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.
(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.