Topic:"Cost Considerations" in M12898

NSPI Responses to Consumer Advocate Information Requests 1 Request IR-2: 2 3 (a) Please provide a workbook in native format with a breakdown of project actual costs 4 by account compared to budget for all distribution routines for 2025. 5...

AI summary NSPI has been asked to provide detailed cost breakdowns for distribution routines in 2025 and over the past five years, including labour, contracts, materials, and administrative overhead. Additionally, NSPI is requested to explain the use of overtime labour for specific distribution routines, particularly in cases where the reason provided previously may not apply.

NON-CONFIDENTIAL 1 spend. While the absolute dollar value of overtime costs has increased due to the overall 2 increase in D055 work volume in 2025, overtime as a percentage of total labour 3 expenditures has declined, indicating that NS P...

AI summary The text discusses NS Power's management of overtime costs related to D055 work volume in 2025. Despite an increase in absolute overtime costs, the percentage of overtime relative to total labour expenditures has decreased, indicating improved efficiency through regular-time labour and expanded field resources.

NON-CONFIDENTIAL 1 (d) NS Power ensures that D055 costs are minimized through its asset management approach 2 which evaluates both condition and criticality to determine the risk of different asset groups 3 and provides priorities for the...

AI summary NS Power outlines its approach to minimizing D055 costs through asset management, competitive procurement, and efficient scheduling practices. The company uses engineered standards, historical data, and field supervision to ensure cost-effective solutions and efficient execution of work orders.

Table 7: REIMBURSABLE EXPENSES Ancillary Services Administrative Fee Access Rock Breaking or Blasting Traffic Control Tree Trimming Backhoe Hydro Vac Truck Floating Costs (Hourly Rates Only) Non-standard\nequipment for transmission Work (b...

AI summary Table 7 outlines reimbursable ancillary services and administrative fees. It specifies that when ancillary services are identified in advance, they must be detailed in Work Orders with estimated costs. If identified in the field, costs are estimated and approved via Change Orders. The Service Provider must manage these services for best value to NSPI.

COSTS/EXPENSES All expenses shall follow NSPI's expense policies as referenced above in Schedule A, Section 3.4(c). All expenses are subject to audit. REDACTED Distribution Routines ATO CA IR-5 Attachment 1 Page 50 of 67 REDACTED (CONFIDEN...

AI summary The document outlines that all expenses must adhere to Nova Scotia Power Inc.'s expense policies and are subject to audit. Certain sections of the document have been redacted and marked as confidential.

NON-CONFIDENTIAL) (iii) For materials costs that are allocated as a percentage of labour, please provide actual percentage allocation factor for each of the five most recent years and the method for deriving that factor.

AI summary The text requests the provision of actual percentage allocation factors for materials costs relative to labour over the past five years, as well as the method used to derive these factors.

nal condition-driven work was largely completed using regular-time labour, supported by increased field capacity through additional Power Line Technicians (PLTs) and expanded PLT contractor resources. In its submissions, the SBA stated tha...

AI summary The SBA supports NS Power's PLT recruitment efforts, noting reduced overtime expenses as a positive outcome. The CA, however, is concerned about the lack of detailed data from NS Power, which makes it difficult to assess expenditures for reasonableness, and questions whether current improvements in data collection will be sufficient to prevent future issues.

and reporting, and agreed that such improvements will be useful. Nevertheless, the CA remains concerned as to whether the proposed tracking will be sufficient to prevent similar issues in the future. The CA also expressed concern about whe...

AI summary The Consumer Advocate (CA) raised concerns about NS Power's cost minimization practices, the effectiveness of tracking mechanisms to prevent future issues, and the significant increase in Bin Work costs, which rose by over 300% in two years, despite only a 38% increase in Field Work costs.

ver the same period. In addition, the CA noted that a particular concern is the $8 million year-over-year increase in Bin Work costs, resulting in a total increase of more than 300% in just two years. The CA suggested that the Board could...

AI summary The Consumer Advocate (CA) raised concerns about the $8 million increase in Bin Work costs and suggested reducing ATO cost recovery and improving reporting transparency. NS Power acknowledged some information gaps due to a 2025 cyber incident but is working to enhance its reporting capabilities.

asset replacements by type. NS Power is actively developing enhanced tracking for 2026 to capture spending associated with specific feeder-level projects identified in the Five-Year Reliability Plan. The Board acknowledges NS Power's comme...

AI summary The Board acknowledges NS Power's efforts in managing costs through procurement and oversight but notes a gap in evidence provided. It approves an ATO for D055 routine spending to improve reliability but requires a detailed breakdown in the 2027 ACE Plan, including cost categories, work descriptions, and cost-benefit analysis.

e operating region; and a cost- benefit analysis comparing the total cost of having the work performed by external contractors with the estimated cost of completing the work using internal resources. Furthermore, the Board recognizes that...

AI summary The Board acknowledges NS Power's efforts to enhance tracking and reporting of distribution-routine spending and requires the submission of a timeline for this initiative in the 2027 ACE Plan, including specific data categories identified by the Consumer Advocate.

6 Request IR-2: 7 (a) Please provide a workbook in native format with a breakdown of project actual costs by 8 account compared to budget for all distribution routines for 2025. 9 10 (b) Please provide a table with the following actual cos...

AI summary The request asks for detailed cost breakdowns and explanations regarding overtime labour usage in various distribution routines. It seeks data on actual costs compared to budgets and reasons for overtime use, as well as any indirect cost effects from reassignments.

19 Request IR-4: 20 Data provided in NSEB RIR-26, M12319, indicate that the average cost of a field driven work 22 21 order increased from $1,481 in 2022 to $3,009 in 2023 and to $19,664 in 2024. 23 (a) Please confirm the values for 2022 t...

AI summary The request asks NS Power to confirm and explain the significant increase in the average cost of field-driven work orders from 2022 to 2024, provide 2025 data, and detail the number and cost of specific types of work orders. It also asks for an explanation if quantitative data are unavailable and how cost minimization is ensured.

38 Request IR-5: 39 (a) Please provide a list of all contracts for D055 with actual expenditures for 2025. In your 40 response, please state for each contract is standardized, negotiated on a non-standard basis, 41 or subject to any type o...

AI summary This request asks for detailed information on contracts related to D055, including their standardized status, procurement methods, budget vs. actual costs, and explanations for non-standard or competitively bid contracts. It also requests details on contracts in effect since 2023 and those with expenditures exceeding $750,000.

13 Request IR-6: - 14 (a) Please explain with specificity the types of materials included in materials costs for D055. 15 In your response, for each type of material, please explain the basis for the cost (e.g., 16 contract pricing, market...

AI summary The text includes a request for detailed information on materials costs for D055, including the types of materials, their cost basis, budget and actual costs from 2021-2025, procurement practices, and allocation factors. Specific attention is requested for materials with cost overruns of 25% or more.

Submissions The Consumer Advocate has reviewed the materials filed in this matter, including NS Power's Application and responses to Information Requests, and makes the following submissions. (a) Sufficiency of Information Provided On revi...

AI summary The Consumer Advocate raises concerns about the insufficient data provided by NS Power in support of its Application, particularly regarding cost and contract details for distribution routines. NS Power has not collected or provided detailed information on contractors, expenditures, or external factors affecting costs, making it difficult to assess the reasonableness of its $8.6 million request for D055. NS Power claims it is improving data collection and reporting in 2026.

(b) Cost Minimization In M12319, the CA expressed concerns "as to whether NS Power has maintained effective cost minimization practices" for capital distribution routines.[6](#page-3-2) The Consumer Advocate's submission provided several e...

AI summary The Consumer Advocate raised concerns about NS Power's cost minimization practices in capital distribution routines, citing a lack of data on cost-effectiveness comparisons between NS Power and contractors. NS Power responded by highlighting its efforts to increase field resources and reduce overtime costs through recruitment, but the CA argues that insufficient data makes it unclear whether the reduction in overtime costs represents actual cost savings.

One suggestion by NS Power is that a backlog in "deficiencies" developed from 2022 that only began to be addressed sometime in 2024. NS Power states: The primary costs and drivers of D055 are determined by asset condition data from ongoing...

AI summary NS Power attributes a backlog in deficiencies from 2022 to 2024 and a significant increase in Bin Work costs from $3.0 million in 2023 to $12.1 million in 2025, but provides limited details on the nature of the deficiencies or the administrative changes driving the cost increase.

(d) Conclusion For all of the foregoing reasons, the CA submits that NS Power has not provided substantial evidence to justify its spending on distribution routines, and specifically: - NS Power is unable to provide evidence as to which co...

AI summary The Consumer Advocate (CA) argues that NS Power has not provided sufficient evidence to justify its spending on distribution routines, citing missing contractor details, inadequate cost-effectiveness explanations, and significant cost increases. The CA recommends a reduction in cost recovery and suggests revising NS Power's reporting practices.

3.1 Sufficiency of Information Provided The CA raises concerns regarding the sufficiency of the evidence supporting the Application. Referring to similar concerns raised in the 2024 Distribution Routines ATO proceeding, the CA submits that...

AI summary The CA raises concerns about the sufficiency of information provided by NS Power in support of the Application, particularly regarding the absence of detailed contractor expenditure data for D055, which limits the ability to assess the reasonableness of expenditures and cost minimization practices.

3.2 Cost Minimization - The CA notes NS Power's explanation that increased PLT recruitment and expanded contractor - capacity contributed to a reduction in overtime costs as a percentage of total labour expenditures. - While the CA submits...

AI summary The Commissioner of the Environment and Sustainable Resource Development (CA) acknowledges NS Power's claim that increased PLT recruitment and contractor capacity reduced overtime costs but notes insufficient data to confirm this explanation. The CA also highlights increased PLT staffing and higher volumes of condition-driven replacement work as potential contributing factors.

3.3 Planning Practices – Cost Drivers - The CA submits that D055 has exceeded budget in prior years, but that the magnitude of the 2025 - overspend is significantly greater than in previous years, driven primarily by the increase in Bin M1...

AI summary The Commissioner of the Environment and Sustainable Resource Development (CA) highlights concerns about D055's 2025 budget overruns, questioning the causes and NS Power's planning practices. The CA points to increased deficiency volumes, changes in work-order practices, and reprioritization as potential factors, but notes a lack of detailed tracking and transparency.

t have already been identified as requiring near-term intervention, where further delay may increase the risk of failure and the need for more costly corrective action. Ordinary reprioritization, by contrast, reflects the ongoing assessmen...

AI summary The text discusses the need for near-term intervention on assets requiring repair and the factors influencing the cost of addressing deficiencies. It highlights that increased deficiency volumes contributed to higher spending in 2025, but the cost of addressing each deficiency can vary based on specific asset and project factors.

nal condition-driven work was largely completed using regular-time labour, supported by increased field capacity through additional Power Line Technicians (PLTs) and expanded PLT contractor resources. In its submissions, the SBA stated tha...

AI summary The SBA supports NS Power's recruitment of Power Line Technicians, noting reduced overtime expenses as a positive sign. The CA, however, remains concerned about the lack of detailed data provided by NS Power, making it difficult to assess expenditures for reasonableness, and questions whether proposed improvements will prevent future issues.

and reporting, and agreed that such improvements will be useful. Nevertheless, the CA remains concerned as to whether the proposed tracking will be sufficient to prevent similar issues in the future. The CA also expressed concern about whe...

AI summary The Consumer Advocate (CA) has raised concerns regarding NS Power's cost minimization practices, the adequacy of tracking mechanisms to prevent future issues, and the significant increase in Bin Work costs, which rose by over 300% in two years. The CA also questioned NS Power's ability to provide sufficient information on the cost-effectiveness of its practices.

ver the same period. In addition, the CA noted that a particular concern is the $8 million year-over-year increase in Bin Work costs, resulting in a total increase of more than 300% in just two years. The CA suggested that the Board could...

AI summary The Consumer Advocate (CA) raised concerns about a significant increase in Bin Work costs and suggested reducing ATO cost recovery and improving reporting transparency. NS Power acknowledged the issues but explained that a 2025 cyber incident limited data availability and noted challenges in implementing more detailed reporting.

e operating region; and a cost- benefit analysis comparing the total cost of having the work performed by external contractors with the estimated cost of completing the work using internal resources. Furthermore, the Board recognizes that...

AI summary The Board acknowledges NS Power's efforts to improve tracking and reporting of distribution-routine spending and directs the submission of a timeline for this initiative in the 2027 ACE Plan, including data categories identified by the Consumer Advocate.

c. All Parties NSEB APPROVAL SHEET Project Title: Distribution Routines CI Number: Various Date: June 11, 2026 Expenditure Profile Type of Filing Year Budget Amount Project Actuals Capital Project Authorization D055 10,620,862 21,980,684 U...

AI summary The document details an Authorization to Overspend (ATO) for the Distribution Routines project by Nova Scotia Power, with a significant variance between the 2025 ACE budget and actual expenditures. The project, labeled D055, had an approved budget of $10,620,862, but actual costs reached $21,980,684, resulting in a $11,359,822 variance. The Nova Scotia Energy Board approved the ATO on September 18, 2026.