Topic:"Equity Access" in M12451

Re: M12451 – Nova Scotia Power Inc. – 2026 General Rate Application (GRA) – Letter of Comment On behalf of the Kwilmu'kw Maw-klusuaqn Negotiation Office (KMKNO) and the Assembly of Nova Scotia Mi'kmaw Chiefs, we respectfully submit comment...

AI summary The Kwilmu'kw Maw-klusuaqn Negotiation Office (KMKNO) and Assembly of Nova Scotia Mi'kmaw Chiefs request a dedicated Mi'kmaq Rate Class under Matter M12451, citing disproportionate energy burdens from historical underinvestment, remote geography, and low incomes. They argue existing programs inadequately address unique challenges and emphasize the need for energy sovereignty and affordability.

Socio-Economic Vulnerability - Median household incomes in Mi'kmaq communities remain significantly below the provincial average, increasing the percentage of income required to meet basic energy needs. - Energy poverty prevalence is highe...

AI summary Mi'kmaq communities in Nova Scotia face higher energy poverty due to lower median incomes and higher per-unit energy consumption. Systemic historical inequities exacerbate their vulnerability to electricity rate increases, requiring a larger share of income for basic energy needs.

Structural and Housing-Related Vulnerability - Older, draft-prone, or poorly insulated housing results in systematically higher electricity usage per household for heating, hot water, and appliances. - Limited access to deep-retrofit finan...

AI summary Older, poorly insulated housing increases electricity usage for heating and hot water. Limited retrofit financing hinders energy efficiency. Community-owned buildings (e.g., schools, health centres) serve Mi'kmaq wellness and governance but face high energy demands.

Geographic and Infrastructure-Based Vulnerability - Many Mi'kmaq communities are rural or semi-remote, facing: - o Reduced access to natural gas or alternative heating fuels. - o Higher reliance on electric heating systems. - o Increased c...

AI summary Mi'kmaq communities in Nova Scotia face heightened energy challenges due to geographic isolation, reliance on electric heating, and increased maintenance costs. Climatic factors like wind and coastal weather further elevate energy demands in these communities.

Demographic Vulnerability - Communities include higher proportions of elders, youth, and low-income households, all of whom are more sensitive to rising energy costs. - Affordable, reliable electricity is foundational for: - o Exercising g...

AI summary Communities with higher proportions of elders, youth, and low-income households face greater vulnerability to rising energy costs. Affordable electricity is essential for governance, cultural preservation, health, and well-being. Reconciliation obligations require the Crown and its agencies to address systemic inequities and prevent disproportionate impacts on vulnerable populations.

Evidence of Disproportionate Energy Burden - Mi'kmaq households consistently spend a larger share of income on electricity than non-Indigenous households. - Weatherization and Demand Side Management (DSM) programs have historically underse...

AI summary Mi'kmaq households face disproportionate energy burdens due to higher electricity costs, underserved weatherization and Demand Side Management (DSM) programs, and the inability of Band facilities to reduce consumption without harming community services. Rate increases exacerbate these issues through non-linear impacts.

AVAILABILITY This tariff is applicable to electric energy for use where the annual consumption is less than 32,000 kWh per year and for which no other rates are applicable, and is available to customers on the General tariff where the annu...

AI summary This tariff applies to electric energy consumption below 32,000 kWh/year and is available on the General tariff for up to 45,000 kWh/year. Customers on the Small General tariff must request service in writing, may switch rate classes twice every 24 months, and must remain on the tariff for six months post-switch if load thresholds are met.

AVAILABILITY CONDITIONS - (a) The customer must commence service under this tariff on November 1st, unless NSPI grants a waiver. - (b) The customer must be equipped with a standard Smart Meter. - (c) The customer must be on electronic bill...

AI summary The availability conditions for the tariff require customers to start service on November 1st (with possible waivers), have a Smart Meter, use electronic billing, and maintain a MyAccount profile. NSPI may limit enrollment and exclude customers on seasonal or Net Metering services under specific regulations.

Interpretation In these regulations unless the context requires otherwise: Words importing male persons include female persons and corporations. Words importing the singular include the plural and vice versa. Marginal notes and appended ci...

AI summary The regulations define interpretive principles, including gender inclusivity in language, singular/plural equivalence, and the exclusion of marginal notes and citations from regulatory content. These provisions aim to ensure clarity and consistency in regulatory interpretation.

4,232 $13,975,949 $12,977,667 $11,979,385 $10,981,103 $9,982,821 $8,984,539 $7,986,257 $6,987,975 $5,989,693 Interest $1,188,355 $1,138,840 $1,089,325 $1,039,811 $990,296 $940,781 $891,266 $841,751 $792,237 $742,722 $693,207 $643,692 $594,...

AI summary The text presents a series of financial figures, including interest, principal, equity balances, equity returns, and taxes, likely related to a financial statement or capital management report. These figures may pertain to a company's financial obligations, returns, and capital structure.

Proven Strategy & ESG Alignment - Climate commitment, including a vision to achieve net-zero CO 2 emission by 2050 - Recognized for excellence in governance, including strong ESG governance

AI summary The document highlights a climate commitment with a vision to achieve net-zero CO2 emissions by 2050 and acknowledges excellence in governance, particularly in ESG governance.

REPRESENTATION OF WOMEN 48% of senior-level positions at Emera Inc. 39% of senior-level positions across the Emera Group of Companies 45% independent Director Nominees Management continues to be focused on helping ensure Emera's hiring and...

AI summary Emera Inc. reports that 48% of senior-level positions are held by women, with 39% across the Emera Group of Companies and 45% of independent director nominees. The company is focused on promoting equity through annual demographic analysis, wage gap monitoring, and recruitment strategies aimed at increasing female participation, especially in male-dominated roles.

CBU assistant professor nominated for Accessibility Trailblazer Award ROSEMARY GODIN LO C A L J O U R N A LI SM I N I T I AT I V E Anassistant professor of political science at Cape Breton University is one of four finalists for the Access...

AI summary Tammy Bernasky, an assistant professor at Cape Breton University (CBU), is a finalist for the Accessibility Trailblazer Award at the Accessibility Confident Employers (ACE) Awards. Her research focuses on disability studies, gender-based violence, and inclusion. The ACE project, led by Sea Change CoLab, aims to remove barriers for people with disabilities in Nova Scotia workplaces.

c. Environmental Justice Communities Avangrid outlines its equity strategy through the Just Transition framework in its 2023 Sustainability Report. Interrog. Resp. UPA-31, p. 1. The Company asserts that the strategy focuses on four stakeho...

AI summary Avangrid outlines its equity strategy through the Just Transition framework, focusing on four stakeholder groups—customers, communities, workforce, and suppliers—to minimize negative impacts and promote positive outcomes as it transitions to a clean energy economy. The company's policies are publicly available and guide its approach to equity.

d. Workforce Diversity and Inclusion Avangrid publicly commits to increasing women's representation in executive and senior leadership roles, as stated in its 2023 Sustainability Report. See 2023 Sustainability Report Goals Scorecard. [140...

AI summary Avangrid has set goals to increase women's representation in leadership roles but lacks detailed reporting on workforce diversity at the operating company level. UI supports these goals through internal programs but does not use formal metrics to assess their effectiveness, and it does not provide disaggregated workforce data as requested.

In a separate data request regarding how UI's hiring and promotion trends support Avangrid's 2025 leadership diversity goals, the Company reaffirmed its commitment to equal employment opportunity. Interrog. Resp. UPA-036. The Company empha...

AI summary The Company reaffirmed its commitment to equal employment opportunity and stated that hiring and promotion decisions are based solely on candidate qualifications. However, no women held senior leadership positions at UI in 2023 or 2024, according to submitted workforce data.

In addition, white employees held the majority of senior leadership positions at UI in both 2023 and 2024. Interrog. Resp. UPA-035, Att. 1. Specifically, white employees represented 85.7% of senior leadership in 2023 and 77.8% in 2024, whi...

AI summary The document highlights the racial and gender disparities in senior leadership positions at UI, noting that white employees held the majority of these roles in both 2023 and 2024, with male employees occupying all senior leadership positions during both years.

e. DEI Training The Company states that it offers a variety of Equal Opportunity (DEI) training programs through both live (synchronous) and on-demand (asynchronous) formats. Interrog. Resp. UPA-042. These trainings aim to enhance particip...

AI summary The Company provides Equal Opportunity (DEI) training programs, both voluntary and mandatory, covering topics such as allyship, digital accessibility, and sexual harassment. Some mandatory trainings, like those on EHS, are legally required, which may affect the perception of the breadth of voluntary DEI programming.

st Transition framework and participation in several Connecticut-based programs, such as the Community Partnership Initiative, Energy Storage Solutions, Residential Renewable Energy Solutions, and the CT EV Charging Program, the Company ha...

AI summary The document highlights UI's lack of transparency and accountability in its ESG initiatives, particularly in equity and sustainability impact assessments, and its failure to align with Avangrid's gender diversity goals. It notes that UI does not measure the effectiveness of its internal strategies for supporting underrepresented groups and lacks specific contributions to Avangrid's ESG performance.

equity by a holder for consider- n’est pas affiliée, en échange de biens utilisés dans ation that includes equity (other than substantive l’entreprise exploitée activement de l’entité visée. debt) of (qualifying issuance) (i) the covered e...

AI summary This text discusses amendments to the Income Tax Act and other legislation as part of the Fall Economic Statement Implementation Act, 2023. It outlines changes to equity considerations and related provisions, including definitions and qualifying issuance criteria.

3.4.1.3.1 Exclusion of Wreck Cove, Mersey and Tusket Hydro System Decommissioning Costs from Proposed Depreciation Rates [157] NS Power believes that removing the Wreck Cove, Mersey and Tusket hydro system decommissioning costs from custom...

AI summary NS Power argues excluding decommissioning costs for Wreck Cove, Mersey, and Tusket hydro systems from depreciation rates balances cost recovery and rate pressure, citing environmental, cultural, and reliability impacts. Mr. Madsen raised intergenerational equity concerns but supported the exclusion, acknowledging the systems' critical role in reliability and the challenges of future cost allocation.

difference will eventually need to be recovered from future customers, putting further upward pressure on rates in later years and potentially leading to intergenerational inequity. This is a concern. [178] The Board is also concerned abou...

AI summary The Board expresses concerns about NS Power's use of partial hydro decommissioning cost estimates in its depreciation study, warning that this approach may understate future costs, leading to higher rates for future customers and intergenerational inequity. NS Power argues its method is responsible and based on minimum estimates, but the Board questions the accuracy and long-term implications.

resulting in more use of the procedure. He also noted that ELG is currently used in Alberta and Newfoundland. His evidence also indicated that ALG is used by Maritime Electric in Prince Edward Island. [204] For this GRA, NS Power submitted...

AI summary NS Power advocates for the use of ELG (Equal Group Life) over ALG (Average Group Life) in rate base calculations, arguing it reduces financing costs more quickly. The Board will evaluate ELG/ALG methodology differences and intergenerational equity. NS Power has used ELG for over 30 years, citing real retirement data. Maritime Electric uses ALG in Prince Edward Island.

t salvage rates for Plant accounts not subject to settlement agreement adjustments and for the three transmission and distribution Plant accounts which are subject to settlement agreement adjustments. [271] The Board has intergenerational...

AI summary The Board approves settlement agreement adjustments to net salvage rates for NS Power's production plant accounts despite intergenerational equity concerns and uncertainty about decommissioning costs, particularly for hydro assets. The decision is based on unresolved questions about future decommissioning scenarios, with a directive for NS Power to address these issues in the next GRA.

3.8 Cost of Service Study [561] Under the PUA , a utility is afforded the opportunity to recover its "reasonable and prudent" costs of providing service and a "just and reasonable" return on its rate base. The total amount of these costs a...

AI summary The section outlines the regulatory framework under the Public Utilities Act (PUA) for cost recovery and rate setting, emphasizing 'reasonable and prudent' cost recovery and 'just and reasonable' returns. It references the Nova Scotia Court of Appeal's decision in Dalhousie Legal Aid Service v Nova Scotia Power Inc. , which prohibits rate discrimination based on customer ability to pay, and highlights factors for grouping customers into classes.

Not Submitted for Approval in this Proceeding NS Power notes that, in this proceeding, it is not seeking approval of the AA and BA rider rates or final approval of fuel costs; a financing order to facilitate securitization; or its Climate...

AI summary NS Power is not seeking approval for AA/BA riders, fuel costs, securitization financing, or its climate plans in this proceeding. The Board emphasizes the need for a just base fuel cost and considers the smoothing mechanism. Securitization forecasts and climate plans are relevant to future rate applications and equity concerns, while NS Power's plans are kept on the Final Issues List for future review.

6% of after-tax income on heat and lights[1](#page-0-0) . 1 Energy Poverty and an Equitable Transition to a Net-Zero Carbon Future in Nova Scotia – EfficiencyOne The Department submits that the Board must assess whether the requested rate...

AI summary The Department argues that NS Power's requested rate changes are not just and reasonable, citing increased profits, service reliability issues, a cyber breach, and excessive rate increases. It asserts NS Power has not met its burden of proof under the Act, considering economic circumstances and the factors outlined.

eness of existing services, the efficiency of the public utility, the nature and extent of the needs and purposes upon which the application is grounded and the propriety of the proposed rate changes. - 27 The "propriety" of the rates invo...

AI summary The text outlines the NSUARB's duty to ensure utility rates are reasonable overall and equitable across customer classes, referencing principles from Dr. James Bonbright's work and a 2002 NS Power rate application decision. It emphasizes adherence to cost-of-service models and legal requirements to prevent unjust discrimination.

CRITERIA OF A SOUND RATE STRUCTURE - 1. The related, "practical" attributes of simplicity, understandability, public acceptability, and feasibility of application. - 2. Freedom from controversies as to proper interpretation. - 3. Effective...

AI summary The document outlines seven criteria for a sound rate structure, emphasizing simplicity, revenue stability, fairness, and efficiency. It references James Bonbright's principles and cites legal precedents, including the Public Utilities Act and the Supreme Court of Canada's Vavilov decision, to guide regulatory assessment.

3.4.1.3.1 Exclusion of Wreck Cove, Mersey and Tusket Hydro System Decommissioning Costs from Proposed Depreciation Rates [157] NS Power believes that removing the Wreck Cove, Mersey and Tusket hydro system decommissioning costs from custom...

AI summary NS Power argues excluding decommissioning costs for Wreck Cove, Mersey, and Tusket hydro systems from depreciation rates balances cost recovery and rate pressure, citing environmental, cultural, and reliability impacts. Mr. Madsen raised intergenerational equity concerns but supported the exclusion due to future cost burdens.

difference will eventually need to be recovered from future customers, putting further upward pressure on rates in later years and potentially leading to intergenerational inequity. This is a concern. [178] The Board is also concerned abou...

AI summary The Board expresses concerns about NS Power's use of partial hydro decommissioning cost estimates in its depreciation study, arguing that this approach may understate costs and lead to future rate increases, creating intergenerational inequity. NS Power defends its method as responsible, citing uncertainty around decommissioning feasibility, but the Board warns that excluding civil work costs could result in higher future decommissioning expenses borne by ratepayers.

resulting in more use of the procedure. He also noted that ELG is currently used in Alberta and Newfoundland. His evidence also indicated that ALG is used by Maritime Electric in Prince Edward Island. [204] For this GRA, NS Power submitted...

AI summary NS Power advocates for using the Equal Life Group (ELG) method over Average Life Group (ALG) in its General Rate Application (GRA), arguing ELG reduces rate base and financing costs more effectively. The Board will evaluate ELG vs. ALG, focusing on procedure appropriateness and intergenerational equity implications.

t salvage rates for Plant accounts not subject to settlement agreement adjustments and for the three transmission and distribution Plant accounts which are subject to settlement agreement adjustments. [271] The Board has intergenerational...

AI summary The Board considers salvage rate adjustments for NS Power's production plant accounts, acknowledging intergenerational equity concerns but approving adjustments due to uncertainty around decommissioning costs, particularly for hydro assets. The decision is conditional on NS Power addressing decommissioning clarity in the next GRA.