Topic:"Capacity Costs" in M12696

4.2 Relief for Planned and Unplanned Outages As noted in Concentric's evidence, planned as well as unplanned outages are expected and necessary for maintaining complex assets in accordance with Good Utility Practice. The Board's Decision r...

AI summary NSPML seeks relief for planned outages in 2023-2024 and an April 2024 shortfall, citing Good Utility Practice and exceptional circumstances. The NSEB may grant relief if conditions are met, terminating the monthly holdback mechanism. Outages relate to LIL infrastructure.

11 Q17. HAVE DELIVERIES OVER THE MARITIME LINK IMPROVED SINCE THE 12 HOLDBACK MECHANISM WAS IMPLEMENTED? 13 A17. Yes. Since the holdback mechanism restructuring in February of 2022, deliveries over the 14 Maritime Link have improved signif...

AI summary Since the 2022 holdback mechanism restructuring, Maritime Link deliveries exceeded 90% monthly thresholds for 11 of 12 months (excluding planned outages). NS Block deliveries reached 140% of contractual requirements, with winter deliveries exceeding 140% when including make-up energy. Shortfalls were redelivered, and the net undelivered energy balance fell below 10% by March 2024. April 2024 deliveries temporarily dipped below 90% due to extreme weather but were later rectified.

1 Q46. SINCE THE LIL COMMISSIONING IN APRIL OF 2023 HAVE NSPI'S 2 CUSTOMERS BEEN HARMED BY UNDER DELIVERIES OF THE NS BLOCK? 3 A46. No, they have not. For the Compliance Period, Nova Scotians have received approximately 4 170% of the contr...

AI summary NSPI customers have not been harmed by under deliveries of the NS Block since the LIL commissioning in April 2023. Customers received 170% of contractual volumes, and the Maritime Link provided economic value exceeding $90 million annually. No financial harm was incurred, and Muskrat Falls assets are expected to deliver increasing benefits.

NSPML Responses to Bates White Information Requests 1 Request IR-01: 2 3 Please refer to Exhibit N-1, page 11 lines 15-16 and footnote 11, and Appendixes A and C. 4 5 (a) Please confirm that NSPML has not included Supplemental Block volume...

AI summary NSPML responds to Bates White's information requests regarding the inclusion of Supplemental Block volumes in Appendix A and C. NSPML confirms that Supplemental Block volumes are included in the calculation of Make-up Balance and provides details on the annual contracted amount and deferred energy balance.

PARTIALLY CONFIDENTIAL 1 Energy balance was essentially eliminated. NSPML's belief is that the economic difference 2 between the two for the Compliance Period will be relatively small given Make-up Energy 3 deliveries were on a timely basi...

AI summary NSPML asserts that energy balance differences during the Compliance Period will be minimal due to timely Make-up Energy deliveries under the Energy & Capacity Agreement. It supports NLH's planned outages during low-load periods, acknowledging higher holdback amounts but noting limited customer impact. The Similar Value Analysis, expected in July, may affect future energy value assessments.

PSH continues to be the preferred least cost technology option for 4–16 hours duration storage. » Energy storage cost for 4–16 hours duration is even lower for compressed air energy storage (CAES), but there are only two CAES projects inst...

AI summary Pumped Storage Hydropower (PSH) remains the preferred least-cost option for 4–16 hour energy storage despite compressed air energy storage (CAES) having lower costs. However, CAES has limited global deployment (only two projects) compared to over 150 PSH installations, influencing technology preference.

5.1.2 Pumped Storage Hydropower For energy storage applications requiring short cycles and extremely rapid responses, battery systems are projected to become cost-competitive relative to PSH by 2025; PSH is expected to remain the least exp...

AI summary Pumped Storage Hydropower (PSH) remains the least expensive option for long-cycle energy storage through 2025, while batteries may become cost-competitive for short-cycle applications. PSH dominates U.S. bulk storage capacity but lacks recent projects, relying on international cost data. Future PSH deployment depends on advancements in competing technologies like batteries.

Labrador Interconnected Group Senwung Luk, Olthuis Kleer Townshend LLP Julia Brown, Olthuis Kleer Townshend LLP March 12, 2021 11 hydro a nalcor energy company NSPML 2026 Holdback Mechanism BW IR-15 Attachment 1 Page 4 of 134

AI summary The document references the NSPML 2026 Holdback Mechanism, BW IR-15 Attachment 1, and involves Hydro and Analcor Energy Company, dated March 12, 2021.

3.1.2 Method 2: Previous Construction Data The second method used to develop a per km cost estimate for reinstatement of the electrode lines onto new wood pole line was to review construction costs from when Locke's electrical completed in...

AI summary Method 2 for estimating the per km cost of reinstating electrode lines onto new wood pole lines involves reviewing previous construction costs from Locke's electrical installation of a wood pole electrode line in Southern Labrador as part of the LIL project.

NSPML Responses to Industrial Group Information Requests 1 Request IR-05: 2 3 Reference: N-01 Application, p. 15, lines 5–12; Appendix A and Appendix C page 4 36 of 37. 5 Preamble: The Application states that deliveries were over 100% (bot...

AI summary NSPML is requested to detail the 'winter readiness outage' in September 2023, including work performed, outage duration, scheduling rationale, and whether similar outages occurred in 2024/2025. The Application cites conflicting MWh shortfall figures (6,000 vs. 6,500) and asks to confirm if the shortfall was solely due to the outage.

PARTIALLY CONFIDENTIAL traditional oversight of holding NSPML and NS Power responsible for management of its assets and the associated agreements with NLH. NSPML believes it is important to acknowledge that 100 percent of the holdback disa...

AI summary NSPML argues that holdback disallowances stem from counterparty performance, not their own, and emphasizes alignment with the Lower Churchill Project's goals, including renewable energy offsetting fossil fuels and capacity enabling plant closures. They assert the Board did not expect perfectly level energy deliveries.

Cable utilization . The utilization of a submarine cable link depends largely on the type of the application (cf. Table 3.8). For a specific cable link the utilization may vary largely from week to week and over the years. Recycling costs/...

AI summary The text discusses factors influencing submarine cable utilization and recycling, including the trade-off between capital and operational expenditures, the impact of energy prices on conductor size selection, and the potential value of copper recovery post-cable life. Larger conductor sizes may be more economically beneficial in the long term, especially with rising energy prices and metal values.

15 The table above shows that in 2023 and 2024 customers received more energy (NS Block Energy 16 plus Make-up Energy) than the Contract amount. This higher energy represents the Deferred 17 Energy that was not redelivered in 2021 and 2022...

AI summary The text discusses the Deferred Energy not redelivered in 2021 and 2022, which was received by customers in 2023 and 2024. By March 2024, the Deferred Energy represented 9% of the annual contracted NS Block, meeting a condition for terminating the holdback mechanism. By June 2024, the balance of undelivered energy was less than 10% of the NS Block annual contracted amount.

PARTIALLY CONFIDENTIAL 1 In terms of Purchased Energy volume, the average offered by NLH in the first three years was 2 approximately per year; however, the qualifying EAA quantities have been impacted by 3 various items including low hydr...

AI summary The text discusses NS Power's purchase of energy from NLH based on economic factors, the impact of low hydrology and deferred energy balances on EAA quantities, and the capacity benefits provided by the Maritime Link. Pricing assumptions are based on MassHub forecasts from 2013-2040.

stion turbine plant in stand by on day one. Similarly, the incremental additions provide for a more attractive cumulative present worth cost alternative over the single 800 MW up front stand by plant. By comparison, Table 7 provides the im...

AI summary The text discusses the cost-effectiveness of incremental additions of combustion turbines compared to a single 800 MW standby plant, highlighting a reduction in the number of turbines needed when the Maritime Link is included, thereby lowering exposure to permanent loss of the bipole.

NON-CONFIDENTIAL - 1 winter period with Make-up Energy deliveries on a timely basis or pushed closer to the winter - 2 period are likely to provide significantly similar value. 3 - 4 The holdback mechanism is also based on a uniform delive...

AI summary The text compares a uniform delivery pattern in the holdback mechanism to the Energy and Capacity Agreement's flexibility, including +/- 40 MWh adjustments and alternative value exploration. It references BW IR-07 for context on these terms.

Q. Please summarize your evidence with respect to NSPI's application. - A. NSPML clearly satisfied one of the conditions for ending the Holdback. Specifically, by the - end of March 2024, the net outstanding balance of undelivered energy w...

AI summary NSPML met the 'Reduction in Undelivered Volumes' threshold (9% undelivered energy) but faced ambiguity in meeting the 'Consistent Deliveries' threshold due to reliance on exceptions and factors like winter weather and LIL design issues. Future LIL performance is deemed risky based on NLH's filings and resource planning.

- 2024, and 2025. NSPML (NSEB) IR-006 Attachment 1. Table 1. Calculation of required annual Base, Supplemental, Total NS Block (2022) (MWh)[36](#page-11-1) 1 Year Base Block Supplemental Block Total NS Block January 83,742 49,272 133,014 F...

AI summary The document presents a table detailing the calculation of required annual Base and Supplemental NS Block volumes for 2022, with data provided for each month and the total for the year. NSPML is noted as appropriately calculating the total undelivered volumes of these blocks.

Table 2. Calculation of undelivered and makeup volumes of Base Block (2021-2025) (MWh)[37](#page-12-1) 1 Month/Year Contract Net Undelivered Net Undelivered Volume Delivered Undelivered Makeup (Month) (Cumulative) Aug-21 45,923 6,131 39,79...

AI summary Table 2 presents the calculation of undelivered and makeup volumes for the Base Block from 2021 to 2025, detailing monthly and cumulative figures in megawatt-hours (MWh). The data includes net undelivered volumes, makeup volumes, and the resulting volume delivered for each month.

3 4 Next, [Table 3](#page-13-0) shows the calculations for the Supplemental Block. 1 Table 3. Calculation of undelivered and makeup volumes of Supplemental Block (2021-2025) (MWh)[38](#page-13-2) 2 3 4 Supplemental Block Month/Year Contrac...

AI summary The text provides a table showing calculations for the Supplemental Block, detailing undelivered and makeup volumes from 2021 to 2025. It outlines monthly and cumulative net undelivered volumes, and includes references to attachments for further information.

Date Filed: May 7, 2026 Page 17 2 40 NSPML (NSEB) IR-006 Attachment 1. - Block was reduced to 9.0% of the annual contract volume under the Energy and Capacity - Agreement. - Q. [Table 5](#page-16-0) shows that cumulative net undelivered vo...

AI summary The response indicates that NSPML did not fail to meet the Board's 'Reduction in Undelivered Volumes' threshold, as the threshold was achieved in March 2024 and there is no requirement for cumulative net deliveries to remain under 10% indefinitely. Undelivered volumes fell below 10% again in November 2024 and remained near zero thereafter.

11 - 13 Q. For the four months in which deliveries were below threshold, did NSPML claim - 14 that the deficiencies were explained by "good utility practice" and/or "exceptional - 15 circumstances?" 48 NSPML Application, page 10 lines 12 t...

AI summary NSPML claims that deficiencies in NS Block volumes during four months were due to 'good utility practice' and 'exceptional circumstances,' specifically citing a planned LIL outage in July 2023 and other factors related to the LIL's performance, not Muskrat Falls or the Maritime Link.

Q: What evidence has NSPML provided to justify its request for relief? - A: NSPML has identified four events that resulted in the four months in which less than 90% of the NS Block was received. - 1. July 2023 Planned Outage – The outage i...

AI summary NSPML attributes four events—planned outages, maintenance, and an ice-related incident—to reduced NS Block delivery below 90%. It argues these meet the Board's relief standards, with Concentric confirming higher delivery rates absent these events. A holdback of $15.4 million was imposed due to continued underperformance post-Compliance Period.

hern California Edison's 2021 general rate case (track 2) on behalf of the Small Business Utility Advocates. Reasonableness of remedial software costs to be included in authorized revenue requirement. Georgia PSC Docket Nos. 4822, 16573 an...

AI summary Expert testimony details involvement in multiple regulatory cases, including fuel adjustment mechanism audits, rate design reviews, and compliance with Commission orders. Key topics include cost recovery, resource planning, and modifications to pricing programs in California and Nova Scotia proceedings.

ths NSPML has met the requirements in provision (2) and provide a workbook with the data included in the graph shown in Exhibit N-1, p. 14. Request IR-3: With respect to Exhibit N-1, Appendix B, 1. Please explain the reason(s) for under de...

AI summary The document includes a request for NSPML to explain under delivery reasons, provide detailed calculations for holdback amounts, and clarify the causes of LIL outages. It also requests WACC calculations in a workbook format.

30 Request IR-3: 32 31 With respect to Exhibit N-1, Appendix B, 36 33 (a) Please explain the reason(s) for under delivery in each month in which the holdback was 34 retained, including the start and end date for each reason and the total u...

AI summary Request IR-3 seeks explanations for under delivery and holdback calculations, including monthly breakdowns, impact of concurrent causes, and WACC computations. It also asks to assess whether specific LIL outages were related to underperformance and to provide detailed workbook calculations with formulas.

ths NSPML has met the requirements in provision (2) and provide a workbook with the data included in the graph shown in Exhibit N-1, p. 14. Request IR-3: With respect to Exhibit N-1, Appendix B, 1. Please explain the reason(s) for under de...

AI summary The document outlines specific requests related to the NSPML's compliance with provision (2), including explanations for under delivery, calculations of holdback amounts, and analysis of LIL outages. It also requests WACC calculations in a workbook.

- 29 (ii) confirm the target capacity level to which NSPML or NLH 30 was attempting to increase operation; 1 (d) Please confirm whether the 900 MW LIL capacity testing that was originally 2 intended to be completed in the winter of 2024–20...

AI summary The text requests confirmation regarding the target capacity level for NSPML or NLH 30 and the status of the 900 MW LIL capacity testing intended for completion in the winter of 2024–2025. It also asks whether the LIL was always intended to have a rated capacity of 900 MW since its commissioning.

- 6 (f) Please confirm the capacity at which the LIL was operating when it was 7 commissioned on April 14, 2023 (i.e., was it 400 MW, 700 MW, or some 8 other level), and when it ramped up to the current 700 MW capacity. - 9 (g) Please prov...

AI summary The text requests confirmation of the initial operating capacity of the LIL when it was commissioned on April 14, 2023, and the schedule for its ramp-up to full 900 MW capacity, including any documentation related to that schedule.

- 1 Request IR-15: - 2 Reference: N-01 Application, Section 6.0; and Appendix B. - 3 And Reference: Matter M11773, N-01 NSPML Holdback Mechanism Letter (June 28, - 4 2024). - 5 Preamble: Appendix B sets out holdback amounts since the Compl...

AI summary NSPML requests interest on deferred holdback funds, verification of financial figures, and a separate proceeding to design a continuing holdback mechanism. The Board questions NSPML's entitlement to interest, data sources, and calculation details, citing prior compliance period data and WACC rates.

ssessment and supporting evidence. - d) If the LIL were to consistently operate at 900 MW as designed, would the Witness's view of the achievability of the 12-month requirement change? Please explain. - Request IR-22: Please refer to Exhib...

AI summary The text includes two questions: one about the impact of LIL operating at 900 MW on meeting a 12-month requirement, and another requesting analysis of Muskrat Falls asset value to customers. It also references Exhibit N-1 and Request IR-22 for specific details.

1. Please refer to Exhibit N-1, page 11 lines 15-16 and footnote 11, and Appendixes A and C. 2. Please confirm that NSPML has not included Supplemental Block volumes from the “Make-up Balance” and “Make-up Balance (%)” columns in Appendix...

AI summary The text consists of a series of requests for information related to the inclusion of Supplemental Block volumes in Appendix A and Appendix C, the availability and performance of the Maritime Link, and references to specific exhibits and board matters. These requests are part of a regulatory proceeding involving Nova Scotia Power (NSPML) and the Nova Scotia Utility and Review Board (NSUARB).

Table 1[9](#page-8-1) 4 Total MWh (excluding purchased energy) 2024 Compliance Period 2025 (May 23 - Apr 24) (Jan - Dec) (Jan - Dec) 2013 Application Commitment 1,228,447 1,226,000 1,226,000 Base NS Block Delivered 889,213 749,208 917,767...

AI summary Table 1 provides a comparison of energy delivery metrics across different time periods, showing total MWh delivered and percentages relative to application commitments for the years 2024 and 2025. The data highlights fluctuations in energy delivery and compliance with commitments.