Topic:"Cybersecurity" in M13042

they may wish to see, and we think that this risk is best managed by the parties involved in the lending transaction. For these reasons we decided to eliminate the equipment certification requirement. - 6. Local Benefits Requirement In the...

AI summary The document outlines changes to the Green Choice Program Power Purchase Agreement (GCP PPA), including the elimination of equipment certification requirements and the introduction of a Local Benefits Report and a Cybersecurity Plan requirement. These changes aim to manage risks and ensure local economic benefits and cybersecurity preparedness.

able, the Energy Bid will be prorated for any portion of a Contract Year. Contract Year – means a twelve-month period during the Term, starting on the Commencement Date or an anniversary thereof. Control – means (i) in relation to a Person...

AI summary The text defines key terms and concepts relevant to the Energy Bid, Contract Year, Control, Convention, CPI, and Cybersecurity Plan. These definitions are foundational for interpreting the agreement and regulatory requirements.

e Parties, NSPI shall have no property rights or interests with respect to the Project or the Site or any authority to affect or control any such activities which are the responsibility of the Seller. - (f) The Seller shall prepare a plan...

AI summary The Seller is required to prepare and submit a Cybersecurity Plan to the IESO, demonstrating compliance with NERC Critical Infrastructure Protection standards, at least six months before the Scheduled Commercial Operation Date. Failure to do so constitutes a Seller Event of Default and delays Commercial Operation.

2.4 Requirements for Commercial Operation (a) Notwithstanding the definition of "Commercial Operation Date" in the Generator Interconnection Agreement, the Facility will be deemed to have achieved " Commercial Operation " for the purposes...

AI summary The text outlines the requirements for a Facility to achieve Commercial Operation, including regulatory approvals, completion of construction, interconnection to the system, and submission of necessary reports. NSPI must confirm or contest the date of Commercial Operation within 10 business days of receiving notice from the Seller.

/span>(l) Commercial Operation has not occurred on or before the date which is 12 months after the Scheduled Commercial Operation Date (other than by reason of an occurrence of a Force Majeure Event). - (m) The Seller fails to obtain or ma...

AI summary The text outlines conditions for Seller Events of Default, including failure to achieve Commercial Operation within 12 months, failure to obtain or maintain Electricity Standard Approval, and failure to submit a Cybersecurity Plan by the deadline.

Cybersecurity Plan Submission Deadline is defined in Section 2.1(f). Daily Energy Bid – means, in respect of a Contract Year, the Energy Bid divided by the number of days in the Contract Year. Delivery Point – means the point of interconne...

AI summary The text defines key terms related to energy contracts and cybersecurity regulations, including the submission deadline for a cybersecurity plan, daily energy bid, delivery point, and dissolution event.

e Parties, NSPI shall have no property rights or interests with respect to the Project or the Site or any authority to affect or control any such activities which are the responsibility of the Seller. Infrastructure Protection standards pe...

AI summary The document outlines requirements for the Cybersecurity Plan related to the Project, which must be submitted to the IESO and NSPI six months before the Scheduled Commercial Operation Date. Failure to submit the plan on time constitutes a Seller Event of Default, and the Facility cannot achieve Commercial Operation until compliance with NERC Critical Infrastructure Protection standards is demonstrated.

2.4 Requirements for Commercial Operation - (a) Notwithstanding the definition of "Commercial Operation Date" in the Generator Interconnection Agreement, the Facility will be deemed to have achieved "Commercial Operation" for the purposes...

AI summary The document outlines the conditions for achieving commercial operation of a facility under the Generator Interconnection Agreement. Key requirements include approval from the Minister of the Environment, completion of the project, certification by an independent engineer, interconnection to the system, submission of a cybersecurity plan, and a local benefits report.

/span>(l) Commercial Operation has not occurred on or before the date which is 12 months after the Scheduled Commercial Operation Date (other than by reason of an occurrence of a Force Majeure Event). - (m) The Seller fails to obtain or ma...

AI summary This section outlines events of default related to the Seller's obligations under the agreement, including failure to achieve commercial operation within 12 months, failure to maintain Electricity Standard Approval, and failure to submit a Cybersecurity Plan by the deadline.

ship of securities or other interests entitling the holder to exercise direction over the activities of the Person (and " Controls ", " Controlling " and " Controlled " are defined accordingly). Convention – means United Nations Framework...

AI summary The text defines key terms and concepts relevant to the regulatory proceeding, including definitions of 'Control', 'Convention', 'CPI', 'Cybersecurity Plan', 'Daily Energy Bid', 'Delivery Point', and 'Dissolution Event', providing clarity for interpretation and application in the context of the proceeding.

s responsible for NSPI's reasonable legal expenses incurred in reviewing the Seller's request for consent in relation to any Project Amendment or any request for consent to amend the Commercial Terms. - (c) The Seller agrees to obtain and...

AI summary The document outlines the Seller's responsibilities regarding legal expenses, permits, interconnection, and cybersecurity for the Project. The Seller is responsible for design, development, construction, and compliance with NERC standards. Failure to submit a Cybersecurity Plan on time is considered a default.

2.4 Requirements for Commercial Operation - (a) Notwithstanding the definition of "Commercial Operation Date" in the Generator Interconnection Agreement, the Facility will be deemed to have achieved " Commercial Operation " for the purpose...

AI summary The document outlines the requirements for achieving Commercial Operation for a Facility under the Generator Interconnection Agreement. It includes conditions such as environmental approval, completion of the project, interconnection to the System, submission of a Local Benefits Report, and approval of the Cybersecurity Plan.

emedied within 30 days after written notice of such breach from NSPI or, if the breach cannot be remedied within such 30 day period, the Seller fails to demonstrate to the satisfaction of NSPI, acting reasonably, that the Seller is diligen...

AI summary This section outlines the conditions under which a Seller may be in default, including failure to remedy breaches within specified timeframes, failure to achieve Commercial Operation by certain dates, failure to obtain Electricity Standard Approval, and failure to submit a Cybersecurity Plan by the deadline.

APPENDIX D - SUMMARIZED STAKEHOLDER FEEDBACK ON PPA DRAFT #1 PPA Section Question Comment Response term is defined by the Generator Interconnection Agreement, has been achieved in respect of the interconnection The requirements for achievi...

AI summary Stakeholders provided feedback on PPA Draft #1, focusing on requirements for commercial operation, cybersecurity plans, local benefits reports, and equipment certification. Concerns were raised about the role of the IESO in reviewing cybersecurity plans and the adequacy of local benefits reporting. Equipment certification was removed due to lack of response from NSPI.

2.14 Cybersecurity Approach a) Proponents must as part of their Proposal submit a description of their approach to cybersecurity for the Project which should include applying best practices throughout the Project's life cycle and will cont...

AI summary The proposal requires proponents to submit a cybersecurity approach as part of their submission, emphasizing best practices throughout the project lifecycle to enhance grid resilience in Nova Scotia.

Cyber-security plan It seems prudent to require an IESO approved cybersecurity plan given NSPI's recent experience.

AI summary The text suggests that requiring an IESO-approved cybersecurity plan is prudent, citing NSPI's recent experience.

Section 2.1 – Design and Construction of the Project Section 2.1 (f) requires that Seller submits a Cybersecurity Plan to the IESO and NSP no later than six months prior to the Scheduled Commercial Operation Date. Section 2.1 (f) as well a...

AI summary The text discusses the requirement for the Seller to submit a Cybersecurity Plan to the IESO and NSP before the Scheduled Commercial Operation Date. It highlights concerns about the lack of a clear deadline for IESO's review and the potential delay in Commercial Operation, which could lead to default under financing agreements. The Seller proposes changes to Section 2.1 (f) and Section 2.4 to establish a 10-business-day review period and a deemed approval process.

r Approval of a Green Choice Power Standard Form Purchase Agreement (PPA) (the "Application") - Page 8 of 19, Paragraph 5. 2M13042, Exhibit P-l(i) -Appendix A- Green Choice PPA- Page 27, Section 2.7. Power Inc. (NSPI). What is NSPI expecte...

AI summary The document contains questions and concerns raised regarding the Green Choice Power Standard Form Purchase Agreement (PPA) involving Power Inc. (NSPI). Issues include the use of funds, the rationale for the Early Completion Incentive, the cybersecurity plan approval process, and concerns over the adequacy of information provided for the PPA's approval.

1 The previous Green Choice PPA had a Pre-COD Amount of $125,000/MW and post-COD Amount of $20,000/MW (Board order for M11455, dated June 6, 2024) Summary Stakeholder Comments Procurement Administrator Response 4. Cybersecurity It is prude...

AI summary The document discusses cybersecurity requirements and tariff adjustments in a regulatory proceeding. It references a previous Green Choice PPA with specific financial terms and mentions the need for an IESO-approved cybersecurity plan. Stakeholders have raised concerns about the feasibility of certain requirements, such as the Local Benefits Report, and the Procurement Administrator has responded regarding confidentiality and flexibility in proposal submissions.

11 https://www.novascotia.ca/sites/default/files/documents/1-3582/nova-scotia-clean-power-plan-presentation-en.pdf 7. Would a lesser term for the payment achieve the delivery of the project would be $57,487 ($75/MW h x 0.25 x 1 MW x 35% x...

AI summary The document discusses a payment term for a project, the cybersecurity plan review by IESO NS, and a request for an Energy Rate adjustment or no-fault termination right in a PPA. The SBA questions IESO's expertise and NSPI's authority to comment on the Cybersecurity Plan. Natural Forces requests adjustments to the PPA based on interconnection costs.

sed at: https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=1810000413. Cybersecurity Plan is defined in Section 2.1(f) Cybersecurity Plan Submission Deadline is defined in Section 2.1(f). Daily Energy Bid – means, in respect of a Contra...

AI summary The text defines key terms related to energy contracts and cybersecurity, including the Cybersecurity Plan, Daily Energy Bid, Delivery Point, Dissolution Event, Early Completion Incentive, and Early Termination Payment. These definitions are critical for interpreting the obligations and financial implications of the agreement.

e Parties, NSPI shall have no property rights or interests with respect to the Project or the Site or any authority to affect or control any such activities which are the responsibility of the Seller. - (f) The Seller shall prepare a plan...

AI summary The Seller is required to prepare and submit a Cybersecurity Plan to the IESO, meeting NERC Critical Infrastructure Protection standards, at least six months before the Scheduled Commercial Operation Date. Failure to do so will constitute a Seller Event of Default and delay Commercial Operation.

2.4 Requirements for Commercial Operation (a) Notwithstanding the definition of "Commercial Operation Date" in the Generator Interconnection Agreement, the Facility will be deemed to have achieved " Commercial Operation " for the purposes...

AI summary The document outlines the requirements for achieving commercial operation of a facility, including approvals from the Minister of the Environment, completion of the project, interconnection to the system, submission of a cybersecurity plan, and a local benefits report. NSPI must confirm or contest the date of commercial operation within 10 business days.

/span>(l) Commercial Operation has not occurred on or before the date which is 12 months after the Scheduled Commercial Operation Date (other than by reason of an occurrence of a Force Majeure Event). - (m) The Seller fails to obtain or ma...

AI summary This section outlines events of default by the Seller, including failure to achieve commercial operation within 12 months, failure to maintain Electricity Standard Approval, and failure to submit a Cybersecurity Plan by the deadline.

sed at: https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=1810000413. Cybersecurity Plan is defined in Section 2.1(f) Cybersecurity Plan Submission Deadline is defined in Section 2.1(f). Daily Energy Bid – means, in respect of a Contra...

AI summary The text defines several key terms related to energy contracts and cybersecurity requirements, including definitions for 'Cybersecurity Plan', 'Daily Energy Bid', 'Delivery Point', 'Dissolution Event', 'Early Completion Incentive', 'Early Termination Date', and 'Early Termination Payment'.

e Parties, NSPI shall have no property rights or interests with respect to the Project or the Site or any authority to affect or control any such activities which are the responsibility of the Seller. - (f) The Seller shall prepare a plan...

AI summary The Seller is required to prepare a Cybersecurity Plan to meet NERC Critical Infrastructure Protection standards, which must be submitted to the IESO and NSPI six months before the Scheduled Commercial Operation Date. Failure to submit the plan on time constitutes a Seller Event of Default and delays Commercial Operation until compliance is demonstrated.

2.4 Requirements for Commercial Operation - (a) Notwithstanding the definition of "Commercial Operation Date" in the Generator Interconnection Agreement, the Facility will be deemed to have achieved " Commercial Operation " for the purpose...

AI summary The document outlines the requirements for achieving Commercial Operation of a Facility under the Generator Interconnection Agreement. Key conditions include approval from the Minister of the Environment, completion of the project, certification by an Independent Engineer, interconnection to the System, submission of a Performance Security, approval of a Cybersecurity Plan by the IESO, and submission of a Local Benefits Report. NSPI must respond to the Seller's notice within 10 Business Days.

/span>(l) Commercial Operation has not occurred on or before the date which is 12 months after the Scheduled Commercial Operation Date (other than by reason of an occurrence of a Force Majeure Event). - (m) The Seller fails to obtain or ma...

AI summary The text outlines conditions for Seller Events of Default, including failure to achieve Commercial Operation within 12 months of the Scheduled Commercial Operation Date, failure to maintain Electricity Standard Approval, and failure to submit a Cybersecurity Plan by the deadline.

PA Feedback # 6. Cybersecurity Plan: The PA outlines that "We cannot commit IESO NS to a review timeline since much depends on the quality of the plan and timing of its submission to IESO NS by the Seller". We acknowledge, that the IESO NS...

AI summary The PA states that IESO NS cannot commit to a review timeline for the Cybersecurity Plan due to dependency on submission quality. The Seller disagrees, arguing that IESO NS can commit to a review timeframe post-submission. The Seller also references PPA terms requiring IESO satisfaction before Commercial Operation and highlights the risk of delays.