Topic:"Capital Expenditures" in M11927

CI 50518 HYD Ruth Falls Main Dam Refurbishment ATO REDACTED November 29, 2024 Nova Sco PO An Emer 14 / F everywhere." UARB APPI ROVAL SHEET Project Title: HYD Ruth Falls Mai n Dam Refurbishm ent CI Number: 50518 Date: October 11, 2024 Expe...

AI summary The document outlines the financial details and authorization for the HYD Ruth Falls Main Dam Refurbishment project, including budget amounts, project estimates, and various approvals and authorizations from 2017 to 2026. Nova Scotia Power Inc. and the Nova Scotia Utility and Review Board are involved in the submission and approval process.

CI Number: 50518 Title: HYD Ruth Falls Main Dam Refurbishment Start Date: 2017/02 In-Service Date: 2026/03 Final Cost Date: 2026/09 Function: Hydro Forecast Amount: $15,445,508

AI summary The document outlines the HYD Ruth Falls Main Dam Refurbishment project, with a start date of February 2017, an in-service date of March 2026, and a final cost date of September 2026. The forecasted amount for the project is $15,445,508.

Summary of Related CIs +/- 2 years: Pursuant to Section 11.2 of the Detailed CEJC, related CIs for Hydro projects include "work completed on the same generating unit and dam structures, but not necessarily the same asset." - 2017 CI 47551...

AI summary The summary outlines related capital investments (CIs) for Hydro projects, including specific projects from 2017 and 2018, their costs, and the depreciation class and estimated life of the asset involved.

CI 50518 Page 3 of 10 REDACTED (CONFIDENTIAL INFORMATION REMOVED) additional requests for information from DFO that had not been requested as part of previous incomplete letters. The additional requests, and any work associated with them,...

AI summary The Ruth Falls Main Dam Refurbishment Project has experienced cost increases due to additional studies, design work, and environmental offsetting required by DFO, as well as extended timelines and increased material and labor costs. The project remains justified due to structural deficiencies and the need to meet CDA Guidelines.

r n a os CI # 50518 - HYD Ruth Falls Main Dam Refurbishment Account UARB Approved ATO Submission Variance Reason for Variance Regular Labour 175,293 619,734 444,441 Additional project management support & environmental services labour requ...

AI summary The document outlines a variance in costs for the Ruth Falls Main Dam Refurbishment project, with significant increases in labour and travel expenses due to extended timelines and additional requirements for environmental compliance.

Location: Hydro Cl# : 50518 Description Unit Quantity Unit Estimate То tal Estimate Cost Support Reference Completed Simil Projects (FP#'s Ducinet Compact. E Regular L abour Ι φ 040 75 : 040.70 1 Project Support - Engineering lot 1 $ 619,7...

AI summary The document presents a detailed breakdown of costs and estimates for various projects and activities related to a hydroelectric project, including engineering support, environmental considerations, travel expenses, and material supplies. It lists quantities, unit costs, and total estimates for different components of the project.

Document No: Please request from IM Hydropower Project Cost Estimate Input Checklist and Maturity Matrix Required fields: Estimate Classification Material Utilization (Borrow Sources) Defined (D) P P P/D D D Logistics Plan Defined (D) P P...

AI summary The document presents a checklist and maturity matrix for hydropower project cost estimate inputs, detailing required fields and classifications for various project components such as logistics, work breakdown structures, risk registers, and technical deliverables like hydraulic design and equipment data sheets.

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 1 (b) Cost minimization will be realized by using internal labour rather than contracted labour 27 of the R...

AI summary NS Power is discussing cost minimization strategies for the Ruth Falls Main Dam Refurbishment project, including using internal labor and completing parts of the project ahead of permit approvals. Some cost-saving efforts were limited due to safety concerns, but partial savings were achieved through the construction of the rubber dams control building.

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.

NON-CONFIDENTIAL 1 Request IR-4: 2 3 With reference to Page 6 of the Application: 4 5 (a) Please confirm that the additional $499,999 contingency is exclusively allocated to 6 address uncertainty around DFO offsetting costs. 7 8 (i) If not...

AI summary The response to Request IR-4 confirms that the additional contingency is solely for DFO offsetting costs and refers to a table for a detailed breakdown of AFUDC interest increase factors, including accrued interest, project scope changes, and interest rates.

2 (i) 2024 includes actual costs to August 31, 2024 and forecasted costs for the 3 remainder of the year. 4 (ii) AFUDC was ceased as of January 2023 in line with policy 6240 – Allowance for 5 Funds Used During Construction due to a forecas...

AI summary The text discusses the inclusion of actual and forecasted costs for 2024, the cessation of AFUDC as of January 2023 due to a construction delay, and the resumption of construction in July 2025 with the project expected to be placed in-service in March 2026. It also mentions the breakdown of an AFUDC increase of $612,215.

REDACTED Request IR-5: With reference to Page 9 of the Application: - With reference to AACE Recommended Practice No. 69R-12, "Cost Estimate Classification - System As Applied in Engineering, Procurement, and Construction for the Hydropowe...

AI summary The document refers to NS Power's project maturity level for the Ruth Falls Main Dam Refurbishment, citing AACE Recommended Practice No. 69R-12. It notes that the project is at a Class 1 estimate maturity level with 95% of deliverables completed.

1 (b) Please refer to the table below: Materials – Costs Forecasted Description Cost background Costs in Thousands Concrete, Steel, Electrical, Quoted pricing by General $1,386 Piping, Rebar Contractor Fish passage upgrades Quoted pricing...

AI summary The table provides a forecast of material and contract costs for the Ruth Falls Main Dam Refurbishment project, including items such as concrete, steel, fish passage upgrades, and generator installations. Costs are quoted by contractors or based on internal estimates. The document references a specific proceeding (CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO, NSUARB M11927) and the responses provided by NSPI to information requests from Midgard Consulting.

REDACTED Internal estimate based on Equipment rental costs judgement $91 Electrical work Internal estimate based on $62 judgement Dewatering ‐ cofferdam & Quoted pricing by General $60 pumping Contractor Concrete testing Internal estimate...

AI summary The text presents a table of cost estimates for various components of a dam refurbishment project, including equipment rental, electrical work, dewatering, and environmental controls. It also references a specific regulatory proceeding (CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO, NSUARB M11927) and the involvement of NSPI in responding to information requests from Midgard Consulting.

CONCEPTUAL LEVEL - OPINION OF PROBABLE CONSTRUCTION COST (COST IN $2017) ITEM# ITEM DESCRIPTION QUANTITY UNIT PRICE ($) UNIT TOTAL ($) TOTAL ($) A. GENERAL $ 405,000 1 MOBILIZATION/DEMOBILIZATION 1 LS $ 100,000 $ 100,000 $ 100,000 2 ENVIRO...

AI summary The document presents a conceptual-level estimate of probable construction costs for a project, with detailed line items including mobilization, environmental protection, site access, crane operations, spillway gate installations, and concrete work. The total estimated cost is approximately $8.6 million, including a 20% contingency.

- 1. OWNER ADMINISTRATION AND OVERHEAD COSTS ARE NOT INCLUDED. - 2. COSTS FOR HYDRO UNIT DOWN TIME RESULTING FROM INSTALLATION ARE NOT INCLUDED. - 3. COSTS ASSOCIATED WITH SALES TAX, HST, AND INSURANCE ARE NOT INCLUDED. - 4. MOBILIZATION A...

AI summary The document outlines exclusions from the total direct construction costs, including owner administration, hydro unit downtime, sales tax, insurance, mobilization, and indirect costs like permitting and engineering. The total direct construction cost is stated as CAD 8,608,000.

ASSUMES (2) 7 MONTH CONSTRUCTION SEASONS CONCEPTUAL LEVEL - OPINION OF PROBABLE CONSTRUCTION COST (COST IN $2017) ITEM# ITEM DESCRIPTION UNIT PRICE ($) UNIT TOTAL ($) TOTAL ($) A. GENERAL $ 1,065,000 1 MOBILIZATION/DEMOBILIZATION 1 LS $ 20...

AI summary The document provides an estimate of construction costs for a project involving modifications to a dam and spillway, including mobilization, environmental protections, dewatering, gate installations, and concrete work. The total estimated cost, including a 20% contingency, is approximately $12.5 million in 2017 dollars.

CONCEPTUAL LEVEL - OPINION OF PROBABLE CONSTRUCTION COST ASSUMES (2) 7 MONTH CONSTRUCTION SEASONS (COST IN $2017) ITEM# ITEM DESCRIPTION QUANTITY UNIT PRICE ($) UNIT TOTAL ($) TOTAL ($) A. GENERAL $ 1,065,000 1 MOBILIZATION/DEMOBILIZATION...

AI summary The document presents a conceptual-level estimate of construction costs for a project, assuming a 7-month construction season with costs in 2017 dollars. It includes line items for mobilization, environmental protection, site access, crane operations, dewatering, cofferdam construction, gate modifications, and spillway modifications.

Schedule of Prices –Lowered Reservoir Option – Rev. 1 ITEM NO. DESCRIPTION UNIT APPROX. QTY UNIT PRICE TOTAL General L.S. 1 1 Mobilization L.S. 1 2 Demobilization L.S. 1 3 Environmental Management L.S. 1 4 Water Controls L.S. 1 5 Site Acce...

AI summary This document presents a schedule of prices for the Lowered Reservoir Option, Rev. 1, detailing various items and quantities related to construction and infrastructure work, including mobilization, demolition, concrete work, and installation of gates and walkways.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO (NSUARB M11927) NSPI Responses to NSUARB Information Requests 1 (ii) Between August 2020 and May 2021, NS Power worked to develop an offsetting 25 a. NS Power completed the constructio...

AI summary NS Power provided details on the costs associated with the construction of the Rubber Dams Controls Building, including various line items such as construction contracts, labor, inflation costs, and additional equipment mobilization and demobilization costs, with a total of $765,896.

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.

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.

2 (b) Please refer to the details in the tables provided in (a) for the work description. 3 4 (c) NS Power attributes the increases to the delayed construction in 2025 combined with the 5 substantial permitting requirements posed by the re...

AI summary NS Power attributes cost increases to delayed construction in 2025, regulatory permitting requirements, and progressive pricing shifts in construction materials. The details are provided in tables referenced in the text.

INTRODUCTION - Midgard Consulting Inc. ( "Midgard" ) has been retained by Counsel for the Nova Scotia Utility and Review - Board ( "NSUARB" ) to carry out a review of Nova Scotia Power Inc.'s ( "NS Power" ) "CI 50518 - HYD Ruth Falls - Mai...

AI summary Midgard Consulting Inc. has been retained by the Nova Scotia Utility and Review Board (NSUARB) to review Nova Scotia Power Inc.'s application for an Authorization to Overspend (ATO) on its Ruth Falls Dam Refurbishment Project. The ATO request follows a previously approved 2019 Annual Capital Expenditure (ACE) application. Midgard will assess NS Power's actions since the close of the original proceeding and review past evidence relevant to the current application.

1.2 Application Context - NS Power's ACE Plan process, guided by adherence to the Capital Expenditure Justification Criteria (" CEJC "), - ensures that capital expenditures undergo scrutiny and justification within the regulatory framework...

AI summary NS Power submitted an Original Application (M08984) in 2018 for approval of capital expenditures, including the Ruth Falls Dam Refurbishment Project. The application was approved in 2019. Now, NS Power is seeking an ATO to increase the project budget by over $8 million.

2.3.3 Conclusion - Based on the limited information available, Midgard does not have any reason to doubt NS Power's - expectation that an authorization will be issued in due course, and considers this to be an area of low risk to - the pro...

AI summary Midgard has no reason to doubt NS Power's expectation of receiving an authorization in due course and considers this area low risk. The navigable waters permit does not appear to have significantly contributed to the cost overruns for which approval is being sought in the ATO.

1 3.1.1 NS Power Submission - 2 In its IR Responses, NS Power attributed attributes approximately $710,000 of its cost increases to increases - 3 in material costs due to the extended construction timeframe. [Table 3](#page-17-0) provides...

AI summary NS Power attributed approximately $710,000 of its cost increases to material cost increases due to an extended construction timeframe, as detailed in Table 3.

Table 3: Material Cost Increase Breakdown[28](#page-17-3) Description Increase in Costs ($k) Increased Material Costs - concrete works $689 Increased Material Costs - rebar dowels $196 General contract - steel walkway $176 Generator for th...

AI summary Table 3 outlines the material cost increase breakdown, showing increases in concrete works, rebar dowels, steel walkways, and other components, with some items showing cost reductions. The total increase is reported as $710,000.

3.2.1 NS Power Submission - In response to IRs, NS Power indicated that $698,000 of the cost increases being applied for in the ATO are - the result of scope changes. [Table 6](#page-20-0) provides a detailed breakdown of the $698,000 incr...

AI summary NS Power explains that $698,000 of the cost increases in the ATO application are due to scope changes, with a detailed breakdown provided in Table 6.

Table 6: Cost Increase Due to Scope Increases Breakdown[31](#page-20-1) Description Increase in Costs ($k) Fish passage upgrades $667 Insulated storage containers (for rubber dams) $16 Back-up generator (winter construction) $15 TOTAL $698...

AI summary Table 6 outlines the cost increases due to scope increases, including fish passage upgrades, insulated storage containers, and a back-up generator. The total cost increase is listed as $698,000.

- Review of the correspondence between NS Power and DFO shows that DFO requirements drove the - modification of several project components, including: - 1. modifications to the upstream fishway and fish passage weirs; - 2. upgrade of the e...

AI summary The document discusses modifications to a project due to DFO requirements, including changes to fish passage systems and the installation of an eel ramp. These changes were driven by the expansion of protected species under the Fisheries Act. Additional costs were incurred due to the early procurement of rubber dams and the absence of backup generator allowances in the contractor's bid.

3.2.3 Conclusion - Overall Midgard concludes that the cost increases due to scope change are reasonable. Specific comment on - each of the three scope increases is provided as follows: M11927, Exhibit N-3, CA RIR-9(a), p. 3 of 3. M11927, E...

AI summary Midgard concludes that the cost increases due to scope changes are reasonable, attributing them mainly to DFO requirements and project delays. The cost of insulated storage containers was justified by savings from early acquisition of rubber dams. Generator cost increases are considered a minor oversight.

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.

- extended construction timeline: M11927, Exhibit N-1, p. 5 of 10. Table 7: Yearly Breakdown – Labour Variance34 Year Regular Labour ($k) Term Labour ($k) 2017-2020 ($19) $3 2021 $85 $0 2022 $124 $1 2023 $56 - 2024 $47 $1 2025 $104 $30 202...

AI summary The document discusses an extended construction timeline and includes a table showing regular and term labour variances from 2017 to 2026. The variances are attributed to efforts related to managing permitting and project activities.

1 4.1.1 NS Power Submission - 2 In response to IRs, NS Power indicated that the ATO has increased the archaeological costs for the project - 3 from $2,256 to $250,361, as indicated in [Table 8:](#page-24-0)

AI summary NS Power has updated the archaeological costs for the project, increasing them from $2,256 to $250,361 as part of their submission in response to IRs.

Table 8: Ruth Falls Archaeological Costs[37](#page-24-2) Description UARB Approved Original Submission ATO Submission Variance Archaeological Reconnaissance and Mitigation for Dewatering of Ruth Falls Reservoir in 2025-2026: To complete ar...

AI summary Table 8 outlines the archaeological costs associated with the Ruth Falls Reservoir project, including reconnaissance, security, and historical analysis. The table shows approved submissions, ATO submissions, and variances between them, with total costs amounting to approximately $248,105.

5 NSPI goes on to explain why these costs were not included in the original application: "NS Power was not aware the reservoir exhibited high potential for impacting archaeological resources prior to the original application. A desktop Arc...

AI summary NS Power explains that it was unaware of the potential archaeological impact of the Ruth Falls headpond prior to the original application. An archaeological resource impact assessment was conducted in 2023 to develop a protection plan as referenced in CA IR-13, part (c).

up>37 M11927, Exhibit N-3, CA RIR-13(c), pp. 2-3 of 3. Table reproduced from NSPI submission (totals calculated and added by Midgard). [38](#page-25-0) 4.1.2 Analysis Though NS Power suggests that it was not aware that there was a high pot...

AI summary NS Power admits that it overlooked archaeological costs in the original application for the Ruth Falls Project. It claims that even if these costs had been included, they would have been immaterial compared to revised costs in the ATO application. Midgard has experience with similar projects and provides a summary of archaeological costs in Table 9.

11 4.1.3 Conclusion 1 - 12 Midgard considers that the archaeological costs estimated in the Ruth Falls ATO are not overstated, and are - 13 in line with previously estimated amounts for Tusket and Gaspereau. Furthermore, in the context of...

AI summary Midgard argues that the archaeological costs estimated in the Ruth Falls ATO are not overstated and align with previous estimates for similar projects. However, it suggests that NS Power underestimated these costs in its original ACE application, based on its experience with similar dam refurbishments.

5.2.1 NS Power Submission - In the ATO Application and in response to IRs, NS Power has asserted that its currently estimated cost - estimate is a Class 1 estimate (as per AACE Standard 69R-12), with an expected accuracy range of -10% and...

AI summary NS Power asserts that its current cost estimate of $15.4 M for the project is reliable, based on Class 1 estimates with a -10% to +15% accuracy range. The estimate is derived from quotes from contractors and consultants, and NS Power expects no further delays, though final approval from DFO is pending.

5.2.3 Analysis – Archaeological Costs Midgard notes the examples of the Tusket and Gaspereau projects identified in [Table 9.](#page-26-0) For these projects archaeological costs were originally estimated at amounts that are comparable to...

AI summary The text discusses the archaeological costs for the Tusket and Gaspereau projects, noting that the original estimates were significantly lower than the amounts ultimately applied for in ATO applications, with the Tusket project being 5.8 times higher. There is concern that similar increases may occur in the future.

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.

6.2.1 Material Cost Increases - In general Midgard concludes that NS Power did face an environment of dramatically increasing costs from - the time of its original submission to the time of the ATO Application. On its face the available in...

AI summary Midgard concludes that NS Power faced significant material cost increases from the time of its original submission to the ATO Application, which may not be fully explained by general inflation data. The analysis suggests that localized impacts and potential scope increases may have contributed to the overspending.

6.3.1 Archaeology - It is Midgard's opinion that at the time of the ACE submission, given its recent experience with similar dam - refurbishment (i.e., Tusket, Gaspereau), NS Power should have been aware that archaeological costs for the -...

AI summary Midgard argues that NS Power underestimated archaeological costs for the Project by several orders of magnitude compared to its estimate of $2,256, based on prior dam refurbishment experiences. However, it is unlikely these costs significantly impacted the original decision.

ut project condition assessment and prepared asset depreciation schedules and cost-of-service model in support of re-contracting negotiations between IPP project owner and provincial electric utility. NARROWS INLET PROJECTS ( 2015 to 2017)...

AI summary The text outlines professional experience in hydroelectric projects, including assessments of design, hydrology, energy yield, capital and operating costs, and construction monitoring for various projects in British Columbia from 2014 to 2019.

E M P L O Y M E N T H I S T O R Y MIDGARD CONSULTING INC. 2011 - Present Consultant, Vancouver BC - Integral part of a small consulting firm with exposure to many aspects of the electricity industry. - Provide consulting services to electr...

AI summary The employment history of Midgard Consulting Inc. highlights their role as a consulting firm providing services to electric utilities, governments, and developers, focusing on transmission and generation design, resource planning, and project management since 2011.

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.

INTRODUCTION - Midgard Consulting Inc. ( "Midgard" ) has been retained by Counsel for the Nova Scotia Utility and Review - Board ( "NSUARB" ) to carry out a review of Nova Scotia Power Inc.'s ( "NS Power" ) "CI 50518 - HYD Ruth Falls - Mai...

AI summary Midgard Consulting Inc. has been engaged by the Nova Scotia Utility and Review Board (NSUARB) to review Nova Scotia Power Inc.'s application for an Authorization to Overspend (ATO) on the Ruth Falls Dam Refurbishment Project. The ATO request follows a previously approved 2019 Annual Capital Expenditure (ACE) application. Midgard's review includes an assessment of past evidence and decisions relevant to the current ATO Application.

1.2 Application Context - NS Power's ACE Plan process, guided by adherence to the Capital Expenditure Justification Criteria (" CEJC "), - ensures that capital expenditures undergo scrutiny and justification within the regulatory framework...

AI summary NS Power submitted an Original Application (M08984) in 2018 for capital expenditures, including the Ruth Falls Main Dam Refurbishment Project, which was approved in 2019. Now, NS Power is seeking an Authorization to Overspend (ATO) to increase the project budget by over $8 million.

REASON FOR VARIANCE: EXTENDED CONSTRUCTION TIMELINE - In the ATO Application, NS Power cites "Extended Construction Timeline" as one of three reasons for - variance, stating: - " As a result of the additional work required to address envir...

AI summary NS Power cites an extended construction timeline due to additional environmental permitting requirements, leading to increased project costs of about $2 million. This includes higher commodity prices and increased labor costs. Midgard assesses this reason for variance.

3.2.1 Analysis In the ATO Application states: "… there have also been increases in the amount of project support labour, technical support labour, and term environmental support labour as a result of the extended construction timeline. " [...

AI summary The ATO Application highlights increased labour and material costs due to extended construction timelines and updated environmental permit requirements. NS Power explained cost minimization strategies, such as using internal labour and applying lessons learned from previous regulatory processes.

9 4.1.2 Analysis 1 - 10 Though NS Power suggests that it was not aware that there was a high potential for archaeological resources - 11 in the headpond, it also goes on to admit that exclusion of these costs was an oversight: 36 M11927, E...

AI summary NS Power admitted to an oversight in excluding archaeological costs for the Ruth Falls Project, but claims the costs would have been immaterial compared to revised ATO application costs. Midgard references experience with similar projects and provides a chronological summary of archaeological costs in Table 6.

4.1.3 Conclusion - Midgard considers that the archaeological costs estimated in the Ruth Falls ATO are not overstated, and are - in line with previously estimated amounts for Tusket and Gaspereau. Furthermore, in the context of this ATO -...

AI summary Midgard concludes that the archaeological costs estimated in the Ruth Falls ATO are reasonable and in line with previous dam refurbishment projects. It suspects that a failure to account for $248,105 in the original ACE application would not have significantly affected the decision on the capital expenditure. However, Midgard believes NS Power underestimated archaeological costs at the time of the ACE submission.

- NS Power's IR response also provides reasons, by year, for the overages. The regular and term labour - variances are primarily attributed to efforts associated with managing permitting and associated project - activities: [49](#page-28-6...

AI summary NS Power's IR response outlines reasons for labour overages, including managing permitting activities with agencies like DFO, contract work, and environmental studies. Regular and term labour variances are attributed to project execution and compliance activities, while overtime labour is noted as not material to the overall conclusion.

5.2.1 NS Power Submission - NS Power reported material cost increases from the 2019 ACE to the ATO Application as detailed in [Table 11](#page-30-0) - an[d Table 12,](#page-30-1) which resulted in labour expense overspending of $1,408,689....

AI summary NS Power submitted a report detailing material cost increases from the 2019 ACE to the ATO Application, resulting in a labour expense overspending of $1,408,689, as outlined in Table 11 and Table 12.

Table 11: 2019 ACE Materials Costs[50](#page-30-2) Description Total Estimate ($) Gates and Actuators XXXXXXXX Rubber Dam (Supply) XXXXXXXXXX Compressor and Blower House XXXXXXX TOTAL: $1,520,000 Table 12: ATO Application Materials Costs[5...

AI summary The text presents two tables detailing material costs for the 2019 ACE project and the ATO application. It includes costs for items such as gates, actuators, rubber dams, and infrastructure upgrades, with a total estimated cost of $2,928,689 for the ATO application. References to regulatory filings and exhibits are provided.

Table 13: Material Cost Increase Breakdown[52](#page-31-1) Description Increase in Costs ($k) ADDITIONAL SCOPE: NEW PERMITTING REQUIREMENTS Fish passage upgrades $667 EXTENDED CONSTRUCTION TIMELINES Increased Material Costs - concrete work...

AI summary Table 13 outlines the breakdown of material cost increases for a project, including expenses related to fish passage upgrades, concrete works, rebar dowels, and other components, with a total increase of $1,408,000.

Table 14: 2019 ACE Costs – Contracts[53](#page-33-1) Description Total Estimate ($) Contractor Costs (Mob/Demob, etc.) XXXXXXXX Environmental Controls XXXXXXX Site Access (Roads, Laydown Areas, XXXXXXXX Staging, etc.) Crane Rental and Oper...

AI summary Table 14 outlines the 2019 ACE Costs – Contracts, detailing various contractor and construction-related expenses, including environmental controls, site access, and infrastructure upgrades. The total estimated cost is listed as $3,652,031.

Table 16: Contractor Administrative Overhead Cost Increase Category NSUARB Approved ($) ATO Submission ($) Variance ($) Contractor $438,973 $724,985 $286,012 Administrative Overhead 2 5.3.2 Analysis - Contracts

AI summary Table 16 presents a variance between the NSUARB-approved amount and the ATO submission for contractor administrative overhead costs, highlighting a significant increase of $286,012. The analysis section discusses contracts in detail.

Table 18: Contractor Administrative Overhead Cost Increase[61](#page-38-1) 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 20...

AI summary Table 18 presents the contractor administrative overhead costs from 2017 to 2026, showing fluctuations in both total contract costs and the applied overhead rate. NS Power attributes the increase in contractor administrative overhead costs to higher contract costs and an extended project timeline.

5.3.4 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 several orders of magnitude higher than estimated in the 2019 ACE. These costs are not categorized as first-level costs in the ACE or ATO Application, but are listed under 'Contracts' as 'Archaeology Related Costs', raising questions about their alignment with NS Power's stated costs.

- 3 NS Power attributes the increase in AFUDC interest, totaling $612,215, to higher project costs, an expanded - project scope, and an extended project timeline.[79](#page-46-5) 4 This is reflected in the year-over-year growth of AFUDC -...

AI summary NS Power attributes the increase in AFUDC interest, totaling $612,215, to higher project costs, an expanded project scope, and an extended project timeline. This is reflected in the year-over-year growth of AFUDC interest balances, as shown in Table 28, which also highlights the applicable rates used during the project timeline.

Table 29: Factors Contributing to AFUDC Increase[84](#page-47-2) Factor Total Change Due to Stated Factor Change in Interest Rates ($42,691) Increase in Total Scope/Project Timeline $654,906 3

AI summary The table outlines the factors contributing to the increase in AFUDC, with a significant impact from the increase in total scope and project timeline, and a negative impact from changes in interest rates.

10 5.7.3 Conclusion - 11 The AFUDC increase reflects extended project duration, expanded scope, and increased costs, all of which - 12 required sustained capital investment. This growth, evidenced by steady AFUDC balance increases from 201...

AI summary The AFUDC increase is attributed to extended project duration, expanded scope, and increased costs, which required sustained capital investment. Midgard concludes that these cost increases are reasonable, citing scope increases and extended timelines as valid reasons for variance.

5.9.1 NS Power Submission - NS Power attributes $500k of its cost increases to additional contingency. [Table 31](#page-50-0) provides a detailed - breakdown of these costs as reported by NS Power.

AI summary NS Power attributes $500k of its cost increases to additional contingency, with a detailed breakdown provided in Table 31.

- 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.

NON-CONFIDENTIAL - under a different set of circumstances. It is Midgard's opinion that based on the evidence presented, NS Power assumed a reasonable position in its assessment of the project, prudently submitted a Request for Review to D...

AI summary Midgard acknowledges that NS Power took a reasonable position in its project assessment and submitted a Request for Review to DFO. However, Midgard did not assess the changes in scope and costs in relation to the Capital Expenditure Justification Criteria (CEJC), focusing instead on the reasonableness of the changes.

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: 20 represent the "lowest reasonable cost to customers." Midgard...

AI summary Midgard Consulting Inc. responded to information requests regarding the Ruth Falls Main Dam Refurbishment project, emphasizing that the project was determined to be the lowest reasonable cost to customers based on industry best practices. The site visit by Midgard staff was conducted to better understand the project and was appreciated by Midgard.

CI 50518 – HYD – Ruth Falls Main Dam Refurbishment ATO – Reply Evidence Redacted - 1 Ultimately, Midgard concludes that the changing context of the Fisheries Act and resulting - 2 consequences on NS Power's Project execution process have i...

AI summary Midgard argues that changes in the Fisheries Act have increased costs for NS Power's dam refurbishment project, impacting ratepayers. It concludes that NS Power acted prudently in responding to DFO's requests and that the project remains the lowest-cost alternative for customers.

CI 50518 – HYD – Ruth Falls Main Dam Refurbishment ATO – Reply Evidence Redacted 1 2.0 MATERIAL COSTS 2 3 Midgard's analysis supports the assertion that there was significant inflationary escalation that 4 contributed to the increase in co...

AI summary Midgard's analysis highlights significant inflationary escalation in material costs for the Ruth Falls Main Dam Refurbishment project, but notes discrepancies between NS Power's 2019 ACE Application and the ATO Application. It also points out inconsistencies in cost categorization and suggests that some cost increases may be due to changes in scope rather than extended timelines.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO - Reply Evidence Redacted • NS Power erred in its original estimation of material costs for the 2019 ACE..6 2 3 4 5 1 Midgard recommends that NS Power provide additional clarification...

AI summary NS Power is criticized for its original estimation of material costs for the 2019 ACE, with Midgard recommending additional clarification on the reasons for and categorization of material cost variances.

Figure 1: Breakdown of Additional Scope Items Description Comments Additional scope items: New Permitt ing Requirements Fish passage upgrades In 2022, new scope was required as a condition of permit approval. In the ATO submission, costs w...

AI summary The document details additional scope items related to a project, including fish passage upgrades, extended construction timelines, and new requirements identified after the original filing, such as the procurement of a propane-fueled generator for backup power. Costs and allocations are discussed in relation to ATO submissions and UARB filings.

4 Midgard states: 6 However, NS Power nevertheless attributes increased material costs due to 7 extended timeline to scope line items not found in the original 2019 ACE, such as 8 "concrete works", "rebar dowels", and "steel walkway". Base...

AI summary NS Power attributes increased material costs to a revised scope of work in its 2024 ATO submission, including line items such as 'concrete works', 'rebar dowels', and 'steel walkway'. The original 2019 ACE estimated these costs differently, and the updated submission reflects new bid pricing and cost allocations between 'Materials' and 'Contracts'.

Figure 3: Archaeological Cost Comparison 7F 8 10 Application Date Filed Archaeological Cost Gaspereau Dam Safety Remedial Works May 3, 2007 $150,000 (Original) Wright's Dam Refurbishment 2015 $11,500 Tusket Falls Main Dam Refurbishment Jul...

AI summary The document presents a table comparing archaeological costs associated with various dam projects in Nova Scotia, including original applications and those under the 2025 ACE Plan, with varying dates and costs.

- 3 Midgard does not present any evidence as to why the Archaeological costs are invalid, other than - 4 noting that NS Power underestimated the costs in its original application. In fact, Midgard states - 5 that the value of archaeologica...

AI summary Midgard argues that NS Power's archaeological cost estimates are valid and in line with previous projects, noting that the underestimation of costs in the original application did not materially affect the decision. Midgard supports this claim by referencing similar projects and previous filings.

IR response). Midgard also - 15 references the Gaspereau Dam Safety (ATO) as support for its position that archaeological costs - 16 were likely well understood prior to the original Ruth filing. 17 - 18 Midgard quoted archaeological costs...

AI summary Midgard references the Gaspereau Dam Safety (ATO) and archaeological costs from the Tusket Main Dam refurbishment to argue that archaeological costs for the Ruth project were likely well understood prior to filing. It highlights differences in the likelihood of encountering artifacts between the two projects.

4 Figure 5: Decommissioning Cost Breakdown Item Description Anticipated Cost 1 Infrastructure removal $22.4M 2 Environmental assessment and permitting $3.8M 3 Environmental monitoring post-removal $1.5M 4 Sediment management $13.0M 5 Archa...

AI summary The document provides a detailed breakdown of anticipated costs for decommissioning infrastructure, including environmental assessments, sediment management, and Mi'kmaq engagement, with a total projected cost of $81.6 million.

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.

Description Summary of Sensitivities Division : Date : 3-Jul-25 Department : CI Number: Power Production Capital Projects 50518 Project No. :

AI summary The document provides a summary of sensitivities related to a power production capital project, with details such as the division, date, department, and project number. It appears to be part of a regulatory proceeding involving Nova Scotia Power Incorporated.

H792 After Tax PV of Revenue PV of EVA / Alternative WACC Requirement NPV Rank IRR Disc Pay A Dam Refurbishment 5.81% -21,926,086 12,516,533 1 12.36% 10.2 years B Partial Decommissioning 5.81% 49,632,167 -37,924,730 2 #NUM! 0.0 years 0 NA...

AI summary The text presents financial and economic analysis of two alternatives—Dam Refurbishment and Partial Decommissioning—evaluated based on metrics such as NPV, IRR, and Discount Payback. The analysis includes variations in capital spend, avoided expenses, and revenue requirements, with a focus on the Dam Refurbishment project showing more favorable outcomes.

Description Avoided Cost Calculations Division : Date : Department : CI Number: Power Production Capital Projects Project No. :

AI summary This section of the document discusses the Description Avoided Cost Calculations related to Power Production Capital Projects. It includes a reference to a picture and project details, though specific content is not elaborated.

Dam Refurbishment Avoided Applicable Year Total Revenue Operating Costs Expenses Capital CCA UCC CFBT Taxes CFAT PV of CF Discount Factor CNPV 2024 - - - (3,866,380.3) - - (3,866,380.3) - (3,866,380.3) (3,866,380.3) 1.00 (3,866,380.3) 2025...

AI summary The document presents a financial analysis table for a dam refurbishment project from 2024 to 2033, including revenue, operating costs, capital expenditures, and net present value (NPV) calculations. It outlines the financial implications of the project over time.

Partial Decommissioning Avoided Applicable Year Total Revenue Operating Costs Expenses Capital CCA UCC CFBT Taxes CFAT PV of CF Discount Factor CNPV 2024 - - - (176,166.0) - - (176,166.0) - (176,166.0) (176,166.0) 1.00 (176,166.0) 2025 - -...

AI summary The document presents a financial analysis of partial decommissioning over several years, detailing capital expenditures, capital cost allowances (CCA), undepreciated capital cost (UCC), cash flow before tax (CFBT), taxes, cash flow after tax (CFAT), present value of cash flows (PV of CF), discount factors, and cumulative net present value (CNPV) for each year from 2024 to 2034.

REDACTED CI 50518 Ruth Falls Main DAM ATO Attachment 3 Page 1 of 2 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Capital Project Detailed Estimate Location: Hydro

AI summary This document provides a detailed estimate for a capital project related to the Hydro sector, specifically concerning the Ruth Falls Main DAM ATO. The content is redacted and classified as confidential information.

50518 CI# : Unit Description Regular Labour Project Support - Engineering lot Project Support - Engineering lot Project Support - Environmental lot Travel Expense Travel lot Supply of gates and actuators lot Supply of rubber dams lot Backu...

AI summary The document provides a detailed breakdown of various project costs, including labor, materials, and equipment, associated with infrastructure and environmental management activities. It lists items such as gates, actuators, rubber dams, and backup generators, along with their estimated costs and quantities.

Capital Project Detailed Estimate Description Unit Quantity Un it Estimate To otal Estimate Cost Support Reference Completed Simil Projects (FP#'s Consult , , Conceptual / Detailed design of refurb. lot 1 $ 231,374 $ 231,374 Juvenile Gaspe...

AI summary The document outlines a detailed estimate for a capital project involving various design, environmental, and legal components. It includes costs for design work, environmental studies, legal fees, and meals, totaling approximately $1,778,916.

Note 2: Small differences in totals are attributable to rounding. Note 3: Contingency for the original 2019 submission was determined using a combination of internal subject matter expert judgement and previous experience with hydro dam re...

AI summary The note explains that small differences in totals are due to rounding. The contingency for the original 2019 submission was based on internal expertise and previous experience with hydro dam refurbishment. The contingency remains appropriate as the project is forecasted to start in July 2025 and has not yet begun.

NSEB APPROVAL SHEET HYD Ruth Falls Main Dam Refurbishment Project Title: CI Number: 50518 Date: July 8, 2025 Expenditure Profile Type of Filing Year Budget Amount Project Estimate Capital Project Authorization 2017 125,191 125,191 Unforese...

AI summary The document outlines the expenditure profile and approval process for the Ruth Falls Main Dam Refurbishment project. It includes budget amounts, project estimates, and authorization details from 2017 to 2026. The total budget submitted is $14,839,116, with a variance of $7,594,694 from the approved amount of $7,244,422.

HEARING ORDER In NS Power's 2019 Annual Capital Expenditure (ACE) Plan proceeding, the Board approved NS Power's capital application for CI 50518 – HYD Ruth Falls Main Dam Refurbishment, in the amount of $7,244,422. NS Power has now applie...

AI summary NS Power requested an Authorization to Overspend (ATO) for the HYD Ruth Falls Main Dam Refurbishment project, increasing the approved capital cost from $7,244,422 to $8,201,086. The Board will conduct a paper hearing, reserving the right to convert it to an oral hearing if needed.

NOTICE OF PAPER HEARING _____________________________________________________________________________________ IN THE MATTER OF an application by NOVA SCOTIA POWER INCORPORATED (NS Power) for approval of an Authorization to Overspend (ATO)...

AI summary Nova Scotia Power Inc. (NS Power) has applied for an Authorization to Overspend (ATO) of $8,201,086 for the HYD Ruth Falls Main Dam Refurbishment project, increasing the total capital cost request to $15,445,508. The Board will consider the matter in a paper hearing process.

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 Incorporated has applied for approval to overspend $8,201,086 on the HYD Ruth Falls Main Dam Refurbishment project, increasing the total capital cost to $15,445,508.

AMENDED HEARING ORDER In Nova Scotia Power's (NS Power) 2019 Annual Capital Expenditure (ACE) Plan proceeding, the Board approved NS Power's capital application for CI 50518 – HYD Ruth Falls Main Dam Refurbishment, in the amount of $7,244,...

AI summary The document outlines an amended hearing order for Nova Scotia Power's request to overspend on the HYD Ruth Falls Main Dam Refurbishment project. The Board has approved a paper hearing and granted Midgard Consulting Inc. additional time to submit evidence. The proceeding involves an Authorization to Overspend (ATO) of $8,201,086, increasing the total capital cost to $15,445,508.

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.

- [1] On October 11, 2024, Nova Scotia Power Incorporated (NS Power) filed an Authorization to Overspend (ATO) application for Board approval in the amount of $8,201,086. This ATO is related to CI Number 50518 - HYD Ruth Falls Main Dam Ref...

AI summary Nova Scotia Power Incorporated (NS Power) filed an Authorization to Overspend (ATO) application for Board approval in the amount of $8,201,086 for the HYD Ruth Falls Main Dam Refurbishment Project, which has seen a 113.2% cost increase since its original approval in 2019. A paper hearing was conducted, with evidence and submissions filed by multiple parties, and the matter was transferred to the Nova Scotia Energy Board following the proclamation of the Energy and Regulatory Boards Act.

s the project was still in the preliminary design phase. This approach is not uncommon, as these permits are typically obtained after preliminary engineering is complete for a selected project option. [11] In December 2019, NS Power submit...

AI summary NS Power submitted a review request for its Ruth Falls main dam refurbishment in 2019, but faced additional requirements under the modernized Fisheries Act in 2020, necessitating an FAA. NS Power has been working with DFO since 2020, but the process has been slow, with multiple incomplete submission letters and delays. The company argues that the FAA requirement, introduced after the 2019 ACE Plan was approved, has added significant costs to the project.

ubmissions. [53] NS Power's reply submissions also addressed the Industrial Group's concern about whether Option 4 continues to be the most cost-effective project choice for customers. It noted that: … Option 4 was the lowest cost option b...

AI summary NS Power defended Option 4 as the most cost-effective choice for the dam refurbishment project, citing lower material costs and fewer gates to install. It also noted that additional work is due to DFO requirements, not changes in project scope, and that the 'do nothing' option is not acceptable due to dam safety concerns.

3.1 Prudency [61] In this ATO application, NS Power stated that following submission of its 2019 ACE Plan for Board approval, the Company was required to obtain an FAA from DFO. Specifically, NS Power submitted a request for DFO review in...

AI summary The document discusses the prudency of NS Power's actions in obtaining an Authorization to Overspend (ATO) for the Ruth Falls main dam refurbishment project. The Board agrees with Midgard that NS Power acted reasonably in expecting that an FAA would not be required in its 2019 ACE Plan and that delays in the FAA process were due to changing regulatory requirements, not imprudence.

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, finding that Option 4 remains the preferred refurbishment option. NS Power did not update its economic analysis due to expected uniform cost increases from FAA and extended timelines, and no other parties challenged this reasoning.

ecent submission. In the Board's opinion, without the FAA in hand, the project remains exposed to potential cost increases, as this issue has been a key factor to date in significant cost escalations. [71] The Board has, therefore, decided...

AI summary The Board has decided to delay the approval of the ATO application until the final FAA is received from DFO. This is due to concerns that without the FAA, the project may face potential cost increases. The Board expects an amended ATO application with updated cost estimates once the FAA is obtained.

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 involved a decision between decommissioning the dam or refurbishing it. NS Power chose refurbishment due to lower costs and the need to replace 7.2 MW of renewable power. The refurbishment will extend the dam's life by 50 years but will require future capital investments and ongoing operating expenses. The document also considers the potential cost-effectiveness of decommissioning and replacing the power source.

4.0 CONCLUSION [84] The current ATO application will be held in abeyance until NS Power receives the final project FAA from DFO. Once the FAA has been obtained by NS Power, the Company can then file an amended ATO application with the Boar...

AI summary The Board has placed the ATO application on hold until NS Power receives the final FAA from DFO. The amended application must include updated cost estimates, a decommissioning cost analysis for Ruth Falls, and considerations for archaeological impacts and Mi'kmaq engagement in future capital applications.

M11927 – Nova Scotia Power Incorporated – CI 50518 – HYD Ruth Falls Main Dam Refurbishment – $14,839,116 (Amended ATO) On June 18, 2025, the Nova Scotia Energy Board (Board) issued a decision in Matter M11927 Nova Scotia Power Incorporated...

AI summary The Nova Scotia Energy Board has approved an amended Authorization to Overspend (ATO) for the Ruth Falls Main Dam Refurbishment Project following receipt of the Fisheries Act Authorization. The amended ATO reduces the requested amount by $606,392 to $14,839,116. A Net Present Value analysis shows the refurbishment option is more favorable compared to decommissioning. Intervenors and consultants have submitted comments on the application.

estimated cost of decommissioning the entire Sheet Harbour system, even accounting for inflation. This is suggestive of a much broader issue with the potential for dam decommissioning in Nova Scotia. The Industrial Group expressed similar...

AI summary The text discusses concerns raised by the Industrial Group regarding the estimated costs for decommissioning the Sheet Harbour system and the lack of justification for offsetting unit costs used by NS Power. The group recommends using the original cost estimate and managing the project within the approved budget, referencing a past Board decision and regulatory requirements.

Board Findings The Board finds that NS Power has provided an adequate response to Midgard's recommendation about providing an update on the July 1, 2025, to July 21, 2025, construction window to construct access roads. No further direction...

AI summary The Board finds that NS Power adequately responded to Midgard's recommendations regarding the construction window and offsetting cost in its amended ATO application. The updated offsetting cost is based on a lower unit price provided by a proponent, so the Board does not require NS Power to adhere to the original $25/m2 estimate.

CI Number: 50518 Date: July 8, 2025 Expenditure Profile Type of Filing Year Budget Amount Project Estimate Capital Project Authorization 2017 125,191 125,191 Unforeseen and Unbudgeted (U&U) 2018 201,467 86,643 Planned & Advanced (P&A) 2019...

AI summary The document presents an expenditure profile for Nova Scotia Power Incorporated, detailing budget amounts, project estimates, and types of filings from 2017 to 2026. It includes a total budget of $7,244,422 and a current submission of $14,839,116, with an ATO variance of $7,594,694. The submission was approved by the Nova Scotia Energy Board.

October 11, 2024 Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: Capital Items Filed Outside the Quarter Dear Ms. Henwood: Enclosed for your r...

AI summary A request for approval to overspend on the HYD Ruth Falls Main Dam Refurbishment project is submitted. The original approval was granted in the 2019 ACE Plan with an ATO of $8,201,086, and $4,378,884 has been spent as of August 31, 2024.

HEARING ORDER In NS Power's 2019 Annual Capital Expenditure (ACE) Plan proceeding, the Board approved NS Power's capital application for CI 50518 – HYD Ruth Falls Main Dam Refurbishment, in the amount of $7,244,422. NS Power has now applie...

AI summary NS Power applied for an Authorization to Overspend (ATO) of $8,201,086 for the HYD Ruth Falls Main Dam Refurbishment project, increasing the total approved capital cost to $15,445,508. The Board will conduct a paper hearing, reserving the right to convert it to an oral hearing if needed.

NOTICE OF PAPER HEARING _____________________________________________________________________________________ IN THE MATTER OF an application by NOVA SCOTIA POWER INCORPORATED (NS Power) for approval of an Authorization to Overspend (ATO)...

AI summary Nova Scotia Power Inc. (NS Power) has applied for approval to overspend $8,201,086 on the HYD Ruth Falls Main Dam Refurbishment project, increasing the total capital cost to $15,445,508. The Board will review the application through a paper hearing process.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended - and - IN THE MATTER OF: An application by Nova Scotia Power Incorporated for approval of an Authorization to Overspend (ATO) in...

AI summary Nova Scotia Power Incorporated has applied for approval to overspend $8,201,086 on the HYD Ruth Falls Main Dam Refurbishment project, increasing the total requested capital cost to $15,445,508.

NOVA SCOTIA UTILITY AND REVIEW BOARD 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 (ATO) in the amount of $8,201,086 on cap...

AI summary Nova Scotia Power Incorporated has applied for approval to overspend $8,201,086 on the HYD Ruth Falls Main Dam Refurbishment project, increasing the total requested capital cost to $15,445,508.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF an application by NOVA SCOTIA POWER INCORPORATED (NS Power) for approval of an Authorization to Overspend (ATO) in the amount of $8,201,086 on capital application project CI 50518 – HYD...

AI summary NS Power has applied for approval to overspend $8,201,086 on the HYD Ruth Falls Main Dam Refurbishment project, increasing the total requested capital cost to $15,445,508.

Request IR-2: - Please confirm that NS Power has included all the measures required by DFO in the "Capital - Project Detailed Cost Estimate" and in the project specifications and design. - a) Has NS Power made any changes to the DFO requir...

AI summary The document requests confirmation that NS Power has included all required measures from DFO in the project's cost estimate and design, and whether any changes were made to DFO requirements without approval.

Request IR-11: - Regarding the Capital Project Detailed Cost Estimate on pages 7 and 8 of the current Application: - a) Has construction of the project been tendered? - i. If so, please provide a copy of each tender submission. - ii. If no...

AI summary The text outlines a series of requests related to the Capital Project Detailed Cost Estimate in the current Application, focusing on tendering processes, cost breakdowns, and explanations for discrepancies compared to the 2019 ACE Plan Application.

1 2024 M11927 2 3 NOVA SCOTIA UTILITY AND REVIEW BOARD 4 IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended 5 - and - 6 7 8 9 10 11 12 IN THE MATTER OF: An application by Nova Scotia Power Incorporated for approval of...

AI summary The Nova Scotia Utility and Review Board is considering an application by Nova Scotia Power Incorporated for an Authorization to Overspend (ATO) on the HYD Ruth Falls Main Dam Refurbishment project, which has more than doubled in budget. The Industrial Group has requested confirmation that Option 4 remains the most cost-effective choice.

31 1 Request IR-6: 2 Reference: Attachment 1, page 1, row 3. 3 4 5 July 8, 2021 - DFO indicated that due to a change in scope of the project, they will not be providing comments on NS Power's May 8, 2021 submission until an updated constru...

AI summary The text discusses delays in the Ruth Falls project due to a 2021 scope change, and clarifications regarding the project's details, including the replacement of a concrete deck with a steel walkway and increased discharge capacity. It references previous regulatory approvals and submissions.

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.

Request IR-4: Refer to N-1 ATO, page 3 of 10, para 2. Extended Construction Timeline, in which the Company concluded that the extended timeline led to increased project costs, including increased material costs, and answer the following: -...

AI summary The text refers to an extended construction timeline leading to increased project costs, including material costs, and requests an explanation of the drivers behind the material cost increase and which changes corresponded to a change in scope since 2018.

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 Incorporated has applied for approval to overspend $8,201,086 on the HYD Ruth Falls Main Dam Refurbishment project, increasing the total requested capital cost to $15,445,508. The application is before Steven M. Murphy, MBA, P.Eng., Member.

AMENDED HEARING ORDER In Nova Scotia Power's (NS Power) 2019 Annual Capital Expenditure (ACE) Plan proceeding, the Board approved NS Power's capital application for CI 50518 – HYD Ruth Falls Main Dam Refurbishment, in the amount of $7,244,...

AI summary Nova Scotia Power applied for an Authorization to Overspend on the HYD Ruth Falls Main Dam Refurbishment project. The Board approved the original capital application in 2019 and has now set an amended timetable for the proceeding, allowing Board Counsel Consultants to submit additional evidence.

AMENDED NOTICE OF PAPER HEARING _____________________________________________________________________________________ IN THE MATTER OF an application by NOVA SCOTIA POWER INCORPORATED for approval of an Authorization to Overspend (ATO) in...

AI summary Nova Scotia Power Inc. has applied for an Authorization to Overspend (ATO) of $8,201,086 for the HYD Ruth Falls Main Dam Refurbishment project, increasing the total requested capital cost to $15,445,508. The Board will review the application through a paper hearing process.

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.

9 Request IR-18: - 10 Reference: N-8, Original Report, page 22, lines 3-8. - 11 2. The insulated storage containers were required because the rubber dams 12 were acquired early, and have had to be stored on site for the intervening 13 year...

AI summary Midgard's original report attributed an additional cost of $16,000 to the early acquisition of rubber dams requiring insulated storage. The report also noted that early acquisition saved $300,000. The request asks if Midgard still believes this cost is due to early acquisition and whether additional expenses like inspection and freight costs were considered.

1 2 page 50, line 17)? If not, why not? If so, how do these other cost increases impact the analysis? 3 (c) Are there additional cost implications in relation to the four-year storage of 4 these rubber dams outside prior to their installat...

AI summary The text discusses questions raised regarding cost implications of storing rubber dams for four years before installation, the savings from early acquisition of these dams, and the reasonableness of storage and inspection costs if NSPI caused project delays. It also addresses archaeological cost estimates for the Ruth Falls project and whether they were appropriately estimated.

- 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 23 4 was estimated to cost $6.61M, it states: "This cost may be lowered to 2...

AI summary The text contains a series of questions and references to a capital application and Kleinschmidt Memorandum, focusing on cost estimates for hydro projects and the impact of changes to project scope, particularly involving stoplog bays and spillways.

January 27, 2025 VIA EMAIL Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M11927 - Application by NOVA SCOTIA POWER INCO...

AI summary The Small Business Advocate (SBA) has reviewed the amended evidence submitted by Midgard Consulting Inc. regarding NS Power's application for an Authorization to Overspend (ATO) on the HYD Ruth Falls Main Dam Refurbishment project and has no further information requests for the Board Counsel Consultants.

(1) There is insufficient evidence to assess the Project remains economically justified This is a foundational consideration. Having regard to the additional costs, the question is whether the Project remains economical. Here, the Board mu...

AI summary The document argues that there is insufficient evidence to determine if the Ruth Falls Main Dam refurbishment project remains economically justified. While the need for the project is acknowledged, the application lacks updated economic justification, and the ATO's justification section is identical to the original capital application.

respect to the requirements for FAAs were well within contemplation, or ought to have been contemplated, at the time of the original Ruth Falls refurbishment capital application on November 29, 2018. In response to Industrial Group IR 8 (f...

AI summary The text discusses the failure to consider potential changes to the Fisheries Act (FAA) during the original Ruth Falls refurbishment capital application in 2018. Midgard argues that NSPI should have been aware of these changes and their implications, and that the Board and stakeholders should have been informed of the potential cost increase. The text criticizes NSPI for not adequately accounting for the FAA requirement in its original application.

e Items.[65](#page-13-4) Some of these items were identified after the original filing, having been inadvertently omitted, and others arose from the delays and changes associated with the FAA process. The timing of NSPI learning these chan...

AI summary NSPI did not act diligently in advancing the Applications to the NSECC and DFO, leading to delays and increased costs in the Ruth Falls refurbishment project. The changes in scope since 2021 should have prompted a Scope Change application to the Board, but NSPI only applied in October 2024. The Industrial Group argues that NSPI's lack of diligence during the FAA process should not be passed on to ratepayers.

March 25, 2025 VIA EMAIL Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M11927 - Application by NOV A SCOTIA POWER INCOR...

AI summary The Small Business Advocate (SBA) has reviewed materials related to NS Power's application for an Authorization to Overspend (ATO) on a dam refurbishment project. The SBA notes that increased costs were partly due to changes in the federal Fisheries Act, which NS Power may not have anticipated initially. The SBA questions why these changes were not raised earlier in the proceeding.

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.

- [1] On October 11, 2024, Nova Scotia Power Incorporated (NS Power) filed an Authorization to Overspend (ATO) application for Board approval in the amount of $8,201,086. This ATO is related to CI Number 50518 - HYD Ruth Falls Main Dam Ref...

AI summary NS Power filed an ATO application for Board approval related to the HYD Ruth Falls Main Dam Refurbishment Project, which has seen a significant cost increase. The matter was handled through a paper hearing with evidence and submissions filed by various parties, and the regulatory body was restructured under the new Energy and Regulatory Boards Act.

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.

ately concluded that: …the overall increase in material costs (93%) is in line with the overall cost increase for the Project as a whole (113%) and therefore does not on its face appear unreasonable. [Exhibit N-9, p. 33] [22] Midgard noted...

AI summary The document discusses the increase in material costs for a project, noting that the 93% increase aligns with the overall 113% project cost increase. Midgard reviewed NS Power's 2019 ACE Plan and found that archaeological costs were not included due to oversight, but the omission was deemed immaterial to the overall project cost.

asonable given the expected scope of archaeological work at the time. The Company submitted that the costs outlined in the ATO application reflect an updated approach, incorporating revised estimates. [58] In considering the Industrial Gro...

AI summary NS Power addressed concerns from the Industrial Group and SBA regarding the ATO application, stating that updated costs reflect revised estimates and that DFO's requirements have been addressed. NS Power also committed to future decommissioning cost reporting and project plan updates.

3.1 Prudency [61] In this ATO application, NS Power stated that following submission of its 2019 ACE Plan for Board approval, the Company was required to obtain an FAA from DFO. Specifically, NS Power submitted a request for DFO review in...

AI summary NS Power's 2019 ACE Plan did not require an FAA, and the Board agrees with Midgard that it was reasonable to expect this. The delay in obtaining the FAA was due to evolving DFO requirements, not imprudence on NS Power's part. The Board finds that NS Power acted prudently in its interactions with DFO and NSECC.

the Board for consideration going forward. In light of this, NS Power will commit to providing decommissioning costs in future hydro applications, as applicable. [NS Power Reply Submissions, pp. 2-3] [80] In other Matters before the Board...

AI summary The NS Power provided a decommissioning cost estimate of $84.5 million for the Ruth Falls main dam refurbishment project, but the Board and intervenors found the information insufficient for testing. The estimate lacks details on when capital expenditures would occur over the eleven-year decommissioning timeframe.

4.0 CONCLUSION [84] The current ATO application will be held in abeyance until NS Power receives the final project FAA from DFO. Once the FAA has been obtained by NS Power, the Company can then file an amended ATO application with the Boar...

AI summary The Board has placed the ATO application on hold until NS Power receives the final FAA from DFO. Once received, an amended application must be filed with updated cost estimates and a decommissioning cost analysis for Ruth Falls. The Board also expects future applications to include lessons learned from prior projects and decommissioning costs.

July 14, 2025 VIA EMAIL Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M11927 - Application by NOV A SCOTIA POWER IN COR...

AI summary The Small Business Advocate (SBA) confirms that the Fisheries Act Authorization for NS Power's project has been approved and reiterates concerns about costs, requesting the Board to require NS Power to provide regular status updates on the project.

- adjusted on only two line items: Line Item ATO Application Updated Difference Offsetting (West River Project) $547,142 $440,750 -$106,392 Offsetting contingency $500,000 $0 -$500,000 Total Difference: -$606,392

AI summary The document shows adjustments made to two line items related to the West River Project and offsetting contingency, resulting in a total difference of -606,392. The adjustments include a reduction of 106,392 for the West River Project and a complete reduction of 500,000 for the offsetting contingency.

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.

- results of the analysis show that even if these two extreme changes to the inputs occur in conjunction, both - of which serve to improve the prospects of the decommissioning alternative, the refurbishment alternative is - still preferabl...

AI summary The analysis indicates that even under extreme changes to input assumptions, the refurbishment alternative remains preferable by over $2 M in NPV. The analysis was rudimentary due to time constraints but suggests that NS Power's economic analysis is stable unless there are extreme deviations in replacement energy and decommissioning costs.

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.

Offsetting In its submission, Midgard indicated that the decrease in offsetting costs, as outlined in the updated Detail Cost Estimate (DCE) would indicate a lower cost per square metre than had been estimated by the Company, as the final...

AI summary Midgard pointed out that the updated Detail Cost Estimate (DCE) shows a decrease in offsetting costs, which suggests a lower cost per square metre than previously estimated by the Company. Midgard requested more details from NS Power on how it is estimating the cost of offsetting. NS Power explained that the initial unit rate of $25/m2 was an estimate used for the project budget, and the updated costs reflect the unit rate from a proponent's proposal awarded after the ATO filing.

Project Budget Approval Amount NS Power respectfully disagrees with the Industrial Group's recommendation for the Company to be required to manage the project expenses within the envelope approved by the Board, before accounting for any al...

AI summary NS Power disagrees with the Industrial Group's recommendation to manage the Ruth Falls Main Dam project expenses within the approved budget before accounting for AFUDC. It argues that all prudently incurred costs should be recoverable through the rate base, unlike the Lower Water Street project, which had viable alternatives and higher risks.

CONCLUSION The Company would like to reiterate, as indicated in its letter dated July 4, 2025, that the construction schedule for the Ruth Falls project is confined by the dates as set forth in the Company's FAA. This requires all in strea...

AI summary The Company reiterates that the Ruth Falls project's construction is constrained by the FAA's timeline, with in-stream work required between July 21, 2025, and March 31, 2026. Deferring construction would lead to cost escalations, and the Company maintains that refurbishing the Ruth Falls Main Dam is the lowest-cost option. The Company requests expedited approval of the ATO with an amended cost of $14,839,116.

M11927 – Nova Scotia Power Incorporated – CI 50518 – HYD Ruth Falls Main Dam Refurbishment – $14,839,116 (Amended ATO) On June 18, 2025, the Nova Scotia Energy Board (Board) issued a decision in Matter M11927 Nova Scotia Power Incorporated...

AI summary The Nova Scotia Energy Board (Board) has put the Authorization to Overspend (ATO) application for the Ruth Falls Main Dam Refurbishment on hold until the Fisheries Act Authorization is obtained. NS Power has now submitted an amended ATO application with a reduced cost estimate of $14,839,116 and a Net Present Value (NPV) analysis showing that the refurbishment option is more economically favorable than decommissioning.

ommissioning cost estimate is for the decommissioning of only the Ruth Falls portions of the Sheet Harbour hydro system, though this is not stated explicitly by NS Power. More broadly, Midgard stated: NS Power's estimation of decommissioni...

AI summary NS Power's decommissioning cost estimate for the Ruth Falls portion of the Sheet Harbour hydro system has increased significantly over seven years, surpassing the previously estimated cost for decommissioning the entire system. This discrepancy raises concerns about the accuracy and consistency of decommissioning cost estimates for hydroelectric facilities in Nova Scotia.

Board Findings The Board finds that NS Power has provided an adequate response to Midgard's recommendation about providing an update on the July 1, 2025, to July 21, 2025, construction window to construct access roads. No further direction...

AI summary The Board finds that NS Power has adequately addressed Midgard's recommendations regarding the construction window for access roads and the offsetting cost in its amended ATO application. The Board does not require further action on these items and acknowledges the updated cost estimate based on a proponent's lower unit cost.

CI Number: 50518 Date: July 8, 2025 Expenditure Profile Type of Filing Year Budget Amount Project Estimate Capital Project Authorization 2017 125,191 125,191 Unforeseen and Unbudgeted (U&U) 2018 201,467 86,643 Planned & Advanced (P&A) 2019...

AI summary The document presents a capital expenditure profile for Nova Scotia Power Incorporated, detailing budget amounts, project estimates, and authorization types for various years from 2017 to 2026. It includes a total budget of $7,244,422 and a current submission of $14,839,116, with an ATO variance of $7,594,694.

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.