p. 3) 3 (a) 4 Pl...

AI summary The document outlines several requests for information regarding additional costs incurred by NS Power, including engagement with the Mi'kmaq of Nova Scotia, cost increases due to labor, materials, contracts, and consulting, as well as cost minimization efforts.

20 Request IR-14: 22 Reference: "The original contingency amount remains unchanged, however additional 23 contingency has been added to cover uncertainty around the amount of offsetting costs required 24 by DFO, which has yet to be confirm...

AI summary The document requests clarification from NS Power on the basis for their claim that the offsetting costs required by DFO may vary significantly, and asks for their best estimates of the potential variance.

9 these costs. 10 12 14 17 19 24 13 Reference: NS Power states that AFUDC will increase by $612,215. 15 (a) Please provide a continuity schedule showing for each year the balances and the AFUDC 16 rates used to calculate the revised AFUDC...

AI summary The text references AFUDC (Allowance for Funds Used During Construction) increases and requests for continuity schedules. It also cites previous ATO applications for hydro projects, including Gaspereau Dam and Tusket Main Dam, and asks about improved planning efforts and their impact on the Ruth Falls project.

1 There is little concordance between the scope line items between the 2019 2 ACE and the ATO Application. 3 Preamble: At the beginning of Midgard's report, it lists the scope of the Ruth Falls 4 refurbishment project as approved in the or...

AI summary The text highlights discrepancies between the scope line items in the 2019 ACE and the ATO Application. It references Midgard's report on the Ruth Falls 4 refurbishment project and raises questions about scope changes, compliance with the CEJC, and the reasonableness of cost increases.

10 Request IR-23: 11 Reference: N-9, page 44 lines 8-14. With respect to the Mi'kmaq observer costs, as noted in Section 4.1 above Midgard considers that NS Power could have known at the time of its ACE submission that its archaeological c...

AI summary Midgard concludes that the increased Mi'kmaw engagement costs associated with NSPI's ACE submission are reasonable. The question focuses on whether NSPI should have known these costs would be higher and the basis for Midgard's assumption, particularly in relation to the Fisheries Act amendments and archaeological costs.

sed 10 offsetting was considerably less for Ruth Falls" and that "the costs / m 2 was considerably higher". 11 The DFO then asked NSPI to update the offsetting plan "based on the discussion". - 12 (a) Has Midgard reviewed these communicati...

AI summary The DFO raised concerns about the offsetting plan for Ruth Falls, noting higher costs per square meter compared to other projects. Midgard is being asked to review and explain its position on the discrepancies, including whether it has considered the DFO's communications and the spreadsheet outlining the differences.

- 28 (f) How are offsetting measurements usually determined on hydro projects 29 such as this? (g) Has Midgard considered the DFO's concerns with respect to "high 7 8 (d) If there are additional delays in receiving the FAA, would this furt...

AI summary The text includes questions about offsetting measurements on hydro projects, concerns from the Department of Fisheries and Oceans (DFO), potential delays in receiving the Federal Assessment Agreement (FAA), and the reasonableness of refurbishment costs. It also references a request for information (IR-32) and a specific page reference.

d how after approximately six years, and a number of scope changes, that NSPI is able to definitively conclude this cost difference between the other three options without actually doing the analysis. It is important to note, that based on...

AI summary The text criticizes NSPI for not adequately analyzing cost differences between project options and highlights concerns about underestimated archaeological costs, referencing previous projects like Gaspereau and Tusket. It also notes that while current archaeological costs are not overstated, there is a risk of future increases.

been in a position to provide any type of reasoned estimate of the additional cost as a result of those potential changes, but that docs not mean that they should not have identified it as a concern. The uncertainty as to the future approv...

AI summary The SBA argues that NS Power should provide regular updates to the Board regarding project delays and costs related to fisheries infrastructure and archaeological expenses. Concerns include uncertainty about DFO approval and past overspending on archaeological work.

Economic Justification: Considering Alternative Refurbishment Options The IG has been critical of the fact that the project justification for this application has not changed. NS Power agrees that the 'Justification' section of the applica...

AI summary The Industrial Group (IG) criticizes NS Power for not updating the project justification in the ATO application, while NS Power defends it as standard practice. The IG also questions whether the recommended option is truly the lowest cost for customers. The application is based on safety concerns from a Dam Safety Review, with the need to address structural issues at the Ruth Falls dam.

1.1 Project Background [5] In 2015, NS Power engaged Kleinschmidt as a consultant to assess the design adequacy of NS Power's Sheet Harbour Hydro System's water retaining structures. The assessment evaluated the structures' stability under...

AI summary In 2015, NS Power commissioned Kleinschmidt to assess the Sheet Harbour Hydro System's dam safety. The 2016 report identified deficiencies in the Ruth Falls Dam, leading to a 2019 ACE Plan approval for a project to address these issues. The current ATO application seeks increased funding due to higher environmental permitting costs, extended timelines, and expenses related to archaeology and Mi'kmaq engagement.

E application. As such, the Company asserts that the need for an FAA, driven by the 2019 amendments to the Fisheries Act and changing regulatory expectations, added substantial costs to the project. [14] Another reason cited by NS Power in...

AI summary Nova Scotia Power (NSP) attributes the need for an FAA and increased project costs to the 2019 amendments to the Fisheries Act and extended construction timelines due to additional environmental permitting requirements, resulting in approximately $2 million in increased costs.

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.

3.3 Approval of Refurbishment Project Costs [67] The Board recognizes that the current ATO application represents a significant cost increase compared to the original Board-approved project cost. However, Midgard concluded that project cos...

AI summary The Board acknowledges a significant cost increase in the ATO application for the refurbishment project but accepts that increases related to environmental permitting and the FAA are reasonable. However, risks such as environmental compensation, archaeological, and geotechnical costs remain, which could add millions to the project cost beyond the allocated contingency.

1. Offsetting Costs In its October ATO application, NSPI used 20,000 m² at $25/m² plus an additional contingency of $500,000 which allowed for total offsetting of 40,000 m². In the FAA, it outlines the permanent and temporary destruction o...

AI summary NSPI's ATO application outlines offsetting costs for habitat destruction, using a unit rate of $25/m² and a contingency of $500,000. However, the Board questions the lack of justification for this rate and highlights uncertainty around potential cost increases if a higher rate is used. The Industrial Group recommends NSPI be held to the $25/m² rate without additional contingency.

complete the offsetting work. The updated costs filed in NS Power's amended ATO application are reflective of the proponent's unit cost rate to complete the required offsetting as established by DFO. NS Power also addressed Midgard's recom...

AI summary NS Power updated the costs in its amended ATO application, reflecting the unit cost rate for offsetting work as established by DFO. They also addressed Midgard's recommendation regarding construction timelines, noting that alternative access routes eliminated the need for certain in-water installations. NS Power clarified that the decommissioning option only applies to the Ruth Falls portion of the Sheet Harbour Hydro System, with the upstream structures remaining in place.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 1 Appendix A Page 1 of 2 REDACTED (CONFIDENTIAL INFORMATION REMOVED) NSEB Approved Contingency/ Unbudgeted Spend Mi'kmaq Engagement (536450) AFUDC (605050) $884,768.00 $308,812....

AI summary This contingency report outlines approved and unbudgeted spending for the Ruth Falls Main Dam Refurbishment. It includes details on Mi'kmaq engagement, AFUDC, and administrative overheads, with specific figures for approved, contingency, and unbudgeted amounts.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 2 Appendix A Page 1 of 1 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Account NSEB Approved Amount Spend-to-Date Contingency/ Unbudgeted Spend-to-Date Comments $28,819.00 $28,819...

AI summary The contingency report details additional costs incurred during the Ruth Falls Main Dam refurbishment, including expenses for water supply arrangements, materials, and contracts, due to unforeseen conditions and changes in project scope.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 3 Appendix A Page 1 of 1 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Account NSEB Approved Amount Spend-to-Date Contingency/ Unbudgeted Spend-to-Date Comments Regular Labour (53...

AI summary The contingency report outlines additional labour costs incurred during the Ruth Falls Main Dam refurbishment, including regular, overtime, and term labour expenses. These costs were due to activities such as trap and truck operations, monitoring barn swallows, and responding to trapped deer, all part of NSPI's commitment to the Department of Fisheries and Oceans (DFO).