N-4NSPI (REI) RIR 1 to 22
4 passages
Plan Revision Summary 1 Request IR-7: 23 approximately $460,000. Since that time, the estimated costs associated with further COD 24 extensions are estimated at approximately $500,000. 25 26 (b) Please refer to Attachment 1 which outlines...
AI summary The text discusses cost overruns and project revisions related to a plan, including estimated costs of approximately $460,000 and $500,000 for further COD extensions. It also references Attachment 1 and REI IR-12 for details on cost recovery measures taken by NS Power.
Labour Overhead Calculation Charge Type 2023 Cost ($) 2024 Cost ($) 2025 Cost ($) 2026 Cost ($) Total ($) Regular Labour 22,393 37,306 44,092 179,859 283,650 Overtime Labour 988 2,197 2,115 (56) 5,244 Term Labour 80,333 49,040 4,446 (291)...
AI summary The document presents a detailed breakdown of labour overhead costs for various charge types over the years 2023 to 2026, including regular labour, overtime labour, and term labour, along with the associated annual overhead percentages. This data is crucial for understanding cost trends and planning for future expenses.
Date Filed: March 3, 2026 NSPI (REI) IR-13 Page 3 of 3 1 Request IR-14: D.27 Business Process & Procedure Development Team has finalized process and procedure documentation from a Role Based perspective. Business Leads have all signed off...
AI summary The document outlines several tasks related to the final stages of a project, including the completion of business process documentation, technical development, and testing. These tasks are currently at various stages of completion, with some already finalized and others not yet started.
5.4 PDF Attachment # Section Name Description Data Type Format Example Required 4 charges. Please refer to REI IR-11 for the details of the administrative overhead rates 5 applied in this project. 6 7 (c) Administrative Overhead costs are...
AI summary The text discusses administrative overhead costs for NS Power, referencing Accounting Policy 6230 and the allocation of costs between capital and operating activities. It also includes a request for information regarding the 'agreed-upon change request process' and the scope for changes in a project.
102536Decision
9 passages
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.
[26] The projected cost is broken down as noted in the following table (which is a summary the Board prepared from a more detailed breakdown that NS Power provided in Exhibit N-1, p. 4 of 6): Cost Category Subcategory Dollars Dollars Labou...
AI summary The text provides a detailed breakdown of projected costs for a project, including categories such as labour, software, contracts, consulting, and contingency. The costs are further divided by year, with actuals and estimates to complete for each category.
3.2.1 Cost Transparency [46] In closing submissions, the Small Business Advocate noted that the costs identified in this application represented a $581,816 increase from the estimated cost that NS Power included in its 2025 ACE Plan. The S...
AI summary The Small Business Advocate highlights a $581,816 increase in costs from the 2025 ACE Plan, noting NS Power's inability to reconcile the changes. NS Power attributes the increase to project delays and administrative overhead, while the Advocate recommends standardized reporting for cost impacts. NS Power provided year-by-year cost details but not driver-level estimates.
between estimated costs for projects identified for subsequent submittal in ACE Plans and the subsequent capital applications. The need for such information should be assessed on a case-by-case basis. [55] In the present case, the cost est...
AI summary The Board acknowledges a 11.5% increase in project costs compared to the 2025 ACE Plan, attributing it to delays. It notes that with over 75% of costs already incurred, the focus shifts from estimating future costs to reviewing the prudence of incurred costs. The prudence test, as established in a prior Fuel Adjustment Mechanism Audit, applies here.
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.
3.2.2.1 Findings [65] The Board finds it entirely reasonable that the shifting business plans and commercial operation dates anticipated by Renewall would have posed challenges for NS Power's management of the project and increased costs....
AI summary The Board finds that NS Power's management of the Renewall project was reasonable despite delays, and accepts NS Power's evidence regarding increased costs due to shifting business plans. Renewall's claims about delays being caused by NS Power or third parties are deemed speculative. The Board also supports NS Power's actions in pausing the project to minimize rework and protect developed code.
3.2.4 Reporting and Business Intelligence Costs [75] NS Power said its current reporting catalog needs to be enhanced to accommodate the anticipated transactional reporting for the new tariffs to support the renewable to retail market and...
AI summary NS Power argues that enhanced reporting infrastructure is necessary to support the renewable to retail market and new settlement processes, citing complexity and lack of pre-existing reports. Renewall suggests that costs should be reconsidered, as deliverables are limited to encrypted files and alternative funding should be explored.
3.2.4.1 Findings [80] It is not apparent to the Board that the scope of the reporting and business intelligence development work has changed through the project. The Board is satisfied with the information provided by NS Power that this wo...
AI summary The Board finds no evidence that the scope of reporting and business intelligence development work has changed during the project. It is satisfied with NS Power's explanation that the work was necessary for operational requirements and notes that Renewall's involvement should have raised any concerns earlier.
101270Submission - REI
5 passages
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.
a) Reporting and Business Intelligence Development Costs NSPI states that its reporting tools are not, in themselves, insufficient, but that "the current reporting catalog needs to be enhanced to accommodate the anticipated transactional r...
AI summary NSPI argues that its current reporting tools are insufficient for new tariffs and settlement processes, requiring enhancements. REI acknowledges the need but criticizes the lack of defined outputs and cost alternatives. NSPI plans to deliver encrypted files monthly via SFTP. REI recommends deferring non-essential reporting costs.
b) Cost Allocation Safeguards and Protection for REI and Non-RtR Ratepayers As the sole LRS and direct payer of the costs approved under this proceeding, REI requires regulatory safeguards ensuring that amounts charged to it are prudent, i...
AI summary REI requests regulatory safeguards to ensure costs allocated to it are prudent and exclusive to RtR implementation, protecting non-RtR ratepayers. Proposed conditions include annual certification, a true-up mechanism, a scalability costing protocol, and a ring-fence for CIS Replacement costs.
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
3 passages
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.
Prudence and Support for Delay Related Costs REI submits that NS Power did not provide a detailed breakdown of delay related cost increases by labour type or task, advised that original estimates could not be 4 M11874 Decision, page 5. 5 I...
AI summary REI argues that NS Power did not provide a detailed breakdown of delay-related cost increases, did not attribute responsibility for delays, and did not pause costs as recommended. REI recommends the Board reduce or disallow these costs due to lack of prudence, causation, and incrementality.
Reporting and Business Intelligence Development Costs With respect to the reporting and business intelligence workstream, REI acknowledges the need for enhanced reporting to support the RtR market but submits that the scope and cost of the...
AI summary REI argues that the scope and cost of reporting and BI development for the RtR market should be deferred or funded outside this capital item, as it has not been tied to defined minimum functional requirements or assessed against lower-cost alternatives. NS Power disagrees, stating that the workstream is essential for meeting operational requirements and ensuring accuracy in RtR implementation.
102536Decision
6 passages
[26] The projected cost is broken down as noted in the following table (which is a summary the Board prepared from a more detailed breakdown that NS Power provided in Exhibit N-1, p. 4 of 6): Cost Category Subcategory Dollars Dollars Labou...
AI summary The text presents a detailed breakdown of projected costs for a project, categorized into labour, software, contracts, consulting, contingency, and administrative overhead. The costs are further broken down by year, showing actuals and estimates to complete, with a total projected cost of $5,644,469.
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.
3.2.1 Cost Transparency [46] In closing submissions, the Small Business Advocate noted that the costs identified in this application represented a $581,816 increase from the estimated cost that NS Power included in its 2025 ACE Plan. The S...
AI summary The Small Business Advocate pointed out a $581,816 increase in costs from the 2025 ACE Plan, noting NS Power could not reconcile the changes. NS Power attributed the increase to delays and administrative overhead, but the Advocate called for more detailed cost impact analysis. NS Power provided year-by-year cost data but could not reconcile at a driver level.
[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.
3.2.2 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 criticizes NS Power for providing insufficient detail on delay costs related to project delays, including labor and task impacts, and for failing to reconcile costs due to a cyber-attack. Renewall also questions the prudence of delay costs and whether NS Power considered pausing the project earlier. Additionally, Renewall notes that AFUDC and administrative overhead costs make up 15% of project costs, but NS Power did not provide detailed reconciliation schedules.
[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.