N-2NSPI (Midgard) RIR 1 to 14 - Redacted
12 passages
CONFIDENTIAL (Attachment Only) S/N List of Sites Internal Labour Contracts (Elect Eng Tech) Contracts (Civil) $ Materials - Travel Exp & Meals ($) Materials RTU Materials- Cables, Accs and Test Equipment Materials -Power Meters Total 87W (...
AI summary The document contains a table with details on internal labour, contracts, materials, and total costs for various sites. The data is presented in a structured format with specific line items and totals. The attachment is marked as confidential and has been removed from public review.
NON-CONFIDENTIAL Response IR-2: 2 1 (a) The methodology used is based on the project team's experience on prior RTU replacement projects, actual estimates received on material pricing, and anticipated cost changes from increased complexity...
AI summary The response outlines the methodology used for estimating project costs, referencing prior experience, material pricing, and lessons learned. It also notes the implementation of more standard contingency guidelines by NS Power after the first four projects.
15 CI Number Title Total Approved (including Contingency) ($) Contingency ($) Contingency % 38142 RTU Replacement Program 512,974 6,000 1% 40245 2011 RTU Replacement 459,517 7,500 2% 41428 2012 RTU Replacement 314,026 - - 43227 2014 RTU Re...
AI summary The table lists various RTU replacement programs with their total approved amounts, contingency funds, and contingency percentages, indicating planned expenditures and risk management strategies for these projects.
NON-CONFIDENTIAL 1 (f) (i) Historical actuals from the most recent RTU Replacement project (CI 52308, Phase 2 5) were used in developing the original Phase 6 estimate. Recent experience and 3 actuals from the completed RTU replacements und...
AI summary The text discusses the RTU Replacement project, highlighting the use of historical data from previous phases to develop estimates for Phase 6. It mentions improvements in productivity due to standardization and technological advancements, and references attachments and other sections for further details on labour adjustments and project reviews.
- 4 (Exhibit N-1), NS Power represents the following table: Title: RTU Replacements Projecution Year: 2025 - 2027 gram – Phas e 6 Description Unit Quantity Un it Estimate Total Estimate Cost Support Reference Completed Similar Pro (FP#'s)...
AI summary The document presents a cost estimate table for the RTU Replacements Project from 2025 to 2027, detailing labor, materials, and other expenses associated with the project. It includes labor costs for various roles, material costs for RTUs and related equipment, and subcontractor costs.
5 Labour AO Rates 6 7 Eligible expenses are accumulated and allocated on the basis of capital labour as a 8 percentage of total labour, to determine the total eligible overhead costs to be capitalized, 9 as outlined in NS Power's NSEB-appr...
AI summary Eligible expenses are allocated based on capital labour as a percentage of total labour to calculate the total eligible overhead costs to be capitalized. NS Power uses its NSEB-approved Accounting Policy 6230 to determine the AO rate, adjusting overtime labour by 50% to account for overtime rates, with only 50% of overtime labour costs attracting administrative overhead.
- presents the following table: CI Cost Element Source C0031048 - 91H-T11 Materials Purchase Agreement Transformer Contracts Internal Expertise/Purchase Agreement Replacement Consulting Internal Expertise C0050834 - Spare EHV Materials Pur...
AI summary The text presents a table detailing various cost elements and their sources for different projects, including materials, contracts, and consulting. It specifically highlights Phase 6 (CI C0051815) and its contracts costs, which are sourced from external advice and internal expertise.
Review of C0051815 NSEB IR-5 Attachment 4 Page 1 of 1 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Harbour Construction Company Ltd. effective as of Nov ember 1, 2021. Authoriz zation Number: Date: September 16 th 2022 Project: RTU Installa...
AI summary The document outlines a contract between Nova Scotia Power and Harbour Construction Company Ltd. for the installation of civil works at various sites, including the supply and installation of buried conduits, pullpits, grounding, and gravel works. The contract was signed on September 16, 2022, with services commencing on September 26, 2022, and expected to be completed by November 30, 2022. The total estimated contract price is $59,210.00 plus HST.
also states: Regular Labour (Internal) Unit Days Total Hours Avg Hours per RTU T & D Labor (Engineering & Technicians) PD 485 3880 485 Preamble: In Undertaking U‑6 (Exhibit N-21 of 2025 ACE Plan), NS Power states that accessibility challen...
AI summary NS Power highlights that accessibility challenges and workforce constraints necessitate overtime for RTU installations in Undertaking U-6. However, the Phase 6 capital project estimate only budgets overtime for SM Electricians, with a limited allowance of 20 person-days for the entire project.
11 Response IR-12: 12 13 (a) Overtime labour is assumed only for Electrician/Technician and PLT in the Phase 6 revised 14 estimate. No overtime labour is assumed for any other roles. 15 16 (i) In the revised Phase 6 detailed estimate, over...
AI summary The response discusses the assumption of overtime labour for specific roles in the Phase 6 revised estimate of the RTU Replacements Program. Overtime is only applied to Electrician/Technician and PLT roles, and not to any other roles.
Review of C0051815 - RTU Replacements Program - Phase 6 (NSEB M12550) NSPI Responses to NSEB Information Requests 1 (a) Please provide a comparison of the original Capital Cost Detailed Estimate as filed in 2 Exhibit N-1 versus the updated...
AI summary The document outlines information requests from the Nova Scotia Energy Board (NSEB) to Nova Scotia Power Inc. (NSPI) regarding the RTU Replacements Program - Phase 6. It includes requests for a comparison of capital cost estimates, explanations for variances, a breakdown of vehicle overhead costs, and details on the Allowance for Funds Used During Construction (AFUDC) calculations.
CI - C0051815 AFUDC Calculation Cost Code 202404 202405 202406 202407 202408 202409 202410 202411 202412 202501 202502 Total Spend Prior to In-Service Date Regular Labour 629 794 1,125 12,554 8,888 15,807 13,891 5,182 7,444 25,244 15,929 1...
AI summary This document details the calculation of AFUDC (Allowance for Funds Used During Construction) for a project, including various cost categories such as labour, materials, and overheads, along with the AFUDC rate and cumulative AFUDC amounts for each month from April 2024 to February 2025.
N-3Evidence - Midgard - Redacted
44 passages
1 INTRODUCTION - Midgard Consulting Incorporated (" Midgard ") has been retained by Counsel for the Nova Scotia Energy Board - (" NSEB ") to carry out a review of the Nova Scotia Power Incorporated's (" NSPI ") "RTU Replacements Program -...
AI summary Midgard Consulting has been retained by the Nova Scotia Energy Board to review NSPI's RTU Replacements Program Phase 6 Application. NSPI seeks approval for approximately $5.96M in capital costs to replace RTUs and maintain system reliability. The report provides professional findings based on a review of the information provided.
1.1 Application Context[2](#page-6-1) - NSPI included CI C0051815 in its 2025 Annual Capital Expenditure (" ACE ") Plan for the replacement of 14 RTUs, - based on risk assessments identifying the equipment as obsolete. During the review of...
AI summary NSPI submitted a project for RTU replacement in its 2025 ACE Plan, but the NSEB withheld approval due to a significant increase in estimated labour hours. The NSEB requested further justification for the four-fold increase in labour hours, attributing it to infrastructure complexity and compliance requirements, and initiated a separate process to verify the budget estimate.
1.2 Report Structure - Midgard evaluates NSPI's rationale for proceeding with the Project, focusing on whether the justifications are - adequately supported by evidence from the application and NSPI's responses to subsequent Information -...
AI summary Midgard evaluates NSPI's rationale for proceeding with the Project, focusing on whether the justifications are adequately supported by evidence from the application and NSPI's responses to Information Requests (IRs). The report is structured into sections that review project context, execution strategy, project controls, cost reasonableness, and appendices with supporting data.
- [2.](#page-9-0) Table 2: Project Key Milestone[s](#page-9-2) 3 Key Milestone Target Date Start Date April 2024 In-Service Date July 20254 Final Cost Date November 2027 - The total forecasted capital cost of the Replacement Project, as fi...
AI summary The Replacement Project has a total forecasted capital cost of $5,959,915, which was later refined to $5,058,964 after adjusting based on execution experience from the first two completed sites. Key milestones include a start date in April 2024, an in-service date in July 2025, and a final cost date in November 2027.
- comprises two primary components: - 1. The acquisition of 14 standardized RTUs to replace obsolete equipment, detailed engineering design to integrate the new units with existing field devices (e.g., IEDs), and the development of telecom...
AI summary NSPI proposes a capital expenditure to replace 14 obsolete RTUs with standardized units to support system reliability, grid modernization, and mitigate equipment failure risks. The project includes engineering design, installation, and integration with the SCADA system. NSPI requests regulatory approval, citing the lack of vendor support and the need for spare parts inventory.
3 PROJECT EXECUTION STRATEGY - This section examines NSPI's execution approach for the Project to assess the efficiency and effectiveness of - the Project's planning, sequencing, and incorporation of prior process improvements. This sectio...
AI summary This section evaluates NSPI's project execution strategy, focusing on whether the Project's planning, sequencing, and integration of prior improvements have been optimized for efficiency and effectiveness, particularly through prioritization based on criticality and leveraging pre-Phase 6 experience to reduce costs.
3.1 Installation Prioritization and Sequencing - NSPI confirms that the selection of the 14 RTUs for Phase 6 relied on an "overall risk matrix of condition and - criticality." [10](#page-11-1) Prioritization was driven by asset age, manufa...
AI summary NSPI prioritized the replacement of 14 RTUs in Phase 6 based on a risk matrix considering asset age, criticality, and manufacturer support. However, the technical complexity of the sites, rather than schedule pressure, is identified as the main cost driver for the increased labour hours required.
5 3.1.1 Conclusions – Installation Prioritization and Sequencing - 6 The installation sequence does not appear optimized to maximize work crew efficiency through progressive - 7 skill development. While NSPI employs process optimizations s...
AI summary The installation sequence for the Program is not optimized for maximizing work crew efficiency through progressive skill development. While NSPI uses process optimizations, the installation schedule is driven by risk mitigation rather than productivity gains. A learning-curve approach could improve efficiency and reduce costs, but the lack of Program-level productivity metrics makes it difficult to assess whether prior efficiency gains are being incorporated into Phase 6 estimates.
22 Table 5: Summary of Findings – Installation Prioritization and Sequencing Report Section Question Midgard Commentary 3.1 Has NSPI optimized the Project's execution by prioritizing installations based on criticality, complexity, or oppor...
AI summary The document discusses the prioritization of installations in a project managed by NSPI, emphasizing that prioritization is based on asset criticality and risk mitigation rather than complexity or learning-curve benefits. The schedule lacks low-to-high complexity sequencing, and the absence of historical productivity metrics hinders verification of claimed process improvements.
3.2 Process Standardization & Cost Reduction NSPI asserts that its execution strategy for the Project builds upon a foundation of historical experience, stating that: "The methodology used is consistent with prior phases and has been progr...
AI summary NSPI claims that its execution strategy for the Project is based on historical experience and has been refined through prior phases. It highlights improvements in standardization, quality assurance, and supply-chain efficiencies, though it acknowledges that Phase 6 involves significantly more complex requirements than earlier phases.
NSPI also argues that: "The greater emphasis on pre-work, detailed planning and QA (Quality Assurance) enhancements have resulted in more efficient installation and commissioning work with greater predictability of time required and reduce...
AI summary NSPI claims that pre-work and QA improvements have increased efficiency and predictability in installation and commissioning. However, no empirical data is provided to support these claims, and historical baseline data was lost in a cyber incident, making it impossible to verify efficiency gains or track process improvements from prior phases.
3.2.1.1 Labour Planning & Institutional Knowledge - Despite operational standardization, NSPI's ability to demonstrate cost efficiency is materially limited by the - absence of formal knowledge management. Knowledge transfer appears to be...
AI summary NSPI lacks formal knowledge management practices, leading to gaps in documented lessons learned and productivity metrics for RTU replacement projects. This creates risks of institutional memory decay and challenges in assessing cost reasonableness due to the absence of reliable productivity benchmarks.
Table 6: Comparative Analysis of Phase 5 vs. Phase 6 RTU Unit Costs (2025$) [30](#page-16-4) 15 Estimate Cost Cost Cost per RTU Cost per RTU Variance Variance Element (Phase 5) (Phase 6) (Phase 5) (Phase 6) ($) (%) Regular Labour $175,896...
AI summary The table compares the costs of Phase 5 and Phase 6 RTU unit costs, showing significant increases in labour and travel expenses, while material costs remained relatively stable. This highlights a shift in cost drivers from hardware to direct labour and logistical support.
8 3.2.1.2 Quantification & Measurement 1 Project management frameworks emphasize quantitative performance metrics as essential for validating process improvements. NSPI's reliance on qualitative assessments (e.g., "greater predictability,...
AI summary NSPI's use of qualitative assessments limits the ability to demonstrate measurable productivity gains and cost efficiencies from standardization efforts. Financial data from prior Program Phases show mixed results, with significant variances and an increase in contingency allowances, despite claims of improved estimating methodology.
3.2.1.3 Adaptive Learning in Phase 6 - Despite these historical gaps, NSPI has demonstrated adaptive learning and improved cost control mechanisms - within Phase 6 itself. The most significant evidence of this is the approximate $900,000 c...
AI summary NSPI has demonstrated adaptive learning in Phase 6, leading to a $900,000 cost reduction after completing the first two sites. The Project team is using real-time data to refine estimates, such as adjusting labour allocation for the Project Manager who supports multiple projects.
Table 7: Phase 6 Cost Estimate Refinements (Adaptive Learning)[38](#page-18-7) Cost Estimate Element Fiscal Change ($) NSPI Variance Explanation Project Management -$111,800 The project manager was determined not to be needed on a full-tim...
AI summary The text discusses cost estimate refinements for Phase 6, including a reduction in Project Management costs due to the project manager not being needed full-time and a reduction in Civil Construction costs due to fewer sites requiring construction, partially offset by increased effort at one specific site.
- 4 The following summarizes Midgard's conclusions from the review of the Project: - 5 1. Installation Prioritization and Sequencing: NSPI's decision to sequence installations based on asset 6 condition and criticality was necessary to mit...
AI summary Midgard's review of NSPI's Project highlights issues with installation sequencing and process standardization. While prioritizing installations based on asset condition was necessary, it missed opportunities for efficiency through learning curves. Standardization efforts improved consistency, but lack of formal reviews and metrics limits validation of efficiency gains.
1 Table 9: Project Execution Strategy Conclusions Report Section Question Midgard Commentary 3.1 Has NSPI optimized the Project's execution by prioritizing installations based on criticality, complexity, or opportunities for learning-curve...
AI summary The document evaluates NSPI's project execution strategy, noting that prioritization is based on asset criticality and risk rather than complexity or learning-curve benefits. It also questions whether NSPI effectively leveraged prior experience to standardize designs and reduce costs, citing a lack of formal lessons-learned reviews and quantitative metrics as limitations.
4 PROJECT CONTROLS & GOVERNANCE - This section evaluates NSPI's use of historical data from Phases 1-5 to inform Phase 6 planning and execution, examining whether the utility maintained adequate productivity tracking, applied lessons learn...
AI summary This section evaluates NSPI's use of historical data from Phases 1-5 to inform Phase 6 planning and execution, focusing on productivity tracking, lessons learned, and cost-effectiveness of internal versus external resources. It also examines the methodology supporting the Phase 6 Capital Cost Estimate classification and contingency allowance.
4.1 Delivery Model Justification - NSPI's Capital Expenditure Justification Criteria (" CEJC ") mandates the "Evaluation of alternative means of acquiring technologies including design and build (NSPI owned)... or contract to others," and...
AI summary NSPI's Capital Expenditure Justification Criteria (CEJC) require evaluating alternative delivery models using financial metrics like NPV, but no such analysis was performed for Phases 1 to 6 of the Program. NSPI instead relied on qualitative justifications and internal resource availability, despite capacity constraints driving the decision to use external contractors.
4 4.1.1 Conclusions – Delivery Model Justification - 5 NSPI fails to demonstrate that its internal resource model is more cost-effective than external alternatives. - 6 NSPI's indication that no formal comparative cost analysis was underta...
AI summary NSPI has not demonstrated that its internal resource model is more cost-effective than external alternatives. The lack of formal comparative cost analysis undermines the validation of its delivery model's efficiency as required by the CEJC. Qualitative justifications for internal resources are not supported by financial data or market benchmarks, raising concerns about the prudence of the overhead premium paid for internal labor.
11 Table 10: Summary of Findings – Delivery Model Justification Report Section Question Midgard Commentary 4.1 Did NSPI demonstrate that its reliance on internal resources was more cost-effective than external alternatives? NSPI acknowledg...
AI summary NSPI did not conduct a formal make versus-buy analysis for Phase 6, and no quantitative evidence was provided to demonstrate that relying on internal resources was more cost-effective than external alternatives, despite competitive tendering for some aspects of the project.
13 4.2 Estimate Basis and Risk Quantification - 14 NSPI's methodology supporting the Phase 6 estimate relies on qualitative expert judgment rather than - 15 quantitative historical baselines, deviating from a strictly data-driven approach....
AI summary NSPI uses qualitative expert judgment rather than quantitative historical data for its Phase 6 estimate, classifying it as an AACE Class 3 Estimate. While this classification is technically supported, the lack of historical calibration and granular data from previous phases increases uncertainty. NSPI's contingency determination is based on qualitative risk assessments rather than quantitative modeling.
Table 11: Historical RTU Program Costs and Contingency Allocations (Phases 1-6)[53](#page-25-1) CI Approved Actual Cost Contingency Number Phase Amount ($) ($) Variance ($) Contingency ($) (%) 38142 - $512,974 $410,229 -$102,745 $6,000 1%...
AI summary The data in Table 11 shows that contingency allocations for RTU Program Phases 1-6 have shifted from 0-2% to a flat 10% for Phases 4, 5, and 6, despite varying risk levels. NSPI does not assign monetary values to identified threats or use probabilistic modeling to calculate risk reserves, suggesting the 10% contingency is a static policy allowance rather than a risk-based reserve.
4.2.1 Conclusions – Estimate Basis and Risk Quantification - While NSPI's estimate classification (Class 3) aligns with the level of engineering definition (via its representative IFC packages), the valuation of that estimate and its conti...
AI summary The document discusses NSPI's estimate classification (Class 3) and its reliance on heuristic judgment rather than empirical data. It highlights the lack of historical productivity metrics and the absence of a data-driven approach for the 10% contingency applied to Phase 6 costs, which excludes internal administrative overhead and capitalized interest.
1 Table 12: Summary of Findings – Estimate Basis and Risk Quantification Report Section Question Midgard Commentary 4.2 Is the Phase 6 Capital Cost Estimate classification and contingency allowance supported by a data-driven methodology? N...
AI summary The Phase 6 Capital Cost Estimate by NSPI is classified correctly but lacks empirical calibration. The base unit rates and 10% contingency are based on judgment rather than quantitative risk analysis, with no clear linkage from the risk register to expected risk costs.
3 4.3 Overall Project Prudence & Ratepayer Interest - 4 The following summarizes Midgard's conclusions from the review of the Project: - 5 1. Delivery Model Justification: NSPI defaults to an internal resource model for core execution with...
AI summary Midgard's review of the Project highlights concerns with NSPI's delivery model and estimate basis. NSPI did not conduct a comparative financial analysis for internal resource allocation, and the Phase 6 estimate lacks historical data calibration, relying instead on judgment rather than probabilistic risk modeling.
19 Table 13: Project Controls & Governance Conclusions Report Section Question Midgard Commentary 4.1 Did NSPI demonstrate that its reliance on internal resources was more cost-effective than external alternatives? NSPI acknowledges that n...
AI summary The document discusses NSPI's reliance on internal resources for Phase 6 without conducting a formal make versus-buy analysis, and highlights that core technical work was assigned internally without market testing, with no quantitative evidence provided.
Midgard Consulting Inc 530 – 1130 West Pender St. Report Section Question Midgard Commentary demonstrate that higher internal overhead rates were offset by productivity gains. 4.2 Is the Phase 6 Capital Cost Estimate classification and con...
AI summary Midgard Consulting Inc. comments on NSPI's Phase 6 Capital Cost Estimate, noting that while it is classification-compliant, the contingency allowance and base unit rates are judgment-based without quantitative linkage to risk register data.
5.1 Labour Hour Escalation & Scope Justification - The assessment of the Project's labour requirements was developed from a constrained but representative evidence base. For three of fourteen sites (91V – Fourth Lake Hydro, 55 74N – Spring...
AI summary The document discusses the assessment of labour requirements for a Project, noting that complete IFC packages are available for only three of fourteen sites. For the remaining sites, ECS and SOD provide limited scope information. NSPI explains that Phase 1 data is unavailable due to the age of the records and the absence of key personnel. Labour hour escalation is attributed to factors such as increased I/O points, integration with SCADA, and site accessibility.
16 However, review of site-specific RFW forms indicates that the total duration allocated for installation and 17 commissioning activities is 11 1111111 1111 111 11. The RFW specifies 11111111 111 11 11111111 1111 1 11 18 11111111111 11111...
AI summary The text discusses discrepancies between the duration allocated for installation and commissioning activities as specified in RFW forms and the 25-32 day estimate provided by NSPI. The RFW forms are noted to reflect the actual scope of field activities, but the basis for NSPI's estimate and its reconciliation to RFW-documented durations was not provided.
- 1 [Table 14](#page-30-0) presents the variances between NSPI's filed labour estimate and Midgard's allocation by resource - 2 category. Midgard's allocations are based upon professional opinion and experience. Detailed Phase-by-Phase - 3...
AI summary Table 14 highlights the differences between NSPI's labour estimate and Midgard's allocation by resource category. Midgard's allocations are based on professional judgment and experience, with detailed phase-by-phase allocations and role definitions provided in Appendix A.
Table 14: Labour Hour Variance Analysis[65](#page-30-1) 4 Resource Category Total Hours/RTU - NSPI Total Hours/RTU – Midgard Variance (Hours) Variance (%) SM Electrician 272 150 -122 -44.9% Engineering 431 255 -176 -40.8% Telecontrol Techn...
AI summary Table 14 presents a labour hour variance analysis comparing Nova Scotia Power Incorporated (NSPI) and Midgard across various resource categories. The data shows significant variances in hours, with some categories showing over 50% reduction in hours for Midgard compared to NSPI.
6 5.1.1 Conclusions - 7 The 33% variance between NSPI's filed labour estimate (1,939 hours/RTU) and the allocation derived from - 8 Phase 6 technical documentation (1,291 hours/RTU) demonstrates that filed labour requirements lack - 9 suff...
AI summary The text highlights a 33% variance between NSPI's filed labour estimate and the allocation derived from Phase 6 technical documentation, indicating insufficient evidentiary support. Midgard recommends a 30% reduction in labour hours to align with a technically supportable baseline.
20 Table 15: Summary of Findings – Labour Hour Escalation & Scope Justification Report Section Question Midgard Commentary 5.1 Are the substantial increases in labour requirements, per RTU, substantiated by objective evidence of expanded s...
AI summary Table 15 discusses findings related to labour hour escalation and scope justification, noting a 33% variance between NSPI's estimate and an independent allocation, and recommending a 30% reduction in labour hours due to unresolved disputes and lack of task-level traceability.
9 5.2.1 Conclusions – Material Procurement & Cost Competitiveness NSPI utilized appropriate competitive tendering processes for major equipment and leveraged established service agreements for labour and civil works, ensuring pricing refle...
AI summary NSPI used competitive tendering for major equipment and service agreements for labour and civil works, ensuring current market pricing. Cost variances are justified by increased functional requirements and macroeconomic factors like inflation and currency devaluation. The material costs represent reasonable value for enhanced functionality.
16 Table 16: Summary of Findings – Material Procurement and Cost Competitiveness Report Section Question Midgard Commentary 5.2 Has NSPI demonstrated that equipment and material costs reflect competitive procurement practices and represent...
AI summary The document confirms that NSPI has demonstrated competitive procurement practices and reasonable value for equipment and material costs, supported by competitive tendering and justified cost variances due to functional increases and inflation.
- 19 NSPI applies Labour Administrative Overhead (" AO ") rates of 57.79% (2024), 56.63% (2025), and 53.98% (2026 - 20 onwards). Contractor AO rates are significantly lower, trending downward from 15.27% in 2024 to 10.45% by - 21 2026, as...
AI summary The document discusses Nova Scotia Power Incorporated's (NSPI) application of Labour Administrative Overhead (AO) rates for 2024 to 2026, noting higher rates for NSPI compared to significantly lower contractor AO rates over the same period.
2 6.1 Conclusions - 3 [Table 20](#page-37-0) summarizes Midgard's findings regarding NSPI's Project execution strategy, controls and governance, - 4 and cost estimating decisions for the Project.
AI summary This section concludes the analysis of Midgard's findings on NSPI's Project execution strategy, controls, governance, and cost estimating decisions.
5 Table 20: Summary of Conclusions Report Section Question Midgard Commentary 3.1 Has NSPI optimized the Project's execution by prioritizing installations based on criticality, complexity, or opportunities for learning-curve benefits? Prio...
AI summary The analysis evaluates whether NSPI optimized project execution by prioritizing installations based on criticality and risk mitigation, and whether prior experience was leveraged to standardize designs and reduce costs. The commentary notes that prioritization was not based on complexity or learning-curve benefits, and that efficiency gains were not empirically validated.
A.1 Methodology - The allocation methodology applies a conservative benchmarking approach. Following review of ECS and SOD documentation for all fourteen sites, the three sites with - complete IFC packages (91V Fourth Lake Hydro, [77](#pag...
AI summary The document outlines a methodology for allocating labour based on the workload derived from IFC packages at selected sites, scaling labour proportionally to signal scope and accounting for travel time based on site presence. This approach was applied to evaluate engineering, design, and commissioning activities across multiple sites.
1 A.2 Comparative Tables - 2 [Table 21](#page-40-1) presents a Phase-by-Phase labour allocation across nine resource categories, totaling 1,291 hours per RTU, alongside NSPI's filed estimate of 1,939 hours per - 3 RTU. The labour compariso...
AI summary Table 21 compares phase-by-phase labour allocation across nine resource categories, totaling 1,291 hours per RTU, with NSPI's estimate of 1,939 hours per RTU. Table 22 provides role definitions for the labour comparison.
DEAL MAKING - Closer: Energy derivatives marketer (helped clients achieve revenue/cost certainty). - M&A: Lead or co-lead of several hydro transactions. - Negotiated 2-year ($200M) power sales and transmission agreements. - Problem Resolve...
AI summary The text outlines various deal-making activities, including energy derivatives marketing, M&A transactions, power sales agreements, problem resolution in power purchase agreements, and asset management agreements with major financial institutions and governments.
MIDGARD CONSULTING INC. 2021 - Present Consultant, Vancouver BC - Delivered consulting services across the electricity industry to clients including electric utilities, municipalities, First Nations, and renewable energy developers. - Cond...
AI summary Midgard Consulting Inc. has provided consulting services in the electricity industry, focusing on solar photovoltaic systems, financial modeling, and regulatory filings. They have worked with utilities, municipalities, and Indigenous communities, and contributed to expert evidence in various regulatory proceedings.
N-7Rebuttal Evidence - NS Power
9 passages
NON-CONFIDENTIAL 1 TABLE OF CONTENTS 2 3 1.0 INTRODUCTION 3 4 2.0 NS POWER RESPONSES TO MIDGARD KEY CONCLUSIONS 5 5 2.1 Project Execution and Prioritization 5 6 2.2 Process Standardization & Cost Reduction 7 7 2.3 Use of Internal Resources...
AI summary Nova Scotia Power (NS Power) submitted a revised estimate for the Remote Terminal Units (RTU) Replacements Program – Phase 6, reducing the original estimate from $5,959,915 to $5,058,726. This follows a review by Midgard Consulting Inc., engaged by the Nova Scotia Energy Board (NSEB), to assess the project's scope and estimated costs as part of the 2025 Annual Capital Expenditure (ACE) Plan.
more complex installations, noting that "such an approach would front-load productivity 20 improvements, reducing unit costs for later installations while compressing overall project 21 duration". 22 23 NS Power's capital investment decisi...
AI summary NS Power's capital investment decisions are based on asset management principles, prioritizing high-risk equipment replacement regardless of complexity. However, the lack of Program-level productivity metrics makes it difficult to assess whether efficiency gains from prior phases are reflected in Phase 6 cost estimates.
24 2.3 Use of Internal Resources 25 26 The Midgard Evidence provided the following conclusion regarding the cost effectiveness of NS 27 Power utilizing internal resources compared to external alternatives: 28 29 NSPI acknowledges that no f...
AI summary The Midgard Evidence evaluated the cost-effectiveness of NS Power using internal resources for Phase 6, noting that no formal make-versus-buy analysis was conducted. NS Power explains that internal resources were used based on task requirements, specialized skills, and availability, with external contractors used where necessary.
17 2.4 Classification and Contingency Allowance 18 19 The Midgard Evidence provided the following conclusion regarding the NS Power estimate 20 classification and contingency allocation: 21 22 NSPI's Phase 6 estimate is classification‑comp...
AI summary The Midgard Evidence concludes that NSPI's Phase 6 estimate is classification-compliant but not empirically calibrated, with the base unit rates and 10% contingency being judgment-based. Contingency allowances have trended upward in recent phases, despite NSPI acknowledging the use of such funds.
11 Exhibit N-3, Midgard Evidence, February 18, 2026, page 38. 1 2 3 4 5 6 were required in only one of the five previous Phases (Phase 3). For Phase 6, the contingency is set at 10%, a rate that aligns with the maximum percentage allocated...
AI summary The document discusses the contingency rate for Phase 6 of a project, set at 10%, which aligns with the maximum percentage used in prior phases. NS Power argues that this rate is based on lessons learned, expert judgment, and market volatility considerations, rather than being influenced by past contingency use.
13 Exhibit N-3, Midgard Evidence, February 18, 2026, page 39. 1 2 The reduction in Project Management hours indicates an optimization of overhead resources, shifting from a dedicated resource model to a shared resource model. 3 Similarly,...
AI summary The text discusses adjustments in project management and civil construction costs, noting a shift to a shared resource model and site-specific cost adjustments. NS Power disagrees with Midgard's assertion that initial estimates were too high, arguing that the changes reflect prudent cost control. NS Power agrees with Midgard's conclusions on procurement practices and indirect cost methodologies.
1 3.0 NS POWER RESPONSES TO MIDGARD RECOMMENDATIONS 2 3 3.1 Adjustment to Labour Estimate 4 5 The Midgard Evidence provided the following recommendation regarding NS Power's labour 6 estimate: 7 8 Reduce the approved labour hours for the P...
AI summary NS Power disagrees with Midgard's recommendation to reduce the approved labour hours by 30%, arguing that their estimate is technically sound and based on actual execution experience. NS Power highlights that Midgard's analysis has limitations and that their own estimate benefits from internal expertise and costs incurred to date.
3 Commissioning: Final validation; requires operational outages; cannot overlap with 14 installation. Includes functional testing, operational trials, documentation, cutover, spare 15 parts harvesting 17 Midgard's analysis appears to assum...
AI summary NS Power argues that Midgard's labor estimate underestimates site-specific variables, potentially leading to equipment failure, safety risks, and an understated labor budget. NS Power believes the project will ultimately require additional regulatory review, which would be inefficient and inconsistent with current budgeting practices.
1 4.0 CONCLUSION 2 3 NS Power submits that the capital expenditures outlined in this application are reasonable, prudent, 4 and in the best interest of customers. No intervenor opposed the application through the 2025 5 ACE Plan proceeding...
AI summary NS Power argues that the capital expenditures in its application are reasonable, prudent, and in the best interest of customers. They claim no intervenor opposed the application during the 2025 ACE Plan proceeding and that they have fully addressed Midgard's recommendations. The project supports NS Power's Five-Year Reliability Plan and is needed for grid resilience and telecommunications connectivity.
100252Midgard (NSPI) IR 1 to 17 - PDF
9 passages
NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION BY NOVA SCOTIA POWER INCORPORATED To obtain a cost reasonableness review of NS Power - CI C0051815 – $5,959,515 - RTU Replacements...
AI summary This document pertains to a cost reasonableness review application by Nova Scotia Power Incorporated under the Public Utilities Act, concerning the RTU Replacements Program – Phase 6, with a total cost of $5,959,515, as outlined in the 2025 Annual Capital Expenditure Plan decision (M12012).
- N-1), NS Power represents the following table: Location: General Plant Cl#: C0051815 Title: RTU Replacements Pro Execution Year: 2025 - 2027 gram – Phas e 6 Description Unit Quantity Unit Estimate Т otal Estimate Cost Support Reference C...
AI summary The document presents a detailed cost breakdown for RTU replacements at NS Power, including labor, materials, and overhead costs, for execution years 2025-2027. It requests an itemized equipment list for Phase 6 and Phase 1 in Excel format.
Request IR-4: - At Attachment 1 of the letter filed by NS Power on December 9, 2025, NS Power presents its updated Capital Project Cost Estimate. According to the Capital Project Detailed Estimate, the total internal labour cost, including...
AI summary NS Power has submitted an updated Capital Project Cost Estimate, detailing internal labour costs and overheads. The document requests clarification on the components and calculation methodologies for Labour AO, Contractor AO, and Vehicle AO, as well as differences between current and previous estimates.
the following table: CI Cost Element Source C0031048 - 91H-T11 Materials Purchase Agreement Transformer Contracts Internal Expertise/Purchase Agreement Replacement Consulting Internal Expertise C0050834 - Spare EHV Materials Purchase Agree...
AI summary The text outlines various cost elements and their sources related to different projects, including materials, contracts, consulting, and internal expertise. It specifically highlights Phase 6 (CI C0051815) under the RTU Replacements Program, with contracts costs sourced from external advice and internal expertise.
Request IR-10: At Page 2 of 3 of the NSPI (NSEB) Undertaking U-6 (Exhibit N-21 of 2025 ACE Plan), NS Power states: Some of the Phase 6 installations are taking place in more remote and/or physically constrained substation environments, inc...
AI summary The proceeding requests detailed information on the travel and setup costs for Phase 6 RTU installations, particularly in remote and constrained locations, and requires a comparison with earlier phases. It also asks for site-specific data on RTU replacement locations for both Phase 1 and Phase 6, including access constraints and logistical details.
At Page 2 of 2 of the NSPI (NSUARB) IR-140 (Exhibit N-9 of 2025 ACE Plan), NS Power also states: Regular Labour (Internal) Unit Days Total Hours Avg Hours per RTU T & D Labor (Engineering & Technicians) PD 485 3880 485 Preamble: In Underta...
AI summary NS Power highlights challenges with accessibility and workforce constraints that necessitate overtime for RTU installations. However, the Phase 6 capital project budget only explicitly allocates overtime for SM Electricians, with a limited allowance of 20 person-days for the entire project.
- At Page 1 of 1 of the letter filed by NS Power on December 9, 2025, NS Power states: - Since the filing of the 2025 ACE Plan application, Nova Scotia Power Inc. (NS Power, Company) has completed some work on CI C0051815. As a result, the...
AI summary NS Power has updated its detailed cost estimate for CI C0051815 following work completed on Phase 6 RTU sites, resulting in a decrease of approximately $900,000. The request asks for details on completed work, in-service dates, cost breakdowns, and lessons learned that contributed to lower forecast costs.
- updated Capital Project Cost Estimate: Description Unit Quantity Unit Estimate Total Estimate Cost Support Reference Completed Similar Pro (FP#'s) , , Regular SM Electrician PD 420 $434 Engineering PD 861 364 $452 $ 389,172 Telecontrol T...
AI summary The document presents an updated capital project cost estimate, including various labor and material costs for different roles and activities involved in a project. It includes detailed breakdowns such as engineering, drafting, project management, and travel expenses, along with quantities and unit estimates.
- b) For each variance identified in Part (a), please explain whether the change is attributable to: - i. A change in measurement Unit (e.g., from Days to PD); - ii. A change in Quantity (with quantification of the delta); - iii. A change...
AI summary The document requests detailed explanations regarding variances in cost estimates, breakdowns of specific costs such as vehicle overhead, and the calculation methodology for AFUDC in capital cost estimates. It also asks for comparisons between original and updated estimates and clarification on assumptions related to AFUDC.