Topic:"Asset Management" in M11927

4.4 Contingency Planning The hydrological information provided below references the Sheet Harbour system flood study, which was completed as part of NS Power's dam safety program in addition to the system dam safety reviews. NS Power does...

AI summary NS Power provides hydrological information from the Sheet Harbour system flood study as part of its dam safety program. Flood study reports are generally not included in watercourse alteration applications due to confidentiality concerns related to the dam safety program.

4.4 Contingency Planning The hydrological information provided below references the Sheet Harbour system flood study, which was completed as part of NS Power's dam safety program in addition to the system dam safety reviews. Figure 2 below...

AI summary This section discusses contingency planning, referencing a flood study for the Sheet Harbour system and an elevation-storage curve for Ruth Falls from a 2008 study by Hatch. It is part of NS Power's dam safety program.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO (NSUARB M11927) NSPI Responses to The Industrial Group Information Requests 1 Request IR-3: 5 (c) Can the Malay Falls hydro generating station still produce energy, if Ruth Falls were...

AI summary NSPI responds to a request regarding the decommissioning of Ruth Falls Generating Station, stating that Malay Falls could still generate energy but would require additional investment to maintain tailwater levels. The station has a remaining life of at least 14 years for major components and is part of the long-term investment plan for small hydro assets.

REFERENCES Kleinschmidt (Kleinschmidt Associates). 2015. 2015 Sheet Harbour Hydro System Dam Safety Review. December 2015.

AI summary A reference to a 2015 dam safety review conducted by Kleinschmidt Associates for the Sheet Harbour Hydro System.

6.0 Facilities & Hygiene Cleaning/sanitizing supplies will be available at all Elliot Group sites and all personnel are encouraged to maintain a clean and healthy site. Handrails, door knobs, vehicles door handles and steering wheels, equi...

AI summary The document outlines hygiene and facility management practices at Elliot Group sites, including cleaning protocols, provision of disinfectants, portable toilets, and changes to break and water access procedures to ensure cleanliness and prevent cross-contamination among employees.

2.0 DESCRIPTION OF PROPOSED WORK, UNDERTAKING OR ACTIVITY NSPI is proposing refurbishment of the Ruth Falls Dam (the "Project"), located on the Sheet Harbour Hydro System in Sheet Harbour NS, in 2021. This work is necessary in order to add...

AI summary NSPI proposes to refurbish the Ruth Falls Dam to address structural and safety issues, in line with CDA guidelines. The project involves replacing stop-log bays with rubber dams and vertical lift gates, modifying spillway structures, and temporarily lowering the reservoir for construction. Fish conveyance systems will be dewatered during the work.

CONTINGENCY PLANNING Table 4 demonstrates the statistical flood peaks for the Ruth Falls Main Dam, from the 2008 Sheet Harbour Hydro System Flood Study.

AI summary Table 4 presents statistical flood peak data for the Ruth Falls Main Dam, derived from the 2008 Sheet Harbour Hydro System Flood Study.

Post‐Construction Monitoring NS Power will monitor the operation of the new dam structure as part of its regular bi‐annual dam inspection and maintenance program as well as weekly inspections conducted by Hydro Operations. NS Power does no...

AI summary NS Power plans to monitor the new dam structure through regular bi-annual inspections and weekly checks by Hydro Operations, and does not expect erosion or scour issues downstream.

5.1 OVERVIEW Once construction is complete, NS Power will monitor the operation of the new dam structure as part of its regular bi-annual dam inspection and maintenance program as well as weekly inspections conducted by Hydro Operations. T...

AI summary NS Power will conduct bi-annual and weekly inspections of the new dam structure and fish passage improvements post-construction. A two-year monitoring program will evaluate the effectiveness of these improvements, focusing on migration impacts and overall dam operation.

CI 50518 NSUIARB IR-12 Attachment 12 Page 420 of 576 REDACTED (CONFIDENTIAL INFORMATION REMOVED) A B C D E F42 Channel Connection & The most persistent surface water connection (outlet channel or pipe, ditch, or overbank water exchange) be...

AI summary The document discusses the identification of the most persistent surface water connection between an Area of Assessment (AA) and a downslope stream network, emphasizing the importance of considering all surface water connections regardless of freezing conditions and the use of topographic maps for determination.

5.2.5 Conclusion - 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 additional overages to - Pro...

AI summary Midgard is concerned that the Project faces risks such as environmental compensation, archaeological, and geotechnical costs, which may lead to overages beyond current contingency allowances. Midgard suggests that if NS Power had analyzed a decommissioning option, it might have clarified the extent of potential cost overruns and their impact on the economic analysis favoring reinvestment.

M&A DUE DILIGENCE - § Technical due diligence of hydroelectric project portfolios in Canada, US and Internationally - § Risk profiling and asset valuation

AI summary The document outlines the scope of M&A due diligence, focusing on technical evaluation of hydroelectric project portfolios across multiple countries and risk profiling and asset valuation.

P R O F E S S I O N A L E X P E R I E N C E – H Y D R O E L E C T R I C CRANBERRY CREEK HYDROELECTRIC PROJECT ( 2023 to present) – A run-of river project in British Columbia's interior. Asset condition assessment and capital investment pri...

AI summary The text outlines the professional experience of an individual in hydroelectric projects, including advisory roles in asset assessments, project optimization, and technical advisory services in regulatory proceedings across Canada and Sierra Leone.

6.2.5 Conclusion - 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 additional overages to - Pro...

AI summary Midgard expresses concern that the Project is exposed to environmental, archaeological, and geotechnical risks that may lead to cost overruns beyond current estimates. It suggests that an analysis of a decommissioning option could provide more clarity on potential cost increases and the economic viability of reinvestment in the Project.

- Midgard suggests that the NSUARB should have been afforded the ability as part of this proceeding - to evaluate whether or not a decommission option would be in the best interest of NSPI's ratepayers - and expresses concern that the Proj...

AI summary Midgard suggests that the NSUARB should have the ability to evaluate decommission options for NSPI's assets and expresses concerns about the Project's exposure to risks. Midgard recommends that the NSUARB require reasonable forecasting of future capital expenditures for assets as part of ATO proceedings and incorporate these forecasts into a full life-cycle decision-making process.

1 4.0 DECOMMISSIONING 2 3 In its evidence, Midgard states: 4 …despite Project costs increasing by 113% and $8.2M, NS Power has not re-5 evaluated its decision to not consider a decommissioning option. Midgard 6 understands the stated justi...

AI summary Midgard argues that NS Power should have considered decommissioning the Ruth Falls Dam and Powerhouse, despite increased project costs, and that the NSUARB should have evaluated this option for ratepayer benefit. NS Power responded by analyzing decommissioning costs based on existing data and forecasts from 2025 to 2035.

22 Figure 4: Decommissioning Activities by Year Year Activity 2025 Development of the conceptual design for Ruth Falls main dam and powerhouse decommissioning including cofferdam design 2026-2028 Completion of the detailed design for the d...

AI summary This section outlines the timeline for decommissioning activities at Ruth Falls, including the development of conceptual design in 2025, detailed design and environmental assessment from 2026 to 2028, and demolition in 2029. The process involves consultation, baseline data collection, and environmental permitting.

CI 50518 – HYD – Ruth Falls Main Dam Refurbishment ATO – Reply Evidence Redacted 2030-2031 Sediment management and archaeological reconnaissance of the exposed shoreline. Sedimentation management is a large work scope during hydro decommis...

AI summary The document outlines decommissioning activities for the Ruth Falls Main Dam, including sediment management, environmental monitoring, and habitat restoration from 2030 to 2035. It also mentions the categorization of decommissioning costs.

CI 50518 – HYD – Ruth Falls Main Dam Refurbishment ATO – Reply Evidence Redacted - 1 with a broad range of accuracy ranging from -50 to +100 percent. Please refer to Appendix A for - 2 a detailed breakdown of the contingency and management...

AI summary The reply evidence argues that refurbishing the Ruth Falls Main Dam is the most economical option for NS Power, emphasizing that decommissioning would lead to higher costs for customers due to the need to replace lost renewable energy generation.

eting dam sill refurbishment work before the start of Nova Scotia's hurricane season. If construction is not commenced by July 21, then the Company may be in a position where July 4, 2025 C. Henwood it must defer the remainder of the capit...

AI summary NS Power needs to commence dam sill refurbishment work by July 21, 2025, to avoid deferring the project and facing cost escalations and potential regulatory delays. Deferral would require an amendment to its FAA, which could involve additional regulatory review and engagement with the Mi'kmaq of NS.

Div ision : Power Production Date : • 3-J ul-25 Dep partment : Capital Projects CI Number: 50 518 Project No. : H7 792 • 1 Ţ , , 1 1 After Tax PV of EVA / _ 1 _ - Α _ В mmissioning 1 - - 0 NA N/ 4 NA NA #NUM! 0.0 years Red Capital Projects...

AI summary The document contains a redacted section related to the Capital Projects CI Number 50518, Project No. H792, focusing on the partial decommissioning of the Ruth Falls Main DAM and its infrastructure, including demolition of the dam and powerhouse from 2025 to 2035. It includes financial and project-related data, such as NPV, EVA, and other technical terms.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by NOVA SCOTIA POWER INCORPORATED for approval of an Authorization to Overspend in the amount of $8,201,086 on capital application project CI 50518 – HYD Rut...

AI summary Nova Scotia Power Inc. applied for an Authorization to Overspend on a dam refurbishment project, but the decision is held in abeyance until they obtain a Fisheries Act Authorization. Once obtained, they must submit an amended application with a Net Present Value analysis comparing refurbishment and decommissioning options.

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.

on and will meet this condition of the FAA. As such, Midgard recommended that NS Power should provide an update on the status of this work and of the associated FAA condition in its reply submissions. Midgard's review of NS Power's Economi...

AI summary Midgard recommended that NS Power provide an update on the status of work related to the FAA condition. While Midgard found NS Power's Economic Analysis Model (EAM) to be robust, it noted that supporting cost information for decommissioning was not provided and that the scope of the decommissioning cost estimate was unclear.

$25/m2 cost NS Power had estimated in its original ATO application. In this case, the Board finds that it is not necessary to hold NS Power to the $25/m2 , as was recommended by the Industrial Group. As it relates to NS Power's EAM compari...

AI summary The Board finds that NS Power does not need to adhere to the $25/m² cost estimate from its original ATO application. While the EAM shows that refurbishment of the Ruth Falls main dam is preferred over decommissioning based on NPV analysis, the Board acknowledges limited supporting cost information for the decommissioning option. Sensitivity analysis supports the refurbishment decision despite increased project costs.

- 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 9 (a) Having not reviewed the decommissioning option specifically for Ruth F...

AI summary The question asks how offsetting measurements are determined on hydro projects, and the text includes a table with questions related to decommissioning options for the Ruth Falls project and Midgard's considerations regarding the Board's involvement.

Possible Decommissioning Nova Scofia Power states in its original applicafion that it considered five different opfions for carrying out the refurbishment that was required to the dam, spillway and sluiceway and chose the opfion that was m...

AI summary Nova Scotia Power considered refurbishment as the most cost-effective option for the Ruth Falls dam but did not reassess this decision or evaluate decommissioning costs in its application. Midgard Consulting suggested decommissioning might not be economic, but the Consumer Advocate recommends including decommissioning as an option in future applications.

is not complete, it should provide further explanation for why it believes it has done sufficient surveying of the shoreline for archaeological sites for the Ruth Falls Main Dam Refurbishment project. The issue of decommissioning is one th...

AI summary The Small Business Advocate (SBA) argues that cost should be a leading factor in considering the decommissioning of the Ruth Falls Main Dam, alongside environmental regulations and load requirements. The SBA emphasizes the need for updated studies, including a Hydro Asset Plan, to better understand the costs and benefits of decommissioning for Nova Scotia ratepayers.

Economic Justification: Considering Decommissioning The increased environmental regulatory requirements from DFO relating to Fisheries Act Authorization (FAA) permits do not apply exclusively to refurbishment projects. Decommissioning hydr...

AI summary The text discusses the economic justification for decommissioning hydroelectric sites, noting that decommissioning is more costly than refurbishment and has significant environmental and water management impacts. NS Power provided an estimate of decommissioning costs, but the IG criticized the lack of detailed explanation for these figures.

REPLY TO SUBMISSIONS OF THE SMALL BUSINESS ADVOCATE As noted in its response to the CA Submissions above, and in response to the SBA's submissions, NS Power will commit to providing decommissioning costs in future hydro applications, as ap...

AI summary NS Power will provide decommissioning costs in future hydro applications and has updated its Hydro Asset Study. It will provide regular updates to the Board regarding DFO costs and project plans. NS Power disagrees with pausing the ATO application until the FAA permit is granted, citing progress made with DFO and the Mi'kmaq.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by NOVA SCOTIA POWER INCORPORATED for approval of an Authorization to Overspend in the amount of $8,201,086 on capital application project CI 50518 – HYD Rut...

AI summary Nova Scotia Power Inc. applied for an authorization to overspend on a dam refurbishment project, but the decision is held in abeyance until they obtain a Fisheries Act authorization. Once obtained, they must submit an amended application with a Net Present Value analysis comparing refurbishment and decommissioning options.

ated entirely to DFO requirements, so changes to the project cost and timeline would apply to all refurbishment options, as drawdown is the primary driver of the environmental permitting requirements. [55] NS Power also submitted that it a...

AI summary NS Power argues that changes in DFO requirements, including the Fisheries Act amendments, have impacted project timelines and costs for refurbishment and decommissioning. It emphasizes that it acted prudently in its original application and that updated cost estimates reflect revised requirements and scope.

3.4 Decommissioning Cost [74] When the Ruth Falls project was included in the 2019 ACE Plan, NS Power had two choices to address safety concerns arising from the related dam safety review: either decommission the dam or refurbish it. At th...

AI summary The Ruth Falls project's decommissioning cost was not chosen in 2019 due to higher costs compared to refurbishment. The refurbishment extends the dam's life by 50 years and maintains 7.2 MW of renewable power. However, ongoing capital investments and operating expenses are required. The document suggests that if decommissioning and procuring alternative power proved more cost-effective, it would have been in ratepayers' best interest.

5.2.1 Cost of Decommissioning Alternative - In the provided economic analysis, the capital cost requirement of the Partial Decommissioning alternative is - given as $74.4 M. This is spent over a period of 2025 through 2035, with the bulk o...

AI summary The economic analysis discusses the discrepancy in decommissioning costs for the Ruth Falls facility within the Sheet Harbour system. NS Power's estimate of $74.4 M for partial decommissioning over 2025–2035 is questioned, especially since a 2018 study estimated full system decommissioning at $55.46 M, which escalated to about $68.2 M by 2025. The higher cost for a smaller portion of the system raises concerns about decommissioning cost estimation practices.

CONCLUSIONS 1 Based on its review, Midgard has arrived at the following overall conclusions: 2 3 • The issuance of an FAA to the Project removes a significant area of risk and has reduced the estimated cost to complete. 4 5 6 • The timelin...

AI summary Midgard concludes that obtaining an FAA reduces risk and cost for the Project, but timelines imposed by the FAA remain a risk. The economic analysis supports refurbishment, though NS Power's decommissioning cost estimate is significantly higher than previous estimates and lacks supporting information.

Delivered by E-mail Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 3rd Floor, 1601 Lower Water Street PO Box 1692, Unit "M" Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M11927 - NSPI - CI 50518 – HYD Ruth...

AI summary The Industrial Group submits comments on M11927 regarding the Ruth Falls Main Dam Refurbishment ATO, addressing unit rates for offsetting, decommissioning, and reporting.

Background In its Application for Authorization to Overspend (" ATO" ), NSPI sought approval for an additional $8.21 million on corrective actions regarding the main dam representing more than a doubling of the original approval of $7.24 m...

AI summary NSPI sought approval for an additional $8.21 million in corrective actions for the main dam, increasing the total project spend to $15.45 million. The Board held the ATO application in abeyance until the final FAA from DFO is received, and required an updated cost estimate and a decommissioning cost analysis in the amended application.

2. Decommissioning Costs In comparing the refurbishment versus the decommissioning option, it appears that the capital investment over time is greater for refurbishment, but it becomes more economic when factoring in the cost of replacing...

AI summary The text discusses decommissioning costs for a hydro plant, comparing refurbishment and decommissioning options. NSPI provided a capital cost for partial decommissioning, but the definition of 'partial' is unclear. The Industrial Group recommends more detailed information on decommissioning options and their environmental impact.

Decommissioning In its submission, Midgard assumes that the cost estimate provided is for the decommissioning of only the Ruth Falls portion of the Sheet Harbour System.[4](#page-2-0) This is a correct assumption. When discussing decommiss...

AI summary Midgard assumes the cost estimate is for decommissioning only the Ruth Falls portion of the Sheet Harbour System. It argues that partial decommissioning is appropriate, as upstream structures like Malay Falls would remain. Midgard also raises concerns that decommissioning Ruth Falls is more costly than decommissioning the entire Sheet Harbour Hydro System, citing exclusions in Hatch's 2018 Hydro Asset Study.

Economic Analysis Results Midgard indicatesthat its review of the EAM suggests the outcome is reasonable, given the inputs. Midgard also indicates that it completed a sensitivity analysis where it made extreme adjustments to the decommissi...

AI summary Midgard's economic analysis of the EAM concludes that the outcome is reasonable, and sensitivity analysis shows that refurbishment remains the preferred option even with extreme adjustments to decommissioning and replacement energy costs.

Decommissioning While speaking about decommissioning the Ruth Falls Hydro system, the IG states: While NSPI has it labelled as "partial decommissioning", it is unclear what makes it "partial" versus full when it includes full dam and power...

AI summary The document discusses the decommissioning of the Ruth Falls Hydro system, with the IG noting that the term 'partial decommissioning' is unclear. NS Power agrees to include decommissioning costs in future applications but does not support developing multiple alternatives for partial decommissioning due to differences in net present value.

on and will meet this condition of the FAA. As such, Midgard recommended that NS Power should provide an update on the status of this work and of the associated FAA condition in its reply submissions. Midgard's review of NS Power's Economi...

AI summary Midgard recommended that NS Power update the status of work related to the FAA condition. While the EAM results appear reasonable and robust under sensitivity analysis, Midgard noted missing cost information and assumptions regarding decommissioning scope.

ult in an onerous regulatory burden. Therefore, given project cost concerns expressed by parties during this proceeding, the Board finds that regular project reporting by NS Power would be beneficial. As such, the Board directs NS Power to...

AI summary The Board finds that regular project reporting by NS Power is necessary to address regulatory concerns and ensure transparency. It also agrees with NS Power's position on decommissioning options but notes that future applications may require more detailed alternatives if the NPV differences are marginal.