Topic:"Eliadc Tariff" in M12661

TABLE OF CONTENTS 1.0 [INTRODUCTION................................................................................................................](#page-2-0) 3 2.0 TARIFF COMPONENTS [.........................................................

AI summary The document outlines a regulatory proceeding's table of contents, focusing on tariff components, a comparison between ELID and ELIADC tariffs, and relief sought. Attachments include tariff designs and customer charge estimates, indicating a focus on rate structure analysis and potential regulatory approval of new tariffs.

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.

- credits to be paid to PHP for the continuation of priority interruptible service. ELID Priority Interruptible Credit reduction per kilovolt ampere reduction in demand charge Effective January 1, 2026 $0.764 Effective January 1, 2027 $0.7...

AI summary The text outlines credits to be paid to PHP for the continuation of priority interruptible service, referencing the ELIADC Tariff and its application to LIIR subscribers. It includes a table specifying credit rates effective January 1, 2026, and January 1, 2027.

- ELID Tariff includes provision for PHP load to be held as Operating Reserve as required by system - conditions. The interruptible notification processes, penaltiesfor non-compliance, etc. are the same - as the LIIR provisions.

AI summary The ELID Tariff includes provisions for PHP load to be held as Operating Reserve as required by system conditions. The interruptible notification processes and penalties for non-compliance are the same as those under the LIIR provisions.

expected to consume equally across the year, indifferent to changes in the marginal cost of system supply. In light of the size of PHP load, running as a conventional ATL customer risks increasing costs for all ATL customers, including PHP...

AI summary The Dispatchable Rider (DR) aims to align interests of all ATL customers by pricing PHP load on an embedded cost basis, with DR credits fully credited to PHP. Costs are recovered from all ATL customers, ensuring no additional burden on them. The DR leverages existing processes between NS Power and PHP under the ELIADC Tariff, reducing volatility and providing benefits through PHP's system cost contributions.

s ultimately approved by the Board; - As applicable, the form and terms of a Board-approved Dispatchable Rider, Interruptible Rider, and priority interruptible service; Attachment 4, page 12, item g. • The timing and energy production from...

AI summary The document outlines the PHP Deferral process, comparing ELID and ELIADC tariffs, emphasizing cost-based rate structures. NS Power details the ELID Tariff's alignment with Nova Scotia rate-making practices, contrasting it with ELIADC's incremental approach. Key considerations include PHP's PPA energy production, tariff subscription, and deferred cost recovery subject to Board approval.

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.

5.0 RELIEF SOUGHT - The Company requests Board Approval of the Extra Large Industrial Dispatchable Tariff as - provided in Attachment 1. Considering the development of this Tariff uses well-established costing - and pricing processes appli...

AI summary NS Power requests Board approval for the Extra Large Industrial Dispatchable Tariff, citing established processes and prior interruptibility provisions. They seek a paper process for the application, emphasizing alignment with existing Large Industrial class costing methods.

Extra Large Industrial Dispatchable Tariff Application – Attachment 1

AI summary This document outlines an application for an Extra Large Industrial Dispatchable (ELID) Tariff, potentially involving cost recovery mechanisms, regulatory approval processes, and related programs. It may address rate design, energy efficiency initiatives, and compliance with Nova Scotia energy regulations.

EXTRA LARGE INDUSTRIAL DISPATCHABLE TARIFF Page 1 of 8 (25,000 kVA and over) Rate Code X The Extra Large Industrial Dispatchable (ELID) Tariff is an Above-the-Line (ATL) embedded costbased tariff wherein the Company will dispatch the load...

AI summary The ELID Tariff is an ATL embedded cost-based rate structure where NS Power dispatches Port Hawkesbury Paper LP's load to manage demand, reduce costs, and return savings to the customer. Charges are determined via General Rate Applications or regulatory proceedings, with annual year-end calculations under the Dispatchable Rider.

Evidence of Colin T. Fitzhenry and Michael P. Gorman Page 11 12 13  NS Power's proposed design of the ELID Tariff and proposed charges and credits are imbalanced and over-charge PHP for its cost of providing service. 14 15 16 17 18  PHP...

AI summary The evidence provided by Colin T. Fitzhenry and Michael P. Gorman critiques NS Power's proposed ELID Tariff design, arguing that it is imbalanced and over-charges PHP. They recommend that the ELID Tariff should include a capacity charge for firm demand service and recover non-firm power supply costs through the energy charge.

1 II. NS POWER'S PROPOSED ELID TARIFF

AI summary This document outlines NS Power's proposed ELID tariff, which is under consideration by the Nova Scotia Energy Board. The proposal may involve rate design and regulatory approval processes, though specific details are not provided in the excerpt.

2 Q PLEASE DESCRIBE NS POWER'S PROPOSED ELID TARIFF FOR PHP. 3 A NS Power is requesting approval of an Extra Large Industrial Dispatchable ("ELID") 4 Tariff for PHP, to be available on, or before, January 1, 2027, following the termination...

AI summary NS Power proposes an ELID Tariff for PHP, replacing the expiring ELIADC Tariff. The ELID includes a Dispatchable Rider allowing NS Power to curtail PHP's load above 8 MW to reduce system costs and ensure reliability. PHP retains 8 MW firm demand rights, with NS Power prioritizing other customers during curtailments.

17 Q DOES NS POWER RECOVER PORTIONS OF ITS GENERATING RESOURCE 18 COST THROUGH THE ELID ENERGY CHARGE? 19 A Yes. NS Power uses a System Load Factor ("SLF") methodology to functionally allocate generating resource cost to demand and energy....

AI summary NS Power uses a System Load Factor (SLF) methodology to allocate generating resource costs to demand and energy under the ELID Tariff. This approach applies uniformly to all generation assets, allowing PHP to support cost recovery of a significant portion of generating resource costs through the ELID energy charge.

3 Q HOW SHOULD THE ELID TARIFF BE CHANGED TO MORE EQUITABLY REFLECT 4 PHP'S FIRM AND INTERRUPTIBLE SUPPLY? 5 A The ELID provides both firm service and interruptible service to PHP. The cost of firm 6 service is based on NS Power's COS, whi...

AI summary The ELID tariff should reflect PHP's firm and interruptible supply by allocating capacity costs based on NS Power's cost of service (COS), including the Planning Reserve Margin (PRM). Interruptible demand beyond firm levels does not incur additional capacity costs as it can be curtailed during shortages.

capacity additions, $13.107/KVA. 8 Q IF THE ELID INTERRUPTIBLE CREDIT WAS SET AT NS POWER'S AVOIDED 9 CAPACITY COST OF $13.107/KVA, WOULD PHP PAY ANY CAPACITY COST FOR 10 ITS INTERRUPTIBLE SERVICE? A Yes. The proposed ELID 2027 energy char...

AI summary The ELID interruptible credit at $13.107/KVA does not fully offset capacity costs for PHP. NS Power's energy charge ($0.1124/KWh) exceeds its fuel cost ($0.08299/kWh), creating non-fuel margins. PHP would pay the difference between the demand charge ($14.310/kVA) and the credit. NS Power's capacity costs have risen since the $160.44/kW benchmark in the ELID tariff, based on the 2020 IRP and 2019 Supply Options Study.

12 Q WHAT DO YOU RECOMMEND THIS BOARD APPROVE AS THE APPROPRIATE 13 R/C RATIO APPLICABLE TO PHP IN THIS PROCEEDING? 14 A We would recommend that an R/C ratio of 1.0 be applied to PHP's rate calculation 15 under the proposed ELID tariff. PH...

AI summary The BOARD recommends an R/C ratio of 1.0 for PHP under the ELID tariff, arguing PHP as a new customer class should pay its full cost to serve without subsidizing or being subsidized by other classes.

9 Q. Please describe how the dispatch of PHP's electricity load is managed by 10 NS Power and PHP under the ELIADC Tariff. 11 12 A. NS Power, the NSPSO, and PHP are all highly coordinated in the dispatch of 13 PHP's load. The Active Demand...

AI summary NS Power, NSPSO, and PHP coordinate dispatch under the ELIADC Tariff via the ESP protocol. DA and RT schedules are shared daily and hourly, with adjustments for system changes. NS Power uses economic energy analysis, and PHP notifies of constraints to adjust schedules.

14 Q. Please explain why PHP is interested in NS Power's Application for an 15 Extra Large Industrial Dispatchable Above-the-Line Tariff. 16 17 A. PHP is currently a below-the-line customer that is billed for the highest priced 18 marginal...

AI summary PHP, a below-the-line customer, seeks an above-the-line tariff for greater energy cost predictability amid volatile marginal pricing. This would reduce risks from uncertain power availability and support long-term investments, especially with their new wind facility under a fixed-price PPA. The tariff would provide stability against hourly pricing fluctuations.

9 Q. How will the dispatch of PHP's load change under the Active Demand 10 Control Protocol if PHP takes service under an Above-the-Line Tariff? 11 12 A. PHP assumes that the ADC component of the ELID tariff and its associated 13 protocol...

AI summary PHP anticipates minimal changes to the ADC component of the ELID tariff, maintaining dispatchability similar to ELIADC while adapting to electronic dispatch and revised reporting requirements. Coordination with NSPSO will be needed for process development.

Response IR-7: (a) No, the ELID Tariff demand and energy elements are costed on an embedded cost basis like other above-the-line customers. The costing and pricing of the energy and demand components has been determined through the Company...

AI summary The response addresses the ELID Tariff, stating that it is costed on an embedded cost basis and references the 2026-2027 General Rate Application Settlement Agreement. It also notes that no review of PHP's financial condition has been undertaken and directs to another document for further details on LIIR Tariff rates.

9 Table 3 – Estimate of PHP's 2026 and 2027 Charges under the ELID Tariff, using 10 PHP's Actual Load in 2025 Year Energy (GWh) Monthly Demand (MW) Firm portion of monthly demand (MW) Energy Charge (cents/ kWh) Demand Charge ($/KVA) Interr...

AI summary Table 3 provides an estimate of PHP's 2026 and 2027 charges under the ELID Tariff, based on PHP's actual load in 2025. The table includes energy charges, demand charges, interruptible credits, and total charges for each year.

NSPI Responses to BW Information Requests 1 Request IR-9: 2 3 Please refer to Exhibit N-1, page 10 lines 5-7 and section 2.5. 4 5 (a) Please identify "the cost of providing DR service" that "is borne by PHP." Is this a 6 reference to the C...

AI summary NSPI responds to BW's information requests regarding the ELID Tariff, addressing dispatch instructions, cost allocation, enforcement mechanisms, and exogenous factors affecting PHP's consumption. Questions focus on cost recovery, dispatchability, and tariff compliance.

DETAIL OF MONTHLY CLASS SYSTEM COINCIDENT KW DEMAND FOR THE YEAR ENDING DECEMBER 31, 2026 (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) TOTAL SMALL GENERAL SMALL MEDIUM LARGE SHORE REAL TIME MONTH COMPANY DOMESTIC...

AI summary This document details monthly coincident kW demand across various customer classes in Nova Scotia for 2026, including breakdowns for small, medium, large industrial, and municipal sectors. It highlights demand patterns, interruptions, and firm large industrial demands, relevant to regulatory proceedings on energy management and tariff structures.

ALLOCATION FACTOR INFORMATION Calendar Month of System Peak 1 (155) (156) System Coincident 3CP DMD (157) EHV - LIR 60,986.8 (158) HV - LIR (159) HV - Municipal 55,214.2 51,011.0 (160) Distribution BP Substation - LIR (161) Distribution BP...

AI summary The text presents a table with allocation factor information, including system peak calendar months and associated loss factors for the ELIADC. It includes data on various system components and their respective values.

REDACTED (Attachment Only) 1 (a) Please refer to the following: 2 (i) Partially Confidential Attachment 2 and Partially Confidential Attachment 3. 3 (ii) Partially Confidential Attachment 4 and Partially Confidential Attachment 5. 4 (iii)...

AI summary The document refers to various attachments and matter numbers related to the 2026 PHP revenue under the ELIADC Tariff, as well as cost-of-service models and general rate applications. It includes references to partially confidential attachments and specific matter numbers such as M12451 and M1266.

FOR THE YEAR ENDING DECEMBER 31, 2026 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- SYSTEM (5) COINCIDENT COINCIDENT COINCIDENT (6) (7) LINE (8) SYSTEM DEMAND SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT (10) 3CP (11) 3CP % (11) SUB-TOTAL 1...

AI summary The document presents a summary of energy usage and related metrics for the year ending December 31, 2026, including data on various energy lines, demand, and percentages. It includes subtotals and breakdowns for different categories, such as shore power, generation replacement, and ELIADC.

FOR MARCH 2027 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT (12) SHORE POWER (13) GEN.REPL./LOAD FOLL. (14) ELIADC (15)...

AI summary The table presents data for March 2027, including energy line items, system coincident demand, and export sales. It shows various categories such as Shore Power, GEN.REPL./LOAD FOLL., ELIADC, and others, with corresponding values and percentages. The data includes sub-totals and total figures for energy and demand lines.

REVENUE TO EXPENSE COMPARISON (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (371) (372) FX COST REVENUE OF BTL RATE CLASSES (373) SHO...

AI summary The document presents a revenue to expense comparison table, detailing various cost and revenue categories including FX cost revenue of BTL rate classes, shore power, generation replacement, load follow, ELIADC, BUTU, and spill. The table includes total costs, unit costs, and variances for different operational and customer-related categories.

Distribution Primary Voltage - Municipal ELIADC - MWh Loss Factor ELIADC - Peak kW Loss Factor 2.5% 4.3% 2.5% 4.0% 2.6% 3.3% 2.4% 2.9% 2.3% 2.6% 2.3% 2.2% 2.2% 2.5% 2.1% 2.6% 2.3% 2.6% 2.3% 2.8% 2.5% 3.6% 2.4% 4.3% 45,013.2

AI summary The document provides allocation factor information for Distribution Primary Voltage - Municipal, including ELIADC - MWh Loss Factor and ELIADC - Peak kW Loss Factor across different periods, with percentages and a final value of 45,013.2.

FOR SEPTEMBER 2026 (1) MWH SALES (2) ENERGY LINE LOSSES (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM COIN. PEAK DMD. (KW) (9) SYST...

AI summary The table presents energy sales, losses, and demand metrics for September 2026. It includes data on total energy sales, energy losses, system demand, and various subtotals such as shore power and ELIADC. The data highlights energy requirements, demand factors, and losses associated with the system.

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.

CONFIDENTIAL (Attachment Only) - The requested timeline for each event where a customer has been provided with an Advisory, Alert, or Interruption request, including showing the dispatch of NS Power resources and PHP load under the ELIADC...

AI summary NS Power explains that detailed timelines for customer advisories, alerts, and interruptions under the ELIADC Tariff are not readily available due to data complexity. They also clarify that no interruption calls have been initiated under the ELIADC Tariff since 2020 and that only interruptible customers with Telemetry & Control are held in reserve.

NSPI Responses to Industrial Group Information Requests 1 Request IR-16: 1 classes (including the ELID Tariff). So, when the year-end math is performed to determine 2 the DR credit to PHP, all else being equal, the BCF would be unchanged....

AI summary NSPI responds to information requests regarding the ELID Tariff and its impact on the BCF and FAM Riders. The response explains that the DR credit to PHP does not affect the BCF, and notes that the ELID Tariff offers a more streamlined and transparent process for future FAM calculations.

NON-CONFIDENTIAL 1 (AGC) volumes will be included on PHP's bill as appropriate and PHP will be 3 PHP (at its levelized load). This is unchanged from current FAM operations (other than the 4 inclusion of PHP). 5 6 It is expected that change...

AI summary The text discusses how changes in fuel costs will impact the compensation paid to PHP for load flexibility under the FAM mechanism. It explains that the DR design is a 'zero-sum' system, where PHP is compensated and the FAM is charged based on savings. The compensation will be recovered through a BTL category in the COSS BCF spreadsheet, similar to the ELIADC Tariff. The impact of these changes on other FAM rate classes is expected to be minimal.

NON-CONFIDENTIAL 1 For clarification, there have been no interruptions of PHP load under the ELIADC tariff, 2 thus there are no PHP load interruption records. For interruption records for LIIR 3 customers, please refer to Synapse IR-5 Atta...

AI summary The text clarifies that there have been no interruptions of PHP load under the ELIADC tariff, resulting in no records of such interruptions. For LIIR customer interruption records, references to Synapse IR-5 and Synapse IR-23 attachments are provided.

NON-CONFIDENTIAL It is important to keep in perspective the aspects of the Application with which PHP does not agree. The ELID Tariff is a comprehensive above-the-line (ATL) tariff construct that enables the transfer of the system's larges...

AI summary The document discusses disagreements between PHP and NS Power regarding the ELID Tariff, emphasizing that PHP's concerns are narrow and focused on costing/pricing matters in the Settlement Agreement. The Company argues that the ELID Tariff provides stability and cost recovery, while amending it would increase costs for other customers. The text references CA IR-2 and CA IR-9 for financial impact assessments.

NSPI Responses to NSEB Information Requests 1 Request IR-5: 5 6 7 8 If there is an application to further extend the ELIADC, even for only a short duration, that application must be supported by the financial information contemplated by th...

AI summary NSPI must provide detailed financial information and justification for any extension of the ELIADC tariff, even for a short duration, as required by the NSUARB. The timeline for completing this process and submitting an application to the Board has not yet been determined, but NSPI is prepared to expedite the process if needed.

NSPI Responses to Port Hawkesbury Paper Information Requests 1 Request IR-1: 11 12 and very high (e.g. 160 MW), depending largely on system load conditions and the level of PHP demand that produces the lowest cost to serve the system in 13...

AI summary The document discusses NSPI's responses to information requests regarding the determination of PHP coincident peaks, referencing the ELID Tariff and the use of judgment in establishing a demand billing determinant. It highlights the unique nature of the ELID Tariff and the need for judgment due to the characteristics of a single, large customer with dispatchable load.

NSPI Responses to SBA Information Requests 1 provisions of the ELID Tariff (and other interruptible tariffs such as Large Industrial 2 Interruptible Rider), the capability to hold interruptible customer load as the operating 3 reserve anci...

AI summary NSPI provides responses to SBA information requests regarding the ELID Tariff and other interruptible tariffs, including the Priority Interruptible credit and its derivation. The response references specific attachments and documents for further context.

NON-CONFIDENTIAL 1 randomized throughout the year to simulate the non-dispatched and thus unpredictable 2 customer load, which would not be concentrating full-day outages in high price periods to 3 achieve an economic benefit. The comment...

AI summary The text discusses the ELID Tariff and the Dispatchable Rider (DR) for PHP, emphasizing alignment of ATL customer interests. It notes the need for randomized outage simulations to avoid economic biases and references Synapse and SBA documents. The DR aims to credit PHP fully for load dispatch, ensuring cost alignment.

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-1: 2 3 Refer to NS Power's Application, p. 3, lines 8-10 regarding the expiration of the ELIADC 4 tariff by the end of 2026 and an "alternative course of ac...

AI summary The document outlines NSPI's responses to Synapse Energy Economics, Inc.'s information requests regarding the ELIADC tariff expiration and alternative course of action if Port Hawkesbury Paper LP does not subscribe to the ELID tariff. It also inquires about the distinction between above-the-line and below-the-line tariffs.

REDACTED 1 (d) Please refer to Confidential Attachment 2. Note the Cause Code "NDN" identifies the 2 down dispatches initiated by the Nova Scotia Power System Operator. 3 4 (e) There are no non-NS Power tariff related load shifting actions...

AI summary The text discusses load reductions initiated by Nova Scotia Power and the Nova Scotia Power System Operator (NSPSO) for PHP under the ELIADC Tariff, noting that these reductions are not classified as 'gray area reductions' and are governed by the ELIADC Tariff Protocols. It references attachments containing details on dispatch codes, load shifts, and operating procedures.

1 (h) For all 25 instances where LIIR customers were interrupted in the period 2022-2025 2 inclusive, PHP's load was either dispatched down by NS Power Energy Marketing ahead 3 of time due to forecasted system conditions or dispatched down...

AI summary The document discusses 25 instances of LIIR customer interruptions between 2022-2025, where PHP's load was dispatched down by NS Power Energy Marketing or NSPSO due to system conditions. Under the ELID Tariff, LIIR interruptions are anticipated during capacity shortfalls, with potential reductions in load if capacity issues worsen.

CONFIDENTIAL (Attachment Only) 1 Request IR-6: 2 3 Refer to the Application, p. 3, regarding the ELID tariff being based on the Large Industrial 4 tariff. 5 6 (a) In Excel with working formulas and all billing determinants, please provide...

AI summary The document requests Nova Scotia Power Inc. (NSPI) to provide detailed bill calculations for Port Hawkesbury Paper LP (PHP) under the Large Industrial (LI) and Real Time Pricing tariffs for 2023-2024, including load differences and impacts on billing. It also asks whether PHP's load would have varied under these tariffs and how that would affect costs.

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-7: 18 ELIADC Tariff under which PHP is currently served, the Company has approximately 19 280.0 MW of interruptible load on a system peak of 2,459 MW. 20 21...

AI summary NSPI provides information regarding the ELIADC Tariff and the calculation of the IR credit value, referencing specific GRA attachments and other related requests. The response discusses interruptible load and its role as an alternative to generation capacity acquisition.

Response IR-23: (a) The existing order of interruptibility by rate class was established through regulatory proceedings which gave rise to various interruptible service rates over the last few decades. The priority interruptible status of...

AI summary The document explains the historical basis for interruptible service rate prioritization, noting that the ELID Tariff's second position reflects longstanding practices accommodating large pulp and paper operations. It references regulatory proceedings and specific tariff structures, with GRLF load interruption prioritization detailed in IG IR-25 part (a).

CONFIDENTIAL (Attachment Only) would be completed at the end of the year to account for not just load shifting between hours but also months. Please see Synapse IR-16 part (a) for a calculation of DR credit methodology and can be used as a...

AI summary The text outlines methods for calculating DR credits, fuel cost savings from PHP's load management under the ELID Tariff, and two scenarios (A and B) explaining billing impacts. It references Synapse IR-16 and a Settlement Agreement, noting that fuel cost savings require annual dispatch comparisons in PortOps, not Excel.

FOR THE YEAR ENDING DECEMBER 31, 2027 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL PHP MUNICIPAL UNMETERED FACT...

AI summary The document presents data on demand and generation metrics for the year ending December 31, 2027, including percentages of responsibility across various categories and exhibits. The information is related to the ELIADC Tariff and is part of a regulatory proceeding, with some sections redacted as confidential.

Response IR-1: (a) Pursuant to section 16(3)(a) of the Board Regulatory Rules, N.S. Reg. 90/2021, PHP is not providing the requested information as PHP's confidential financial information is not relevant to the determination of a cost-bas...

AI summary PHP refuses to provide financial information as it is not relevant to the cost-based tariff under the Public Utilities Act. The ELIADC Tariff for 2026 has been approved at a lower rate than PHP's proposed ATL tariff. NS Power did not provide a marginal cost forecast for 2027, and PHP did not prepare its own forecast. The Large Industrial Tariff was reviewed but does not include dispatchable service provisions.

Response IR-2: - The market for paper is somewhat seasonal with winter and summer months having generally less demand than spring and fall. PHP's energy demand corresponds to this seasonal variance. Some customers only have one annual larg...

AI summary PHP's energy demand aligns with seasonal paper market fluctuations, with winter and summer months seeing lower demand. Grid access during peak winter months is noted as a constraint. The text also requests clarification on PHP's position regarding net costs under the ELIADC Tariff compared to alternatives.

Response IR-3: PHP agrees with the proposition that the ELIADC Tariff has had a cost to PHP versus a more standardized tariff that does not expose PHP to the variations of energy supply that can limit operations of PHP lines. The wear and...

AI summary PHP acknowledges the ELIADC Tariff's operational costs due to equipment strain from frequent load variations but lacks quantified data. PHP does not provide hourly forecasts, instead using monthly load shapes. The GRA Settlement Agreement reference is deferred to a prior response.

Response IR-2: (a) Neither PHP nor BAI have conducted an independent production-cost modelling or analysis regarding the potential system savings achievable through dispatch of PHP's load. Such estimates are highly dependent on actual syst...

AI summary PHP and BAI argue they have not conducted independent production-cost modeling for dispatch savings, emphasizing the proposed methodology's reliance on actual system conditions. They note discrepancies between modeled and realized savings due to unpredictable events and lack access to NS Power's proprietary model. The ELIADC Tariff's past performance is cited as a reference.

2 Response IR-6: (a) Confirmed. The reduction of PHP load during peak events is likely to produce savings to the benefit of PHP under both the ELIADC Tariff and the proposed ELID Tariff.

AI summary The response confirms that reducing PHP load during peak events is likely to produce savings for PHP under both the ELIADC Tariff and the proposed ELID Tariff.

Request: Please confirm, or explain otherwise, if it is BAI's understanding that in accordance with the Company's proposed cost-of-service methodology, as supported by PHP, and the proposed rate design, under the proposed ELID Tariff: (a)...

AI summary The request seeks confirmation from BAI regarding the proposed ELID Tariff's cost-of-service methodology, specifically whether non-fuel energy-related fixed costs are included in the Energy Charge and if demand-related costs are recovered solely through a demand charge.

icant transmission capacity costs to PHP's interruptible load, which is assumed to be absent during peak periods, would result in an over-allocation of costs that does not reflect actual system usage. Request IR-10: Reference: Evidence of...

AI summary The text discusses concerns about the ELID Tariff's cost allocation for PHP's interruptible load, arguing that NS Power's proposal ignores PHP's operational costs. BAI asserts that PHP should be compensated for operational benefits under the ELID Tariff rather than recovering costs through it, and questions whether incremental costs should reduce energy savings benefits under the ELID or ELIADC Tariff.

Request IR-2: Refer to M12661, Exhibit N-3, the PHP Evidence, page 6, lines 6-7, where it states, in reference to the benefits that ADC provides the grid, "If this practice is expected to continue, an improved tariff protocol will be requi...

AI summary Request IR-2 seeks clarification from PHP on tariff provisions requiring improvement under the ELID relative to ELIADC, specifically addressing reliability events, dispatch communication, and other provisions. It also asks which issues have been addressed in NS Power's ELID filing and requests a redline version of the ELID tariff.

on for failure to interrupt as the current ELIADC Tariff (Application, Attachment 1, page 6): - (4) Failure to comply in whole or in part with a requirement to interrupt load will result in penalty charges. The penalty will be comprised of...

AI summary The text outlines penalty charges under the ELIADC Tariff for non-compliance with load interruption requirements. Penalties include a Threshold Penalty based on firm billing costs and a Performance Penalty calculated using a formula involving kVA rates (15/kVA for A and 30/kVA for B).

Responses to IG Consultant (Bowman) Questions – 2 of 4 Question NS Power Response Please also refer to 2. The PHP related savings from optimizing load are indicated to be already included in the COS from the GRA. NSP indicates this means t...

AI summary The document discusses responses from NS Power to questions raised by an IG consultant regarding demand response (DR) savings and the Customer Baseline Load (CBL) calculation. It explains that if PHP does not optimize load, the costs would be absorbed by NS Power, and the CBL is based on a high-load factor annual profile to ensure optimal energy use.

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.

e Demand Control under the ELIADC Tariff and the Dispatchable Rider under the ELID Tariff are limited to changes to incorporate the provisions of dispatchable service and nomenclature.[25](#page-10-5) When questioned about the value that o...

AI summary The document discusses NSP's response to concerns about the ELID Dispatchable Rider, explaining that under the ELID Tariff, PHP customers fully cover fixed costs, benefiting all customers. However, the value from dispatching PHP load accrues solely to PHP, as their charges are embedded cost-based, aligning with ATL tariff principles.

ate the value of the Dispatchable Rider Credit, NSPI will conduct an after-the-fact production cost simulation model run to determine the total system FAM costs using "actual system conditions that occurred throughout the year," but assumi...

AI summary NSPI proposes calculating the Dispatchable Rider Credit via a production cost simulation, assuming PHP operates at a high load factor. The process involves subtracting adjusted costs from system FAM costs. NSPI's GRA (M12451) is cited as an ongoing matter related to this proceeding.

14 Q. Please summarize the direct evidence submitted on behalf of PHP. 15 A. On February 20, 2026, PHP filed evidence in this matter that included evidence co-sponsored by 16 two PHP employees (Bevan Lock and John Esaiw, respectively the C...

AI summary PHP submitted evidence opposing the ELID Tariff, requesting four changes: lower winter demand metrics, higher interruptible credits, adjusted revenue-to-cost ratios for an above-the-line tariff, and updated energy forecasts. Brubaker & Associates supported these positions. PHP's evidence was filed on February 20, 2026.

- not undertake a review of PHP's financial condition.[32](#page-6-1) In response to a data request, PHP chose not to - provide its annual financial statements and indicated that "[n]othing in the [ELID] Tariff proposed in the - Applicatio...

AI summary PHP has declined to provide its annual financial statements, asserting that the ELID Tariff and proposed modifications are not dependent on its financial circumstances.

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. What is the specific value of the Customer Charge proposed for the ELID Tariff? - A. NSPI proposes a charge of $10,000 to apply for each month through the end of 2027. [37](#page-8-3) After - 2027, NSPI proposes that "the ELID Tariff Cu...

AI summary NSPI proposes a $10,000 monthly Customer Charge for the ELID Tariff until 2027, after which it will be determined through future General Rate Application proceedings.

NSPI then simply selected the "low" end of this estimated range, or $10,000/month. 2 Q. Did NSPI elaborate on why it used the low end of the Customer Charge range? - A. NSPI explained that "the internal processes required to support the EL...

AI summary NSPI selected the lower end of the estimated Customer Charge range at $10,000/month. When asked why, NSPI explained that internal processes supporting the ELID Tariff are under development.

Q. What is your recommendation regarding the proposed Customer Charge? - A. We recommend that NSPI file additional evidentiary support for its proposed Customer - Charge. Absent this, we recommend NSPI set the Customer Charge for 2026 and...

AI summary The recommendation suggests NSPI must provide additional evidence for the proposed Customer Charge. If not, set it at $12,291.67/month (midpoint of its estimate range) with reconciliation mechanisms ensuring PHP receives credits if actual ELID Tariff costs are below collections. NSPI must also explain cost-tracking methodologies for ELID Tariff administration.

III. Assessment of the Energy Charge - Q. Please summarize the ELID Energy Charge proposed in NSPI's application. - A. NSPI proposes an Energy Charge of 9.977 ¢/kWh in 2026 and 11.240 ¢/kWh in 2027. 52 - Q. How were the Energy Charge rates...

AI summary NSPI proposes ELID Energy Charges of 9.977 ¢/kWh (2026) and 11.240 ¢/kWh (2027), calculated via a cost-of-service study (COSS) that treats PHP as an ATL customer. The rates incorporate fixed costs and net PHP load after subtracting Goose Harbour output (507 GWh), reducing PHP's modeled load to 304 GWh. This lowers PHP's total payments but increases per-kWh charges due to fixed cost allocation.

Q. Do you have concerns regarding the way the Energy Charge was determined? - A. Yes. Most significantly, we conclude that the net PHP load used in deriving the ELID Energy - Charge is too high, and the resulting Energy Charge rates are co...

AI summary The respondent raises concerns that NSPI's calculation of the ELID Energy Charge is flawed, citing an overestimated PHP load and an underestimated Goose Harbour capacity, leading to an incorrect net load figure and thus undervalued Energy Charge rates.

Q. What is the effect of PHP net load being too low in the COSS? - A. In most direct terms, if PHP's net load in 2027 subject to the Energy Charge is 121 GWh rather - than 304 GWh, a 60% reduction, the revenue from PHP to NSPI would be low...

AI summary A lower PHP net load in the COSS reduces NSPI's revenue by ~$21M (60% reduction) and increases ELID Energy Charge rates due to fixed costs not scaling with energy use. This risks under-contributing to system costs, shifting burdens to other FAM customers. NSPI's application uses an inflated PHP net load, leading to undervalued Energy Charge rates.

the proposed Energy Charge? - A. No, not based on our reading of the proposed PHP Deferral account provisions. As specified in - the GRA Settlement, the PHP Deferral account is only intended to address effects from one or more of the - fol...

AI summary The proposed Energy Charge deferral is not applicable under the GRA Settlement, which limits the PHP Deferral account to specific scenarios. The text clarifies that distortions from PHP net load discrepancies with NSPI's ELID Energy Charge modeling are not covered by the deferral provisions.

Q. What do you recommend with respect to the ELID Energy Charge? - A. We recommend that the Board does not approve the ELID Energy Charge as proposed. We - recommend that NSPI be required to update the COSS model to better reflect likely P...

AI summary The recommendation is to reject the ELID Energy Charge as proposed, emphasizing the need to update the COSS model with accurate PHP net load estimates, including Goose Harbour's 168 MW capacity output. Modifying other ELID tariff components without this update risks under-recovery of costs from PHP, increasing FAM customer risk.

IV. Assessment of the Dispatchable Rider Credit

AI summary The document section evaluates the Dispatchable Rider Credit, focusing on its implications for rate structures and cost recovery mechanisms within Nova Scotia's energy regulatory framework. Key considerations include alignment with existing programs and impacts on stakeholder interests.

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.

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. 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 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.

Application (GRA)? A. NS Power's 2026-2027 GRA was resolved through a settlement agreement[9](#page-6-5) that was 2026-2027 GRA SR-01, Attachment 1b, p. 2, lines 21-24. Response to Synapse IR-2(c), 2026-2027 GRA SR-01, Attachment 1b, p. 2,...

AI summary The 2026-2027 GRA Settlement Agreement was approved with modifications, outlining assumptions for PHP's load characteristics and the creation of a regulatory deferral account to address variances between the ELID tariff and GRA assumptions. The agreement allows flexibility in the ELID tariff filing.

NS Power ELID Application, page 14. 1 subject to future recovery from ATL customers, subject to Board approval. These 2 differences may include final approved tariff design, PHP's participation, or related cost 3 12 and load assumptions. 4...

AI summary The ELID tariff is based on NS Power's existing Large Industrial (LI) tariff, with an Interruptible Rider and a Dispatchable Rider. Key elements include monthly customer charges, demand and energy charges, and various riders such as the fuel adjustment mechanism and demand-side management cost recovery.

Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report (NSEB M12768) NSPI Responses to BW Information Requests 1 Request IR-1: 2 3 For each month of 2025, please provide: 4 5 (a) ELIADC Energy Charge 6 7 (b) CBL En...

AI summary The document provides responses to information requests regarding the ELIADC Tariff 2025 Annual Report. It outlines where to find specific charges and mentions a confidential attachment related to the calculation of the CBL Energy Charge for 2025.

NON-CONFIDENTIAL 1 For the NSPSO, data relevant to the administration or reporting of the ELIADC Tariff was 2 minimally impacted by the cyber incident. The web-based application used to maintain 3 System Operator logs was unavailable in th...

AI summary The NSPSO's administration of the ELIADC Tariff was minimally affected by a cyber incident. The web-based application for maintaining System Operator logs was unavailable initially, leading to the use of manual logs to capture system events such as loss of generating units and real-time PHP re-dispatch.

Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report (NSEB M12768) NSPI Responses to BW Information Requests

AI summary The document outlines the Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report and Nova Scotia Power Inc.'s (NSPI) responses to BW Information Requests, providing insights into the tariff's implementation and related inquiries.

Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report (NSEB M12768) NSPI Responses to IG Information Requests 1 Request IR-1: 2 3 4 Reference: 2025 Annual Report, Exhibit N-1, p. 3/9, Table 1 5 (a) Please explain...

AI summary The document outlines a request and response related to the ELIADC Tariff 2025 Annual Report, focusing on the benefits reported for 2025 compared to initial forecasts and the factors influencing the ADC load shifting differential. The response references a 2019 tariff application and provides context on expected annual benefits.

NON-CONFIDENTIAL - 1 movement, consistent with NS Power's internal calculations of load shifting benefits of the - 2 ELIADC Tariff. Date Filed: May 8, 2026 NSPI (IG) IR-1 Page 4 of 4

AI summary The text references the ELIADC Tariff and mentions load shifting benefits calculated internally by NS Power. It also includes a date and page reference from a filing by NSPI.

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).

NON-CONFIDENTIAL 1 Request IR-10: 2 3 Has NSPI omitted any data, analysis or internal assessments from the Annual Report 4 regarding ELIADC operations in 2025 that were available to NSPI, on the basis that such 5 information will not be re...

AI summary NSPI has been asked whether it omitted any data, analysis, or internal assessments from the Annual Report regarding ELIADC operations in 2025, based on the assumption that such information would not be required under a successor tariff. NSPI responded that it did not omit any such information.

10 Recommendation XV-3 11 12 However, in its efforts to provide useful and meaningful quantifications, NS Power 13 continued to pursue and, in the 2025 ELIADC Tariff Annual Report, has provided more 14 data and metrics and has additionally...

AI summary NS Power has been working to improve quantifications of ADC load shifting benefits in the 2025 ELIADC Tariff Annual Report, using PortOps-based backcast modelling. This work was paused due to a cyber incident but is expected to resume once data is collected and models are tested in the new version of PortOps.

14 Year 2020 2021 2022 2023 2024 2025 ELIADC Tariff Energy Sales (GWh) 875 966 957 670 766 691 Revenue ($M) 55.5 60.3 170.1 28.31 77.7 70.9 Revenue (ȼ per kWh) 6.3 6.2 17.8 4.2 10.1 10.3 Large Industrial Tariff Energy Sales (GWh) 726 759 7...

AI summary The 2022 ELIADC Tariff Annual Report and a change in methodology for calculating the cost to serve PHP load was approved by the Board on July 5, 2023, leading to a $50.9 million adjustment in 2022 fuel recovery for the ELIADC Tariff compared to a preliminary calculation using forward replacement pricing.

1 Request IR-1: 2 3 Refer to M12768, Exhibit N-1, NS Power's Extra Large Industrial Active Demand Control 4 (ELIADC) Tariff – 2025 Annual Report – Redacted, dated March 26, 2026, (the "2025 5 Report"), which states, on page 2 at para 2: 6...

AI summary The document references M12768, Exhibit N-1, NS Power's ELIADC Tariff, and discusses the 2025 Annual Report. It notes that in 2025, the difference between the forecast CBL Energy Charge and actual cost to serve resulted in a positive ADC differential, requiring PHP to pay the full actual CBL cost to serve, including additional costs from variances from dispatch schedules.

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.

Request IR-2: Refer to Section V of Bates White Evidence, where Bates White notes that PHP receives significant benefits from the treatment of Goose Harbour output as a direct reduction of its purchases of tariff energy under the ELID Tari...

AI summary Bates White raises concerns that treating Goose Harbour output as a direct reduction of PHP's tariff energy purchases under the ELID Tariff may distort cost allocation. The question seeks whether this necessitates robust design of ELID Tariff elements like the Customer Charge and Dispatchable Rider, along with verifiable true-up mechanisms for accurate cost recovery from PHP.

8 Response IR-2: 9 (a) Under the ELIADC, PHP in effect purchases marginal cost power. This is 10 an entirely different pricing model than embedded cost (or ATL) service. To 11 the extent PHP pays prices that exceed the marginal cost from m...

AI summary PHP purchases power under the ELIADC at marginal cost, differing from embedded cost pricing. If PHP pays prices exceeding marginal cost, it contributes to NSP's fixed costs.

IG Request IR-1: Reference: N-19, Evidence of InterGroup, p. 5/pdf p. 7. Preamble: In s. 4.1, Inclusion of Interruptible Load in 3CP Calculation InterGroup stated: In InterGroup's experience this is a common problem with "interruptible" lo...

AI summary InterGroup is asked to identify alternative cost allocation methods for interruptible loads in the ELID Tariff, explain their operation, and assess their impact on demand cost allocation. It is also asked whether it agrees with using PHP's expected CBL operating load and if any method aligns better with the principle that ATL customers should pay their proper share of embedded system costs.

beyond 2027, the Board direct NSP to develop an approach for verifying a reasonable baseline capacity for PHP that reflects normal business operating needs. e) In InterGroup's view, the SA load parameters were agreed upon by the parties to...

AI summary The Board directs NSP to establish a baseline capacity verification method for PHP post-2027. InterGroup questions NSP's rationale for increasing DR credit sharing from 25% to 100% under the ELID Tariff, noting PHP's existing VCC contributions under ELIADC. CA confirms InterGroup's view that PHP's status as an ATL customer justifies full DR credit allocation.

IG Request IR-3: Reference: N-19, Evidence of InterGroup, p. 10/pdf p. 12. In InterGroup's view, the proposed ELID Tariff includes many moving parts, including changes as compared to the ELIADC Tariff, with complex interactions between dif...

AI summary InterGroup raises concerns about the complexity of the proposed ELID Tariff, noting significant changes compared to the ELIADC Tariff and complex interactions between components. They argue the proposed DR credit ratio adjustment requires further reasonableness testing.

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.

CA Response IR-7: - a) Yes, with allowance for future refinements, also subject to the Board approval. - b-c) InterGroup considers that the scope of the first-year review should include testing the performance of each approved ELID Tariff...

AI summary InterGroup agrees to future refinements and supports a first-year review of the ELID Tariff's performance against NSP's targets. They also endorse quarterly reporting on DR status by NSP, aligning with Mr. Bowman's recommendation for transparency in funding estimates.

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.

CA Response IR-6: - a) and b) The stated assertion that the two services are distinct and PHP is being compensated for two separate value streams (IR for planning relief (i.e the avoided cost of building new generation) and DR for operatio...

AI summary The document discusses the potential for duplicate compensation to PHP under two separate mechanisms — the Dispatchable Rider and the Interruptible Credit — due to overlapping load reductions. NSP confirmed that PHP has not been called for load reductions under the ELIADC Tariff and that during capacity scarcity, PHP load is already dispatched down, raising concerns about double-counting of credits.

- Methodology and the Risk of Under-Recovery. At p. 12, lines 10-22, the evidence states: NSPI did not use a bottom-up methodology (using assumed labour hours and labour rates) to develop the estimate, nor did it use historical data to dev...

AI summary The evidence indicates that NSPI did not use a bottom-up methodology or historical data to estimate costs for the ELID and ELIADC Tariffs, despite similar operational processes between them.

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.

Request IR-9: - Reference: N-20, Bates White Evidence, p.26, line 18- p. 27, line 2 describes its fifth - concern relating to the use of forward replacement fuel pricing: However, NSPI has specifically veered away from using forward replac...

AI summary Bates White questions NSPI's use of forward replacement fuel pricing in the ELIADC Tariff for DR credit calculations, noting NSPI previously rejected this method in 2022 due to volatility concerns. Bates White seeks clarification on methodological consistency, rationale for current use, potential inflation of DR credits, and recommendations for alternative approaches.

Response IR-9: (a) NSPI's responses to NSPI-Synapse IR-24 (d) and NSPI-IG IR-16 (d) do not sufficiently elaborate on the specifics of the use of "forward replacement costs" to determine if the methodology being proposed is identical to the...

AI summary NSPI's responses to inquiries about 'forward replacement costs' lack sufficient detail to clarify if the methodology differs from the 2022 abandoned approach. Concerns are raised about inconsistencies with NSPI's recent ELIADC Tariff administration, which previously found forward replacement pricing overstates fuel costs. Clarification is requested on the methodology and inconsistency.

And: We also recommend NSPI explain the methodology for tracking the costs of administering the ELID Tariff and how NSPI plans to ensure that 100% of the costs incurred above in administering the ELID Tariff are paid by PHP, including thos...

AI summary The text requests NSPI to explain the methodology for tracking the costs of administering the ELID Tariff and how PHP will cover these costs. It also seeks Bates White's opinion on quarterly reporting, the relationship between annual evaluation and true-up mechanisms, and the sequencing of these mechanisms in case of over-generation. Additionally, it asks whether the Board should impose specific reporting obligations.

A No. PHP's current Tariff, the ELIADC Tariff, which will expire at the end of 2026, utilizes marginal energy cost rates. Marginal cost rates are generally applied to customers that are new to a system, charging them a premium energy rate...

AI summary PHP argues that its current ELIADC Tariff, which uses marginal energy cost rates, is unfair as it charges a premium to reflect incremental costs, despite PHP's long-standing contribution to the NS Power system. PHP requests a transition to a properly structured ELID Tariff on an ATL basis to ensure fair cost allocation and recognition of its operational flexibility.

V. RESPONSE TO BOARD STAFF WITNESS BATES WHITE Q CAN YOU BRIEFLY SUMMARIZE THE RECOMMENDATIONS OF BATES WHITE? A Bates White recommends that several key components of Nova Scotia Power's proposed ELID Tariff be rejected or substantially mo...

AI summary Bates White recommends rejecting or modifying several components of Nova Scotia Power's proposed ELID Tariff, including the ELID Energy Charge, DR credit framework, and mechanisms in the Power Sales Agreement, to prevent cost-shifting and under-recovery risks. They suggest recalculating the ELID Energy Charge using an updated COSS model and implementing an annual true-up mechanism for cost recovery.

EMBEDDED SYSTEM COSTS? A No. Bates White outlines a highly speculative scenario where PHP's annual net load drops to zero, concluding that the mill would completely evade its responsibility for embedded system costs. This claim relies on a...

AI summary The document critiques Bates White's argument that PHP could avoid embedded system costs if its net load drops to zero. It argues that even with a wind farm offsetting energy use, PHP remains responsible for fixed charges based on peak demand and grid infrastructure use.

hanism is approved under the ELID, PHP is unable to comment further on Bates White's stated concerns as they failed to elaborate or provide any suggestions as to how to further address their concerns. consider the reasonableness of the DR...

AI summary PHP is unable to comment further on concerns raised by Bates White due to lack of elaboration. The discussion revolves around the reasonableness of DR savings, the development of an ATL embedded cost based tariff, and the ELID's role in charging PHP its full cost of service. PHP highlights the operational and commercial costs of load shifting and the need for ADC benefits to accrue solely to PHP.

id="page-7-3"> In its Decision on the ELIADC Third Term Application (M12184), the Board directed NS Power file an application for the ELIADC successor tariff "no later than December 31, 2025."

AI summary The Board directed NS Power to file an application for the ELIADC successor tariff by December 31, 2025, following its decision on the ELIADC Third Term Application (M12184).

and, as a result, it is proposed the benefits accrue fully to PHP (other than the portion recovered from PHP through the FAM).[36](#page-17-1) While the ELIADC Tariff has a sharing mechanism, this was appropriate because the cost foundatio...

AI summary The text discusses demand assumptions related to the ELID Tariff, highlighting the sharing mechanism and the fixed non-fuel cost component for PHP. It also addresses concerns about the DR credit as an imperfect proxy for marginal price signals and the reasonableness of assuming a high load factor premise for the ELID Tariff.

NOTICE OF INTERVENTION TO: The Nova Scotia Energy Board ("Board") AND TO: Nova Scotia Power Inc. ("NSPI") - 1. PORT HAWKESBURY PAPER LP ("PHP") conducts its business in Nova Scotia, and is engaged in the manufacture of paper at its Port Ha...

AI summary Port Hawkesbury Paper LP (PHP) is requesting intervenor status in a proceeding before the Nova Scotia Energy Board, as it purchases significant amounts of power from Nova Scotia Power Inc. under the ELIADC Tariff and has a vested interest in the matter.

Refer to M12661, Exhibit N-1, 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: - a) Desc...

AI summary The text requests detailed explanations regarding the demand charge structure in the ELIADC Tariff for Port Hawkesbury Paper, including the rationale for specific MW values, definitions of terms like 'judgment', and comparisons with other tariff structures. It also asks about the consistency of billing demand definitions and cost implications.

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.

Table 1 – Cost of service of PHP by service area in thousands of dollars 2026 2027 Service Area M14251 CA IR- 001 M12451 U-3 Var. Var. M14251 CA IR- 001 M12451 U-3 Var. Var. (65 MW Demand) (8 MW Demand) ($) (%) (65 MW Demand) (8 MW Demand)...

AI summary The document includes a table detailing the cost of service for PHP by service area in thousands of dollars for the years 2026 and 2027, and references an application by NS Power for approval of the ELID Tariff and information requests to PHP.

M12661 – NS Power Application for Approval of the ELID Tariff NSPI Information Requests to PHP 1 2 3 site, that includes approximately 4MW that are needed to maintain the shared services required for the NS Power Port Hawkesbury Biomass Pl...

AI summary NS Power's ELID Tariff proposal is criticized for being imbalanced and for not considering the increased operating costs and production delays PHP incurs when providing NS Power with the right to dispatch and interrupt PHP's load with only 10 minutes' notice.

___________________________________ Crystal Henwood, Clerk of the Board 1 Request IR-1: Refer to NS Power's Application, p. 3, lines 8-10 regarding the expiration of the 2 ELIADC tariff by the end of 2026 and an "alternative course of acti...

AI summary The document outlines several requests related to the ELIADC tariff expiration, alternative course of action for Port Hawkesbury Paper LP, and the distinction between above-the-line and below-the-line tariffs in Nova Scotia Power's cost-of-service study.

- iii. Interruptible rider to the ELID Tariff 1 1. Billed interruptible demand 24 b. How would the firm billing be determined for a single month? In this response, please 25 respond to how the "addition" of incremental firm service is an a...

AI summary The text discusses the determination of firm billing for a single month under the interruptible rider to the ELID Tariff, emphasizing that the addition of incremental firm service is an annual or multi-annual commitment rather than a monthly one.

1. Refer to NS Power’s Application, p. 3, lines 8-10 regarding the expiration of the ELIADC tariff by the end of 2026 and an “alternative course of action” if Port Hawkesbury Paper LP (PHP) will not subscribe to the Extra Large Industrial...

AI summary The text outlines questions regarding the ELIADC tariff expiration, alternative tariffs for Port Hawkesbury Paper LP, and the distinction between above-the-line and below-the-line tariffs. It also requests information on cost allocation in NS Power’s cost of service study.

Email: [email protected] 1 2 IR-1 3 4 5 6 7 Reference: Application, page 5, lines 15-17. "In accordance with the Company's Cost of Service Study (COSS), demand-related costs are proposed to be allocated to the ELID Tariff cla...

AI summary The email references an application's cost of service study and a report on a cold weather event, requesting a breakdown of hourly net load by customer class, including PHP. It involves regulatory considerations related to demand-related cost allocation.

INFORMATION REQUESTS To: James MacDuff Legal Counsel McInnes Cooper 1300 – 1969 Upper Water Street Purdy's Wharf, Tower II Halifax, NS B3J 2V1 By e-mail: [email protected] From: Bates White LLC Responses Due : Thursday, March...

AI summary The document contains information requests from Bates White LLC to James MacDuff of McInnes Cooper, seeking PHP's financial statements, cost modeling under alternative tariffs, explanations of seasonal demand fluctuations, and energy forecasts for 2026 and 2027, as well as an assessment of potential contraventions of the GRA Settlement Agreement.

25 Request IR-12: - 26 (a) Where PHP's load under ELIADC was optimized along with other supply 27 resources in the development of the day-ahead dispatch plan to provide 28 the least cost dispatch of energy and ancillary services for custom...

AI summary The text presents two questions regarding the operation of ELID under the ELIADC tariff and its impact on day-ahead dispatch planning, specifically focusing on whether PHP's load optimization would affect ELID's operation and how PHP's load is dispatched during periods of low generation reserve margins.

2 Reference: N-1, ELID Application, page 11. Based on initial analysis completed in 2025 utilizing forecast data, the Company has estimated that for that period, if PHP load had been dispatched at 100 percent optimal, this service would ha...

AI summary The Company estimates that dispatching PHP load at 100% optimal could save PHP between $7 to $11 million annually, but actual savings are expected to be about half due to system conditions and customer constraints. This estimate is based on initial analysis from 2025 and experience with the ELIADC Tariff.

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. - 12 (a) Please elaborate on the sentence...

AI summary The text requests detailed explanations and data regarding the ELIADC Tariff, including operational examples, cost-of-service study data, and modeling for future years. It also asks how high load factors and SEA amounts are considered in calculations related to PHP and NSPI.

- (a) For each recommendation, quantify the specific impact on NSP's proposed ELID tariff charges and credits and the additional costs that would be allocated to PHP under Mr. Bowman's proposed approach. Provide all workpapers in excel for...

AI summary The text requests quantification of the impact of recommendations on NSP's ELID tariff charges and credits, as well as revised tariffs if all seven recommendations are adopted. It also asks for detailed Excel workpapers.

arkin.com>; Mike Willett ; Monique MacLean ; Muhammad Syfuddin Tamim ; Nancy Rubin ; Painting-MacLean, Kimberly ; Patrick Bowman ; Paul Dandurand ; Pronko, Steve ; Rebekah Powell ; Sofia Reiner ; Stefanie DeYoung ; Taylor Montgomery ; Vinc...

AI summary This message acknowledges the receipt of a response to IRs regarding the application for approval of the ELID Tariff, which is available to PHP. The response was received on June 18, 2026, and has been directed to the Board and staff. The documents have been posted in Matter No. M12661 on the Board's public website.

Statement of Confidentiality This message (including any attachments) may contain private or protected information meant for a specific person or organization. If you received this by mistake, please let the sender know, do not communicate...

AI summary This email is a confidentiality notice related to a regulatory proceeding (M12661) concerning the approval of the ELID Tariff by NSPI. It includes a list of recipients and is addressed to various stakeholders involved in the process.

Statement of Confidentiality This message (including any attachments) may contain private or protected information meant for a specific person or organization. If you received this by mistake, please let the sender know, do not communicate...

AI summary This email is a confidentiality notice related to a regulatory proceeding involving the ELID Tariff and PHP, sent by William Mahody to multiple recipients including Nova Scotia Power Inc. and Efficiency Nova Scotia.