N-11Evidence of Doane Grant Thornton
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- 4 Figure 1 Summary of findings, observations and conclusions # Report section Findings, observations, and conclusions 7. Request for immediate temporary financial relief Applicable capital cost approval and review requirements. o Based u...
AI summary The report discusses IESO Nova Scotia's request for temporary financial relief, noting the need for approval to ensure continued operations and regulatory compliance. It highlights concerns about the misuse of the FAM for purposes beyond its defined scope and emphasizes the need to establish a clear process for allocating and recovering deferred costs from customers.
7.3.2 The IESO Nova Scotia's request - Per the Application, IESO Nova Scotia is requesting Board approval for immediate temporary financial relief, to - enable it to pay its liabilities as they become due. Following internal review of the...
AI summary IESO Nova Scotia is requesting temporary financial relief of $950,000 per month from NS Power to meet its liabilities until a permanent cost recovery mechanism is approved. NS Power is agreeable to this request, provided the amount can be recorded, deferred, and recovered through its Fuel Adjustment Mechanism (FAM).
5 Figure 25 – Summary of intervenor submissions Party Position Summary of reasoning for position CA Opposes the request for temporary financial relief96 • The request is not supported by sufficient evidence (minimal financial detail and re...
AI summary The intervenors (CA, SBA, and IG) oppose the request for temporary financial relief. They argue that the proposed use of the Fuel Adjustment Mechanism (FAM) is inappropriate, lacks sufficient evidence, and shifts financial risks to customers. They also highlight inconsistencies with legislation, the lack of clarity in the proposal, and the existence of alternative financing options.
10 Figure 26 – Summary of IESO Nova Scotia's response to Intervenors Topic Intervenor concern IESO Nova Scotia's explanation/supporting evidence provided101 Fuel Adjustment Mechanism Intervenors expressed significant concern regarding the...
AI summary Intervenors raised concerns about the use of the Fuel Adjustment Mechanism (FAM) by IESO Nova Scotia, including potential misalignment with its statutory purpose and unfair cost distribution. IESO Nova Scotia responded by emphasizing the exceptional and temporary nature of the FAM's use, proposing an interim sub-account or a stand-alone deferral account to address concerns while maintaining regulatory clarity.
- 2 On February 25, 2026, the Board issued its decision, approving IESO Nova Scotia's request for interim temporary 3 financial relief, in part. The Board ordered that: - 4 Nova Scotia Power Incorporated will pay monthly fees to IESO Nova...
AI summary The NSEB approved interim financial relief for IESO Nova Scotia, requiring NS Power to pay monthly fees of $950,000, with deferral and interest at NS Power's WACC. The decision was made due to IESO Nova Scotia's failure to establish a fee recovery mechanism, and the relief is intended to ensure continued not-for-profit operations while preserving regulatory authority for future adjustments.
7.4 Conclusion - Based upon our review of IESO Nova Scotia's request for immediate temporary financial relief and the Board's letter published on February 25, 2026, we offer the following comments: - We recognize the need for approval of t...
AI summary The document supports IESO Nova Scotia's request for temporary financial relief to ensure operational continuity and public interest, aligning with GUP reliability principles. It criticizes using FAM for non-fuel costs, violating regulatory compliance, and recommends stringent forecasting processes for deferred costs. The Board's order and matter M12663 are referenced.
1 Appendix A - Glossary of terms Abbreviation Term We, us, our, Doane GT or Doane Grant Thornton Doane Grant Thornton LLP # Document 1 100921 - NSEB – Submission – PHP – February 12, 2026 2 100923 - NSEB – Submission – CA – February 12, 20...
AI summary This document provides a glossary of terms and abbreviations used in the Nova Scotia regulatory proceeding, including references to submissions, decisions, and applications related to energy regulation and financial mechanisms.
100926Submission - IG
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Re: M12663 – IESO-NS - 2026-27 Revenue Requirement and Fees Application These submissions are filed on behalf of the Industrial Group in response to the IESO-NS's request for immediate relief for NSPI to remit $950,000 per month, exclusive...
AI summary The Industrial Group opposes the IESO-NS's request to use the Fuel Adjustment Mechanism (FAM) to recover a monthly assessment of $950,000, arguing that it is improper, shifts risks to ratepayers, and lacks support. They also suggest alternative approaches that align better with legislative intent.
eports. Exceptional or nonrecurring costs appropriately classified as a fuel and purchased power cost will be brought to the attention of the Small Working Group for review for inclusion in the FAM. In only specific and limited circumstanc...
AI summary The FAM is used for exceptional non-fuel costs like administrative penalties and excess earnings as credits, not ratepayer costs. The Board authorized these credits via legislation and the Public Utilities Act, with jurisdiction over excess earnings disposition. Recent amendments preserve this discretion, ensuring such items remain FAM credits.
(2) Ratepayers Bear all the Risks under this Proposal The proposal shifts four distinct risks to NSPI customers: - 1. Approval risk. The IESO-NS's 2025/26 revenue requirement remains under review, and the 2026/27 revenue requirement may fu...
AI summary The proposal shifts four risks to NSPI customers: approval risk due to uncertain revenue requirements, forecasting risk from unquantified Phase II costs, timing risks from FAM deficits and carrying costs, and loss of prudence review for monthly assessments. Intervenors and consultants highlight deficiencies in evidence and potential ratepayer burden.
(3) The $950,000 Monthly Assessment has not been justified The IESO-NS has failed to provide adequate justification or evidentiary support for the proposed $950,000 monthly assessment. It is also unclear what the total payment will be incl...
AI summary The IESO-NS has not adequately justified the proposed monthly assessment of $950,000, and no documentary evidence has been provided to support the claim that IESO-NS will be unable to meet its liabilities by May 2026. The financial projections and assumptions underlying the assessment are not fully explained or supported.
(4) Alternatives to FAM-Based Bridge Financing Better alternatives exist that would protect ratepayers and maintain appropriate risk allocation and regulatory frameworks. The IESO-NS has presented the Board with a single option, with limit...
AI summary The document discusses alternatives to FAM-based bridge financing, suggesting provincial financing, phased fee implementation with guarantees, and expenditure pacing. It argues that the Province, not ratepayers, should provide bridge financing, and highlights the need for proper regulatory oversight to protect ratepayers and maintain cost causation.
Conclusion The Industrial Group respectfully requests that the Board: - 1. Reject the IESO-NS's request for interim approval of the requested Monthly Assessment through the FAM retroactive to February 1, 2026 (or at all, based on the curre...
AI summary The Industrial Group requests the Board to reject IESO-NS's interim approval of the FAM retroactive to February 1, 2026, direct alternative bridge financing until final fee recovery mechanism approval, and set a deadline of April 30, 2026, for submitting the recovery fee mechanism application.
100954IG (IESO NS) IR 1 to 32 - PDF
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10 Request IR-7: - 11 Reference: N-1, Notice of Application, pdf p.3-4 requests approval of NS Power's - 12 recording, deferral and recovery of associated costs through its Fuel Adjustment - 13 Mechanism. - 14 (a) Please explain IESO-NS's...
AI summary The document requests IESO-NS to explain its approach to allocating Fuel Adjustment Mechanism (FAM) costs across customer classes, address potential allocation issues if non-fuel costs are included, compare FAM with a separate rider, and analyze financial impacts of retroactive approval. Key concerns include transparency, rate design, and cost allocation fairness.
19 Request IR-12: - 20 At N-1(i) Exhibit A-1, pdf p. 6, IESO-NS states that actual expenditures for fiscal year 2025/2026 - 21 are "materially tracking" against its proposed 2025/2026 Revenue Requirement. Please explain - 22 this modifier...
AI summary The text includes two requests related to the IESO-NS's 2025/2026 Revenue Requirement and procurement timelines. The first asks for a quantitative explanation of expenditures tracking against the Revenue Requirement. The second inquires about the timeline for procuring fast-acting generation and the process for securing cost-recovery, including ratepayer involvement and potential Board approval requirements.
- 2 Reference: N-1(i), Exhibit D-1, pdf p.42 states that any excess amounts paid by NSPI - 3 " will be subject to reconciliation through a permanent fee recovery mechanism … credited - 4 back to NS Power through a reduction in future fees...
AI summary The text references a reconciliation process involving excess payments by NSPI through a permanent fee recovery mechanism, with credits potentially being returned immediately or at the next test year. It also asks about the carrying cost for over- or under-collection between collection and refund dates.
101002Rebuttal Submission from IESO-NS re: temporary financial relief
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VIA ELECTRONIC SUBMISSION Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Dear Ms. Henwood: RE: M12663 - Nova Scotia Independent E...
AI summary IESO Nova Scotia seeks temporary financial relief for 2026/2027, rebutting intervenor opposition citing insufficient evidence, FAM misuse, and lack of prudency findings. Intervenors (except PHP) oppose interim relief, while IESO provides additional evidence and legal context to justify the request under the More Access to Energy Act.
A. OVERVIEW Despite the concerns raised by intervenors, the circumstances underlying IESO Nova Scotia's request are clear, urgent, and exceptional. As this rebuttal demonstrates, temporary financial relief is required immediately to ensure...
AI summary IESO Nova Scotia seeks urgent interim financial relief due to lack of approved fees and reliance on a credit line, risking insolvency and operational failures. The request emphasizes temporary FAM use, pending prudency determinations in 2025–2026 and 2026–2027 proceedings, and statutory authority under MAEA. Customer safeguards and transition to independence are highlighted as critical.
sets out its objects (s. 9). When read as a whole, the MAEA is designed to create, and ultimately transition system operation responsibilities to, a functional and financially viable IESO Nova Scotia. Section 29 forms part of that scheme a...
AI summary The MAEA establishes a framework for transitioning system operations to IESO Nova Scotia, requiring sufficient funding through section 29. The Board may temporarily use NS Power's FAM or other mechanisms to secure interim fees during the transition, supported by legislative discretion and compatibility with the Public Utilities Act.
FUEL ADJUSTMENT MECHANISM In light of IESO Nova Scotia's immediate funding needs and the absence of available LOC or commercial financing, IESO Nova Scotia has proposed temporary financial relief in the form of monthly fees charged to NS P...
AI summary IESO Nova Scotia proposes temporary financial relief via monthly fees charged to NS Power, deferred within the FAM. Intervenors, including PHP, oppose using FAM to recover IESO costs, arguing it shifts non-profit IESO expenses to NS Power's for-profit operations. PHP urges IESO to file a permanent fee recovery mechanism without utility equity costs.
The CA provided the following: …the Consumer Advocate is concerned about the appropriateness of IESO NS receiving payment from NS Power through the FAM. While the FAM applies to many customer groups, including residential customers, it doe...
AI summary The Consumer Advocate is concerned that IESO NS receiving payments from NS Power via the FAM may lead to unfair cost distribution, as non-FAM customers' costs are effectively covered by FAM customers. If these costs are recovered through FAM, NS Power benefits from WACC application.
The IG provide, in part, the following: The FAM is a statutory and highly structured mechanism designed for the recovery of NSPI's fuel and purchased-power costs. It is established under s. 64AB of the Public Utilities Act and has only thr...
AI summary The Fuel Adjustment Mechanism (FAM) is a statutory mechanism for NSPI to recover fuel and power costs, with a deficit of $101.6 million as of 2025. Delays in resetting fuel costs and adding a Monthly Assessment increase the deficit, leading to higher customer bills due to financing costs.
The SBA provided the following: The SBA notes that FAM customers and ratepayers are not interchangeable terms as the FAM is not paid by all Nova Scotia ratepayers. For example, it is not paid by PHP under the ELIADC tariff currently in pla...
AI summary The SBA argues that the proposed financial relief using the FAM does not meet legislative requirements, as FAM is not paid by all ratepayers (e.g., PHP under ELIADC). It clarifies that MAEA section 30 pertains to energy resource contracts, not the Application. Submissions from multiple stakeholders are referenced.
PRUDENCY OF COSTS PHP provided the following regarding prudency of costs: With respect to the request that the monthly assessment be pre-approved as a prudent cost of NS Power, PHP notes that if agreed to by the Board it should be made cle...
AI summary PHP argues pre-approving NS Power's monthly assessments shouldn't imply approval of IESO Nova Scotia's underlying costs, requiring mechanisms to prevent customer charges for imprudent costs. SBA asserts prudency decisions must await IESO Nova Scotia's incurred costs and emphasizes FAM payments are subject to audits. Both parties discuss prudency criteria and audit processes for cost approvals.
The CA provided as follows: In addition, this exceptional request would also require the Board to deem any such payments through this mechanism to be prudent. Such a presumptive finding would inappropriately limit the Board's ability to re...
AI summary The document discusses concerns over presumptively deeming FAM payments prudent, which could limit the Board's review and ratepayer recourse. IESO Nova Scotia argues a full prudency assessment may not be feasible before an interim order, suggesting reliance on a deferral account for later adjustments. Intervenors raise forecasting risks, but IESO notes alignment between actual and forecasted 2025/2026 costs. The IG and Board consultant found no methodological flaws in IESO's approach.
C. CONCLUSION The circumstances described in this rebuttal demonstrate that temporary financial relief is urgently required to ensure IESO Nova Scotia can continue its operations during the transition mandated by the MAEA. Even with full u...
AI summary IESO Nova Scotia requests temporary financial relief to avoid insolvency during the transition mandated by the MAEA, citing inability to meet liabilities by May 2026. They propose using the FAM as a temporary tool and address intervenor concerns regarding prudency and evidentiary sufficiency. A minimum of $950,000 monthly is required to prevent insolvency during this period.