Topic:"Cost Recovery" in M12550

5 Response IR-4: 6 7 (a-b) Please refer to the tables below for the calculation of Labour and Contractor AO. The 8 calculation is the total labour costs by charge type multiplied by the Labour AO rate for 9 the year.

AI summary The response provides a reference to tables containing the calculation of Labour and Contractor AO, which involves multiplying total labour costs by the Labour AO rate for the year.

(i) Please identify all external parties whose advice or services informed the Contracts cost estimate (e.g., engineering consultants, installation contractors, OEMs), and for each, provide the relevant statements of work, proposals, rate...

AI summary The request asks for identification of external parties and internal groups involved in developing the Contracts cost estimate, along with documentation and explanation of how inputs were translated into final line-item amounts.

Review of C0051815 - RTU Replacements Program - Phase 6 (NSEB M12550) NSPI Responses to NSEB Information Requests 1 estimated hours or PD, labour rates, unit rates, and any mark‑ups or 22 request-for-quote process, along with representativ...

AI summary The document outlines NSPI's responses to NSEB information requests regarding the RTU Replacements Program - Phase 6, including details on cost estimation processes involving internal expertise, external vendor input, and labour rate calculations.

NON-CONFIDENTIAL Phase 6 Regular Overtime Total Average hours per RTU SM Electrician 240 0 240 Electrician/Technician (overtime) 0 64 64 Engineering 431 0 431 Telecontrol Technologist 182 0 182 PLT-Field Resources 160 0 160 RTU Technician...

AI summary The document outlines a table showing labor hours for various roles in Phase 6 of the RTU Replacements Program and includes information requests from the NSEB regarding updates to the 2025 ACE Plan application, including cost reductions, completed work, in-service dates, and lessons learned.

1.2 Report Structure - Midgard evaluates NSPI's rationale for proceeding with the Project, focusing on whether the justifications are - adequately supported by evidence from the application and NSPI's responses to subsequent Information -...

AI summary Midgard evaluates NSPI's rationale for proceeding with the Project, focusing on whether the justifications are adequately supported by evidence from the application and NSPI's responses to Information Requests (IRs). The report is structured into sections that review project context, execution strategy, project controls, cost reasonableness, and appendices with supporting data.

5 3.1.1 Conclusions – Installation Prioritization and Sequencing - 6 The installation sequence does not appear optimized to maximize work crew efficiency through progressive - 7 skill development. While NSPI employs process optimizations s...

AI summary The installation sequence for the Program is not optimized for maximizing work crew efficiency through progressive skill development. While NSPI uses process optimizations, the installation schedule is driven by risk mitigation rather than productivity gains. A learning-curve approach could improve efficiency and reduce costs, but the lack of Program-level productivity metrics makes it difficult to assess whether prior efficiency gains are being incorporated into Phase 6 estimates.

NSPI also argues that: "The greater emphasis on pre-work, detailed planning and QA (Quality Assurance) enhancements have resulted in more efficient installation and commissioning work with greater predictability of time required and reduce...

AI summary NSPI claims that pre-work and QA improvements have increased efficiency and predictability in installation and commissioning. However, no empirical data is provided to support these claims, and historical baseline data was lost in a cyber incident, making it impossible to verify efficiency gains or track process improvements from prior phases.

8 3.2.1.2 Quantification & Measurement 1 Project management frameworks emphasize quantitative performance metrics as essential for validating process improvements. NSPI's reliance on qualitative assessments (e.g., "greater predictability,...

AI summary NSPI's use of qualitative assessments limits the ability to demonstrate measurable productivity gains and cost efficiencies from standardization efforts. Financial data from prior Program Phases show mixed results, with significant variances and an increase in contingency allowances, despite claims of improved estimating methodology.

3.2.1.3 Adaptive Learning in Phase 6 - Despite these historical gaps, NSPI has demonstrated adaptive learning and improved cost control mechanisms - within Phase 6 itself. The most significant evidence of this is the approximate $900,000 c...

AI summary NSPI has demonstrated adaptive learning in Phase 6, leading to a $900,000 cost reduction after completing the first two sites. The Project team is using real-time data to refine estimates, such as adjusting labour allocation for the Project Manager who supports multiple projects.

3.2.2 Conclusions – Process Standardization & Cost Reduction - NSPI asserts it leveraged prior experience to implement tangible standardization in vendor selection, - technology platforms, labour role definition, and quality assurance proc...

AI summary NSPI claims that process standardization and operational refinements have improved execution consistency, but the lack of formal reviews, quantitative metrics, and discrepancies in budget estimates obscure the effectiveness of these measures in achieving cost reduction for RTU replacement activities.

1 Table 9: Project Execution Strategy Conclusions Report Section Question Midgard Commentary 3.1 Has NSPI optimized the Project's execution by prioritizing installations based on criticality, complexity, or opportunities for learning-curve...

AI summary The document evaluates NSPI's project execution strategy, noting that prioritization is based on asset criticality and risk rather than complexity or learning-curve benefits. It also questions whether NSPI effectively leveraged prior experience to standardize designs and reduce costs, citing a lack of formal lessons-learned reviews and quantitative metrics as limitations.

4.1 Delivery Model Justification - NSPI's Capital Expenditure Justification Criteria (" CEJC ") mandates the "Evaluation of alternative means of acquiring technologies including design and build (NSPI owned)... or contract to others," and...

AI summary NSPI's Capital Expenditure Justification Criteria (CEJC) require evaluating alternative delivery models using financial metrics like NPV, but no such analysis was performed for Phases 1 to 6 of the Program. NSPI instead relied on qualitative justifications and internal resource availability, despite capacity constraints driving the decision to use external contractors.

13 4.2 Estimate Basis and Risk Quantification - 14 NSPI's methodology supporting the Phase 6 estimate relies on qualitative expert judgment rather than - 15 quantitative historical baselines, deviating from a strictly data-driven approach....

AI summary NSPI uses qualitative expert judgment rather than quantitative historical data for its Phase 6 estimate, classifying it as an AACE Class 3 Estimate. While this classification is technically supported, the lack of historical calibration and granular data from previous phases increases uncertainty. NSPI's contingency determination is based on qualitative risk assessments rather than quantitative modeling.

3 4.3 Overall Project Prudence & Ratepayer Interest - 4 The following summarizes Midgard's conclusions from the review of the Project: - 5 1. Delivery Model Justification: NSPI defaults to an internal resource model for core execution with...

AI summary Midgard's review of the Project highlights concerns with NSPI's delivery model and estimate basis. NSPI did not conduct a comparative financial analysis for internal resource allocation, and the Phase 6 estimate lacks historical data calibration, relying instead on judgment rather than probabilistic risk modeling.

5 ASSESSMENT OF COST REASONABLENESS - 2 This section evaluates the reasonableness of NSPI's cost estimate for the Project to determine whether the - 3 proposed expenditure represents a prudent allocation of ratepayer funds, considering the...

AI summary This section assesses the reasonableness of NSPI's cost estimate for the Project, focusing on whether the proposed expenditure is prudent. It examines increases in labor requirements, equipment and material costs, and indirect cost components to ensure appropriate cost recovery and value for ratepayers.

9 5.2.1 Conclusions – Material Procurement & Cost Competitiveness NSPI utilized appropriate competitive tendering processes for major equipment and leveraged established service agreements for labour and civil works, ensuring pricing refle...

AI summary NSPI used competitive tendering for major equipment and service agreements for labour and civil works, ensuring current market pricing. Cost variances are justified by increased functional requirements and macroeconomic factors like inflation and currency devaluation. The material costs represent reasonable value for enhanced functionality.

16 Table 16: Summary of Findings – Material Procurement and Cost Competitiveness Report Section Question Midgard Commentary 5.2 Has NSPI demonstrated that equipment and material costs reflect competitive procurement practices and represent...

AI summary The document confirms that NSPI has demonstrated competitive procurement practices and reasonable value for equipment and material costs, supported by competitive tendering and justified cost variances due to functional increases and inflation.

Table 17: Comparative Overhead Rates (Internal vs. Contractor)[73](#page-34-1) Year Internal Labour AO Rate Contractor AO Rate 2024 57.79% 15.27% 2025 56.63% 14.46% 2026+ 53.98% 10.45% - To mitigate ratepayer burden during periods of high...

AI summary The document presents comparative overhead rates for internal and contractor labor from 2024 to 2026, highlighting a significant difference between the two. It also mentions an adjustment for overtime labor to mitigate ratepayer burden during high resource utilization periods.

1 Table 18: Summary of Findings – Indirect Cost Allocation & Transparency Report Section Question Midgard Commentary 5.3 Are indirect cost components (including administrative overhead allocations, vehicle and travel loadings, and capitali...

AI summary The document discusses the transparency of indirect cost components, including administrative overhead, vehicle and travel loadings, and capitalized financing costs. It confirms that these components are calculated using transparent methodologies consistent with approved accounting policies, with measures such as a 50% reduction in overhead on overtime labour to minimize burden on ratepayers.

3 5.4 Overall Project Prudence & Ratepayer Interest - 4 The following summarizes Midgard's conclusions from the review of the Project: - 5 1. Labour Hour Escalation and Scope Justification: The filed labour estimate of 1,939 hours per RTU...

AI summary Midgard's review of the Project highlights concerns with the labour estimate, noting insufficient evidence for the 1,939 hours per RTU. It recommends a 30% reduction in labour hours and enhanced reporting requirements. Material costs are deemed reasonable, and indirect cost allocation is considered prudent.

7 Table 19: Assessment of Cost Reasonableness Conclusions Report Section Question Midgard Commentary 5.1 Are the substantial increases in labour requirements per RTU substantiated by objective evidence of expanded scope, infrastructure com...

AI summary The document assesses the reasonableness of costs for a project, with Midgard commenting that while NSPI's complexity drivers are valid, the substantial increase in labor requirements per RTU is not fully substantiated. A 30% reduction in labor hours is recommended. Equipment and material costs are deemed reasonable due to competitive procurement, and indirect cost components are calculated using transparent methodologies.

5 Table 20: Summary of Conclusions Report Section Question Midgard Commentary 5.2 Has NSPI demonstrated that equipment and material costs reflect competitive procurement practices and represent reasonable value relative to market condition...

AI summary The document confirms that NSPI has demonstrated competitive procurement practices and reasonable value for equipment and material costs. It also verifies that indirect cost components are calculated using transparent methodologies that ensure appropriate cost recovery without undue burden on ratepayers.

A.1 Methodology - The allocation methodology applies a conservative benchmarking approach. Following review of ECS and SOD documentation for all fourteen sites, the three sites with - complete IFC packages (91V Fourth Lake Hydro, [77](#pag...

AI summary The document outlines a methodology for allocating labour based on the workload derived from IFC packages at selected sites, scaling labour proportionally to signal scope and accounting for travel time based on site presence. This approach was applied to evaluate engineering, design, and commissioning activities across multiple sites.

Request IR-1: - Reference : With respect to Midgard's statement that NS Power's execution strategy uses - "sequential execution" (p. 13) and that: - The installation sequence does not appear optimized to maximize work crew efficiency throu...

AI summary Midgard is asked to evaluate NS Power's use of sequential execution in the RTU Replacements Program, including its impact on operational efficiency, cost, and scheduling. The inquiry also explores whether earlier filing or alternative execution strategies could have reduced costs and improved efficiency.

Request IR-4: - Reference : With respect to Midgard's recommendation (p. 36) stating, "Midgard recommends a - 30% reduction in labour hours to align the estimate with reasonable productivity levels supported - by technical documentation":...

AI summary Request IR-4 seeks clarification on Midgard's recommendations regarding labour hour reductions, overtime, contingency costs, and overhead rates. It asks for revised project budgets, explanations of discrepancies, and insights into how Midgard evaluated contractor and internal labour productivity.

Midgard Response IR-4: a) i. Based on the revised labour analysis, aligning NSPI's estimated labour hours to the 1,291 hours supported by technical documentation yields an average direct cost of $88,327 per RTU. This represents a 33.4% red...

AI summary Midgard recommends a 30% reduction in NSPI's estimated labour costs for RTUs, citing a 33.4% reduction based on revised labour hours. The revised budget excludes overhead adjustments and travel expenses, and contingency funds are not intended for systematic overtime.

Midgard Response IR-5: - a) Midgard assesses the 10% contingency as a matter of cost reasonableness, utilizing NSPI's non- binding guidelines as an industry reference for Class 3 estimating practices rather than conducting a compliance aud...

AI summary Midgard assesses the 10% contingency as a matter of cost reasonableness, referencing NSPI's non-binding guidelines for Class 3 estimating practices. It also discusses the implications of the Board accepting or rejecting a 30% labour reduction and confirms its engagement scope.

Midgard Response IR-6: - a) Midgard's finding regarding the absence of formal lessons-learned assessments was documented as a risk observation. [13](#page-12-0) Midgard limited its formal recommendations to adjusting the labour hour estima...

AI summary Midgard's response to IR-6 highlights a risk observation regarding the absence of formal lessons-learned assessments. Midgard's recommendations focus on adjusting labour hour estimates and enhancing reporting requirements to ensure cost reasonableness in the proceeding.

supported by technical documentation." - (a) Please confirm that applying the recommended 30% reduction in labour hours would reduce the prudent capital cost for the project. If not, please explain. - (b) With reference to the revised esti...

AI summary The text contains three questions requesting confirmation and recalculations related to a project's prudent capital cost, specifically addressing a 30% reduction in labour hours, revised estimates, and adjustments to overhead, contingency, and AFUDC.

Midgard Response IR-3: a) Midgard confirms that a 30% reduction in labour hours will reduce the total capital cost of the Project. As stated in Section 5.1.1 at page 32 of its Evidence Report: "Considering the lack of comparative data prov...

AI summary Midgard recommends a 30% reduction in labour hours to align capital cost estimates with a technically supportable baseline. The labour subtotal from NSPI's budget is $1,411,802, excluding non-labour items. The prudence of capital costs is determined by the Board.

1 Although key personnel as compared to Phase 1 work are no longer with the Company, consistent 2 personnel have been assigned to this work for the past several Phases; this ensures that learnings 3 and execution efficiencies are maintaine...

AI summary NS Power argues that its project execution and prioritization are prudent and informed by asset management and institutional knowledge. However, the Midgard Evidence questions the empirical validation of efficiency gains and cost reductions, citing a lack of formal lessons-learned reviews and historical baseline data due to a cyber incident.

1 more remote sites in later phases, and the updated estimate includes more granular separation of 2 vehicle-related costs from general travel expenses. 3 4 Midgard provides the following regarding prior phase estimation accuracy: 5 6 Fina...

AI summary The document discusses the accuracy of cost estimates for the RTU Replacement Program, noting mixed results from prior phases. While five of six phases were completed under budget, significant variances occurred. The underspend in Phase 5 is attributed to the incomplete 106W Pubnico Point Windfarm RTU. NS Power's estimating approach is deemed generally prudent, with Phase 6 estimates informed by recent actuals from Phase 5.

13 Exhibit N-3, Midgard Evidence, February 18, 2026, page 39. 1 2 The reduction in Project Management hours indicates an optimization of overhead resources, shifting from a dedicated resource model to a shared resource model. 3 Similarly,...

AI summary The text discusses adjustments in project management and civil construction costs, noting a shift to a shared resource model and site-specific cost adjustments. NS Power disagrees with Midgard's assertion that initial estimates were too high, arguing that the changes reflect prudent cost control. NS Power agrees with Midgard's conclusions on procurement practices and indirect cost methodologies.

1 2 3.2 Enhanced Reporting Requirements 3 4 The Midgard Evidence provided the following recommendation regarding future reporting 5 requirements: 6 7 Direct NSPI to (i) reconcile assumed installation durations to site-specific technical 8...

AI summary NS Power acknowledges the Midgard Evidence recommendations for enhanced reporting but argues they are forward-looking governance suggestions rather than findings of imprudence. While some data was lost due to a cyber incident, NS Power had previously tracked and plans to rebuild necessary information for future phases.

[[email protected]](mailto:[email protected]) Lana Myatt Manager, Regulatory Capital Nova Scotia Power Inc. PO Box 910 1223 Lower Water Street Halifax, NS B3J 3S8 Dear Ms. Myatt: M12550 – To obtain a cost reasonableness review of N...

AI summary This document is a request for a cost reasonableness review of Nova Scotia Power Inc.'s RTU Replacements Program – Phase 6, as outlined in Section 2.1 of the 2025 Annual Capital Expenditure Plan decision (M12012), with a total cost of $5,959,515.

1. Introduction An RTU refers to a Remote Terminal Unit, a microprocessor-controlled field device that collects data from field equipment and sends or receives information to and from a central control system (SCADA) for process control. N...

AI summary NS Power proposed Phase 6 of the RTU Replacements Program in the 2025 ACE Plan, but the Board did not approve it due to insufficient justification for increased labour hours. The Board engaged Midgard Consulting Inc. to review the project and assess the reasonableness of costs, with various stakeholders submitting evidence and responses throughout the proceeding.

- An approximate $900,000 budget reduction following just two completed Phase 6 sites suggests that initial estimates either did not rely on available historical efficiency Document: 331396 - data, or the historical data was not relevant,...

AI summary The document discusses a budget reduction of approximately $900,000 following the completion of two Phase 6 sites, suggesting initial estimates may have been inaccurate. Labour estimates for the project were found to be 33% higher than what Midgard considers appropriate, based on technical documentation. Disputes over installation duration and lack of task-level traceability are cited as reasons for the variance.

NS Power Rebuttal Evidence – Exhibit N-7: - NS Power's capital investment decisions are grounded in asset management principles, as outlined in Section 6.2 of the Board-approved Capital Expenditure Justification Criteria (CEJC). This frame...

AI summary NS Power explains its capital investment decisions are based on asset management principles and the Board-approved CEJC. The company highlights variability across sites and acknowledges challenges in baseline data due to a cyber incident. NS Power also emphasizes accurate cost estimates and adaptive cost management in its December 2025 filing.

From: [Painting-MacLean, Kimberly](mailto:[email protected]) To: [Painting-MacLean, Kimberly](mailto:[email protected]) Subject: FW: M12550 - To obtain a cost reasonableness review of NS Power -...

AI summary This email discusses a cost reasonableness review of NS Power's Replacements Program – Phase 6, as outlined in Section 2.1 of the 202 ACE Plan Decision (M12012). The matter is referenced as M12550.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION BY NOVA SCOTIA POWER INCORPORATED To obtain a cost reasonableness review of NS Power - CI C0051815 – $5,959,515 - RTU Replacements...

AI summary This document pertains to a cost reasonableness review application by Nova Scotia Power Incorporated under the Public Utilities Act, concerning the RTU Replacements Program – Phase 6, with a total cost of $5,959,515, as outlined in the 2025 Annual Capital Expenditure Plan decision (M12012).

- b) For each variance identified in Part (a), please explain whether the change is attributable to: - i. A change in measurement Unit (e.g., from Days to PD); - ii. A change in Quantity (with quantification of the delta); - iii. A change...

AI summary The document requests detailed explanations regarding variances in cost estimates, breakdowns of specific costs such as vehicle overhead, and the calculation methodology for AFUDC in capital cost estimates. It also asks for comparisons between original and updated estimates and clarification on assumptions related to AFUDC.

M12550 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION BY NOVA SCOTIA POWER INCORPORATED To obtain a cost reasonableness review of NS Power - CI C0051815 – $5,959,515 - RTU Repla...

AI summary The Nova Scotia Energy Board has requested non-confidential information related to NS Power's RTU Replacements Program – Phase 6, which involves replacing fourteen RTUs and associated equipment from 2025 to 2027. The information is needed for a cost reasonableness review under the Public Utilities Act.

1. Please provide the methodology used to develop the Class 3 Estimate. For example, is the estimate based on historical data or NSPI’s prior RTU replacement experience? 2. Please confirm if the methodology used to develop the Class 3 Esti...

AI summary The text contains a series of questions directed at Nova Scotia Power (NSP) regarding the methodology and contingency usage in RTU replacement projects across multiple phases. It seeks details on historical data usage, differences in methodology, contingency usage breakdowns, and productivity tracking and its impact on Phase 6 estimates.

ficant labor cost variances, identifying how differences in equipment scope, site conditions, installation methodology, or commissioning/testing requirements contributed to the labor estimate changes. At Attachment 1 of the letter filed by...

AI summary The document discusses labor cost variances in a capital project, including internal and contractor labor administrative overhead (AO) costs, and requests detailed breakdowns of these costs. It also references an updated Capital Project Cost Estimate and compares methodologies used in different estimates.

1. Please provide a comparison of the original Capital Cost Detailed Estimate as filed in Exhibit N-1 versus the updated Capital Cost Detailed Estimate included in NS Power's letter dated December 9, 2025, in the form of an Excel spreadshe...

AI summary The document requests a detailed comparison of original and updated capital cost estimates, explanations for variances, breakdowns of specific costs, and clarification on AFUDC calculations. It emphasizes transparency in cost changes, categorization, and assumptions related to capital expenditures.

1 Request IR-1: 2 With respect to Midgard's statement that NS Power's execution strategy uses "sequential 3 execution" (p. 13) and that: 4 5 The installation sequence does not appear optimized to maximize work crew 6 efficiency through pro...

AI summary The document includes a request to Midgard for their opinion on NS Power's execution strategy for the RTU Replacements Program, including the use of sequential execution, phased implementation, and potential cost reductions through earlier filing and operational efficiency improvements.

1. On p. 18, Midgard finds that, “Overtime Labour rose by approximately 228%, indicating a materially higher reliance on premium hours relative to historical norms.” On p. 25, Midgard quotes NS Power as stating that, “Risks intended to be...

AI summary The text discusses concerns raised about overtime labour costs and contingency planning in a project budget, requesting a revised budget that incorporates a 30% reduction in labour hours, prioritizing the reduction of overtime hours. It also questions the methodology used by Midgard in comparing estimates and contingency cost assumptions.

8 Request IR-3: 9 Reference: Page 39, Midgard Commentary on Report Section 5.1. "While NSPI identifies valid complexity drivers, the specific magnitude of labour increases remains unsubstantiated. A 33% variance exists between NSPI's filed...

AI summary The Midgard Commentary questions the validity of NSPI's labour cost estimates, noting a 33% variance between NSPI's estimate and an independent allocation. Midgard recommends a 30% reduction in labour hours, prompting a request for confirmation of the impact on prudent capital costs, clarification of the labour subtotal, and a full recalculation of the project's total cost.

1. 1. At page 11, Midgard states it assessed “whether the Project, as proposed, is justified, reasonable, and aligned with regulatory expectations for prudent utility investment”. Please explain what Midgard considers to be NSEB “regulator...

AI summary Midgard evaluated the Project's prudence and alignment with regulatory expectations, identifying a 33% variance in labour estimates. It recommended a 30% reduction in labour hours for cost reasonableness. Questions are raised about the impact of this reduction on prudent capital costs, the labour subtotal used, and a full recalculated total.

VIA WEB PORTAL VIA EMAIL Crystal Henwood, Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Dear Ms. Henwood: Re: M12550 - To obtain a cost reasonableness review of N...

AI summary The Consumer Advocate submits materials related to a cost reasonableness review of NS Power's RTU Replacements Program, with a total cost of $5,959,515, under matter M12550.

Background This proceeding arises from the Nova Scotia Energy Board's decision concerning the 2025 Annual Capital Expenditure (ACE) Plan (M12012), where the Board stated its intention to engage an expert to review the scope of project CI C...

AI summary This proceeding concerns the Nova Scotia Energy Board's review of NS Power's 2025 Annual Capital Expenditure (ACE) Plan, specifically the RTU Replacements Program Phase 6, which involves replacing outdated remote terminal units across Nova Scotia. Midgard Consulting Inc. was commissioned to assess the reasonableness of the estimated project costs, which were later reduced by $0.90M.

the factual record of the report and enable direct empirical comparison with Phase 1 data." As this information was not provided, there would appear to be somewhat of an evidentiary gap on this point. In the absence of a technical comparis...

AI summary The Consumer Advocate agrees with Midgard's findings that NS Power's labour estimate has a 33% variance compared to technically supported data, suggesting a 30% reduction in labour hours. However, NS Power argues that certain activities, such as SM Electrician and Engineering tasks, may account for this variance, though it does not quantify them.

The CA states that it: …acknowledges NS Power's assertion that Midgard's assessment appears not to have taken into account certain activities which NS Power says "drive significant labour hours," including various SM Electrician and Engine...

AI summary The Consumer Advocate acknowledges NS Power's assertion that Midgard's assessment may have overlooked certain labor-intensive activities but notes that NS Power has not quantified these activities or shown they account for the 33% variance. The CA suggests a reasonable reduction in Midgard's range is supportable.

Enhanced Reporting The SBA states: …the SBA also respectfully requests that the Board require NS Power to report after the completion of this project on lessons learned (as highlighted by Midgard in their Report, notably the labour hours r...

AI summary The SBA requests NS Power to report on lessons learned and potential revisions to the CEJC and PDM after project completion. NS Power argues these recommendations are for internal governance improvements, not mandatory reporting requirements, and that lessons learned will be documented under existing PDM requirements.

- An approximate $900,000 budget reduction following just two completed Phase 6 sites suggests that initial estimates either did not rely on available historical efficiency Document: 331396 - data, or the historical data was not relevant,...

AI summary The document discusses a budget reduction of approximately $900,000 following the completion of two Phase 6 sites, suggesting initial estimates may have been inaccurate or based on irrelevant data. It also highlights discrepancies between NS Power's labour estimates and those recommended by Midgard, with a 33% variance and a recommended 30% reduction in labour hours.

NS Power Rebuttal Evidence – Exhibit N-7: - NS Power's capital investment decisions are grounded in asset management principles, as outlined in Section 6.2 of the Board-approved Capital Expenditure Justification Criteria (CEJC). This frame...

AI summary NS Power's rebuttal evidence highlights its capital investment decisions based on asset management principles and the variability in project complexity. It acknowledges challenges in evidencing baseline data post-cyber incident but notes accurate estimating and cost management practices, as reflected in its amended cost estimate from December 2025.