Topic:"Fuel Cost Adjustment" in M11927

CI 50518 CA IR-5 Attachment 19 Page 174 of 423 REDACTED (CONFIDENTIAL INFORMATION REMOVED) 3 # Indicators Condition Choices Data Definitions/Explanations Protection and off road vehicles appear to effectively exclude or divert visitors and...

AI summary The text outlines various indicators and condition choices related to environmental protection, consumptive uses, domestic wells, and calcareous fen within a specific area. It includes data on wildlife disturbance, sustainable consumptive uses, proximity of domestic wells, and calcareous fen identification.

- 1 (e) NS Power has not formally responded to the June 6, 2024 DFO email to date. NS Power - 2 continues to work to address additional information requirements in the email to satisfy the - 3 FAA application, namely increasing the offsett...

AI summary NS Power has not formally responded to a June 6, 2024 email from the Department of Fisheries and Oceans (DFO) and is still working to meet additional information requirements for the FAA application, specifically increasing the offsetting amount for the Project.

Table 3: Nova Scotia CPI Trend19 Table 4: Canada IPPI Trend20 Table 5: Ruth Falls Archaeological Costs24 Table 6: Comparison of Recent Project Archaeological Costs25 Table 7: Ruth Falls Main Dam Refurbishment Variance Summary28 Table 8: 20...

AI summary The document presents a series of tables detailing various cost-related data, including archaeological costs, labour costs, materials costs, administrative overhead, and other expenses associated with projects such as the Ruth Falls Main Dam Refurbishment and the 2019 ACE and ATO applications.

Description Total Estimate ($) AFUDC $272,553 Table 27: ATO Application AFUDC Costs[78](#page-46-4) Description Total Estimate ($) AFUDC $884,768 2 5.7.2 Analysis

AI summary The document provides an analysis of AFUDC costs associated with the ATO application, including estimates of approximately $272,553 and $884,768 for AFUDC. These figures are presented in tables and referenced in the analysis section.

2.0 EVIDENCE AND SUBMISSIONS [8] One of the three primary reasons identified by NS Power in the ATO application for the project cost variance is related to additional environmental permitting requirements. Out of the total $8.2 million ATO...

AI summary NS Power's ATO application includes a request for additional funds due to environmental permitting requirements, particularly related to the Ruth Falls Reservoir project. The changes to the Fisheries Act in 2018 necessitated obtaining a Fisheries Act Authorization (FAA). The project's cost was submitted for Board approval in 2019, even though permits had not yet been obtained, as this is a common practice during the preliminary design phase.

ated entirely to DFO requirements, so changes to the project cost and timeline would apply to all refurbishment options, as drawdown is the primary driver of the environmental permitting requirements. [55] NS Power also submitted that it a...

AI summary NS Power argues that changes to project costs and timelines are driven by DFO requirements, and that it acted prudently in submitting the original refurbishment application. The company highlights that amendments to the Fisheries Act occurred after the application and that decommissioning costs are significantly higher than refurbishment costs.

3.2 Preferred Refurbishment Option [65] In approving NS Power's 2019 ACE Plan, the Board agreed with NS Power that Option 4 was the preferred and most economic refurbishment alternative for the project. As noted above, NS Power's CEJC expl...

AI summary The Board approved NS Power's 2019 ACE Plan, finding that Option 4 remains the preferred refurbishment option. NS Power did not update its economic analysis due to expected uniform cost increases from FAA and extended timelines, and no other parties challenged this reasoning.

on and will meet this condition of the FAA. As such, Midgard recommended that NS Power should provide an update on the status of this work and of the associated FAA condition in its reply submissions. Midgard's review of NS Power's Economi...

AI summary Midgard recommended that NS Power provide an update on the status of work related to the FAA condition. While Midgard found NS Power's Economic Analysis Model (EAM) to be robust, it noted that supporting cost information for decommissioning was not provided and that the scope of the decommissioning cost estimate was unclear.

s hydro project application once they 33 were made aware an FAA was required? - 34 (e) Why hasn't Midgard reviewed NSPI's initial estimate of the impacted 35 habitat? What would that document include?

AI summary The text includes questions about Midgard's awareness of the FAA requirement for a hydro project application and their review of NSPI's initial estimate of impacted habitat.

33 is related to interactions with the DFO, rather than the NSECC? 1 Please elaborate, and explain how this may or may not have impacted the 8 Midgard agree that the delays in obtaining the Watercourse Alteration 9 Approval were at least i...

AI summary The text discusses delays in obtaining Watercourse Alteration Approval, potentially linked to NSPI's delays in providing detailed design drawings and access road plans, as well as the impact of increasing costs on project variances. It also references Midgard's conclusions and the context of the ATO process.

Viewing the evidence as a whole, NSPI acted imprudently by not including the costs of the FAA within its initial application… Either way, the impact of this imprudence should not rest with ratepayers. Respectfully, these submissions from t...

AI summary The NS Energy Board found that NSPI acted imprudently by not including FAA costs in its initial application, but the IG argues that the absence of these costs does not automatically render them imprudent, citing evidence from NS Power and Midgard.

3.1 Updated Information - NS Power states that as a result of receiving the FAA it has updated its cost estimate for the Project, which - has resulted in a cost reduction of $606,392.

AI summary NS Power has updated its cost estimate for the Project following the receipt of the Fisheries Act Authorization, resulting in a cost reduction of $606,392.

CONCLUSIONS 1 Based on its review, Midgard has arrived at the following overall conclusions: 2 3 • The issuance of an FAA to the Project removes a significant area of risk and has reduced the estimated cost to complete. 4 5 6 • The timelin...

AI summary Midgard concludes that obtaining an FAA reduces risk and cost for the Project, but timelines imposed by the FAA remain a risk. The economic analysis supports refurbishment, though NS Power's decommissioning cost estimate is significantly higher than previous estimates and lacks supporting information.

Fisheries Act Authorization Midgard indicates that the issuance of an FAA for the Ruth Falls project removes a significant area of risk to the project and has reduced the estimated cost to complete the project. Midgard also indicates that...

AI summary Midgard indicates that the issuance of an FAA for the Ruth Falls project reduces risk and cost, but also notes that external factors could affect the project's timeline. Deferring construction would introduce additional costs and not mitigate the challenges of the construction window.