N-3NSPI (NSEB) RIR 1 to 15 - Redacted
3 passages
- 3 In reference to the letter included with the capital application request filed with the Board, - 4 Nova Scotia Power Incorporated (NS Power) stated "Technical setup work and business - 5 process updates have been completed…" 6 7 (a) Pl...
AI summary The document includes a request from the Board for NS Power to detail completed and remaining tasks related to a capital application, identify completed items in the Capital Project Detailed Estimate with final costs, and provide a breakdown of work associated with budget amounts from 2023 to 2026. NS Power refers to an attachment for details.
20 (b-c) The Capital Project Detailed Estimate was not broken down by task but rather by project 21 cost element. The actual costs for work completed by year is provided in the table below: RtR Set Up Actuals Estimates to Complete Totals P...
AI summary The Capital Project Detailed Estimate is categorized by project cost elements rather than tasks. The table outlines actual costs incurred from 2023 to 2025 and estimates for completion in 2026, highlighting expenditures on labour, contracts, consulting, software, overheads, interest, and contingency.
Active Submissions Total A - Technical Evaluation A-1 - Adherence to RFP requirements A-2 - Ongoing support availability and service levels A-3 - Speed and efficiency of implementation (or project) plan, availability, and delivery the indu...
AI summary The text presents a table from an active submission related to technical evaluation and corporate risk criteria for a capital project. It includes sections for adherence to RFP requirements, implementation speed, industry expertise, technology infrastructure, and risk factors such as cybersecurity and insurance. The document is in an early stage, with only a request for information (IR-15) mentioned.
102536Decision
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2.2.1 Project Costs [20] In February 2023, NS Power began work on the project that is the subject of this application. More than three quarters of the forecast costs for the project had already been incurred by NS Power by the time it file...
AI summary NS Power began work on a project in February 2023 and filed an application in December 2025, by which time over three-quarters of the project's costs had been incurred. The project's estimated cost increased from $2.8 million in 2023 to $5.6 million in 2026 due to evolving project scope and delays in seeking Board approval. The project was included in multiple Annual Capital Expenditure (ACE) Plans.
urrent capital application, NS Power will follow the change request process noted in its response to REI IR-21 [Exhibit N-4] to incorporate this work into the overall project implementation and costs. [36] NS Power also provided specific e...
AI summary NS Power is incorporating changes into its capital application through a change request process. It has reviewed various aspects of the project with Renewall, including data interfaces and functional models, though final testing of these interfaces is expected in future work due to the incomplete development of Renewall's IT systems.
3.1.1 Findings [43] The Board finds that the project is necessary to meet NS Power's statutory obligation under s. 22 of the Electricity Act to maintain any tariffs, procedures and standards of conduct necessary to facilitate the renewable...
AI summary The Board finds the project necessary for NS Power to fulfill its statutory obligation under the Electricity Act. NS Power's approach to enhance existing systems was deemed reasonable. Renewall was involved from the beginning but did not present a viable alternative to the project, focusing instead on specific elements like reporting costs and system scalability.
3.2.1.1 Findings [52] The Board's consideration of capital projects should be undertaken before a utility proceeds with any capital work that requires an expenditure above the relevant statutory thresholds in the Public Utilities Act . The...
AI summary The Board emphasizes that capital projects requiring expenditures above statutory thresholds under the Public Utilities Act must be reviewed before approval. NS Power often lists projects for 'subsequent approval' in its ACE Plan filings, which are expected to be submitted later. The Board acknowledges differences in cost estimates between ACE Plans and capital applications but does not require routine reconciliations, reserving the need for such information on a case-by-case basis.
3.2.2 Delay Costs [60] Renewall noted NS Power's evidence that costs relating to delays due to changing commercial operation dates accounted for nearly $1,000,000 of the proposed project costs. NS Power said approximately $460,000 in delay...
AI summary Renewall criticized NS Power for insufficient detail on delay costs, inability to reconcile costs due to a cyber-attack, and failure to consider pausing the project earlier. It also pointed out that AFUDC and administrative overhead costs were 15% of project costs, with no project-specific reconciliation provided.
[63] NS Power argued: The [renewable to retail] implementation is a complex and non-standard undertaking, involving the development of new systems, processes, and integrations to support an emerging market and a retail supplier with a deve...
AI summary NS Power argues that the renewable to retail implementation is complex and non-standard, making it difficult to isolate delay-related costs with precision. It asserts that delays were tied to Renewall's changing commercial operation dates and that there is no evidence to support disallowing these costs.
3.2.3.1 Findings [74] Renewall's concern about cyber-recovery costs is understandable, but speculative. Given NS Power's standard use of project codes, the Board is satisfied that the capital costs for this project do not relate to other w...
AI summary The Board acknowledges Renewall's concerns about cyber-recovery costs but finds them speculative. It is satisfied that NS Power's capital costs for the project are not related to other work and that the project was not impacted by the cyberattack. However, the Board will address any incremental costs from rework due to the cyberattack if they arise.
3.3.2.1 Findings [100] Given the development of markets and market complexity in Nova Scotia, the Board shares Renewall's concern. If the cost of this capital project is being charged to the renewable to retail market, then any future use...
AI summary The Board agrees with Renewall's concern regarding the allocation of costs for a capital project in Nova Scotia's renewable to retail market. It directs NS Power to start an annual certification process to ensure proper cost allocation and recovery, beginning after Renewall's first customer sale and continuing until costs are fully recovered.
NSEB APPROVAL SHEET Project Title: Renewable to Retail Implementation CI Number: C0053699 Date: December 1, 2025 Expenditure Profile Type of Filing Year Budget Amount Project Estimate Capital Project Authorization X Unforeseen and Unbudget...
AI summary The document outlines the expenditure profile for the 'Renewable to Retail Implementation' project, including budget amounts, project estimates, and authorization details for various years. The project involves capital expenditures and has been approved by Nova Scotia Power Incorporated and the Nova Scotia Energy Board.
100135Letter NSPI re: Capital Items Filed Outside the Quarter Package
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December 1, 2025 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: Capital Items Filed Outside the Quarter Package Dear Ms. Henwood: Enclosed for your review and approval...
AI summary A document dated December 1, 2025, from an individual named Crystal Henwood, Clerk of the Board at the Nova Scotia Energy Board, requests the review and approval of capital items that were filed outside the quarter package.
2024 ACE Plan Capital Items for Subsequent Approval • CI C0032664 – Energy Control Centre – Optimization Tools - $7,486,068 2024 ACE amount $4,329,150 $1,776,697 spent as at September 30, 2025 Non-Confidential
AI summary The 2024 ACE Plan includes a capital item for Energy Control Centre optimization tools with a total cost of $7,486,068, of which $4,329,150 was allocated under the 2024 ACE Plan, and $1,776,697 had been spent as of September 30, 2025.
Final Cost (FIN) Capital Items - CI 52314 1C-GT1 and 1C-UT1 Transformer Replacement $1,678,006 Original approval received in the 2018 ACE Plan for $2,032,393 Decreased spend amount $354,387 Non-Confidential - CI 51956 6P Mobile Substation...
AI summary The document outlines two capital items with reduced spending amounts compared to original approvals. The first is the replacement of transformers with a decreased spend of $354,387, and the second is a mobile substation rewind with a decreased spend of $880,345. Both were originally approved under the 2018 ACE Plan.
Unforeseen & Unbudgeted (U&U) Capital Items • CI C0080228 – HYD Hollow Bridge Generator Refurbishment - $2,587,170 $0 spent as at September 30, 2025 Partially Confidential
AI summary The document lists an unforeseen and unbudgeted capital item related to the refurbishment of the HYD Hollow Bridge Generator, with a total cost of $2,587,170 and no funds spent as of September 30, 2025. The item is partially confidential.
Request for Confidentiality Pursuant to Rule 12 of the Board Regulatory Rules, NS Power requests confidential treatment of certain portions of the material filed in support of the following Capital Work Orders: - 1. CI C0070486 HYD Lower G...
AI summary NS Power is requesting confidential treatment for certain portions of documents supporting two Capital Work Orders related to infrastructure projects. The request is made under Rule 12 of the Board Regulatory Rules.
100721REI (NSPI) IR 1 to 22 - Word
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d validation rules supporting each transition; and 4. Customer communication and notification protocols. Reference: N-1, C0053699 Renewable to Retail Implementation Project, page 1 of 6 . Cost recovery for capital expenditures and operatin...
AI summary The document discusses cost recovery for the Renewable to Retail Implementation Project, including the recovery of capital and operating costs through the Annually Adjusted Rates (AAR) process starting in 2026. Questions are raised regarding the scope of cost recovery, legacy costs, and the framework for allocating costs to LRSs.
and found insufficient for RtR settlement and billing and explain why. Reference: N-1, C0053699 Renewable to Retail Implementation Project, pages 4-5 of 6, Capital Project Detailed Estimate. 1. Please provide procurement documentation for...
AI summary The document requests detailed procurement documentation and explanations regarding the RtR Implementation Project, including cost breakdowns, competitive practices, vendor identification, and project deliverables. It also seeks clarification on system outputs and webform specifications.
project cost might be avoided or reduced if NSPI had a modern, cloud-native CIS platform, and if so, please provide that analysis. Reference: M11874, N-4, NSPI (NSUARB) IR 1 Attachment 1, page 4; And Reference: N-1, C0053699 Renewable to R...
AI summary The text raises questions about the increase in AFUDC for NSPI and the methodology used, as well as the scope and processes for change requests in the Renewable to Retail Implementation Project. It also references a Board Order requiring NS Power to engage with interested parties and file an application for new tariffs by April 1, 2026.
101270Submission - REI
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Via Electronic Mail Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Energy Board 3rd Floor, 1601 Lower Water Street PO Box 1692, Unit "M" Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M12588 - NSPI – CI C0053699 Renewable to Retail...
AI summary Renewal Energy Inc. (REI) submits that Nova Scotia Power Inc. (NSPI) has not adequately demonstrated the prudence of several cost components in its Renewable to Retail project, including project delays, administrative overhead, and IT workstreams, despite not opposing the recovery of legitimate costs.
1) Delay Costs Appear Inflated and NSPI Has Not Shown They Were Prudently Incurred NSPI attributes approximately $1 million in total cost increases to ramping up resources a second time as a result of a Commercial Operation Date (" COD ")...
AI summary Nova Scotia Power Inc. (NSPI) claims $1 million in increased costs due to a COD change, citing increased AO and AFUDC. However, NSPI provides no detailed breakdown, cannot show original estimates due to a cyber incident, and has not attributed delays to specific parties. These costs are considered material, with further estimates of $460,000 and $500,000.
2) Capital Expenditure Justification Criteria — Specific Cost Challenges The CEJC requires NSPI to examine alternatives, to demonstrate least-cost options that meet requirements and to compare acquisition approaches (build vs. buy vs. conf...
AI summary The CEJC requires NSPI to evaluate alternatives for IT projects like Project CI C0053699, ensuring least-cost options are considered. However, NSPI's evidence lacks alternative analysis, cost-minimizing sequencing, and assessment of lower-cost vendor services. REI argues that specific cost components do not meet CEJC standards and should be reduced or disallowed.
b) Scalability Costs NSPI claims that scalability costs are "low and not considered material", that "the MDMS architecture is such that additional computational capability can be added in the future, if required, when additional customers...
AI summary NSPI claims scalability costs are low and not material, stating additional computational capability can be added if needed. However, REI argues that without evidence or analysis, the Board cannot determine if these costs are embedded in the MDMS project figures, and recommends disallowing recovery unless NSPI provides documentation confirming no scalability costs are included.
c) CIS Replacement NSPI plans a CIS Replacement filing in Q3 2026 – CI C0021835. NSPI asserts that CIS RtR changes constitute core functionality and configuration that will carry forward to any future CIS replacement without incremental co...
AI summary NSPI plans to file a CIS Replacement in Q3 2026, asserting that changes to RtR functionality will carry forward without incremental cost. REI accepts this in principle but notes the lack of a migration or dependency plan. The Board is recommended to require NSPI to attest that any rebuild or remapping costs are not charged to REI.
3) Cost Recovery Methodology Section 22(2) (previously 3G(2)) of the Electricity Act is the statutory foundation for cost recovery in the RtR program. In responding to IRs, NSPI was unable to provide any clarity on any of: - The cost recov...
AI summary The document discusses the cost recovery methodology for the RtR program under the Electricity Act, highlighting NSPI's inability to clarify key aspects such as cost recovery mechanisms and allocation methodologies. REI argues against tying recovery to a fixed depreciation schedule and emphasizes the need for a methodology based on actual market use. NSPI outlines two scenarios for asset ownership and cost recovery, but uncertainty remains regarding future market developments and their impact on REI's customers.
CONCLUSION AND RELIEF SOUGHT REI respectfully submits that the Board: - 1. Disallow or reduce delay related costs where NSPI has failed to demonstrate that such costs were prudent, unavoidable, or attributable to REI. - 2. Direct NSPI to p...
AI summary REI requests the Board to disallow or reduce various costs incurred by NSPI, including delay-related, cyber-recovery, and software development costs, and to impose conditions on cost recovery and data readiness. REI also seeks a CIS Replacement ring fence and a true-up mechanism to prevent misallocation of costs.
101449NS Power's Reply to Intervenor Submissions
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March 31, 2026 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M12588 – CI C0053699 – Renewable to Retail Implementation – Reply to Intervenor Submissions Dear Ms. Henw...
AI summary Nova Scotia Power Inc. (NS Power) has filed a capital application for the Renewable to Retail (RtR) Implementation project. The Nova Scotia Energy Board initiated a paper hearing process, and the Consumer Advocate, Renewall Energy Inc., and the Small Business Advocate submitted their interventions. No intervenor has suggested the project is unnecessary, and concerns raised by Renewall Energy Inc. regarding certain cost elements are addressed in this reply.
Cost Transparency The SBA notes that, in response to IRs seeking additional detail on project cost changes, NS Power advised that a detailed variance analysis by cost driver could not be provided due to the impacts of the 2025 cyber incide...
AI summary The SBA highlights concerns regarding NS Power's inability to provide a detailed variance analysis due to the 2025 cyber incident and the lack of detailed original ACE Plan estimates. The SBA suggests greater transparency in indirect costs and standardized reporting for schedule changes. NS Power explains that cost increases were primarily due to delayed COD and implemented mitigation measures, but acknowledges the lack of detailed original estimates. NS Power argues that existing processes already provide sufficient reporting on cost and schedule impacts.
onciliation. REI recommends that the Board reduce or disallow delay related labour, consulting, and overhead costs on the basis that prudence, causation, and incrementality have not been established. There is a clear relationship between t...
AI summary REI recommends the Board reduce or disallow delay-related costs due to unproven prudence, causation, and incrementality. The delay costs are linked to extended LRS COD and scope changes, leading to increased labour, consulting, and overhead costs. NS Power provided detailed cost breakdowns and responses to information requests.
CIS Replacement and Carry Forward of RtR Functionality REI notes NS Power's position that RtR related CIS changes constitute core functionality that will carry forward into a future CIS replacement without incremental cost but submits that...
AI summary REI challenges NS Power's claim that RtR-related CIS changes will carry forward into a future CIS replacement without incremental cost, citing the need for a migration or dependency plan. NS Power argues that these changes are core functionality and will be incorporated into the new CIS environment as standard practice.
102536Decision
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- [1] On December 1, 2025, Nova Scotia Power Incorporated asked the Nova Scotia Energy Board to approve a capital project to develop and implement updates and enhancements to existing software solutions to facilitate the "renewable to reta...
AI summary Nova Scotia Power Incorporated requested approval for a capital project to update software solutions for the 'renewable to retail' market. The project, which began in 2023, is necessary to comply with statutory obligations. While no intervenors argued the project was unnecessary, concerns were raised about cost transparency and recovery. The Board approved the project, directing NS Power to ensure costs are not leveraged outside the renewable to retail market.
2.2.1 Project Costs [20] In February 2023, NS Power began work on the project that is the subject of this application. More than three quarters of the forecast costs for the project had already been incurred by NS Power by the time it file...
AI summary NS Power began work on a project in February 2023, with over three-quarters of the projected costs already incurred by the time of the application filing in December 2025. The project was included in multiple Annual Capital Expenditure (ACE) Plans, with costs increasing over time due to evolving project scope and customer onboarding timelines.
urrent capital application, NS Power will follow the change request process noted in its response to REI IR-21 [Exhibit N-4] to incorporate this work into the overall project implementation and costs. [36] NS Power also provided specific e...
AI summary NS Power has engaged with Renewall on various aspects of the current capital application, including reviewing data exchange interfaces, testing phases, and functional models. NS Power developed configurations and internal integrations for its systems and designed interfaces for data exchange with Renewall, though final testing will occur in future work.
3.1.1 Findings [43] The Board finds that the project is necessary to meet NS Power's statutory obligation under s. 22 of the Electricity Act to maintain any tariffs, procedures and standards of conduct necessary to facilitate the renewable...
AI summary The Board finds that NS Power's project is necessary to meet its statutory obligations under the Electricity Act. The project involves system enhancements rather than new systems, and Renewall was involved from the beginning. Renewall did not present a viable alternative that would have changed NS Power's approach.
[51] Regarding standardized filings, NS Power said: With respect to the suggestion of a standardized schedule change report, NS Power considers existing processes to provide appropriate reporting. Where a schedule change gives rise to cost...
AI summary NS Power argues that existing processes provide sufficient reporting for schedule changes, addressing cost impacts through the capital approvals framework with Authorization to Overspend (ATO) or Final Cost (FIN) applications, and that additional parallel reporting would not add value.
3.2.1.1 Findings [52] The Board's consideration of capital projects should be undertaken before a utility proceeds with any capital work that requires an expenditure above the relevant statutory thresholds in the Public Utilities Act . The...
AI summary The Board emphasizes that capital projects exceeding statutory thresholds under the Public Utilities Act must be reviewed before implementation. NS Power often lists projects for 'subsequent approval' in its ACE Plan filings, with less developed cost estimates. The Board acknowledges this but notes that significant variances in cost estimates may raise concerns about reasonableness, requiring explanations on a case-by-case basis.
[63] NS Power argued: The [renewable to retail] implementation is a complex and non-standard undertaking, involving the development of new systems, processes, and integrations to support an emerging market and a retail supplier with a deve...
AI summary NS Power argues that the renewable to retail implementation is complex and non-standard, leading to delay-related costs that cannot be isolated with the same precision as in conventional projects. NS Power asserts that these costs are justified and that Renewall has not provided evidence to support their disallowance.
NSEB APPROVAL SHEET Project Title: Renewable to Retail Implementation CI Number: C0053699 Date: December 1, 2025 Expenditure Profile Type of Filing Year Budget Amount Project Estimate Capital Project Authorization X Unforeseen and Unbudget...
AI summary The document outlines the expenditure profile for the Renewable to Retail Implementation project, including budget amounts and approvals from Nova Scotia Power Incorporated and the Nova Scotia Energy Board. The project involves multiple years of planned and approved expenditures, with a total budget of over $5.6 million.