N-4NSPI (REI) RIR 1 to 22
4 passages
1 Request IR-3: 2 3 Reference: N-1, C0053699 Renewable to Retail Implementation Project, page 1 of 6. 4 5 Cost recovery for capital expenditures and operating costs associated with the 6 initial setup and ongoing operation will be recovere...
AI summary The document outlines a request for information regarding the cost recovery framework for the Renewable to Retail (RTR) Implementation Project, specifically focusing on capital expenditures and operating costs associated with the project, and how these costs will be recovered from Licensed Retail Suppliers (LRSs) through the Annually Adjusted Rates (AAR) process starting in 2026.
Interest to be compounded Beginning Balance Additional costs deferred (001.180450.000.0000.000.000.0000.000) 786,053 786,053 786,053 786,053 786,053 786,053 786,053 786,053 786,053 786,053 786,053 786,053 (185.50) 785,867 785,867 785,867 7...
AI summary The document presents a financial table showing the beginning balance, additional costs deferred, ending balance prior to interest recovery, compounded interest, and total including compounded interest. The values remain consistent across multiple columns, indicating a structured approach to financial calculations and interest recovery.
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 PDF Attachment PDF Copy of Form Copy of the signed PDF with the customer action request Document Upload PDF only PDF only Yes 1 Request IR-18: 2 3 Please confi...
AI summary The document includes a request and response regarding NSPI's recovery of regulatory hearing costs and a reference to a matter number related to the vintage of the Customer Information System. The response indicates that NSPI has historically sought recovery of these costs incrementally, but this approach may need reconsideration as the RtR framework evolves.
102536Decision
13 passages
- [1] On December 1, 2025, Nova Scotia Power Incorporated asked the Nova Scotia Energy Board to approve a capital project to develop and implement updates and enhancements to existing software solutions to facilitate the "renewable to reta...
AI summary Nova Scotia Power Incorporated requested approval for a capital project to update software and business processes to support the renewable to retail market. The project, costing $5.6 million, was deemed necessary by the Board despite concerns about cost recovery and transparency. Renewall Energy Inc. raised some concerns, but the Board found them speculative and approved the project.
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.
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.
3.2.6.1 Findings [90] Once again, the Board believes it would be inappropriate to predetermine this issue. If rework is needed, despite NS Power's assurances, whether the costs for that should be borne by the renewable to retail market, NS...
AI summary The Board finds it inappropriate to predetermine the issue of cost allocation for rework, suggesting that the responsibility should be determined based on the specific circumstances when these costs arise.
3.2.7 Stranded Costs from Market Evolution [91] Renewall submitted that if the Nova Scotia Independent Energy System Operator (IESO Nova Scotia) assumes the administration of the renewable to retail market, it is unclear whether assets dev...
AI summary Renewall expressed concern that a potential transfer of assets to IESO Nova Scotia could lead to stranded costs due to market structure changes. NS Power acknowledged the uncertainty but stated that the regulatory framework would prevent duplicate cost recovery.
3.3.2 Annual Certification [98] As the (currently) sole licensed retail supplier and party responsible for the payment of costs arising from the approval of the proposed capital project, Renewall submitted that NS Power should be required...
AI summary Renewall proposed that NS Power must file annual certifications to ensure renewable to retail project assets are used appropriately and prevent cost misallocation. NS Power countered that such processes are unnecessary as project costs are tracked separately and subject to Board review in the Annually Adjusted Rates process.
3.3.2.1 Findings [100] Given the development of markets and market complexity in Nova Scotia, the Board shares Renewall's concern. If the cost of this capital project is being charged to the renewable to retail market, then any future use...
AI summary The Board agrees with Renewall's concern regarding the allocation of costs for a capital project in Nova Scotia's renewable to retail market. It directs NS Power to start an annual certification process to ensure proper cost allocation and recovery, beginning after Renewall's first customer sale and continuing until costs are fully recovered.
3.4 Cost Recovery [101] The Small Business Advocate also expressed concern about a level of uncertainty around the recovery of these costs from the renewable to retail market. This concern was shared by the Consumer Advocate who noted that...
AI summary The Small Business Advocate and Consumer Advocate raised concerns about the uncertainty of cost recovery from the renewable to retail market, with the latter attributing cost variances to Renewall. Renewall argued that costs should not be tied to a 10-year depreciation life but to actual market use. NS Power plans to propose a cost recovery methodology in its 2027 Annually Adjusted Rates application.
3.4.1 Findings [104] The issues relating to cost recovery are matters for a future Board proceeding. As NS Power noted in this matter, the Nova Scotia Utility and Review Board initially contemplated these issues would be addressed in Annua...
AI summary The Board notes that cost recovery for the renewable to retail market should be addressed in a future proceeding. While the Annually Adjusted Rates process was initially considered, the Board is concerned about its appropriateness due to the complexity of the issues involved. If new mechanisms or tariff language are needed, a separate process may be required.
4.0 SUMMARY OF BOARD FINDINGS [107] The Board finds the proposed project is necessary and approves the proposed cost of $5,644,468. [108] The Board also directs NS Power to begin the annual certification process confirming that assets fund...
AI summary The Board approves a $5,644,468 project and requires NS Power to annually certify that project assets are used solely for renewable to retail purposes. Certification must begin after Renewall's first customer sale and continue until project costs are recovered or further directed by the Board.
100720REI (NSPI) IR 1 to 22 - PDF
4 passages
1 2026 M12588 2 3 NOVA SCOTIA ENERGY BOARD 4 IN THE MATTER OF: The Public Utilities Act 5 6 7 IN THE MATTER OF: An Application by Nova Scotia Power Incorporated for approval of CI C0053699 Renewable to Retail Implementation $5,644,468 8 9...
AI summary The Nova Scotia Energy Board is handling an application by Nova Scotia Power Incorporated for approval of a Renewable to Retail Implementation Project. Renewall Energy Inc. has submitted information requests regarding the project team, detailed requirements, customer transition mechanisms, and cost recovery processes.
30 (a) Please confirm whether NSPI intends to recover all the RtR Implementation 31 Project costs incurred under capital application C0053699 through the AAR 1 process. 2 3 (b) If any portion of the costs will not be recovered through the...
AI summary The text requests confirmation on whether NSPI intends to recover all costs from the RtR Implementation 31 Project through the AAR, and if not, how these costs will be recovered. It also asks for details on the cost recovery framework, legacy costs, and the timing of the first AAR filing.
23 Please confirm whether NSPI is seeking recovery of its own regulatory hearing costs (internal and 24 external legal, consulting, expert witness costs) associated with this RtR capital application and 25 other RtR applications? 1 RtR imp...
AI summary The text discusses the implementation scope and cost estimate of the Renewable to Retail (RtR) project, including questions about regulatory hearing costs, changes in assumptions due to a cybersecurity incident, and coordination with the CIS Replacement project. It also requests documentation on project planning and cost adjustments due to changes in the project's completion date.
27 1 Request IR-19: 20 21 22 23 (c) Please advise whether NSPI has conducted any analysis estimating what portion of the $5.6M project cost might be avoided or reduced if NSPI had a modern, cloud-native CIS platform, and if so, please prov...
AI summary The text outlines several requests and references related to a regulatory proceeding, including an inquiry about potential cost savings from a modern CIS platform, an explanation for an increase in AFUDC, and questions regarding AO rates and their application. It also references prior proceedings and documents.
101270Submission - REI
7 passages
ISSUES REI identifies the following issues for the Board's consideration: - 1. Whether NSPI has demonstrated the prudency of the costs claimed in the Application, including costs arising from project delays; - 2. Whether the Application co...
AI summary REI presents four key issues for the Board's consideration, including the prudency of NSPI's costs, compliance with CEJC, adequacy of cost recovery evidence, and sufficiency of the proposed reporting framework and approval conditions.
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.
b) Scalability Costs NSPI claims that scalability costs are "low and not considered material", that "the MDMS architecture is such that additional computational capability can be added in the future, if required, when additional customers...
AI summary NSPI claims scalability costs are low and not material, stating additional computational capability can be added if needed. However, REI argues that without evidence or analysis, the Board cannot determine if these costs are embedded in the MDMS project figures, and recommends disallowing recovery unless NSPI provides documentation confirming no scalability costs are included.
c) CIS Replacement NSPI plans a CIS Replacement filing in Q3 2026 – CI C0021835. NSPI asserts that CIS RtR changes constitute core functionality and configuration that will carry forward to any future CIS replacement without incremental co...
AI summary NSPI plans to file a CIS Replacement in Q3 2026, asserting that changes to RtR functionality will carry forward without incremental cost. REI accepts this in principle but notes the lack of a migration or dependency plan. The Board is recommended to require NSPI to attest that any rebuild or remapping costs are not charged to REI.
3) Cost Recovery Methodology Section 22(2) (previously 3G(2)) of the Electricity Act is the statutory foundation for cost recovery in the RtR program. In responding to IRs, NSPI was unable to provide any clarity on any of: - The cost recov...
AI summary The document discusses the cost recovery methodology for the RtR program under the Electricity Act, highlighting NSPI's inability to clarify key aspects such as cost recovery mechanisms and allocation methodologies. REI argues against tying recovery to a fixed depreciation schedule and emphasizes the need for a methodology based on actual market use. NSPI outlines two scenarios for asset ownership and cost recovery, but uncertainty remains regarding future market developments and their impact on REI's customers.
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
6 passages
Cost Recovery The CA notes that the Application identifies a cost variance of $581,816, which NS Power attributes primarily to the need to ramp up project resources a second time as a result of changes to the Licensed Retail Supplier's (LR...
AI summary The CA notes a cost variance of $581,816 attributed to actions by the LRS, including changes to COD and increased costs. The CA is concerned about the risk of incomplete cost recovery if the LRS fails. The Board's decision in M11874 supports recovery through RtR tariffs, with NS Power planning to implement this in the 2027 AAR filing.
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.
MDMS Scalability and Cost Allocation REI notes NS Power's evidence that scalability costs under this project are immaterial and not included to support future LRSs and that any future scalability requirements would be addressed and allocat...
AI summary REI argues that NS Power's claims about MDMS scalability costs being immaterial lack supporting evidence and recommends disallowing certain costs unless NS Power provides documentation. NS Power counters that the project's scope was appropriately scaled to support RtR operations without unnecessary cost exposure and that any future scalability needs would be addressed in a regulatory proceeding.
Cost Recovery Methodology for RtR Implementation REI submits that NS Power has not yet provided clarity on the RtR cost recovery approach, including the recovery mechanism, allocation to future LRSs, which implementation costs would appear...
AI summary REI argues that NS Power has not provided sufficient clarity on the cost recovery approach for the RtR implementation, including how costs will be allocated to future LRSs and recovered through future AAR filings. REI also highlights the need to avoid redundant or stranded costs due to potential market structure changes. NS Power acknowledges uncertainty but asserts that the final recovery mechanism will be determined in the 2027 AAR proceedings.
esses, including system testing, training, business readiness confirmation, and internal approvals prior to proceeding to go-live. NS Power anticipates following these same processes for this project. As outlined in REI IR-16 and REI IR-21...
AI summary NS Power is following established processes for project implementation, including collaboration with REI and LRS. Demonstrations, testing, and training have been conducted to ensure readiness. NS Power asserts that existing mechanisms address prudence, incrementality, and cost segregation, making additional certifications unnecessary.
102536Decision
12 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.
3.2.1 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.
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.
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 Renewall's claims about delays and costs in the project are speculative and insufficient to challenge NS Power's incurred costs. NS Power's actions were reasonable in managing the project, and the delay in pausing the project was due to ongoing work. Renewall agreed to pause the project due to a deferred commercial operation date.
3.2.6 Customer Information System Replacement Project [88] Renewall noted that NS Power plans to replace its Customer Information System and expressed concern about the potential for rework associated with any of the development undertaken...
AI summary Renewall expressed concern about potential rework in NS Power's Customer Information System replacement project, urging the Board to require an attestation that no renewable to retail functionality is rebuilt or remapped. NS Power stated that core functionality, including renewable to retail features, is typically included in future upgrades and does not anticipate incremental rebuilding.
3.2.7 Stranded Costs from Market Evolution [91] Renewall submitted that if the Nova Scotia Independent Energy System Operator (IESO Nova Scotia) assumes the administration of the renewable to retail market, it is unclear whether assets dev...
AI summary Renewall expressed concern that a potential transfer of assets from NS Power to IESO Nova Scotia could lead to stranded or redundant costs, requesting the Board to confirm no duplication of costs would occur. NS Power acknowledged the possibility of evolving cost recovery approaches but emphasized that the regulatory framework prevents duplicate recovery of the same costs.
3.3.2 Annual Certification [98] As the (currently) sole licensed retail supplier and party responsible for the payment of costs arising from the approval of the proposed capital project, Renewall submitted that NS Power should be required...
AI summary Renewall requests that NS Power file an annual certification to ensure project assets are used solely for renewable to retail purposes and that no costs are misallocated. NS Power argues such processes are unnecessary as costs are tracked separately and subject to Board review.
3.3.2.1 Findings [100] Given the development of markets and market complexity in Nova Scotia, the Board shares Renewall's concern. If the cost of this capital project is being charged to the renewable to retail market, then any future use...
AI summary The Board agrees with Renewall's concerns regarding the allocation of costs for a capital project in Nova Scotia's renewable to retail market. It directs NS Power to start an annual certification process to ensure proper cost allocation and recovery, beginning after Renewall's first customer sale and continuing annually.
3.4 Cost Recovery [101] The Small Business Advocate also expressed concern about a level of uncertainty around the recovery of these costs from the renewable to retail market. This concern was shared by the Consumer Advocate who noted that...
AI summary The Small Business Advocate and Consumer Advocate raised concerns about cost recovery from the renewable to retail market, attributing variances to Renewall. Renewall argued that costs should not be tied to a 10-year depreciation life but to actual market use. NS Power plans to propose its cost recovery methodology in its 2027 Annually Adjusted Rates application.
3.4.1 Findings [104] The issues relating to cost recovery are matters for a future Board proceeding. As NS Power noted in this matter, the Nova Scotia Utility and Review Board initially contemplated these issues would be addressed in Annua...
AI summary The Board notes that cost recovery issues for renewable to retail market implementation costs should be addressed in future proceedings. While initially planned for Annually Adjusted Rates proceedings, concerns about the appropriateness of this forum have been raised due to the complexity of the issues involved.
4.0 SUMMARY OF BOARD FINDINGS [107] The Board finds the proposed project is necessary and approves the proposed cost of $5,644,468. [108] The Board also directs NS Power to begin the annual certification process confirming that assets fund...
AI summary The Board approves a proposed project with a cost of $5,644,468, finding it necessary. It also directs NS Power to begin an annual certification process for assets funded through the project, ensuring they are used solely for renewable to retail purposes until the project costs are fully recovered.