N-1LOCs Redacted (N-1 from M12273)
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\ \ EXTERNAL EMAIL / COURRIEL EXTERNE \ \ Exercise caution when opening attachments or clicking on links / Faites preuve de prudence si vous ouvrez une pièce jointe ou cliquez sur un lien Hello, I am writing to add my perspective to the on...
AI summary The email expresses concern over a data breach at NSP, highlighting issues with privatization, service interruptions, and the lack of alternatives. The writer criticizes the fairness of passing the cost of data breach mitigation to customers and calls for free markets or government-run power distribution.
That, in itself is a major breach of trust, during an ongoing security breach. Even now, NS Power will not provide the basic NS Power profile information to a customer calling in and requesting same. I was born in this province and have li...
AI summary The letter highlights a breach of trust by NS Power due to a security breach and failure to inform customers promptly. It criticizes NS Power for poor infrastructure maintenance, frequent power outages, and excessive rate increases, leading to financial hardship for Nova Scotians. The writer questions the government's response to these issues.
nt, and the Customer Information System replacement store or process customer personal information. For each, provide the storage and processing location per Question 2 and the vendor per Question 1. Question 10 — Customer-facing disclosur...
AI summary The text outlines several questions regarding NS Power's handling of customer data, including storage locations, vendor processing, and disclosure practices. It also raises concerns about affordability analytics and data confidentiality. The author requests transparency on jurisdictional data storage and processing and limits confidentiality claims to genuine security details.
N-17NS Power Rebuttal Evidence - Redacted
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Reasonableness of credit monitoring offer - NS Power wishes to also address INQ's finding that the initial offer of two years of credit - monitoring was not reasonable, while the subsequent offer of five years was reasonable. 38F [39](#pag...
AI summary NS Power defends its initial offer of two years of credit monitoring following a data breach, arguing it aligns with industry standards in Canada. It acknowledges that extending the offer to five years was reasonable. The discussion highlights the absence of legal or regulatory requirements for credit monitoring duration in Canada, with industry practice commonly favoring two years.
12 Expert Opinion - 13 I disagree with this finding. Customers were sent two different types of notifications: those where - 14 SINs were collected and therefore could have been affected in the Incident and those whose SINs - 15 were not c...
AI summary The expert disagrees with a finding regarding customer notifications following a data incident, arguing that the letter provided clear guidance consistent with industry standards. The use of a TransUnion call center is noted as a common practice, and any credit monitoring issues were addressed.
19 (d) Credit Monitoring Is a Protective Measure, Not a Cash Reimbursement Program - 20 NS Power has been clear that TransUnion's services were not intended to be a financial - 21 reimbursement to customers. This position is consistent wit...
AI summary NS Power clarifies that TransUnion's credit monitoring service is a protective measure, not a financial reimbursement program. The company argues that it is not standard practice for victim companies to reimburse customers for independently purchased credit monitoring services.
3 (b) The Recommendation Fails to Define an "Accredited" Monitoring Service - 4 There is no recognized accreditation body for credit monitoring services in Canada. If NS Power - 5 were required to reimburse customers for alternative servic...
AI summary The recommendation does not define an 'accredited' monitoring service, as there is no recognized accreditation body for credit monitoring services in Canada. Reimbursing customers for alternative services would require a contentious and resource-intensive process.
8 (c) Customer-Selected Alternatives Would Create Unnecessary and Uncertain Costs - 9 The value of the TransUnion myTrueIdentity service offered through NS Power's mass-enrollment - 10 breach response engagement may differ from the retail...
AI summary The text argues that customer-selected alternatives, such as the TransUnion myTrueIdentity service, may lead to unnecessary and uncertain costs. It highlights concerns about potential costs exceeding reasonable caps and the lack of clarity on reimbursement and dispute resolution.
18 (a) The Five-Year Offer Was Already Beyond Standard Practice - 19 The record establishes that NS Power's five-year offer was itself a voluntary extension beyond the - 20 two-year industry standard. Any direction to examine longer-term o...
AI summary NS Power's five-year offer is considered beyond standard practice, as only six percent of Canadian companies offered five years of credit monitoring in 2025. The document emphasizes that the offer should not be viewed as inadequate but rather as a forward-looking governance measure.
N-23M12835 Exhibit N-2 Att 3 2025 Managements Discussion AnalysisHIGHLIGHTED
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Consolidated Statements of Income For the Three months ended Year ended millions of dollars December 31 December 31 2025 2024 2025 2024 Operating revenues $ 504 $ 479 $ 1,944 1,855 $ Fuel for generation and purchased power 269 (216) 1,065...
AI summary The consolidated statements of income for Nova Scotia Power Inc. show operating revenues of $504 million for the three months ended December 31, 2025, and $1,944 million for the year ended. Fuel costs and other deferrals, operating expenses, and income from operations are detailed, with net income at $22 million for the quarter and $141 million for the year.
NSPI has a contractual obligation to pay NSPML, a related party, for the use of the Maritime Link over approximately 38 years from its January 15, 2018, in-service date. On December 23, 2025, NSPML received an Interim Order from the NSEB t...
AI summary NSPI has a long-term contractual obligation to pay NSPML for the use of the Maritime Link. An interim order allows NSPML to collect up to $199 million from NSPI in 2026, with a monthly holdback. NSPI's financial obligations include debt, pension contributions, and various operational and service contracts.
PENSION FUNDING For funding purposes, NSPI determines required contributions to its registered defined benefit pension plans based on smoothed asset values. This reduces volatility in the cash funding requirement as the impact of investmen...
AI summary NSPI determines pension fund contributions based on smoothed asset values to reduce volatility. In 2026, $10 million is expected for defined benefit plans, with $9 million for defined contribution plans. Investments are managed by external managers, focusing on long-term returns and risk management.
Guarantees and Letters of Credit As at December 31, 2025, the Company had $94 million USD (2024 - $104 million USD} of guarantees outstanding with terms of varying lengths, all of which are issued on behalf of NSPEMI. As at December 31, 20...
AI summary As of December 31, 2025, the Company had $94 million USD in guarantees and $6 million USD and $8 million CAD in letters of credit outstanding, all issued on behalf of NSPEMI. These figures represent a decrease from the previous year.
General Economic Risk The Company has exposure to the macro-economic conditions in Nova Scotia. Like most utilities, economic factors such as consumer income, employment and housing affect demand for electricity, and in turn the Company's...
AI summary The Company faces economic risks influenced by Nova Scotia's macroeconomic conditions, including impacts on customer affordability of rate increases and potential challenges in recovering costs and regulatory assets due to adverse economic changes and inflation.
Public Health Crisis Risk An outbreak of infectious disease, a pandemic or other public health threats, or a fear of any of the foregoing, could result in a Material Adverse Effect to NSPI. This could include causing operating, supply chai...
AI summary A public health crisis, such as an infectious disease outbreak or pandemic, could lead to a Material Adverse Effect on NSPI by causing operational delays, supply chain disruptions, labor shortages, and impacts on demand, revenue, and capital investments.
Commercial Relationship Risk The Company is exposed to commercial relationships risk in respect of its reliance on certain key partners, suppliers and customers. For the year ended December 31, 2025, NSPl's five largest customers contribut...
AI summary The Company faces commercial relationship risk due to its reliance on key partners, suppliers, and customers. In 2025, the five largest customers contributed 7% of electric revenues, and losing a major customer could significantly impact operating revenues and lead to a Material Adverse Effect.
Supply Chain Risk NSPl's ability to meet customer energy requirements, respond to storm-related disruptions and invest in capital in a cost-effective and timely manner are dependent on maintaining an efficient supply chain. Domestic and gl...
AI summary NSPI's ability to meet energy demands, manage disruptions, and invest in capital is dependent on an efficient supply chain. Supply chain issues, trade restrictions, inflation, labor shortages, and international conflicts could delay deliveries, increase costs, or cause shortages of critical materials and resources.
Commodity Price Risk The Company's fuel supply is subject to commodity price risk. The Company's fuel supply is exposed to broader global market conditions, which may include impacts on delivery reliability and price, despite contracted te...
AI summary The Company's fuel supply is subject to commodity price risk due to global market conditions, including currency fluctuations, geopolitical risks, and supply disruptions. NSPI aims to hedge 50-100% of fuel costs for 2026 and 50-90% for 2027, adjusting as needed to maintain fuel cost stability and minimize transaction costs.
Future Employee Benefit Plan Performance and Funding Risk NSPI has both defined benefit and defined contribution employee benefit plans that cover both employees and retirees. The defined benefit plan is closed to new entrants. The cost of...
AI summary NSPI manages defined benefit and contribution employee plans, with the defined benefit plan closed to new entrants. The cost of the defined benefit plan is influenced by investment performance, interest rates, inflation, and actuarial assumptions. Future contributions may increase due to changes in these factors, potentially leading to a Material Adverse Effect.
Uninsured Risk NSPI maintains insurance to cover accidental loss suffered to its facilities, and to provide indemnity in the event of liability to third parties. A significant portion of NSPl's transmission and distribution assets are not...
AI summary NSPI maintains insurance for some of its assets but a significant portion of its transmission and distribution assets remain uninsured due to high costs. NSPI also has deductibles and self-insured retentions. Uninsured claims or claims exceeding coverage limits could have a Material Adverse Effect if regulatory recovery is not available.
The Company has the following categories on the Consolidated Balance Sheets related to derivatives receiving regulatory deferral: As at December31 December31 millions of dollars 2025 2024 Derivative instrument assets (current and other ass...
AI summary The Company's Consolidated Balance Sheets show changes in derivative instrument assets, regulatory assets, and related liabilities as of December 31, 2025, and December 31, 2024, with a net asset of $2 as of December 31, 2025.