Topic:"Comfit" in M03632

e included a 34 return on equity of 13% for biomass CHP projects, even though the developers of these 1 projects are likely to be seen as less risky than the developers of other COMFIT 2 projects. 3 4 Finally, in-stream tidal projects are...

AI summary The text discusses varying return on equity (RoE) for different COMFIT projects. Biomass CHP projects are assigned a 34% RoE despite lower risk, while in-stream tidal projects, due to high uncertainty, are suggested to have a 15% RoE to compensate for risks.

6 Q: What do you conclude from these comparisons? 7 A: I have three observations. First, the $139/MWh proposed by Synapse for large 8 COMFIT wind projects is much higher than the actual prices in the contracts for 9 recent RFP wind project...

AI summary The response highlights three key findings: the proposed $139/MWh price for large COMFIT wind projects is higher than recent contract prices; NSPI has rejected lower-priced projects; and no economies of scale are observed across different unit sizes, with costs remaining stable.

19 A: No. NSPI will meet its RES targets, whether through COMFIT, RFPs, or NSPI 20 ownership. Neither NSPI nor the Board has shown any interest in acquiring 1 renewable energy in excess of the RES. If the government, the Board, or NSPI 2 d...

AI summary The text discusses NSPI's ability to meet its RES targets through various mechanisms like COMFIT, RFPs, and NSPI 20 ownership. It also raises a question about whether COMFIT projects at Synapse's proposed rates would be an efficient mechanism for increasing renewable supply or reducing coal use.

1. The text above is taken from an email of February 9, 2011 from Synapse to Jonathan Barry of Seaforth Energy which included a Word document attachment, the text of which appears exactly as above. Nova Scotia Utility & Review Board FIT Mo...

AI summary The text presents a table related to the Nova Scotia Utility & Review Board FIT Model for small wind energy systems (50 kW and smaller), detailing revenue components such as standard offer price, fixed and escalating price components, and total revenue across different columns.

Debt Financing and Debt Equity for small wind projects: Although Synapse does note the difficulty in obtaining debt financing for small wind projects due to size, they nevertheless assume debt financing for small wind projects over 10 year...

AI summary The text discusses the challenges of obtaining debt and construction financing for small wind projects, noting that Synapse assumes financing is available despite industry experience suggesting otherwise. CanWEA emphasizes the need for greater evidence that financial institutions are willing to fund COMFIT projects.

- g. The necessity for Mi'kmaq renewable project integration is paramount given the current state of on reserve utility usage rates as a result of sub-standard housing and over population issues. - 2.0 Comparative analysis on the different...

AI summary The KMKNO argues that Mi'kmaq communities face significant challenges in developing renewable energy projects due to legal constraints under the Indian Act, particularly Section 89, which limits their ability to secure financing. They emphasize that non-Mi'kmaq communities have greater access to capital and financial tools, making it harder for Mi'kmaq communities to participate in programs like COMFIT.

Feed In Tariff Inputs While SWFI agrees with many assumptions included in the Synapse models, there are still a few key assumptions for small and large wind that do not accurately reflect current or even anticipated market conditions. As d...

AI summary SWFI acknowledges many Synapse model assumptions but raises concerns about specific assumptions related to small and large wind inputs in FIT calculations, which could impact the COMFIT program's success.

Q. Has ANSS participated in the COMFIT process to date? Yes, members of the ANSS have participated in the process from the Dr. Wheeler-led stakeholder sessions up to and including the technical conferences with Synapse. The ANSS has made t...

AI summary ANSS has participated in the COMFIT process, including stakeholder sessions and technical conferences with Synapse, and has made two written submissions regarding the biomass CHP COMFIT, which are attached as Appendix A and B.

Responses to COMFIT Information Requests Submitted by Synapse Energy Economics January 24, 2010

AI summary Synapse Energy Economics submitted responses to COMFIT Information Requests on January 24, 2010. The document includes images from pages 161 and 162, though the content of these pages is not provided in the text.

Wood Product Manufacturers Association of Nova Scotia PO Box 1303, Truro, Nova Scotia B2N 5N2 Cassie Turple, BPR Jamie Lewis Wade Turner Kim Fuller, BBA CA Richard Freeman Ledwidge Lumber Lewis Mouldings J.A. Turner & Sons Ltd. Ledwidge Lu...

AI summary The Wood Product Manufacturers Association of Nova Scotia (WPMANS) supports the Alliance of Nova Scotia Sawmillers in presenting evidence regarding the Community Feed-in Tariff (COMFIT) process. WPMANS represents independent forestry-related businesses in Nova Scotia with a long history in the province.

revisions, rather than introducing revisions based on the attainment of capacity targets, as the former increases stability and predictability in the market, both for investors and for the Government. - 8. The following paragraphs turn to...

AI summary The text highlights a disparity between <50kW and >50kW tariffs, suggesting it could lead to regulatory arbitrage by encouraging smaller projects to exploit higher rates. This may result in less renewable electricity and higher costs, referencing a similar issue in Spain. The COMFIT wind market is at risk of clustering around the 50kW size, reducing efficiency.

6.2.2 Findings [74] The Board concluded above that it is appropriate to adopt a methodology under the COMFIT modeling that identifies the "typical cost" for the input assumptions of each generation class in order to determine reasonable CO...

AI summary The Board concluded that adopting a methodology under the COMFIT modeling to determine typical costs for each generation class is appropriate. It also found that Synapse's treatment of project ownership in the COMFIT modeling is reasonable and no further adjustments are needed.

[217] When discussing the St. FX project, Synapse had problems with it being considered a CHP: ... And frankly, that's one of the concerns I would have about this project because it has an overall efficiency of 28 percent, and I would have...

AI summary The discussion centers on the St. FX project's classification as a CHP and its efficiency concerns, with Synapse criticizing its low efficiency and higher costs. St. FX recalculates the rate using the Synapse model but argues the model is not suitable for a university heating plant. The Board accepts Synapse's conservative COMFIT rate approach and plans a review in three years.

11.2 Findings [250] Other than comments from the Consumer Advocate there was very little comment in the hearing on run-of-the-river hydroelectricity. [251] The Board also understands that there may be significant other challenges in securi...

AI summary The Board acknowledges limited commentary on run-of-the-river hydroelectricity, notes challenges in securing environmental and fisheries approvals, and accepts Synapse's cost determinations. It rejects adjustments proposed by Mr. Chernick and views land donation and property tax relief as speculative. The tariff will be reviewed in three years and as part of the Province's 2012 regulatory review.

an annual report with the Board by January 31 st each year which provides a listing of, and details regarding, each COMFIT generator that is at any stage of the application or interconnection process. [290] The Board directs Synapse to pro...

AI summary The Board requires Synapse to submit revised FIT model calculations and draft terms and conditions for tariffs. An annual report detailing COMFIT generators is also mandated.

2.0 Purpose The NSUARB has hired Synapse Energy Economics, Inc., a consulting company from Massachusetts, to derive the prices for the various COMFITs. The consulting group will be evaluating a number of factors in the determination of the...

AI summary The NSUARB has engaged Synapse Energy Economics, Inc. to determine COMFIT prices for biomass CHP. The study will be transparent, allowing direct comparison of data with the consultant's model. If discrepancies arise, the information will be challenged at a rate hearing. ESI Inc. may be called to testify on the study's details.

4.5 Deadlines and Communication The deadlines established for this study are of paramount importance as it is likely that the information in the study will be submitted as evidence at the NSUARB rate hearings regarding the establishment of...

AI summary The deadlines for submitting information in the study are critical as the data will be used as evidence in NSUARB rate hearings concerning the biomass CHP COMFIT. Late submissions will not be accepted and are considered of no value.

6.6 Parasitic Loads ANSS recommends including the cost of parasitic loads equal to 14% of CHP plant generation, or 1,769 MWh. We have analyzed the impact of this change in the Excel file "Synapse U-6 Parasitic Loads14%." In this file, we c...

AI summary ANSS recommends including the cost of parasitic loads at 14% of CHP plant generation, impacting operating expenses and increasing the fixed portion of the COMFIT rate to $107 per MWh. This recommendation is based on an analysis in the Excel file 'Synapse U-6 Parasitic Loads14%'.

ut that does open the door to now having a facility that actually generates very little electricity in combined heating power mode and is basically an electricity only plant with a nominal steam host. And we thought about ways to get aroun...

AI summary The discussion addresses the design of the COMFIT (Community based feed-in tariff) to ensure biomass facilities are true combined heat and power (CHP) plants. The approach involves allocating a significant portion of the boiler cost to the steam host, ensuring that only facilities with a consistent steam demand can participate, thereby promoting genuine CHP operations.

CONCLUSION For each class of electricity generation facility for which the Board has been instructed to set a tariff there is a wide range of reasonable presumptions or criteria which the tariff should accommodate. While Synapse has recomm...

AI summary The Board is instructed to set COMFIT tariffs for electricity generation facilities, considering the need for just and reasonable rates while providing incentives to generators. The Board should set tariffs at the lower end of the reasonable range due to the lack of precedent and potential negative consequences of setting them too high.

y produced from a combined heat and power plant; - (c) small-scale in-stream tidal; - (d) developmental tidal arrays; and - (e) other generation facilities as provided by the regulations. - (8) In order to qualify as a generator under this...

AI summary The text outlines the qualifications for generators under the Electricity Act, including eligible entities and the factors considered by the Board in setting Community Feed-In Tariffs (COMFIT), such as depreciation, labor costs, and return on investment.

Introduction The Ecology Action Centre has acted on behalf of the Nova Scotian environment and population on a wide range of issues for over 40 years. Brennan Vogel (Bachelors Environmental Studies, University of Waterloo; Masters of Arts...

AI summary The Ecology Action Centre (EAC) supports the Community Feed-In Tariff (COMFIT) program but expresses concerns about its potential underperformance and risks. EAC argues that FITs are a better pathway for renewable electricity development and recommends policy clarification. The submission highlights issues with COMFIT and suggests considerations for the Board when setting rates.

Recommendations: 1. The Board should consider opportunities for considerable improvement to the tidal tariff if it is to be approved in the COMFIT, otherwise the matter should be referred to the Minister of Energy for further policy develo...

AI summary The Board is recommended to improve the tidal tariff for approval in the COMFIT program, or refer the matter to the Minister of Energy for further policy development.

Re: Community Feed-in-TariffHearing 2010 - BRD-E-R-I0 Please acceptthe briefcommentsinthis letter asreply submissionsinthe above-noted proceeding onbehalf ofthe Nova Scotia Department ofEnergy ("NSDOE"). Upon reviewofthe closing submission...

AI summary The Nova Scotia Department of Energy (NSDOE) submits that the Nova Scotia Utility and Review Board does not have the jurisdiction to impose capacity caps on renewable energy generators under the Electricity Act or Renewable Electricity Regulations, as these matters are already addressed in the regulations. NSDOE also states that certain tariff provisions recommended by the Consumer Advocate are already covered by existing regulations and may be subject to change during a 2012 COMFIT program review.

A CONSERVATIVEApPROACH The Nova Scotia Department of Energy and the Nova Scotia Depaliment of Environment make the following points at paras. 17 and 20 oftheir submission. - 17. ...NSDOE and NSE further submit that while the approach taken...

AI summary The Nova Scotia Department of Energy and the Department of Environment emphasize uncertainty in COMFIT project costs and advocate for a conservative approach to setting rates. The Consumer Advocate supports this, suggesting that rates and capacity caps should be set at the lower end of the reasonable range.

INTRODUCTION As in the evidence which was presented to the Board, we will restrict our comments to the establishment of a tariff for wind > 50 kW. We wish to thank Synapse for their engagement of stakeholders and for their considerable eff...

AI summary The comment focuses on establishing a tariff for wind > 50 kW and acknowledges Synapse's efforts in stakeholder engagement and development of COMFIT rate proposals.

RATE FOR "LARGE WIND" The rate developed by Synapse for Wind (greater than 50kW) was $139/MWh and this formed the basis of the COMFIT proceeding. Having regard for the intent of Government " to encourage a range of projects widely disperse...

AI summary The rate for 'Large Wind' proposed by Synapse at $139/MWh is based on a cost-recovery approach, aligning with the COMFIT proceeding. The Consumer Advocate's assertion that rates should not be cost-based is refuted, as Synapse's method balances cost and policy objectives to encourage renewable development.

6.2.2 Findings [74] The Board concluded above that it is appropriate to adopt a methodology under the COMFIT modeling that identifies the "typical cost" for the input assumptions of each generation class in order to determine reasonable CO...

AI summary The Board concluded that adopting a methodology under the COMFIT modeling to identify the 'typical cost' for each generation class is appropriate. It also found that Synapse's treatment of project ownership in the COMFIT modeling is reasonable and no further adjustments are needed.

[217] When discussing the St. FX project, Synapse had problems with it being considered a CHP: ... And frankly, that's one of the concerns I would have about this project because it has an overall efficiency of 28 percent, and I would have...

AI summary The St. FX project's efficiency of 28% raises concerns about its classification as a CHP and the resulting COMFIT rates. Synapse questioned the appropriateness of the tariff, while St. FX recalculated the required rate. The Board acknowledges the need to adjust COMFIT rates and will review them in three years, noting that Nova Scotia's rates are higher than those in other jurisdictions due to different criteria and incentives.

Standard power purchase agreement for feed-in tariff program - 32 (1) The Minister, in consultation with NSPI, must prepare a standard form of power purchase agreement to be used for the feed-in tariff program and must have the form of pow...

AI summary The document outlines the process for creating and approving a standard power purchase agreement (PPA) for the feed-in tariff program. The Minister, in consultation with NSPI, must prepare and have the PPA approved by the Board. The Board will review the PPA when it is filed by the Minister.

Page 2 Large Wind 8-2-11 no tax Nov a S ia C OM FIT Mo del cot Ca sh Flo w W ork she Bot et: tom Syn e C aps lian om p ce Lar Win ge d n o ta x 20-y r SL 2.50 % 5.00 % 5.00 % 5.00 % 5.00 % 5.00 % 5.00 % 5.00 % 5.00 % 5.00 % 5.00 % 5.00 % 5...

AI summary The document presents a table related to the COMFIT model, specifically focusing on a 20-year SL with various percentages listed across multiple columns, likely representing financial or tax-related data. The table includes the phrase 'no tax,' suggesting a specific context or condition under which the data applies.

Nova Scotia COMFIT Model Depreciation Worksheet: Bottom Synapse Compliance Large Wind, Taxable Owner Ope ratin Yea g r 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Total Amount Allocated 20-yr SL 30-yr SL 37-yr SL 40-yr SL 100.0% 3...

AI summary The document presents a depreciation worksheet for a large wind project in Nova Scotia, showing the allocation of total amounts over different straight-line depreciation periods (20-yr, 30-yr, 37-yr, 40-yr) under the COMFIT model. It focuses on the taxable owner's compliance.

August 17, 2011 VIA EMAIL Nancy McNeil Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 3 rd Floor 1601 Lower Water Street Halifax Nova Scotia B3J 3S3 Dear Ms. McNeil: Re: Renewable Energy Community Feed-In Tariffs – B...

AI summary Minas Basin Pulp and Power submits comments on the COMFIT compliance filing, suggesting revisions to the diesel indexing methodology and the availability condition for biomass projects to align with government policy and ensure generated electricity remains on the distribution system.

VIA EMAIL Nancy McNeil Utility and Review Board, NS 3rd Floor - 1601 Lower Water Street Summit Place Halifax, NS B3J 3P6 Dear Ms. McNeil: Re: Community Feed-in-TariffHearing 2010 - BRD-E-R-IO/Matter No.: M03632 The Nova Scotia Department o...

AI summary The Nova Scotia Department of Energy supports revisions to the COMFIT terms and conditions, including a revised diesel indexation methodology and adjustments to the biomass tariff's eligibility criteria. They propose a review mechanism to ensure that electricity generated by backpressure turbines remains on the distribution system throughout the contract period.

August 19, 2011 Nancy McNeil Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3 rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: Renewable Energy Community Feed-in Tariffs - BRD-E-R-10...

AI summary Nova Scotia Power comments on the Compliance Filing by Synapse regarding the Renewable Energy Community Feed-in Tariffs, suggesting modifications to the Availability clause in the Terms and Conditions to align with provincial requirements regarding energy generation and distribution.

screen shot of the map zoomed-in to show Halifax and its surrounding area. Figure 2 - Sample from the embedded map zoomed-in to show Halifax Using a single click on a particular icon, the available data associated with that substation loca...

AI summary Nova Scotia Power has developed an interactive map to identify available COMFIT generation capacity at each distribution substation. The map provides details such as geographic area names, distribution zones, and voltage levels. Nova Scotia Power requests approval from the Board to upload the map to its website.

addition, any existing or committed generation within each distribution zone will be subtracted from the minimum load to determine the capacity that is available for COMFIT generation interconnection. The Board recognizes that this methodo...

AI summary The Board acknowledges the methodology used to calculate available capacity for COMFIT generation interconnection and emphasizes that the interactive map provided by NSPI is a guide, not a replacement for detailed studies. The Board is satisfied with NSPI's efforts to provide publicly available information and directs NSPI to maintain the map on its website.

March 21, 2013 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: Renewable Energy Feed In Tariffs – BRD-E-R-10 / Matter No....

AI summary NS Power is re-filing Attachment 1 of its 2012 COMFIT report to include additional information requested by the Board, noting that there were no COMFIT projects in service in 2012.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS the quantities of each type of resource and multiplying 1 and adding it up. 2 MR. KEITH: Can I make a clarification 3 there? 4 MR. MERRICK: Sure. 5 MR. KEITH: You may be misreading that 6 sen...

AI summary The discussion centers on the COMFIT program and how its cost is balanced against the cost of electricity, with clarification that the approach focuses on achieving a reasonable level of development activity within each resource class rather than comparing against a specific measure of electricity cost.

- all you can think of? Page 64 NSUARB-BRD-E-R.10 9 spreadsheet information showing 10 the new heat rate calculations 11 MR. MERRICK: Can I turn you to your 12 report at page 26, and we're still on biomass. And at the 13 very bottom of tha...

AI summary The text discusses the allocation of costs related to biomass and combined heat and power (CHP) within a regulatory proceeding. It highlights that the level of avoided cost assumed in the model is a policy decision balancing ratepayer costs with the goals of the COMFIT program. The discussion also touches on the definition and treatment of CHP in different jurisdictions.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS MR. VOGEL : I'll try and be brief. 1 NSUARB-BRD-E-R.10 Page 285 THE CHAIR: No, I didn't mean to hurry 4 could you comment on what provisions are being considered 5 with respect to distributio...

AI summary The discussion revolves around distribution zone capacity and availability, with a focus on the assumptions made regarding available capacity and the importance of transparency in grid capacity information for COMFIT projects. The participants emphasize that transparency could lead to more efficient project development.

- glad somebody read my testimony. 1 Page 1016 NSUARB-BRD-E-R.10 MR. DOEHLER: At least more than just 2 me. Okay. So those should be reversed. 3 MR. CHERNICK: Yes. Thank you very 4 much. 5 MR. DOEHLER: On page 13 no, sorry. 6 That's alread...

AI summary The text contains a conversation between participants in a regulatory proceeding, discussing the Synapse proposal's fuel escalation rate and the risk reduction associated with a known feed-in tariff. The discussion highlights concerns about double-counting fuel escalation and the impact of known versus uncertain pricing mechanisms.

- percent. NSUARB-BRD-E-R.10 Page 1029 1 And of course, NSPI's revenue base 2 will be changing over time as well, so these numbers are 3 based on a snapshot as if the entire COMFIT came in 4 immediately. This increase would be spread out o...

AI summary The discussion revolves around NSPI's revenue base and the impact of the COMFIT program, with references to past project failures related to transmission studies. A cross-examination is taking place regarding failed RFP projects and transmission study constraints.

- possible now. What is possible now will be possible five - years from now, and I believe the COMFIT, the way it is - designed, can be extremely successful. It is intended, by - my reading of the electricity plan and the sustainability -...

AI summary The speaker discusses the potential success of the COMFIT program, emphasizing its broad design and the importance of not letting individual project difficulties influence overall strategy. They also mention recent RFPs issued at the distribution level and express disappointment at not being selected despite being just one cent higher than the winning bid.