N-3NSPI (CA) RIR-1 to 18 - Redacted
13 passages
NON-CONFIDENTIAL 1 Request IR-2: 2 3 Reference: NS Power indicates that "Option 4" was the preferred option from the five 4 options initially considered, for the following reason: "Option 4 is approximately $500,000 5 less costly than the...
AI summary The document discusses a request (IR-2) regarding the continued viability of 'Option 4' as the most economical choice for a project, based on its lower cost and operational suitability. The response directs the reader to refer to NSUARB IR-7 for further details.
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.
NON-CONFIDENTIAL 1 Request IR-7: 2 3 Reference: "As a result of the additional work required to address environmental permitting 4 requirements, the construction timeline was extended leading to increased project costs of 5 approximately $...
AI summary The document discusses a request regarding the extended construction timeline and increased costs for a project, attributing the delay to environmental permitting requirements. NS Power asserts that the delay was directly caused by the environmental regulatory process and that obtaining permits more timely would have kept the project on budget.
- 3 Reference: NS Power states that regular labour costs will increase by $444,441, with term - 4 labour increasing by $94,851, plus associated overtime, all due to additional "project - 5 management support & environmental services labour...
AI summary NS Power has reported an increase in internal labour costs of $444,441, attributed to expanded project management support and environmental services labour due to an extended project timeline and scope. The costs are related to securing environmental permits for construction.
20 Yearly breakdown: Year Increase in costs (in Thousands) Description 2017-2020 ($19) 2021 $85 Managing permitting (DFO, NSECC, and DNRR), Contract LNTP activities 2022 $124 Managing permitting (DFO, NSECC, and DNRR), Controls Building co...
AI summary The yearly breakdown outlines cost increases from 2017 to 2023, detailing activities such as managing permitting with DFO, NSECC, and DNRR, as well as fish passage upgrades and building construction. Costs range from a decrease of $19 thousand to an increase of $124 thousand.
2 A variance of $94,851 on term labour costs is attributed to Environmental Services labour 3 required for providing monitoring support for the 9 months drawdown period in during 4 construction, assisting with post-construction monitoring...
AI summary A variance of $94,851 in term labour costs is attributed to Environmental Services labour required for monitoring support during the 9-month drawdown period in construction, post-construction monitoring, environmental studies, engagement meetings, and an offsetting project on West River as mandated by environmental permits.
8 Yearly breakdown: Year Increase in costs (in Thousands) Description 2017-2020 $3 Managing site work pertaining to obtaining permits 2021 $0 Managing site work pertaining to obtaining permits 2022 $1 Managing site work pertaining to obtai...
AI summary The yearly breakdown shows incremental costs related to managing site work for obtaining permits, with a significant increase from 2025 to 2026, reflecting the costs of managing permit conditions execution.
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 2 at a mark...
AI summary NS Power is responding to information requests regarding cost minimization efforts for the Ruth Falls Main Dam Refurbishment project. They mention using internal labor instead of contracted labor and employing competitive procurement to reduce material costs by approximately $780,000.
REDACTED 1 Request IR-12: 2 - 3 Reference: NS Power states that costs for consulting have increased by approximately $1.6M. - 4 (ATO, p. 5) 5 6 (a) Please provide a full breakdown of these costs. 7 8 (b) Please elaborate upon any cost mini...
AI summary The document requests a detailed breakdown of consulting costs that have increased by approximately $1.6M, as stated by NS Power, and asks for explanations regarding cost minimization efforts and offsetting programs related to these costs.
NON-CONFIDENTIAL 1 Request IR-15: 2 3 Reference: NS Power states that costs for Administrative Overhead will increase by 4 $341,503, compared to an original budget of $72,085. 5 6 (a) Please provide a full breakdown of these costs. 7 8 (b)...
AI summary NS Power has requested an increase in administrative overhead costs for a project, citing a significant increase from the original budget. The response indicates that administrative overhead is calculated based on NSUARB-approved accounting policies and includes regular and overtime labour costs.
23 Year Total Regular, Term and Overtime Labour Administrative Overhead Rate Applied Total Administrative Overhead 1 2017 0F $16,312 51.90% $8,141 2018 $21,446 42.69% $9,155 1 Prior to August 2017, AO was calculated based on individual emp...
AI summary The table presents data on total regular, term, and overtime labour costs and administrative overhead rates and costs for 2017 and 2018. The administrative overhead rate decreased from 51.90% in 2017 to 42.69% in 2018, with corresponding changes in total administrative overhead costs.
2 (b) Please refer to CA IR-09 (b). 3 4 (c) The increase in administrative overhead (AO) is due to the increase in labour spend and an 5 increase in rates. Please refer to part (a) for a breakdown of labour spend and rates used in 6 the AO...
AI summary The text discusses an increase in administrative overhead due to higher labour costs and increased AO rates, referencing prior and current filings. It also mentions the inclusion of overtime labour in the AO calculation and refers to a specific project (CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO) and a regulatory matter (NSUARB M11927).
2 (b) The cost minimization efforts related to Contract costs, as described in CA IR-11 (b), 3 would have a direct impact on the minimization of contract AO, as every dollar of Contact 4 investment attracts Contract AO. 1 2024 includes act...
AI summary The text discusses how cost minimization efforts related to contract costs, as outlined in CA IR-11 (b), directly impact the minimization of contract asset obligations (AO), noting that each dollar invested in contracts attracts contract AO. It also mentions that 2024 data includes actual costs up to August 31, 2024, and forecasted costs for the remainder of the year.
N-6NSPI (NSUARB) RIR-1 to 13 - Redacted
10 passages
- 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 text lists exclusions from the cost calculation, including owner administration, hydro unit downtime, sales tax, insurance, mobilization, and indirect costs such as permitting and engineering. The total direct construction cost is reported as CAD 9,709,000.
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 ($) TOTAL ($) WALKWAY MOUNTING CONNECTIONS 1 LS $ 24,000 $ 24,000 C...
AI summary The text presents a conceptual-level opinion of probable construction costs for a project, assuming a 7-month construction season with costs estimated in 2017 dollars. The table outlines various construction items, including walkway mounting connections, concrete disposal, and fish passage modifications, along with associated costs and a 20% contingency.
REDACTED 1 Request IR-10: 2 3 Regarding the Account Variance Sheet on pages 5 and 6 of the current Application: 4 5 (a) For the "Materials" Line Item: 6 7 (i) Please identify the percentage increase in materials cost that NS Power has 8 al...
AI summary The text outlines an information request (IR-10) directed at NS Power concerning cost variances in the Account Variance Sheet related to the 2019 ACE Plan Application, specifically focusing on materials, contracts, and additional costs such as archaeological site security and pumping expenses.
REDACTED Description Increase in costs (in Thousands) ADDITIONAL SCOPE: NEW PERMITTING REQUIREMENTS Fish Passage upgrades $1,630 Engineering support for environmental permit $15 application Barn Swallow nest removal $11 Pre-tree clearing n...
AI summary The text outlines various cost increases associated with a project, including fish passage upgrades, archaeological engagement, and extended construction timelines. The table details specific line items with associated costs, such as engineering support, environmental permits, and construction-related expenses.
REDACTED 1 month and total cost included in the original NSUARB submission were 2 $133,000. However, more recent hydro projects saw site supervision costs 3 of approximately $30,000 per month. The increase in site supervision costs 4 is at...
AI summary The text discusses increased site supervision costs for a hydro project, including inflation-related increases and additional costs from project timeline changes. Freight costs for materials sourced overseas are also mentioned, which were not included in the original ACE Plan Application due to a change in manufacturing assumptions.
7 (d) Materials costs associated with "Supply of Gates and Actuators" and "Supply of Rubber 8 Dams" are lower than the costs shown in the 2019 ACE Plan Application because the costs 9 used in the ACE submission were based on estimates from...
AI summary The document discusses lower material costs for gates, actuators, and rubber dams due to a competitive RFP process, and mentions the need for a backup generator for construction during winter months, recommended by the electrical designer engineer.
11.14 PERFORMANCE SECURITY Please note that the cost for Performance Security as outlined in the RFP is not currently in our price. The cost for this security is $ per $ of the project value plus HST.
AI summary The text discusses the cost of Performance Security as outlined in the RFP, noting that it is not included in the current price and is calculated as a fee per dollar of project value plus HST.
Year 1 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 Salaries and Wages (Millbrook) Amount to reimburse Millbrook community members...
AI summary The document outlines the costs associated with a project involving the CMM, Millbrook, and NSSA, including salaries, travel, and administrative expenses, totaling approximately $36,442.50.
Pre – Offset Table 2 Year 1 (2022) Budget Category Description Amount Salaries and Wages (the CMM) Project Manager (70 hrs @ $80/hr = $ 5,600) Field technicians (3 x technicians for 21 hrs @ $45/hr = $2,835) $8,435.00 Training Environmenta...
AI summary The document outlines the Year 1 (2022) budget for a project managed by the Community Management Corporation (CMM), including expenses for salaries, training, travel, professional services, and administrative costs, totaling approximately $21,520.59.
N-8Midgard Evidence - Redacted
13 passages
- 13 indirectly affect material costs. However, while the CPI provides a benchmark for inflation, it does not 28 M11927, Exhibit N-3, CA RIR-9(a), p. 3 of 3. 29 Statistics Canada, CPI, Monthly, Not Seasonally Adjusted [. Link.](https://www...
AI summary The text discusses the impact of the CPI on material costs, noting that while CPI serves as an inflation benchmark, it does not directly affect material costs. It references statistical data and exhibits from a regulatory proceeding.
- 1 capture the unique price dynamics of materials like concrete and steel, which are influenced by global - 2 markets, supply chain issues, and local factors. - 3 The Industrial Product Price Index (" IPPI ") measures the price changes of...
AI summary The text discusses the use of the Industrial Product Price Index (IPPI) to capture material cost increases relevant to NS Power's projects, highlighting categories such as fabricated metal products, construction materials, and cement. It notes that these categories align with the material cost increases reported by NS Power and provides a reference to Table 5 for trend analysis.
- The IPPI data suggests that an increase for inflationary reasons on the order of 25.4% across all sectors is in - line with general economic trends. However, more specific categories, such as fabricated metal products and - construction...
AI summary The text discusses the impact of inflation on material costs for a construction project, noting a 25.4% overall increase, with higher increases in specific sectors like fabricated metal and construction materials. A 47% increase in material costs is attributed to an extended construction timeframe, though savings in certain line items reduced the overall increase to 85% of the original budget, with concrete costs alone contributing $689,000 of the increase.
3.1.3 Conclusion - 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. Inflationary pressures, as seen in both -...
AI summary Midgard concludes that NS Power faced significant cost increases due to inflation and other factors between the original submission and the ATO Application. Inflationary pressures, as seen in CPI and IPPI data, contributed to a 35-40% increase in certain categories, though the 85% increase in some line items may also be due to localized impacts or scope changes.
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.
3.3.2 Analysis Given the updated environmental permit requirements and the need for additional regulatory oversight, the increased labour and material costs reflect actions taken to address these challenges. The four staff types associated...
AI summary The analysis discusses increased labour and material costs due to updated environmental permit requirements and regulatory oversight. NS Power explained cost minimization efforts, including the use of internal labour and reducing regulatory delays, to maintain economic efficiency while meeting project requirements.
3.3.3 Conclusion The increased labour and material costs reported by NS Power stem from updated environmental permitting requirements and an extended timeline to meet regulatory conditions. The allocation of costs across regular labour cat...
AI summary NS Power attributes increased labour and material costs to updated environmental permitting requirements and extended timelines. The allocation of costs across various labour categories reflects the complexity of the project and efforts to ensure compliance. Midgard concludes that these cost increases are reasonable.
13 4.2.3 Conclusion - 14 Midgard concludes that the "Additional KMKNO Capacity Payments" increased costs are reasonable, as NS - 15 Power was required to continue consultation with KMKNO as the Project changed. 43 M11927, Exhibit N-3(C), C...
AI summary Midgard concludes that the Additional KMKNO Capacity Payments are reasonable due to ongoing consultation with KMKNO as the Project changed. It also notes that while NS Power may have underestimated archaeological costs, including Mi'kmaq observer costs, these were unlikely to have significantly impacted the original decision.
5.1.1 NS Power Submission - The Project involves the refurbishment of the Ruth Falls Main Dam's water-retaining structures, with five - alternatives reviewed during the conceptual design phase: [45](#page-29-1) - 1. Option 1: Replace the e...
AI summary NS Power submitted a proposal for the refurbishment of the Ruth Falls Main Dam, presenting five design alternatives. Option 4 was selected due to its cost-effectiveness. NS Power argues that re-evaluation of the options was unnecessary because all would be similarly impacted by delays in the Fisheries Act Authorization and environmental permitting.
5.2.4 Analysis – Geotechnical Issues - Geotechnical issues have only been explored in limited fashion thus far on the project. NS Power has not yet - completed a detailed geotechnical investigation at the Project site: - "NS Power has not...
AI summary Geotechnical issues at the Project site have not been thoroughly investigated, raising concerns about potential cost overruns similar to those experienced on the Tusket Falls project. NS Power proceeded with detailed design based on conceptual reviews, but this remains a risk area.
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.
6.4.2 Potential Additional Cost Increases - 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 add...
AI summary Midgard is concerned that the Project is exposed to risks such as environmental compensation, archaeological, and geotechnical costs, which could lead to additional overages beyond current contingency allowances. The lack of a decommissioning analysis makes it unclear how much Project costs could exceed the ATO estimate.
N-9Amended Evidence - Midgard - Redacted
42 passages
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.
2.1.4 Conclusion - While the Project was initially developed in accordance with earlier frameworks and included mitigation and - offsetting proposals, the 2019 amendments to the Fisheries Act introduced new requirements that triggered - th...
AI summary The conclusion discusses how the 2019 amendments to the Fisheries Act required NS Power to submit more detailed proposals to DFO, leading to delays and increased costs. Midgard acknowledges these costs as necessary for compliance and views NS Power's actions as prudent in responding to evolving regulatory requirements.
2.2.3 Conclusion - In Midgard's opinion NS Power was acting reasonably in its interactions with NSECC. The delays associated - with the watercourse alteration permit issuance appear to stem from issues that originally initiated with the -...
AI summary Midgard concludes that NS Power acted reasonably in its interactions with NSECC, with delays in watercourse permits attributed to DFO's FAA process. The cost overages of $4.4 million are primarily linked to DFO delays, and this is considered a valid reason for the variance.
3.1.1 Analysis - Midgard has referenced additional metrics to provide context to NS Power's claim that an extended - construction timeline contributed significantly to the $2 million cost variance. The Consumer Price Index - (" CPI ") is a...
AI summary Midgard has referenced the Consumer Price Index (CPI) to provide context for NS Power's claim that an extended construction timeline caused a $2 million cost variance. The CPI measures inflation and is used to track price trends in Nova Scotia from May 2019 to October 2024.
- indirectly affect material costs. However, while the CPI provides a benchmark for inflation, it does not - capture the unique price dynamics of materials like concrete and steel, which are influenced by global - markets, supply chain iss...
AI summary The text discusses the limitations of the CPI in capturing material cost dynamics and highlights the IPPI as a more relevant indicator for tracking material costs, particularly for construction and machinery, relevant to NS Power's projects.
3.1.2 Conclusion - 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. Inflationary pressures, as seen in both -...
AI summary Midgard concludes that NS Power faced significantly increased costs due to inflation, as reflected in CPI and IPPI data, particularly in categories like concrete and fabricated metal products, which saw increases of 35-40% between the original submission and the ATO Application.
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.
3.2.2 Conclusion - Faced with the increased regulatory requirements that emerged as NS Power progressed the Project, it is - Midgard's view that NS Power had little choice but to increase the amount of effort that its internal resources -...
AI summary NS Power faced increased regulatory requirements during the Project, leading to higher internal resource allocation and additional costs. Midgard acknowledges these efforts as part of NS Power's commitment to due diligence and economic efficiency. This is considered a valid reason for variance in costs.
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.
5 4.2.3 Conclusion - 6 Midgard concludes that this is a valid reason for variance, which will inform Midgard's comments on the - 7 quantity of the cost increases, as discussed in Sectio[n 5.](#page-27-1)
AI summary Midgard concludes that the reason for variance is valid and will influence their comments on the quantity of cost increases, as discussed in Section 5.
7 5.1.1 NS Power Submission 3 8 NS Power reported labour cost increases from the 2019 ACE to the ATO Application as detailed in [Table 8](#page-28-0) and 9 [Table 9](#page-28-1) which resulted in labour expense overspending of $545,477. co...
AI summary NS Power reported labour cost increases from the 2019 ACE to the ATO Application, resulting in a labour expense overspending of $545,477. The details are outlined in Table 8 and Table 9.
1 - 3 [Table 10](#page-28-2) summarizes NS Power's detailed yearly breakdown of the labor cost variances resulting from the
AI summary The text refers to a table summarizing NS Power's detailed yearly breakdown of labor cost variances, indicating a focus on labor cost analysis within the regulatory proceeding.
5.1.3 Conclusion - The increased labour and material costs reported by NS Power stem from updated environmental permitting - requirements and an extended timeline to meet regulatory conditions. The allocation of costs across regular - labo...
AI summary NS Power's increased labour and material costs are attributed to updated environmental permitting requirements and extended timelines. Midgard concludes that these cost increases are reasonable, given the need to manage project complexity and ensure compliance with regulatory conditions.
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.
5 5.2.3 Analysis – Extended Construction Timelines - 6 The extended project timeline, resulting from delays in securing environmental permitting approvals, - 7 contributed to fluctuations in the costs of key construction materials, includi...
AI summary Extended construction timelines caused delays in environmental permitting, leading to increased material costs for NS Power. The cost increase of $741k is attributed to factors beyond inflation, with some line items showing savings. The original 2019 ACE application had limited material categories, raising questions about the scope of additional costs.
5.2.4 Conclusion - As Midgard noted in Section [3.1.2,](#page-19-2) NS Power was facing an environment of dramatically increasing costs - between its Original Application and the ATO Application. On its face this would not appear to fully...
AI summary Midgard highlights an 87% increase in material costs for NS Power between the 2019 ACE Application and the ATO Application, attributing it to inflation and potential misclassification of costs. The increase is in line with the overall project cost increase, but clarity is needed to determine the reasonableness of the material costs.
4 5.3.1 NS Power Submission - 5 NS Power reported contract cost increases from the 2019 ACE to the ATO Application as detailed in [Table 14](#page-33-0) - 6 an[d Table 15,](#page-34-0) which resulted in contract expense overspending of $2,...
AI summary NS Power reported increased contract costs from the 2019 ACE to the ATO Application, leading to an overspending of $2,595,802 as detailed in Table 14 and Table 15.
Table 16: Contractor Administrative Overhead Cost Increase Category NSUARB Approved ($) 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.
2 1. Fish Passage Upgrades ($1,630,000): Updated environmental permit requirements, including design, 3 construction, and installation 4 2. Construction Supervision ($241,000): Extended timeline and project execution delays 5 3. Security S...
AI summary The document outlines increased contracting costs for a project due to expanded scope items, including fish passage upgrades, construction supervision, and security services. These increases are attributed to changes in design, environmental permit requirements, and compliance with regulations. NS Power attempted to minimize costs through a Limited Notice to Proceed (LNTP), but this resulted in additional expenses.
5.3.3 Analysis – Contractor Administrative Overhead - NS Power attributes the $286,012 increase in Contractor AO costs to the expanded project scope and - extended timeline driven by environmental permitting requirements. These factors inc...
AI summary NS Power attributes an increase in Contractor Administrative Overhead costs to expanded project scope and extended timelines caused by environmental permitting requirements. The increased complexity of contractor coordination and administrative support needed for the delayed project is detailed in Table 18.
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.
- 1. Increased Contract Costs: AO charges are directly proportional to total contract costs. These costs rose significantly due to new scope items, higher commodity prices, and additional work required to meet regulatory demands. - 2. Exte...
AI summary The text discusses increased administrative overhead (AO) charges due to rising contract costs, driven by new scope items, higher commodity prices, and regulatory demands. Delays in environmental permits extended the project timeline, increasing AO costs. NS Power highlighted that cost minimization efforts helped control AO variance.
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.
5.3.5 Conclusion - 1. Contracts: The $2,689,000 increase in contract costs reflects the expanded project scope and evolving requirements, including fish passage upgrades, construction supervision, and archaeological mitigation. While the $...
AI summary The conclusion discusses the reasons for increased contract and contractor administrative overhead (AO) costs, attributing them to expanded project scope, regulatory delays, and environmental permitting. Midgard concludes that these cost increases are reasonable, except for archaeological costs, which may not be a valid reason for variance.
5.4.1 NS Power Submission - NS Power reported consulting cost increases from the 2019 ACE to the ATO Application as detailed in [Table](#page-40-0) - [19](#page-40-0) an[d Table 20,](#page-40-1) which resulted in consulting expense overspe...
AI summary NS Power reported consulting cost increases from the 2019 ACE to the ATO Application, resulting in an overspending of $1,630,672 as detailed in tables referenced in the submission.
5.4.4 Conclusion - From the information provided, the vast majority of the consulting cost increases are directly linked to - increased Project requirements associated with environmental protection and with fish. As previously - discussed,...
AI summary Midgard concludes that most consulting cost increases are reasonable, linked to environmental protection and fish-related project requirements. However, archaeological reconnaissance costs are not considered a valid reason for variance, and associated cost overages are deemed unreasonable.
5.6.2 Analysis - NS Power attributes $341,503 of its cost increases to Labour AO, driven by increased internal labor and - changes in AO rates. The increase is a result of the original filing's estimation using 2020 AO rates, while the - A...
AI summary NS Power attributes a $341,503 increase in costs to Labour AO, citing changes in AO rates from 2020 to 2024. The original filing used outdated rates, while the ATO filing reflects actual and updated rates. Table 25 provides a detailed breakdown of these costs.
Table 25: Cost Increase – Administrative Overhead[71](#page-44-1) Year Total Regular, Term and Overtime Labour AO Rate Applied Total AO 201772 $16,312 51.90% $8,141 2018 $21,446 42.69% $9,155 2019 $36,107 39.29% $14,186 2020 $71,116 37.16%...
AI summary Table 25 outlines the increase in administrative overhead costs from 2017 to 2025, showing rising labour costs and applied AO rates. NS Power explained the increase in AO costs over the past five years and the steps taken to minimize these.
Power states: "Cost minimization will be realized by using internal labour rather than contracted labour at a marked-up rate during the upcoming monitoring during the nine months drawdown of Ruth Falls reservoir. NS Power also sought to mi...
AI summary NS Power implemented cost-saving measures by using internal labor, leveraging regulatory experience, and assigning familiar staff to the Sheet Harbour Hydro Project. The AO variance of $341,503 is justified by project complexities and extended timelines. Midgard concludes that the increased administrative overhead is reasonable.
5.7 AFUDC - 5.7.1 NS Power Submission - NS Power reported Allowance for Funds Used During Construction (" AFUDC ") cost increases from the 2019 - ACE to the ATO Application as detailed i[n Table 26](#page-46-0) an[d Table 27,](#page-46-1)...
AI summary NS Power submitted an increase in AFUDC costs from the 2019 ACE to the ATO Application, citing a labour expense overspending of $612,215 as detailed in Table 26 and Table 27.
Description Total Estimate ($) AFUDC $272,553 Table 27: ATO Application AFUDC Costs[78](#page-46-4) Description Total Estimate ($) AFUDC $884,768 2 5.7.2 Analysis
AI summary The document provides an analysis of AFUDC costs associated with the ATO application, including estimates of approximately $272,553 and $884,768 for AFUDC. These figures are presented in tables and referenced in the analysis section.
- 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 $612,215, to higher project costs, an expanded project scope, and an extended project timeline. This is reflected in the year-over-year growth of AFUDC interest balances, as shown in Table 28, which also highlights the applicable rates used during the project timeline.
10 5.7.3 Conclusion - 11 The AFUDC increase reflects extended project duration, expanded scope, and increased costs, all of which - 12 required sustained capital investment. This growth, evidenced by steady AFUDC balance increases from 201...
AI summary The AFUDC increase is attributed to extended project duration, expanded scope, and increased costs, which required sustained capital investment. Midgard concludes that these cost increases are reasonable, citing scope increases and extended timelines as valid reasons for variance.
5.8.1 NS Power Submission - NS Power attributes various cost increases to additional travel, freight, legal, and meal expenses, driven by - the sequenced construction approach, environmental compliance requirements, delivery of critical ma...
AI summary NS Power attributes cost increases to factors such as sequenced construction, environmental compliance, material delivery, and legal reviews, with a detailed breakdown provided in Table 30.
Table 30: Cost Increase – Other Expenses[85](#page-48-1) Description NSUARB Approved ($) ATO Submission ($) Variance ($) Travel Expenses $17,074 $28,819 $11,745 Freight/Postage/Delivery $0 $17,440 $17,440 Legal $0 $141 $141 Meals $5,378 $8...
AI summary Table 30 outlines the approved and submitted costs for various other expenses, highlighting significant variances, including travel, freight, legal, meals, and equipment costs. The table shows a notable increase in expenses submitted by ATO compared to what was approved by NSUARB.
5.8.2 Analysis - The increase in the additional travel, legal, and meal expenses can be attributed to the extended construction - timeline and associated environmental permitting requirements. Specific comments on each of expense is as - f...
AI summary The analysis discusses increased travel, legal, meal, and equipment costs due to project delays, environmental permitting, and expanded project scope. These costs are attributed to extended timelines, regulatory requirements, and unexpected vendor selections. NS Power explains these variances as necessary for project compliance and cost efficiency.
Table 31: Cost Increase – Other Goods & Services (Contingency)[89](#page-50-1) Description NSUARB Approved ($) ATO Submission ($) Variance ($) Other Goods & Services (Contingency) $842,715 $1,342,714 $499,999 5.9.2 Analysis
AI summary Table 31 shows a significant variance between the NSUARB-approved amount and the ATO submission for Other Goods & Services (Contingency), with the ATO requesting an additional $499,999.
5.9.3 Conclusion - Based on the factors discussed above, Midgard concludes that the overspending associated with additional - contingency is reasonable. M11927, Exhibit N-3, CA RIR-14(a), p. 1 of 2. M11927, Exhibit N-3, CA RIR-14(b), pp. 1...
AI summary Midgard concludes that the overspending related to additional contingency is reasonable, based on the factors discussed.
6.2.1 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 submitted an ATO Application, asserting that its current cost estimate of $15.4 M for the project is reliable, based on quotes from contractors and consultants. The estimate is a Class 1 estimate with an accuracy range of -10% to +15%. NS Power expects no further delays and is awaiting FAA from DFO, contingent on additional information.
6.2.5 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 expresses concern that the Project is exposed to environmental, archaeological, and geotechnical risks that may lead to cost overruns beyond current estimates. It suggests that an analysis of a decommissioning option could provide more clarity on potential cost increases and the economic viability of reinvestment in the Project.
Table 32: Summary of Overspending Amount Conclusions Cost Category Midgard Conclusion Labour Reasonable Materials Recommend that NS Power provide additional clarity on the source of the material cost overspending. Contracts Reasonable, wit...
AI summary Table 32 summarizes conclusions regarding cost category overspending. Most categories are deemed reasonable, but additional clarity is requested for material costs, and archaeology-related costs are questioned as valid reasons for variance.
7.3.2 Potential Additional Cost Increases - 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 add...
AI summary Midgard is concerned that the Project may face additional cost increases due to environmental compensation, archaeological, and geotechnical risks. These risks could lead to cost overages beyond current contingency allowances and Class 1 error bounds. Midgard suggests that an analysis of a decommissioning option could provide more clarity on potential cost overruns.
96572IG (Midgard - BCC) IR - 1 to 33
10 passages
33 is related to interactions with the DFO, rather than the NSECC? 1 Please elaborate, and explain how this may or may not have impacted the 8 Midgard agree that the delays in obtaining the Watercourse Alteration 9 Approval were at least i...
AI summary The text discusses delays in obtaining Watercourse Alteration Approval, potentially linked to NSPI's delays in providing detailed design drawings and access road plans, as well as the impact of increasing costs on project variances. It also references Midgard's conclusions and the context of the ATO process.
4156-4407-7910 v3 32 to managing expenses. - 1 (a) Please elaborate on the "allocation of costs across regular labour 2 categories", as listed, within the ATO, and why that allocation is viewed as 3 reasonable? Please specifically address...
AI summary The text contains a series of questions regarding the allocation of costs across regular labour categories in an ATO, the consideration of inflation rates, and the impact of overtime labour on project timelines and progress.
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.
1 2 reasonable; what is Midgard's recommendation to the Board on how to proceed? 3 4 (g) Does Midgard have any recommendation on how cost estimates for archeological costs can be improved on future hydro projects? 5 Request IR-20: 6 Refere...
AI summary The document contains requests for clarification regarding cost estimates, confidentiality of contract amounts, and the reasonableness of increased contract costs in a 2019 ACE application. Midgard concludes that the increased costs are reasonable, citing expanded project scope and regulatory delays.
- 33 (d) On what basis has Midgard concluded this would not have "materially 34 affected the outcome" of the original approval of this project? 1 (e) Does Midgard view the estimated engagement costs included in the ATO 2 to be reasonable?...
AI summary The text raises questions about Midgard's reasoning regarding the impact of a project on prior approvals, the reasonableness of engagement costs in an ATO, and the increase in the AO rate. It also references cost management practices by NS Power and asks about lessons learned from previous regulatory applications.
29 they did not answer affirmatively? Please explain. 1 (c) Has Midgard done an independent analysis of the cost savings in relation 2 to internal labour on this project (i.e. comparing costs of the internal labour 3 to the cost of outside...
AI summary The text presents a question regarding whether Midgard has conducted an independent analysis of cost savings from using internal labour compared to external contractors, and if not, how they justified the prudence of this approach.
- Reference: N-9, page 51, lines 14-20. - 9 Midgard quotes NSPI with respect to how it determined the contingency amount. Please confirm - 10 the source of this statement. - Request IR-27: - Reference: N-9, Revised Report, page 52, lines 1...
AI summary NS Power and Midgard discuss the contingency budget for offsetting requirements in a project. NS Power uses a 20,000 m² estimate at $25/m², resulting in a $500,000 contingency. Midgard supports this as a prudent measure, but questions the rationale behind NS Power's unit rate selection.
- 1 Preamble: In Midgard's Original Report (section 5.2.2), which is identical to that in the second - 2 excerpt, Midgard expressed confusion with the calculation of the offsetting costs outlined by NSPI. - 3 In the Revised Report, Midgard...
AI summary The text discusses discrepancies in Midgard's reports regarding the calculation of offsetting costs and contingency amounts related to a project. It requests clarification on the reasonableness of these calculations, the basis for certain assumptions, and whether additional communications have occurred with NSPI.
- 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 14 opinion that the Board requires this information on decommissioning of 15...
AI summary The text discusses questions raised about offsetting measurements on hydro projects, decommissioning considerations, and the reliability of cost estimates for a project. It references Midgard's response and NS Power's implication that the estimated cost of $15.4 M is reliable and unlikely to increase further.