N-52026-2027 GRA Appendix 1-6 - Redacted
6 passages
2026-2027 GRA Direct Evidence Appendix 3B Page 12 of 54 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Adapting to the changing climate is not an alternative to increasing action to slow climate change, but adaptation has become a crucial com...
AI summary The text emphasizes the importance of climate adaptation as a complement to mitigation efforts, citing high benefit-cost ratios (2:1 to 10:1) from the Global Commission on Adaptation. It highlights NS Power's potential benefits, including reduced economic losses and improved infrastructure resilience through climate risk-based maintenance.
Capital Replacements Capital replacement, in essence replacing the entire asset with a new asset, is often one of the last options selected for risk mitigation as it is often the costliest. The new asset may be of similar specifications to...
AI summary Capital replacement involves replacing entire assets, typically as a last resort due to high costs. It may be chosen if refurbishment is infeasible, risks cannot be managed otherwise, or if it's more cost-effective. An example is replacing a low-lying substation with a higher-elevation one to mitigate flood risks.
6. Step 6: Develop a Business Case for Selected Measures This section overviews the procedure for prioritizing recommended adaptation measures. NS Power has robust existing operating and capital expenditure budgeting processes. Adaptation...
AI summary NS Power integrates climate adaptation into existing operating and capital expenditure processes. Measures are selected based on cost, implementation ease, risk mitigation effectiveness, and asset mission. Risk management plans undergo approval by asset teams, management, and regulators. The CEJC process uses a 5x5 risk matrix to prioritize capital expenditures, with detailed criteria outlined in a 2023 document submitted to the Nova Scotia Utility and Review Board.
2026-2027 GRA Direct Evidence Appendix 3B Page 43 of 54 REDACTED (CONFIDENTIAL INFORMATION REMOVED) CRITICALTY VALUE RISK MATRIX 5 5 10 15 20 25 4 4 8 12 16 20 3 3 6 9 12 15 2 2 4 6 8 10 • 1 2 3 4 5 1 2 3 4 5 Rare Unlikely Possible CONDITI...
AI summary The document outlines a risk matrix from NS Power's CEJC Summary Document, categorizing risks based on criticality and likelihood. It emphasizes the use of an Economic Analysis Model (EAM) for recommendations requiring economic analysis, approved by the Nova Scotia Energy Board through the CEJC process, considering factors like payback period and time-value of money.
2026-2027 GRA Direct Evidence Appendix 3B Page 54 of 54 REDACTED (CONFIDENTIAL INFORMATION REMOVED) - Monitoring Plan : Creating a robust climate data and weather monitoring plan to continually collect observations of key climate variables...
AI summary NS Power outlines a climate monitoring plan to collect data on key climate variables, allocate resources for monitoring, collaborate with external organizations, enhance in-house data collection technologies, and benchmark empirical data against climate projections to inform climate change pathways.
1.4.5 Cost of Service Updates NS Power undertook stakeholder engagement throughout 2024 around its Cost of Service. In Appendix 13A NS Power has proposed changes to its COS, including changes to the COS for FAM. NS Power has updated the FA...
AI summary NS Power engaged stakeholders in 2024 on its Cost of Service (COS) updates, proposing changes to the Fuel Adjustment Mechanism (FAM) COS and updating the FAM POA in Appendix 13A, Section 3.
N-62026-2027 GRA Appendix 7A-E - Redacted
3 passages
1.5.7 Cost Savings Initiatives NS Power has continued to evolve its focus on meeting customer-requested work in a timely manner and is investing to meet increased customer reliability expectations. The Company has made significant progress...
AI summary NS Power has improved customer reliability through initiatives like the Five-Year Reliability Plan, leading to increased costs. The company emphasizes providing value for these investments and highlights the Management Operating System as part of the WAM project transition to enhance operational efficiency.
REDACTED Appendix 7A – OM&G Costs by Group - Enhancement of the asset management approach to reduce substation maintenance cycles and costs. - Addition of GPS automatic vehicle locators on all T&D fleet vehicles in order to track crew on-s...
AI summary NS Power outlines initiatives to reduce OM&G costs through technology integration (e.g., GPS, GIS, ADMS), process optimization (e.g., mobile fueling, shift repurposing), and collaboration with Bell Aliant and government departments. These measures aim to improve efficiency, reduce downtime, and lower operational expenses.
Grid Modernization and Customer Integration - Operating costs associated with the WAM Support team, which were not yet in place at the time of the 2023-2024 GRA. The responsibilities of this team, as contemplated in the WAM capital applica...
AI summary The document discusses the WAM Support team's cost-saving achievements and operational improvements, including automated scheduling and inventory tracking. It also notes increased staffing in the Customer Experience team due to the restated 2024 GRA Compliance forecast. NS Power's WAM initiative has exceeded cost-saving targets, while NS Power faces higher operating expenses from expanded customer-focused initiatives.
N-44STATE OF CONNECTICUT
PUBLIC UTILITIES REGULATORY AUTHORITY
4 passages
3. Compliance with the Resilience Framework UI's Resilience Plan complies with the Resilience Framework requirements established by the Authority on August 31, 2022. 17-12-03RE08 Decision, pp. 57-71. "[W]hen seeking approval for resilience...
AI summary UI's Resilience Plan complies with the Resilience Framework established by the Authority in August 2022. The plan identifies priority zones based on historical outage data and other criteria, evaluates multiple mitigation measures, and includes cost-benefit analyses over 5-, 10-, 20-, and 30-year periods. The 30-year BCA results in a break-even scenario under one storm scenario and a positive return under another.
i. Background and AMI Plan Requirements As part of its broader efforts to accelerate the modernization of Connecticut's electric grid in innovative, cost-effective, and equitable ways, the Authority previously identified the deployment and...
AI summary The Authority emphasizes the importance of Advanced Metering Infrastructure (AMI) in modernizing Connecticut's electric grid. A Benefit Cost Analysis (BCA) is required in each EDC's AMI Plan to ensure that AMI investments align with economic, environmental, and policy goals, and to monitor actual costs and benefits.
ii. Analysis of UI's Submission The BCA portion of UI's AMI Plan submission does not comply with the framework and requirements established in the AMI Decision for at least three reasons. First, the BCA does not provide most of the request...
AI summary The BCA portion of UI's AMI Plan submission fails to meet the AMI Decision's requirements by lacking necessary data, benefit targets, and a proper 20-year planning horizon. UI argues that most benefits have already been realized, but the submission provides limited quantified benefits, making it difficult to evaluate the value of AMI investments.
hority's broad regulatory authority and discretion in setting just and reasonable rates. See Hope, 320 U.S. 591 (1944); see also Barasch, 488 U.S. 299 (1989); Woodbury Water Co., 174 Conn. 258 (1978). Here, the substantive matter under con...
AI summary The document discusses the regulatory authority of the Public Utilities Regulatory Authority (PURA) in setting just and reasonable rates, focusing on United Illuminating's (UI) Advanced Metering Infrastructure (AMI) Plan and its required Benefits-Cost Analysis (BCA). The Authority requested clarifying information on costs and benefits, and UI was on notice that its plan was under review.
101354Board Decision
8 passages
Q. So in this case, it refers to Appendix 5A and it says: On page 34 of Appendix 5A, the application states that NSPML's forecast assessments for the Maritime Link against Nova Scotia Power are $200.5 million in 2026 and $203.9 million in...
AI summary The document discusses discrepancies between projected and actual assessments for the Nova Scotia Power Maritime Link (NSPML) under the Federal Loan Guarantee (FLG). The 2026 assessment was reduced by $1.8 million, primarily due to a $1.8 million decrease in FLG costs, with similar reductions expected in 2027. The speaker questions whether adjustments should be made to the base cost of fuel based on these differences.
o the Nova Scotia Independent Energy System Operator (IESO Nova Scotia) in December 2025 in Phase 1 of the transition and 32 employees in 2027 in Phase 2 (Transcript, January 12, 2026, pp. 1056-1058). - [77] Doane Grant Thornton LLP was en...
AI summary NS Power proposed staffing increases of 22 employees in 2025 (Phase 1) and 32 in 2027 (Phase 2). Doane Grant Thornton LLP reviewed OM&G cost forecasts but did not assess operational efficiency. The Nova Scotia Department of Energy argued the staffing increases were unreasonable given affordability concerns, stating NS Power had not justified the need for additional staff or demonstrated compliance with industry standards.
ty engagement with its present staffing complement, having conducted 65 community meetings recently across the province. The Board finds that adding more staff on these initiatives would be redundant. [98] Secondly, and more importantly, d...
AI summary The Board rejects NS Power's request for additional staffing for customer engagement, citing lack of formal customer satisfaction metrics and reliance on performance standards. NS Power failed to justify increased costs for digital programs and did not conduct a cost-benefit analysis for engagement initiatives.
ll be used to determine rates and the revenue derived from rates will inform the value of the rate base). [403] Bonbright notes that out of this criticism sprung the cost-based approach to valuation: Impressed with the force of the vicious...
AI summary The text discusses Bonbright's critique of fair-value rate base approaches, advocating for cost-based valuation to avoid circularity in rate-setting. It highlights original cost rate bases' administrative efficiency and benefits for capital access, emphasizing their role in maintaining creditworthiness and reducing regulatory expenses.
[431] The Board went on to find: [42] In summary, the Board finds that the threshold for rebutting the presumption of prudence is contextual. It requires a reasonable question – something that is more than a bald statement or speculation –...
AI summary The Board clarifies that the threshold for rebutting the presumption of prudence in a FAM Audit requires a reasonable question, not mere speculation. The Department argues NS Power's prudence may be questioned due to (1) overly low depreciation rates inflating coal asset net book values and (2) unnecessary investment in retiring coal assets.
NS Power maintains that the current costing methodology adequately and fairly allocates capacity costs to the provision of Regulation Service and submits that there is no double-counting of capacity. [665] Regarding NS Power's treatment of...
AI summary NS Power argues its current costing methodology fairly allocates capacity costs for Regulation Service without double-counting. It caps Wreck Cove's spinning reserve contribution at 32 MW, resulting in a negligible cost difference. NS Power adjusted CBAS calculations for 30-minute reserves by incorporating CT dispatch data, reflecting the system's shift toward variable renewable energy.
ocesses. But appreciate the point again that there's much more data that's associated with this and how those are assigned to our specific asset classes. [Transcript, January 12, 2026, pp. 1030-1031] [705] Hydro-Québec's Climate Change Ada...
AI summary The document compares Hydro-Québec's Climate Change Adaptation Plan (2022-2024) with NS Power's approach. Hydro-Québec's plan includes two phases: risk identification and action areas with adaptation measures. NS Power acknowledges a comparable first phase but claims its plan lacks the second phase's detailed information, asserting that such data resides in its climate adaptation management system and database.
is forecast to provide in the test period. It recommended that the proposed large increase in sustaining capital costs for Lingan 2 "be supplemented with additional narrative support" by the company. [715] In response to questions from Boa...
AI summary NS Power seeks to refurbish Lingan Unit 2 due to safety concerns, requesting additional narrative support for increased sustaining capital costs. The company cites NERC and NPCC requirements for system capacity and customer load service. Refurbishment delays risk consequential damages, and capital costs are not automatically approved with the GRA.
99742Doane Grant Thornton (NSPI) IR 1 to 93
5 passages
Request IR-30: - Reference: N-6 2026-2027 GRA Direct Evidence Appendix 7C Page 27-28 of 58 - Per N-6, (Appendix 7C), page 27-28 of 58, we understand that a wind generation acquisition - forecast in 2024 GRA Compliance forecast did not occu...
AI summary Request IR-30 seeks clarification on the non-occurrence of a 2024 wind farm acquisition forecasted in the GRA Compliance forecast, which impacted costs in 'Wind, Hydro, and Solar energy.' It requests an explanation for the acquisition's failure and a summary of related costs included in the 2024 compliance restated.
Request IR-35: - Reference: N-6 2026-2027 GRA Direct Evidence Appendix 7C Page 37-38 of 58 - Per N-6, (Appendix 7C), page 37-38 of 58, we understand that other goods & services expense - has increased from 2024 compliance restated to 2026...
AI summary The request seeks an explanation for the increase in other goods & services expenses from 2024 to 2026, attributed to grid-scale battery costs in regional operations. It asks for a breakdown of these costs.
Request IR-47: - Reference: N-6 2026-2027 GRA Direct Evidence Appendix 7C Page 49-50 of 58 - Per N-6, (Appendix 7C), page 49-50 of 58, we understand that other goods and services expense - has decreased from 2024 actual, 2025 budget, 2026...
AI summary Request IR-47 seeks evidence supporting a $5 million reduction in administration expenses attributed to the GRA settlement agreement, referencing Appendix 7C, pages 49-50 of N-6.
Request IR-49: - Reference: N-6 2026-2027 GRA Direct Evidence Appendix 7C Page 51-52 of 58 - Per N-6, (Appendix 7C), page 51-52 of 58, we understand that other goods and services has - decreased from 2024 compliance restated, 2024 actual,...
AI summary The request seeks clarification on a $2 million reduction in 'customer service' costs under the GRA settlement, asking for details on the settlement terms and supporting documentation. The reduction is noted in N-6 Appendix 7C pages 51-52 of 58, comparing 2026 forecasts to prior years.
Request IR-77: - Reference: FO-13 - Please provide additional support for the Deferred FAM charges found in FO-13 attachment 1 - line 35-38. In particular, provide support for the opening balance with detailed calculations for - interest a...
AI summary The request seeks additional support for Deferred FAM charges in FO-13 attachment 1, lines 35-38, including detailed interest calculations and adjustments to the account.
99748NSEB (NSPI) IR 1 to 152
9 passages
Request IR-17: - Reference: Exhibit N-5, Appendix 3A, Status of GRA-Related Deliverables - In Item 3, NS Power notes that it created a Climate Change Adaptation Plan in 2021. - a) Please explain why, if NS Power had already created a Clima...
AI summary The Board requests NS Power to explain delays in submitting its Climate Change Adaptation Plan, provide deferred cost breakdowns, detail stakeholder engagements, clarify discrepancies in plan status, and explain the Climate Action Leadership Program. Additional requests concern climate data usage in risk analysis and holistic economic modeling for climate resilience measures.
Request IR-54: - Reference: Exhibit N-6 Appendix 7A - Regarding s. 1.5.7 (Cost Savings Initiatives), please identify any initiative or pilot projects NS - Power plans to undertake in 2026 and 2027 to identify or assess new cost savings ini...
AI summary The document requests NS Power to identify cost-saving initiatives or pilot projects planned for 2026 and 2027 under section 1.5.7, aimed at increasing efficiency and reducing costs for customers.
Request IR-62: - Reference: Exhibit N-6(ii), Corporate Human Resources - a) The reason given for the increase from 2024 compliance restated to forecast 2026 expense in labour under Human Resources is due to staffing level increase and sala...
AI summary Request IR-62 questions NS Power's 58% HR expense increase, 47% consulting rise, and talent management costs, citing ScottMadden Report findings that NS Power's HR costs exceed peers. Asks for justification of safety programs, internal vs. external consulting, and alignment with industry benchmarks.
Request IR-67: - Reference: Exhibit N-6(ii), Transmission & Distribution Contractor Management - There was a 133% increase in contracts expense in 2024 versus the forecast amount in the 2024 - compliance. The explanation given for the high...
AI summary Nova Scotia Power (NSP) reported a 133% increase in contracts expense for 2024 compared to the compliance forecast, attributing the $7.6 million rise to higher maintenance costs for aging fleet vehicles, increased utility services, and inflation. The request seeks further details on these expenses.
Request IR-73: - Reference: Exhibit N-14, OP-03 Attachment 1, ScottMadden Report - On page 17 it is noted that NS Power's total OM&G increased 23% in nominal terms from 2019 - to 2023 while the peer median decreased 9% in nominal terms ove...
AI summary NS Power's operational and maintenance (OM&G) costs increased significantly compared to peers between 2019 and 2023, with total OM&G up 23%, transmission OM&G per retail MWh up 90%, and distribution OM&G up 32%. The request seeks the nominal changes after excluding level 3 and 4 storm costs.
Request IR-89: - Reference: Exhibit N-3 GRA Direct Evidence, Section 9.2.1 Average Capital Assets - On pages 52-53 of its application, NS Power notes that it has removed approximately $700 million - from its rate base for the DDA assets (P...
AI summary NS Power removed $700 million from its rate base for DDA assets, citing securitization by 2026, and seeks to defer depreciation and return if delayed. Requests include documentation on securitization timelines, deferral costs, debt issuance breakdowns, and updates on retired assets, customer deposits, and unapproved capital items. The proceeding involves GRA, FAM, and RTR programs.
Request IR-96: - Reference: Exhibit N-3 GRA Direct Evidence, 9.3 Maritime Link Capital Applications - On page 60, NS Power addresses the Board's directive from the 2023-2024 GRA Decision - regarding inclusion of four Maritime Link transmis...
AI summary NS Power must demonstrate that Maritime Link transmission projects' combined wheeling tariff revenue and Nalcor surplus energy benefits meet costs (depreciation, financing, etc.) over four quarters, as per the 2023-2024 GRA Decision. The request includes detailed cost-benefit breakdowns, energy purchase amounts, alternative generation costs, and project capital forecasts.
Request IR-132: - Reference: Exhibit N-3 GRA Direct Evidence, Section 13 Rate Design - On page 81 of the application, NS Power notes it is not proposing to introduce new concepts or - materially modify any of its rate design. Please descri...
AI summary The document requests NS Power to describe any work done on innovative rate designs leveraging AMI meters, efficient resource use, and addressing market changes due to decarbonization and decentralization, despite NS Power's assertion of not proposing new concepts or modifications.
Request IR-144: - Reference: Exhibit N-3 GRA Direct Evidence, Section 13.7, AMI Opt-Out Fee - a) Please describe any limits NS Power currently faces in reading AMI meters over the air as a result of its cybersecurity breach. - b) Please de...
AI summary Request IR-144 seeks information from NS Power regarding cybersecurity breach impacts on AMI meter readings, manual reading arrangements, timelines for resuming automated readings, and the accuracy of cost estimates for manual reading of opt-out customers in 2026–2027.
100863Reply Submissions - NS Power
3 passages
1 costs and operating costs associated with continuing to run Lingan 2 as a system resource given 2 current and foreseeable constraints. 3 On this issue, it is important to note two central facts: (1) as discussed at pages 926-929 of the 4...
AI summary NS Power argues Lingan 2 remains essential for system reliability due to uncertain replacement timelines and rising peak demand. The DOE supports securitization initiatives but expresses reservations about cost savings and coal asset valuation. NS Power hopes the Board will address these concerns.
- 1 REI's "Suggested action/changes" - 2 As demonstrated above, the proposed OATT rate calculations are accurate and consistent with the - 3 approved methodology. The OATT calculation process has been revised to better align with the - 4 C...
AI summary NS Power defends the accuracy of OATT rate calculations aligned with COS through COSS stakeholder input, rejecting REI's request to make COS determinative of OATT. NS Power also argues against REI's call for more precise fuel cost forecasts, citing the Plan of Administration (POA) as sufficient. Future OATT administration by IESO Nova Scotia is noted.
1 6.0 CONCLUSION 2 - 3 NS Power repeats and relies on the evidence presented in this proceeding in support of the relief - 4 sought in the GRA. The evidentiary record reflects extensive analysis, expert input, and detailed - 5 scrutiny of...
AI summary NS Power reiterates its evidence supporting the General Rate Adjustment (GRA), emphasizing extensive analysis and stakeholder collaboration. The proceeding highlights challenges in balancing cost pressures, reliability, affordability, and energy transition goals. NS Power reaffirms its commitment to transparency and ongoing engagement with the Nova Scotia Utility and Review Board (NSUARB) and stakeholders.
101354Board Decision
8 passages
ty engagement with its present staffing complement, having conducted 65 community meetings recently across the province. The Board finds that adding more staff on these initiatives would be redundant. [98] Secondly, and more importantly, d...
AI summary The Board rejects NS Power's request for additional staffing for customer engagement, citing no formal customer satisfaction surveys on reliability and reliance on performance metrics instead. NS Power also failed to provide cost-benefit analyses for existing digital programs like My Energy Insights.
s production plant accounts. Therefore, for the purposes of the current GRA, the Board also approves the settlement agreement adjustments to net salvage rates for NS Power's production plant accounts. [272] The Board also finds that the us...
AI summary The Nova Scotia Utility and Review Board approves adjustments to net salvage rates for NS Power's production plant accounts. It favors the ALG depreciation method over ELG, citing Mr. Madsen's asset service life recommendations. This shift would reduce depreciation rates by $45 million, lowering customer rates by 2% but potentially harming NS Power's cash flow, debt levels, and FFO:Debt metrics.
ll be used to determine rates and the revenue derived from rates will inform the value of the rate base). [403] Bonbright notes that out of this criticism sprung the cost-based approach to valuation: Impressed with the force of the vicious...
AI summary The text discusses Bonbright's argument for a cost-based approach to rate base valuation, emphasizing administrative efficiency and capital access. It critiques value-based approaches as flawed, advocating instead for original cost rate bases to avoid circularity in rate-making and ensure fair return standards.
ower. Instead, it will allow for NS Power's recovery of prudently incurred costs while making the transition to increased renewables to 2030 and beyond more affordable for customers. [2023 NSUARB 12] [426] The decision strikes a balance be...
AI summary The NSUARB decision balances NS Power's cost recovery with customer affordability during the transition to renewables by 2030. It avoids sharp rate increases from accelerating asset depreciation or absorbing coal asset write-offs, which could harm NS Power's financial health and ultimately raise customer costs. The decision is referenced in a 2024 Alberta Law Review article on electrification and net-zero grid implications.
ovide all stakeholders with transparency around transfers to or from the DDA in any given year and the Board may choose to review any of these transfers. [NS Power Reply to Closing Submissions, p. 5] [74] Based on this, it is possible that...
AI summary The Board emphasizes transparency in DDA transfers but rejects mandatory prudence reviews for costs transferred to the DDA, aligning with the Public Utilities Act. NS Power's expenditures are presumed prudent, and the Department failed to meet the threshold to rebut this presumption due to insufficient evidence and general allegations.
lculated by the "zero-intercept" method whereby regression equations are run relating costs to various sizes of equipment and eventually solving for the cost of a zero-sized system (Sterzinger, 1981). What this last-named cost imputation o...
AI summary The text critiques the 'zero-intercept' method for calculating distribution system costs, arguing it ignores customer density and fails to correlate system area with customer numbers. It supports excluding minimum system costs from demand-related costs, as remaining costs may vary with peak load.
3.8.3.1 Findings [616] As with the discussion about the use of the minimum system method or the basic customer method, the Board finds that a more satisfactory resolution of this issue would result from a broader debate about this issue. T...
AI summary The Board directs a comprehensive analysis of distribution system cost classification, emphasizing the need for broader debate beyond jurisdictional scans. It expects issues identified by Ms. Palmer, including primary system usage, residential service at primary voltages, and demand relative to peak, to be thoroughly addressed in the proceeding.
6, pp. 127-130] [630] In its closing submissions, Port Hawkesbury Paper endorsed NS Power's testimony on this point. It also argued that the parties needed certainty and stability about these points: Based on the considerable record before...
AI summary Port Hawkesbury Paper (PHP) supports NS Power's position, opposing Synapse's recommendation to defer decisions on alternative Cost-of-Service Study (COSS) methodologies. PHP emphasizes the need for stability in COSS frameworks, citing Nova Scotia's historical approach to rate-class cost allocations.