Topic:"Dcrr" in M12661

2.2 Demand Charge - In accordance with the Company's Cost of Service Study (COSS), demand-related costs are proposed to be allocated to the ELID Tariff class based on PHP assigned demand at the time of the three coincident peaks (3CP). Rec...

AI summary The document discusses the allocation of demand-related costs to the ELID Tariff class based on PHP's demand during three coincident peaks (3CP), proposing a fixed charge using historical 65 MW data. NS Power disagrees with PHP's argument for using 8 MW, citing the GRA Settlement Agreement and cost-of-service treatment. Proposed 2026/2027 demand charges are $12.872 and $14.310 per kVA/month, respectively.

2.5 Dispatchable Rider - The Dispatchable Rider (DR) will allow PHP to operate in a manner which reduces PHP's - individual cost of service, enables NS Power to manage PHP's load in response to system - conditions, reducing overall system...

AI summary The Dispatchable Rider (DR) enables PHP Wind Ltd to reduce its operational costs while allowing NS Power to manage PHP's load for system efficiency. It compensates PHP for load flexibility and shields ATL customers from PHP's potential cost impacts. The DR incentivizes non-levelized load profiles for optimal system performance.

3.2 Financial Benefits to ATL Customers Attachment 2 provides the cost-of-service applicable to PHP using the figures in the SA, including its fuel and non-fuel components and identifies the FCR provided by PHP if served on an ATL tariff f...

AI summary The ELID Tariff increases FCR for ATL customers compared to the ELIADC Tariff, with reductions in 2027 due to PHPW PPA displacing NS Power supply. DR service reduces system costs but benefits PHP, resulting in neutral net effects. Marginal fuel costs impact ATL classes differently based on whether they are above or below average.

4.0 CONCLUSION - Development and approval of the Extra Large Industrial Dispatchable Tariff will mark an - important milestone in the evolution of service to the province's largest electricity consumer. PHP - has progressed from a customer...

AI summary The conclusion highlights the development of the ELID Tariff as a milestone for PHP, transitioning from load retention to embedded cost-based service. It emphasizes increased fixed cost contributions, price stability, and simplified regulatory processes through year-end benefit calculations. The tariff leverages PHP's load flexibility for customer value and builds on two decades of stakeholder collaboration.

DSM COST RECOVERY RIDER The Demand Side Management Cost Recovery charge (in cents per kilowatt-hour) applicable to the Tariff for the current rate year, shown in the Demand Side Management Cost Recovery Rider, shall apply, in addition to t...

AI summary The Demand Side Management Cost Recovery Rider imposes a charge (in cents per kilowatt-hour) on the Tariff for the current rate year, in addition to the Energy Charge. This charge is part of the regulatory framework for recovering DSM-related costs.

Extra Large Industrial Dispatchable Tariff Application – Attachment 1 (25,000 kVA and over) Rate Code X (4) Failure to comply in whole or in part with a requirement to interrupt load will result in penalty charges. The penalty will be comp...

AI summary Attachment 1 outlines penalty charges for Extra Large Industrial Dispatchable customers failing to comply with load interruption requirements. Penalties include a Threshold Penalty based on firm billing costs and a Performance Penalty calculated via a formula involving $15/kVA and $30/kVA multipliers. The structure aims to enforce compliance with load management obligations.

APPLICABILITY This schedule applies to all electric rate classes with the exception of the Wholesale Market Non-Dispatchable Supplier Spill Tariff, the Load Retention Tariff, and the Extra Large Industrial Active Demand Control Tariff. For...

AI summary This schedule applies to all electric rate classes except specific tariffs. Cost recovery for electricity efficiency and conservation activities, as defined in Section 79A of the Public Utilities Act, is direct billed to customers in Wholesale or Renewable to Retail markets, mimicking NS Power's bundled service offerings.

DEMAND SIDE MANAGEMENT COST RECOVERY RIDER (DCRR) The monthly amount computed under each of the rate schedules to which this DSM Cost Recovery Rider is applicable shall be increased or decreased by the DCRR at a class-specific rate per kil...

AI summary The Demand Side Management Cost Recovery Rider (DCRR) adjusts monthly charges under applicable rate schedules using a class-specific rate formula (DCRR = PCR + BA), reflecting cost recovery mechanisms for demand-side management initiatives.

BA = Balance Adjustment The BA is comprised of two components: - (1) BA1 = Annual Volume Variance Adjustment is calculated for each rate class separately on a previously completed calendar year basis and is used to reconcile the difference...

AI summary The Balance Adjustment (BA) comprises two components: BA1, which reconciles revenue differences using a two-year lag, and BA2, which adjusts for actual DSM program costs post-DSM Term. Both ensure accurate billing based on actual usage and expenditures.

Total BA = BA1 + BA2 The BA shall be updated annually to reflect BA1, and at the conclusion of each Approved DSM Term to reflect BA2. The NSUAREB-approved DCRR shall be placed into effect with bills rendered on and after the effective date...

AI summary The Balance Adjustment (BA) is updated annually to reflect BA1 and at the end of each Approved DSM Term to reflect BA2. The NSUAREB-approved Dispatch Cost Recovery Rider (DCRR) is implemented with bills after its effective date, ensuring alignment with regulatory approvals.

2025 DSM Cost Recovery Rider Charges Effective: January 1, 20265January 1, 2026 The Demand Side Management Cost Recovery Rider (DCRR) charges, along with its components, (PCR) and (BA), for the period from the approved effective date of Ja...

AI summary The 2025 DSM Cost Recovery Rider (DCRR) charges, including Program Cost Recovery (PCR) and Balance Adjustment (BA), apply from January 1, 2025, to December 31, 2025. The BA2 calculation for 2023, based on revenue versus DSM costs, will be applied annually from 2028–2031. The Approved DSM Term refers to the full DSM Plan period (e.g., 2023–2026, 2027–2031).

DSM Cost Allocation MethodApproach There are 3 kinds of cost benefits resulting from DSM: - (1) System avoided future infrastructure and related costs, reduced fuel costs, and contribution to achieving environmental and emissions restricti...

AI summary The text outlines three types of benefits from DSM: system-wide, class-based, and participation-specific. It argues that DSM cost recovery should align with the benefits received by customer classes, with those receiving more benefits bearing higher costs. However, precise allocation is deemed impractical due to DSM program complexities.

Method - Step 1 Allocate the system benefits to all applicable customer classes, as 25% of the total Approved DSM program costs, in accordance with the COSS methodology per the most recent rate case decision. - Step 21 Allocate the class a...

AI summary The method outlines a five-step process for allocating system and class benefits from DSM programs, recovering costs via bundled service rates or direct billing, and annually adjusting allocations based on prior two years' data. It references COSS methodology and BA1/BA2 for true-up adjustments.

DEMAND SIDE MANAGEMENT COST RECOVERY RIDER (DCRR) Page 5 of 5 - For bundled service customers other than those who take service in the Wholesale Market (whether in whole or in part), this approach applies to classes as a whole (not to indi...

AI summary The DCRR applies differently based on customer service type: classes as a whole for non-wholesale market customers, and individual customers for those in the wholesale market. Total Approved DSM costs are subject to this approach.

8 Q DO YOU AGREE WITH NS POWER THAT THE ELID IS STRUCTURED TO CREDIT 9 TO PHP ALL COST SAVINGS CREATED BY NS POWER'S ABILITY TO DISPATCH 10 PHP'S FLEXIBLE LOAD? 11 A No. We do not dispute the lower power supply benefits that can be realize...

AI summary The Board disagrees with NS Power's assertion that the ELID tariff fully credits PHP for all cost savings from dispatching PHP's flexible load. It argues the ELID design unfairly allocates non-fuel interruptible benefits and that PHP incurs production delays and increased operating costs due to the dispatching terms.

1 Q PLEASE DESCRIBE THE NON-FUEL SAVINGS CREATED BY THE DR 2 COMPONENT OF THE ELID. 3 A NS Power's ability to dispatch PHP load allows it to curtail PHP's demands above the 4 8 MW firm demand when it does not have the system resource capac...

AI summary NS Power avoids investing in additional generating/transmission capacity by curtailing PHP's demand above 8 MW during peak periods and emergencies. This creates non-fuel savings through capacity cost avoidance, which are partially allocated to other customers under the ELID Tariff design rather than fully reflected in rate charges.

NON-CONFIDENTIAL (e) NS Power intends to continue reporting cause codes for deviation from optimal dispatch on a monthly basis. At the conclusion of the year, NS Power will calculate actual load shifting benefit as a comparison of actual r...

AI summary NS Power plans to monthly report dispatch deviation cause codes and annually calculate load shifting benefits by comparing actual PHP load profiles to theoretical CBL profiles using consistent pricing. It argues that CBL ignores exogenous power prices, potentially increasing costs under levelized pricing. DR credits will use actual load data with flat CBL profiles and randomized outages to ensure equal energy consumption comparisons.

ALLOCATION OF OPERATING EXPENSES (1) INTERR. RIDER DMD ADJ. (2) (3) (4) Peak Dmd. in KWs (at Generator) Int Credit Amount 69,594 11,165 (5) (6) PHP DEMAND ADJUSTMENT CALCULATION (7) (8) Demai nd Usage An nual Credit Amo ount Calculation on...

AI summary The document presents a table detailing the allocation of operating expenses through a demand adjustment mechanism, including peak demand figures, credit amounts, and calculations related to winter month usage and priority interruptions. The data reflects a specific rate rider (INTERR. RIDER DMD ADJ.) and associated financial computations.

NOVA SCOTIA POWER INC. ALLOCATION OF OPERATING EXPENSES FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) Depreciation 173,712 60,150 49,872 283,734 (1) INTERR. RIDER DMD ADJ. (3) Dmd. in KWs 69,857 (4) Int Credit Amount 11,2...

AI summary Nova Scotia Power Inc. presents operating expense allocations for 2027, including depreciation and demand adjustment calculations. The document details PHP demand adjustment computations, winter month power factor adjustments, and priority interruption credits, with figures totaling over $10 million in demand-related credits.

NON-CONFIDENTIAL (d) Please confirm that ELID load is expected to operate at an approximate 20% load factor by 2027 (160 MW peak, per N-1 page 5, and 304 GWh per page 3). If not, please indicate the assumed customer-specific annual load fa...

AI summary The response confirms that ELID load is expected to operate at a 20% load factor by 2027, with assumptions based on the Cost of Service Study (COSS) and the Dispatchable Rider (DR) credit. The DR credit is intended to shift demand to lower-cost hours, similar to the ELIADC Tariff, and reduce the impact of PHP's energy consumption on economic patterns as more wind generation is added.

NON-CONFIDENTIAL 1 Request IR-14: 2 3 Reference: N-1, ELID Application, page 9 – Priority Interruptible Credit. 4 5 (a) Please provide all workpapers, calculations, and analysis supporting the value of 6 $0.764/kVA and $0.767/kVA as the pr...

AI summary The request seeks clarification on the basis for the priority interruptible credit ($0.764/kVA and $0.767/kVA) and whether it is derived from actual avoided costs or a policy-based 10% uplift over the standard LIIR credit. The response directs to specific filings (M12451, SBA IR-2, and IG IR-13) for detailed calculations and historical context.

Request IR-3: In their evidence, Brubaker & Associates state: Q IF THE ELID INTERRUPTIBLE CREDIT WAS SET AT NS POWER'S AVOIDED CAPACITY COST OF $13.107/KVA, WOULD PHP PAY ANY CAPACITY COST FOR ITS INTERRUPTIBLE SERVICE? A Yes. The proposed...

AI summary Brubaker & Associates explain that even if the ELID interruptible credit equals NS Power's avoided capacity cost ($13.107/KVA), PHP would still pay capacity costs. The ELID 2027 energy charge ($0.1124/KWh) exceeds NS Power's fuel cost ($0.08299/kWh), generating non-fuel margins. PHP would also pay the difference between the demand charge ($14.310/kVA) and the credit.

Response IR-4: (a) BAI has not performed the requested analysis. The recommend interruptible credit of $13.107/kVA-month was derived from NS Power's Application, Attachment 1 Extra Large Industrial Dispatchable Tariff, Page 8 of 19, footno...

AI summary BAI did not perform the requested analysis for IR-4 and IR-5. The interruptible credit calculation for ELID class uses winter coincident peak and avoidable peaker costs. Reducing PHP's demand determinant from 65 MW to 8 MW is estimated to reduce revenue requirements by $6.5M (2026) and $9.4M (2027), though BAI has not confirmed reallocation details or secondary cost impacts.

Response IR-2: Although PHP understands it would meet the availability requirements to take service under the Large Industrial Rate Interruptible Rider tariff, this tariff was not designed to accommodate the dispatch service proposed to be...

AI summary PHP argues the Large Industrial Rate Interruptible Rider tariff is unsuitable for its dispatch service and requires separate cost allocation. NS Power proposes treating PHP as a distinct rate class due to unique load characteristics. PHP suggests a below-the-line tariff if an above-the-line option is unavailable.

Response IR-8: BAI agrees that the application of the interruptible credit, that is that the per unit credit would be multiplied by a fixed, agreed upon, interruptible demand level, in the same manner as the LIIR class. However, that is wh...

AI summary BAI agrees with the interruptible credit structure for ELID but highlights differences in calculation methods compared to LIIR. ELID load is prioritized for interruption, potentially leading to more interruptions. NS Power argues that interrupting PHP load above 8 MW reduces system costs and supports reliability by using interruption as operating reserves.

he Performance Penalty which is based on the Customer's performance during the interruption event is calculated as per the formula below: Performance Penalty = ($15/kVA x A) + ($30/kVA x B) Where: - "A" is any residual customer demand (abo...

AI summary The text outlines a Performance Penalty formula for customer demand during interruptions, defines variables A and B, and discusses NS Power's policies on interruptible load. It argues that PHP's load should not be treated as firm service, and that capacity allocation charges may be excessive. BAI did not perform the requested calculation, while PHP lacks penalty examples.

s PHP's energy forecast for the test years in Section V at page 27, line 2 to page 28, line 9. PHP's testimony discusses its updated forecast energy requirements at page 9, line 26 to page 10, line 7. c) The dollar value of the Interruptib...

AI summary The text discusses PHP's energy forecasts, the Interruptible Credit for interruptible load, Active Demand Control (ADC) cost recovery proposals, and the Dispatchable Rider. PHP and NS Power will analyze ADC's value for a proposed rate rider, while BAI addresses interruptible credit calculations. The Dispatchable Rider's role in capturing load flexibility is highlighted.

Responses to SBA Questions – 1 of 4 Question NS Power Response Please also refer to I. Historical Load Questions: a) What specific governance or planning criteria does NS Power apply when using the 65MW 3CP demand determinant to assure tha...

AI summary NS Power explains that the 65MW 3CP demand determinant's reasonableness is governed by the Settlement Agreement for 2026-2027, with future methodology proposals required for the next GRA. It agrees to consider a standardized, formula-based metric if it ensures fair cost allocation under the ELID Tariff for PHP.

2.0 SUMMARY OF RECOMMENDATIONS Based on the analysis summarized in this report, InterGroup makes the following recommendations to the Board: - Recommendation 1: InterGroup recommends that the Board reject PHP's proposed modifications for t...

AI summary InterGroup recommends rejecting PHP's modifications, assessing DR savings reasonableness, requiring Board approval for Operating Procedures, approving ELID Tariff's Interruptible Service component for 2026-2027 with a 2028 review, and reviewing the ELID Tariff post-implementation. These actions aim to ensure transparency, fairness, and alignment with regulatory standards.

5.0 PROPOSED ELID DISPATCHABLE RIDER NSP states that the Dispatchable Rider (DR) will allow PHP to operate in a manner which reduces PHP's individual cost of service, enables NS Power to manage PHP's load in response to system conditions,...

AI summary NSP proposes the ELID Dispatchable Rider (DR) to reduce PHP's service costs, enable load management to lower system costs, and compensate PHP for load flexibility. The DR shields ATL customers from PHP's potential cost impacts and credits PHP fully for dispatch value, differing from ELIADC Active Demand Control primarily in nomenclature and dispatch service provisions.

Recommendation: The Board should consider reasonableness of the DR savings to be fully credited to PHP. Further, NSP states that consistent with the ELIADC Tariff, PHP operations under the DR will be governed by Operating Procedures develo...

AI summary The Board is urged to assess the reasonableness of DR savings credits to PHP. NSP argues Operating Procedures for PHP under DR should not require NSEB approval, as benefits/costs flow solely to PHP. However, stakeholders recommend Board approval to ensure transparency and protect other ATL customers from potential revisions favoring PHP.

Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Confidential Version - Customer Charge ($/month) : Designed to recover the "costs associated with the provision of dispatch service to...

AI summary NSPI proposes an Above-the-Line Tariff for Port Hawkesbury Paper (PHP), including monthly customer charges, demand charges based on peak demand, energy charges tied to load and Goose Harbour output, and Above-the-Line Rider charges. PHP may earn Dispatchable Rider Credits to offset costs. The proposal is part of NSPI's 2026-2027 General Rate Application.

Q. Please summarize your evidence with respect to NSPI's application. - A. Again, our evidence addresses only the Customer Charge, Energy Charge, Dispatchable Rider, - and treatment of Goose Harbour output. Regarding the Customer Charge, w...

AI summary The evidence recommends revising NSPI's proposed Customer Charge to $12,291.67/month with reconciliation for ELID Tariff costs, updating the COSS model for ELID Energy Charge accuracy, and rejecting the DR credit due to insufficient load-shifting safeguards. PHP's cost recovery and Goose Harbour output integration are emphasized.

Q. Please describe the DR credit proposed by NSPI in the ELID Tariff. - A. NSPI asserts that the DR credit "will allow PHP to operate in a manner which reduces PHP's - individual cost of service, enables NS Power to manage PHP's load in re...

AI summary NSPI proposes a DR credit in the ELID Tariff to reduce PHP's cost of service, enable load management during system peaks, and compensate PHP for load flexibility. The credit structure aims to shield above-the-line customers from PHP's potential incremental cost impacts by incentivizing system-cost-reducing operations.

Q. Please explain NSPI's logic for including the DR credit as part of the ELID Tariff. - A. NSPI's logic is based on a "premise" that, as an above-the-line customer "with demand and - energy charges," PHP "would generally be incented to op...

AI summary NSPI argues that including the DR credit in the ELID Tariff aligns the interests of all above-the-line customers, including PHP, by addressing PHP's load flexibility. Without the Rider, PHP's levelized load profile could increase costs for all customers. The Rider ensures optimal system load profiles while managing PHP's demand and energy charges.

1 Q. What is your second concern? - 2 A. Our second concern is that the DR credit is built upon a shaky premise, namely, that PHP's load - 3 is sufficiently predictable as to allow for an after-the-fact determination of how PHP would have...

AI summary The second concern is that the DR credit relies on the assumption that PHP's load is predictable enough to determine hypothetical annual operations. However, historical data shows PHP's load is volatile, leading to rate outcomes based on uncertain system fuel costs.

Q. Why is verification of the DR credit important? PHP (IG) IR-7 (c). NSPI (BW) IR-9 (g).

AI summary The verification of the Dispatchable Rider (DR) credit is critical to ensure accuracy in financial mechanisms tied to demand response programs, particularly for entities like Port Hawkesbury Paper (PHP) and Nova Scotia Power, Inc. (NSPI). Proper verification prevents errors in cost recovery and maintains regulatory compliance.

Q. Why will the DR credit be difficult (or impossible) for the Board and stakeholders to verify? - A. NSPI is afforded substantial discretion in determining the CBL. While NSPI is not purporting to - change the actual volume of PHP's load...

AI summary NSPI's discretion in levelizing PHP's load and lack of detailed data from PHP create verification challenges for the DR credit. NSPI's method is unclear, relying on limited examples and subjective factors. PHP's reluctance to share data (e.g., financial statements) and NSPI's lack of review exacerbate information asymmetry, undermining stakeholder confidence in the DR credit calculation.

Q. How substantial is NSPI's discretion in calculating the DR credit? A. Quite substantial. While NSPI did not conduct an estimate of the Credit in 2026 or 2027, [94](#page-25-0) NSPI conducted an "initial analysis" of the DR credit using...

AI summary NSPI's discretion in calculating the DR credit is substantial, as its initial analysis using 2025 data showed a potential $7–$11 million credit, but adjustments reduced it by half to $3.5–$5.5 million. NSPI's adjustments, based on subjective factors like system conditions, were not fully disclosed due to a cyber incident, raising concerns about transparency and verification.

Q. What is your fifth concern? A. Our fifth concern relates to NSPI's plan to use "forward replacement fuel costs"[100](#page-25-6) to determine the DR credit. While NSPI did not elaborate on the specific approach it would take, forward re...

AI summary The fifth concern is NSPI's use of 'forward replacement fuel costs' to determine DR credits, which may overstate system costs. NSPI has previously avoided this method in calculating load-shifting benefits under the ELIADC Tariff, citing concerns about overestimation.

Q. What is your sixth concern? - A. Our sixth concern is that the DR credit represents a zero-sum mechanism that, if incorrectly - calculated, could harm other FAM customers. Any load "smoothing" exercise inherently assumes that - actual d...

AI summary The sixth concern is that the DR credit mechanism risks overestimating load smoothing contributions from PHP, potentially harming FAM customers by incorrectly attributing operational variations to PHP rather than system conditions.

regarding load-shifting activity? - A. Yes. NSPI states that "[b]ecause the cost of the [DR credit] service is based on the benefit the - service provides to the system, [above-the-line] customers will be held harmless under the [Dispatcha...

AI summary NSPI confirms that load-shifting activity is addressed by holding above-the-line customers harmless under the Dispatchable Rider construct, as the cost of the DR credit service is tied to system benefits.

Q. What is PHP's view of the DR credit? - A. Nowhere in the PHP Evidence did PHP criticize or raise concerns with the DR credit, as - proposed. (PHP raised concerns with other aspects of the ELID Tariff.) In response to data requests, PHP...

AI summary PHP did not criticize the proposed DR credit but raised concerns with other aspects of the ELID Tariff. PHP and its consultant believe the DR credit is 'appropriate.' NSPI's prior filings and tariff proposals are referenced in the context of ELIADC-related matters.

Q. What is your recommendation regarding the DR credit? - A. We do not recommend that the Board approve the DR credit as proposed. To be reasonable, at - least two things must be true: (1) any payments to PHP from FAM customers under the D...

AI summary The respondent recommends against approving the DR credit as proposed, citing its vagueness, lack of verifiability, and risk of mismatched payments. Two conditions are required for approval: payments must be tied to load-shifting due to energy prices, and FAM customers must not compensate PHP in hours without load-shifting activity.

REDACTED 1 Request IR-8: 2 3 Reference: 2025 Annual Report, Exhibit N-1, p. 5/9 – Schedule Deviations (Cause Code 5, 4 "PDN") and Off-schedule Details, p. 3/3 5 6 (a) Please describe in detail the methodology used to calculate the $706,609...

AI summary The document outlines a request (IR-8) for detailed information on the methodology used to calculate a $706,609 system cost attributed to PDN deviations in 2025, including modeling assumptions and the treatment of avoided or incremental system costs. It also asks whether this cost represents a harm to customers or a forgone benefit, and seeks clarification on cost allocation between FAM customers and PHP.

REDACTED 1 • Hourly Off-Schedule Charge = (PortOps modeled cost to serve x PHP load) - (CBL 2 Energy Charge x PHP load) 3 4 (b) The Off-Schedule Charge is neither a cost to customers (as PHP pays for its incremental 5 cost to serve) nor a...

AI summary The document discusses the Off-Schedule Charge under the ELIADC Tariff, explaining that it is not a direct cost to customers but a construct designed as an incentive for PHP to follow dispatch. It references the ADC Load Shifting Differential and the 2025 Annual Report (NSEB M12768).

1.1 Findings and Recommendations - The proposed ELID rate is complicated and unusual in utility rate regulation. No comparable rate could be - identified in Canada, particularly for a major customer on a regulated utility system. - Despite...

AI summary The proposed ELID rate is criticized for being complex and unfair, failing to reflect service costs or value. Recommendations include adjusting capacity values, limiting PHP's DR credits, rejecting interruptibility credits, and ensuring transparency in operating procedures. The ELID's predecessor, ELIADC, is acknowledged as beneficial but requires reforms to address inequities in cost allocation and dispatchability.

2.0 NSP ELID RATE PROPOSAL - PHP is NSP's largest customer, forecast in the most recent NSP GRA to use over 810 GW.h per year for - 2026, with the hourly on-site demand able to vary from 12 M[W](#page 1-7) 1 to 160 MW.[2](#page 1-8) PHP no...

AI summary NSP proposes a new ELID tariff for its largest customer, PHP, retaining the dispatch role under the 'Dispatchable Rider' (DR). The proposal uses 'above the line' Cost of Service techniques and a DR credit to allocate costs, claiming it is functionally similar to the existing ELIADC tariff but with updated rate-setting methods.

3.2 Issues Associated With Application of the DR - The DR is a highly accommodating and beneficial aspect of the ELID rate to PHP. It also appears to be - unprecedented in Canada. - Not only does PHP secure the ability to access approximat...

AI summary The Dispatchable Rider (DR) under the ELID rate provides PHP with significant benefits, including compensation for load variation and access to NSP's embedded resources. The DR is unprecedented in Canada and allows PHP to shift load without obligation, though NSP retains dynamic dispatch rights. This arrangement is clarified in a 2026 Technical Conference.

Request IR-2: - Reference: Testimony, Section IV, Page 28, Lines 18-21. "It may be that, with additional - elaboration, revisions, reporting requirements, and verifiability guardrails, the mechanism may - achieve these objectives, but as p...

AI summary The text references concerns raised about the DR credit mechanism being vague and unverifiable, with a request for Bates White's suggested elaboration, revisions, and reporting requirements to address these issues.

ce this a reduction of 57 26 MW, and Mr. Bowman's recommendation would be an increase of 55 MW, 27 the relative ratio of change should be comparable. Using 2027 numbers, 28 the impacts are as follows: 29 Under the 65 MW scenario, PHP's all...

AI summary The text discusses cost allocation impacts under different peak reduction scenarios for PHP, with a 57 MW reduction leading to a $9.4 million cost decrease. It also outlines recommendations related to demand response (DR) control and savings sharing, with the latter having a potential impact of up to $11 million.

26 Response IR-5: 27 (a) This is not clear. Mr. Bowman's understanding is that the interruptibility 28 values are based on $160/kW. In Exhibit N-2, Brubaker and Associates 29 indicate that this value is linked to a dated value of the avoid...

AI summary The response discusses the basis for interruptibility credits, particularly the $160/kW value linked to avoided generation costs. It questions the relevance of using a dated value and highlights that the actual contribution to system capacity avoidance depends on the customer's load during system peaks, not their maximum potential load.

es InterGroup support some form of benefit sharing like under the current ELIADC rather than a 100% allocation of all calculated DR savings to PHP? Please explain. CA Response IR-2: a) Confirmed. b) Confirmed. Please also see the response...

AI summary InterGroup supports a benefit-sharing model similar to the current ELIADC rather than allocating 100% of DR savings to PHP. They propose a lower DR credit ratio to PHP, with costs recovered from other customers via FAM.

CA Response IR-3: a) In InterGroup's view, the following factors need to be considered in assessing the quantum of DR savings proposed to be credited to PHP: - NSP cost-of-service study (COSS) already reflects interruptible service credit...

AI summary InterGroup argues that NSP's proposed DR credit to PHP may misalign with load seasonality, lacks alignment with existing cost allocations, and would shift costs to other customers via FAM. The response highlights issues with modeled baseline load assumptions, exclusion of VCC in the ELID Tariff, and reliance on theoretical data.

the ELID Tariff approved in this Matter after the first year of implementation. - a) Does InterGroup recommend that the Operating Procedures be approved as a pre-condition to approval of the ELID? If not, how or when does InterGroup contem...

AI summary The text raises questions about the approval process for the ELID Tariff, including pre-conditions for approval, the scope and timing of a first-year review, and the frequency of DR credit reporting. It seeks InterGroup's stance on requiring quarterly rather than annual reporting for DR credit calculations.

CA Response IR-3: a) The rationale for why an interruptible credit based on a utility's avoided marginal cost of capacity cannot or should not exceed an embedded cost-of-service demand charge in the case of NSP's PHP ATL Tariff application...

AI summary The response discusses the rationale for limiting interruptible credits to avoid exceeding embedded cost-of-service demand charges in NSP's PHP ATL Tariff application, citing fairness and cost recovery principles. It also notes uncertainty about whether capacity costs are functionalized as energy costs under NSP's cost-of-service study.

CA Response IR-5: a) No. InterGroup's evidence page 9 and 10 discusses NSP's response to NSEB-3 (Exhibit N-7), where NSP states: While on the ELIADC Tariff, 75 percent of the Active Demand Control (ADC) value was assigned to FAM. However,...

AI summary The response discusses the ELIADC and ELID tariff differences, focusing on how PHP's fixed cost contributions and DR credit impacts other customer classes. NSP explains that PHP can ignore DR price signals, but this results in increased costs for other customers. InterGroup raises concerns about fairness and cost causation.

bility. Who bears the cost risk of percentage error in the CBL? (c) Bates White identifies that many variables affecting PHP's load are "unrelated to the price of energy in Nova Scotia." Is there a CBL methodology that can reliably separat...

AI summary The text raises questions about cost risk allocation in the CBL methodology, the reliability of separating price-responsive load components from external factors, and differences in demand response operationalization compared to ELIADC. It highlights concerns about current approaches to cost recovery and program evaluation.

Response IR-7: - (a) Yes. - (i) Not applicable. - (b) We have not put forth an alternative tariff mechanism. As we state in our evidence, we do not recommend that the Board approve the DR credit as proposed. We do explain that the DR credi...

AI summary The response to IR-7 states that an alternative tariff mechanism is not proposed, and the DR credit is deemed too vague and unverifiable. The ELIADC Tariff's variable rate differs from the proposed ELID Tariff's fixed rate, with concerns that exogenous factors may obscure load-shifting benefits. The DR credit requires revisions for verifiability.

Request IR-10: Reference: N-20, Bates White Evidence, p. 27, lines 4-9. Our sixth concern is that the DR credit represents a zero-sum mechanism that, if incorrectly calculated, could harm other FAM customers. Any load "smoothing" exercise...

AI summary The concern is that the DR credit calculation could overestimate benefits, harming FAM customers due to incorrect assumptions about load smoothing and operational variations.

And at p. 28, lines 14-21: We do not recommend that the Board approve the DR credit as proposed. To be reasonable, at least two things must be true: (1) any payments to PHP from FAM customers under the DR credit must demonstrably tied to P...

AI summary The DR credit is not recommended for approval due to vagueness and lack of verifiability. Key requirements include tying payments to actual load-shifting and ensuring no compensation when no load-shifting occurs. Revisions and guardrails may make it approvable.

- capacity in order to ensure that the credits provided to PHP provide net benefits to other customers. - (e) (i iv) "Induce participation" means a credit high enough that PHP is willing to take service on the tariff. The minimum compensat...

AI summary The text discusses the determination of interruptible credit levels for PHP, emphasizing the need to balance participation incentives with ratepayer benefits. It highlights that the minimum compensation required to induce participation is higher than $8.404/kVA but lower than PHP's proposed $13.107/kVA. The discussion also considers industry practices and the importance of maximizing net benefits to all ratepayers.

Request IR-2: Reference: Testimony, page 13, lines 10-19. "First, compensating PHP at the full marginal cost of generation capacity would overstate the value of its interruptible load from the perspective of other customers. While PHP's in...

AI summary The text discusses the compensation of PHP for its interruptible load, arguing that compensation should be capped at the avoided capacity cost net of its expected revenue contribution under firm service. It raises questions about the appropriate value to net from the avoided capacity cost and whether the expected revenue contribution should be limited to portions of PHP's COS for generation.

Request IR-3: Reference: Testimony, pages 13-14, lines 20-6. "Second, setting the interruptible credit equal to the full marginal cost would allocate all of the benefits of avoided capacity to PHP, leaving other customers no better off tha...

AI summary The text discusses the interruptible credit mechanism and its implications for allocating benefits of avoided capacity between PHP and other customers. It raises questions about the methodology used by NSP in determining the interruptible credit and whether the current assumptions understate the marginal cost of new generation.

Request IR-2: Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Section 2.4 Interruptible Service, starting at page 8 of 19, and please answer the following: - a) Describe the rationale for the use of the interruptible c...

AI summary This request (IR-2) asks NS Power to explain the rationale, derivation, and changes in the interruptible credit used in the LIIR, the difference between ELID and ELIADC rates, avoided peaker costs, and the implications of redefining the interruptible rider's credit, including the 10% priority credit and its relation to ancillary services.

Request IR-4: - Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Section 2.5 Dispatch Rider, starting on page 9 of 19, and please answer the following: - a) Provide the mathematical formulation of the DR credit. - b) Pr...

AI summary This request (IR-4) asks Nova Scotia Power to provide detailed information on the mathematical formulation of the DR credit, methodology for calculating Customer Baseline Load (CBL), explanations of factors influencing CBL, analyses of savings figures, and clarification on the nature of DR credits, ELID charges, and reporting requirements.

Request IR-6: - Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Section 3.1 Consistency with Established Rate-making Practice in Nova Scotia, starting on page 15 of 19, and please answer the following: - a) Confirm if...

AI summary Request IR-6 asks NS Power to clarify and justify the use of incremental and marginal cost-based mechanisms in the ELID Tariff, compare credits under ELIADC and ELID, and provide detailed calculations and workpapers related to interruptible events, including the Maritime Link trip on February 13, 2026.

the Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (the “Application”), Section 2.2 Demand Charge, starting at page 5 of 19, and please answer the following: 1. Describe the rationale for the use o...

AI summary The text presents a set of questions related to the Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper. The questions focus on demand charges, definitions, cost recovery, and tariff comparisons, particularly concerning the ELIADC Tariff and the 3CP (coincident peak) figures used for billing purposes.

1. Describe the rationale for the use of the interruptible credit at the same rate as the large industrial interruptible rider (“LIIR”). 2. Describe the derivation of the credit. Is the credit based on a marginal cost of capacity or embedd...

AI summary The text outlines a series of questions directed at NS Power regarding the rationale, derivation, and implications of various credits and rates, including the interruptible credit, LIIR, ELID, ELIADC, and the Dispatchable Rider. The questions focus on cost calculations, fairness, and alignment with established practices.

tion including any workbooks with formulas intact. 10. Does NS Power believe that the 10% priority credit captures the value of ancillary services implicitly? Please explain answer. Request IR-3: Regarding interruptible events since 2020,...

AI summary The document requests NS Power to explain the 10% priority credit for ancillary services and provides detailed information on interruptible events since 2020, including event counts, MW reductions, durations, and causes. It also asks for the mathematical formulation of the DR credit and methodology for determining the Customer Baseline Load (CBL), referencing a specific application and exhibit.

ations of the Customer’s major scheduled maintenance periods and other factors as may be appropriate to calculate a representative CBL. please explain what ‘other factors’ may be included in the CBL. 1. Provide the analyses demonstrating t...

AI summary The text outlines several requests for clarification and supporting documentation related to the calculation of the Customer Base Load (CBL), demand response (DR) credits, and tariff structures. Questions focus on savings analyses, DR credit composition, tariff alignment, and potential new tariff development timelines.

to M12661, Exhibit N-1, the Application submitted by NS Power, Section 3.1 Consistency with Established Rate-making Practice in Nova Scotia, starting on page 15 of 19, and please answer the following: 1. Confirm if the components listed as...

AI summary The text outlines several requests related to NS Power's application, focusing on the ELID Tariff and its components, including the Customer Charge, Interruptible Rider credit, and DR credit. It asks for definitions, calculation methods, and comparisons of credits under different mechanisms, as well as clarification on cost inclusion and reporting practices.

Request IR-7: Refer to M12661, Exhibit N-2, Evidence of Colin T. Fitzhenry and Michael G. Gorman on behalf of PHP, regarding the utilization of the marginal cost of capacity at $13.107/kVa for the interruptible credit, beginning at page 20...

AI summary The text refers to evidence provided by Colin T. Fitzhenry and Michael G. Gorman on behalf of PHP in M12661, Exhibit N-2, concerning PHP's use of NS Power's estimate of the marginal cost of capacity at $13.107/kVa for an interruptible credit. It requests confirmation and explanation on several related questions regarding PHP's position on capacity valuation, interruptibility, and DR credits.

iff would occur? 2. Would it be a new ATL or a below-the-line tariff? 3. Would PHP require interim service if the alternative tariff was not developed prior to January 1, 2027? If so, under what rate? Request IR-5: Refer to M12661, Exhibit...

AI summary The text contains a series of regulatory questions and requests related to the development of an alternative tariff, the use of NARUC Manual guidance for interruptible capacity allocations, and the potential penalties for non-performance during interruptible events. It also asks for statistical methods aligned with NARUC principles and critiques of historical peak contribution metrics.

ed by NS Power is not appropriate. 8. If 65MWs reflects the historical reliance of interruptibility (including suppressed meter readings), why is this not an appropriate allocation? Request IR-6: Refer to M12661, Exhibit N-2, Evidence of C...

AI summary The text contains several requests for information related to the Dispatchable Rider (DR) and interruptible credit, including questions about the allocation of capacity, the appropriateness of the DR component, and the valuation of capacity. These requests are part of a regulatory proceeding and involve NS Power and PHP.

Request IR-3: - On page 10, NS Power proposed that the value created by the dispatch of PHP load should be fully credited to PHP. It also proposed that the cost of the DR service should be included as a FAM cost and recovered from all ATL...

AI summary NS Power proposed that the value from dispatching PHP load be credited fully to PHP and that DR service costs be recovered from all ATL customers, who would be held harmless. Questions are raised about the anticipated dollar value of the dispatch, how ATL customers will be held harmless, and what value other ATL customers receive from the ADC component.

iscontinue. 1. Please explain how the $500,000 was derived. 2. With reference to “more review”, please elaborate on what additional review is contemplated and what associated metrics are anticipated. On page 10, NS Power proposed that the...

AI summary The document includes questions raised regarding the derivation of a $500,000 figure, the proposed tariff adjustments by NS Power, and concerns from PHP about the ATL tariff. It also asks about the financial and operational impacts of tariff amendments and whether BTL tariffs were considered.

been enrolled in the Large Industrial Interruptible Rider for 2023 and 2024. 7. Refer to the Application, p. 3, lines 13-15. Are there any differences between the “Dispatchable Rider” under the ELID tariff and the “Active Demand Control” u...

AI summary The text outlines a series of questions directed at an applicant regarding the Large Industrial Interruptible Rider (LIIR), the Dispatchable Rider under the ELID tariff, and the Active Demand Control under the ELIADC tariff. It also requests clarification on the derivation of firm and interruptible load calculations, the use of three coincident peaks (3CP) for billing determinants, and differences in how NS Power manages firm and interruptible load.

from PHP during the winter peak, as well as the PHP firm load amount that the asset was designed to serve. 7. What firm load from PHP was the Port Hawkesbury Biomass plant designed to accommodate? 1. Refer to the Application, p. 8, lines 3...

AI summary The document includes questions about the Port Hawkesbury Biomass plant's capacity to serve PHP firm load, the derivation of a 10% credit for priority interruptible service, and the rationale for matching winter month system coincident demand with negotiated firm plus interruptible demand. It also asks for NS Power’s forecast for avoided costs and the comparison of dispatch service to interruptible service for LIIR customers.

1. Refer to the Application, p. 9, lines 20-24. 1. Please explain if PHP would be incented to reduce load due to priority interruptibility orders if the ELID tariff included the interruptible service credit and priority interruptible credi...

AI summary The text contains a series of questions directed at clarifying aspects of the PHP tariff, interruptibility credits, dispatchable rider implications, and the financial impact of the Goose Harbour Lake Wind Farm on PHP bills. The questions seek explanations on incentives, calculation methods, and tariff changes.

1. Refer to the Direct Evidence of Port Hawkesbury Paper LP, p. 12, line 15 to page 13 line 9. 1. Please describe if NS Power agrees with the characterization of the event. If not, please provide any corrections. 2. Please describe why the...

AI summary The document contains a series of questions directed at NS Power regarding the implementation of load reductions under the ELIADC tariff, specifically focusing on the 60 MW load reduction event and whether the ADC and interruption protocol were followed. It also inquires about interruptions and direct control actions for PHP during specific peak periods.

interruptible credit for PHP be developed for the years following 2027? 7. If a GRA is not held for 2028, in what process does NS Power propose the interruptible credit for PHP be revisited? IR-5 Reference: Application, Attachment 1, page...

AI summary The text discusses the interruptible credit for PHP (Peak Hourly Load) and its calculation, including whether an interest component should be included in the credit. It references the Dispatchable Rider and the Large Industrial Interruptible customer class, asking for details on demand cost reductions for 2026 and 2027.

casted generation output from Goose Harbour that was incorporated into NSPI's GRA forecast for 2026 and 2027, by year. Request IR-9: Please refer to Exhibit N-1, page 10 lines 5-7 and section 2.5. - a) Please identify "the cost of providin...

AI summary The text includes several requests for clarification regarding the Dispatchable Rider, the ELID Tariff, and the Goose Harbour PPA and PSA. Questions focus on cost allocation, dispatch instructions, enforcement mechanisms, and the impact of exogenous factors on PHP's consumption and credits.

purposes throughout the year (i.e. the PHP 3CP figure employed for Tariff costing and pricing would also be applied for billing purposes essentially making the demand cost recovery a fixed charge). 1. Are there any other ATL customer class...

AI summary The text discusses the billing practices for demand charges, specifically the use of the PHP 3CP figure for fixed demand charges and the procedures for revising such charges through regulatory processes. It also references a Rider proceeding and a FAM proceeding, and asks for clarification on these terms and their application.

to operate at an approximate 20% load factor by 2027 (160 MW peak, per N-1 page 5, and 304 GWh per page 3). If not, please indicate the assumed customer-specific annual load factor for ELID supplies. NSPI states at page 7 that the ultimate...

AI summary The document discusses the ELID Application and its implications on interruptible credit for PHP, including the proposed rates and the potential impact of using an established pricing approach. It also requests an analysis of the impact on industrial customers if PHP is not found responsible for FLG2 costs.

erationally necessary; 2. Materially different from DR dispatch; and 3. Not substitutable with DR load reductions. Reference: N-1, ELID Application, pages 9-11, Dispatchable Rider (DR). 1. Please confirm that, under the proposed Dispatchab...

AI summary The document discusses the proposed Dispatchable Rider (DR) mechanism and its implications on the Fuel Adjustment Mechanism (FAM) accounting for non-ELID customers. It raises questions about how FAM calculations would be based on hypothetical system fuel costs and the complexity of future FAM reviews. The text also references estimated savings from optimal load dispatch, noting that actual benefits may be significantly lower due to operational constraints.

at times, conflict with optimal load dispatch. Based on experience with the ELIADC Tariff, the Company estimates that the actual benefit that can be realized will be approximately half this amount. 1. Please elaborate on the sentence that...

AI summary The text discusses the ELIADC Tariff and its impact on the DR credit, noting that the actual benefit may be half of initial estimates. It requests detailed explanations, data, and calculations related to the DR savings, including how the SEA is considered and the impact of Goose Harbour Lake wind contributions. It also mentions that the DR cost will be recovered from all ATL customers, with ATL customers being held harmless.

, it is expected changes will be required to the FAM Plan of Administration to recognize this and potentially other ELID Tariff elements…. ATL customers will be held harmless under the DR construct. 1. Please provide NSPI's current best es...

AI summary The text requests information about the Fuel Adjustment Mechanism (FAM) and its interaction with the Dispatchable Rider (DR), including cost recovery estimates, proposed changes to the FAM Plan of Administration, and the meaning of 'held harmless' for ATL customers. It also asks for quantitative analyses and potential scenarios where ATL customers may not be held harmless.

the Operating Procedures? Reference: N-1, ELID Application, page 17. In addition to [fixed cost recovery], the ELID tariff will affect fuel costs borne by other customer classes in two respects: 1. DR service will reduce total system costs...

AI summary The ELID tariff will impact fuel costs for other customer classes, particularly through DR service and incremental costs for serving PHP. The GRA includes DR benefits in the fuel budget but lacks compensation for PHP, which will be addressed via the FAM. The excerpt outlines the relationship between marginal and average fuel costs but does not fully explain how DR credit interacts with these variations.

above excerpt addresses the relationship between marginal and average fuel costs in general terms but does not address how the DR credit interacts with or is affected by variations in marginal costs. 1. In relation to item (2) above, pleas...

AI summary The text requests an explanation of how marginal and average fuel costs interact with the DR credit for PHP and ATL customers under various scenarios, a class-level breakdown of fuel-cost allocation changes under the ELID tariff, a reconciliation of DR credit impacts on FAM, and an estimate of additional FAM costs if PHP savings are overestimated.

4. If PHP’s annual savings are over-estimated by 10-20%, what is the dollar estimate year-over-year of additional FAM costs to LI and MI? Reference: N-1, ELID Application, pages 14-15, PHP Deferral. 1. Please provide analysis showing the p...

AI summary The text discusses the potential financial impact of overestimating PHP’s annual savings by 10-20% on FAM costs to LI and MI customer classes, referencing the ELID Application and PHP Deferral. It also outlines the conditions for holding monthly demand charges constant and the calculation of interruptible demand credits.

avoided peaker cost used in determining the proposed $7.661/kVA monthly credit for both Large Industrial Interruptible and for ELID is out of date and undervalues the benefit of interruptible load. 1. Please indicate whether NSPI considers...

AI summary The document raises concerns about the outdated nature of the $7.661/kVA monthly credit for Large Industrial Interruptible and ELID customers, suggesting it undervalues interruptible load benefits. It requests NSPI's position on the matter and explores potential scenarios for updating the rate, considering fairness and practicality.

14 Request IR-3: - 15 Reference: N-2, Evidence of C. Fitzhenry and M. Gorman, page 3. - 16 Preamble: PHP's consultant, Brubaker & Associates, Inc., states that the current ELID 17 R/C ratio is 1.04373 and recommends an R/C ratio of 1.0 " e...

AI summary The text outlines several requests from a regulatory proceeding, including inquiries about the R/C ratio, interruptible credit calculations, and the impact of reducing PHP's demand determinant on revenue requirements and customer classes. These requests are aimed at ensuring transparency and proper cost allocation.

Application by NS Power for Approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff Applicable to Port Hawkesbury Paper (NSUARB M12661) PHP Information Requests to Bates White IR-2 Reference: Testimony, Section IV, Page 28...

AI summary The document contains information requests from PHP to Bates White regarding concerns about the DR credit mechanism and a scenario where a customer class may not use energy from NSP's system. The requests seek clarification on revisions and verifiability measures, as well as whether fixed energy costs should apply in such a scenario.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and IN THE MATTER OF: An Application by Nova Scotia Power Inc. ("NS Power") for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable to Port...

AI summary The Nova Scotia Energy Board is considering an application by Nova Scotia Power Inc. for an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Consumer Advocate (InterGroup Consultants) has been asked to respond to several questions regarding settlement agreements, load modeling, and the calculation of interruptible credits and demand charges.

Application by NS Power for Approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff Applicable to Port Hawkesbury Paper (NSUARB M12661) PHP Information Requests to the CA (InterGroup) IR-6 Reference: Testimony, page 13. "I...

AI summary NS Power has applied for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. InterGroup raised concerns about potential double-counting of benefits if the Dispatchable Rider and Interruptible Credit are paired, as they may provide overlapping savings to PHP.

In order to address this issue, the Board should retain some form of benefit sharing, as is in place under the current tariff (ELIADC), rather than 100% allocation of all theoretical savings to PHP." (a) Does Mr. Bowman agree that hypothet...

AI summary The document discusses the proposed ELID tariff by NSP and includes questions regarding benefit sharing, demand response (DR) calculations, and interruptibility rider (IR) provisions. It references the ELIADC tariff and the impact of DR on PHP under different scenarios.