N-52024-2025 Bates White FAM Audit Report - Redacted
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VII.A. Background NSPI's gas-fired facilities are served by the Maritimes & Northeast Pipeline – Canada ("M&NE-CA"). During the Audit Period, gas transported on this pipeline was sourced from the U.S. and Canada via the TransCanada Pipelin...
AI summary NSPI's gas-fired facilities rely on the Maritimes & Northeast Pipeline – Canada for gas supply, sourced from various pipelines and LNG terminals. During the Audit Period, NSPI evaluated and contracted for pipeline capacity to deliver gas to Tufts Cove but declined additional capacity due to cost concerns and potential long-term reduced demand. NSPI also participated in pipeline regulatory proceedings with other shippers.
VII.B.2. Audit Period Gas Transportation Options Considered by NSPI Natural gas is a commodity, and if pipeline access to gas is available, then contracting for the gas commodity is straightforward. It is more complex to contract for FT ca...
AI summary NSPI considered various gas transportation options during the audit period, including accepting assignments of FT capacity and using IT. In Canada, FT rates are lower than IT rates, while in the U.S., IT capacity was sometimes available at a discount to FT rates. NSPI extended its FT contract on M&NE-CA through 2026, and NSPEMI occasionally contracted for discounted M&NE-US capacity.
VII.B.2.b. Interruptible Capacity on M&NE-US When NSPEMI began energy transactions in the US in November 2020, they were able to buy gas at Westbrook, ME and transport it to Baileyville, ME using IT capacity on M&NE-US. This continued thro...
AI summary NSPEMI began energy transactions in the US in November 2020, using interruptible capacity on M&NE-US to transport gas from Westbrook, ME to Baileyville, ME during the Audit Period.
Firm Transportation from Alberta NSPEMI continued to manage the FT contracts on TCPL and PNGTS used to transport MMBtu per day from Empress, AB to Westbrook, ME. They then arranged for the re-delivery of this gas to NSPI at Baileyville.
AI summary NSPEMI manages firm transportation contracts on TCPL and PNGTS to transport gas from Alberta to Maine, and arranges for re-delivery to NSPI at Baileyville.
VIII.B.1. Counterparties and Procurement Locations During the Audit Period, NSPI and NSPEMI had master agreements for natural gas in place with the following counterparties.333
AI summary During the Audit Period, NSPI and NSPEMI had master agreements for natural gas in place with various counterparties.
Figure VIII-2: NSPI's Natural Gas Master Agreements Counterparty Effective Date March 7, 2023 April 19, 2012 May 1, 2023 April 8, 2015 March 17, 2023 March 3, 2005 May 4, 2022 September 13, 2018 March 28, 2019 February 12, 2008 April 1, 20...
AI summary NSPI and NSPEMI purchased natural gas from various counterparties during the Audit Period, with purchases occurring at multiple locations including Empress, Tufts Cove, Baileyville, and Westbrook. Transactions were executed by NSPI and NSPEMI, and prices fluctuated based on time, location, and other factors.
Selling Gas at Other Locations In the previous Audit Period, most of NSPI's gas resales were at Baileyville. This meant that the realized price would reflect the additional cost a buyer would incur to move the gas to a different market. Du...
AI summary During the current Audit Period, NSPEMI sold gas at multiple locations including New Hampshire and Maine, with notable transactions in March 2025. These sales occurred while some Tufts Cove units were offline, and NSPI also sold gas in AB and ONT. The reasons for these sales were not explicitly detailed in the Shift Reports.
Market Definition and Price Determination During the Audit Period, NSPEMI's market area for natural gas included portions of New England and locations accessed by TCPL across Canada. As described in NSPI's 2025 Natural Gas Report, NS Power...
AI summary NSPEMI's natural gas market area during the Audit Period included parts of New England and locations connected via TCPL in Canada. NS Power continues to source from New England despite pipeline capacity constraints, with regular transactions at Baileyville and Westbrook.
VIII.F. Recommendations Recommendation VIII-1: Provide monthly documentation of gas sales by NSPEMI and NSPI (excluding transactions between NSPEMI to NSPI) identifying the terms (e.g., quantity, location, price, etc.) of the transaction,...
AI summary The recommendation calls for monthly documentation of gas sales by NSPEMI and NSPI, excluding internal transactions, detailing terms such as quantity, location, price, counterparty selection, pricing agreement, and title transfer location.
Figure VIII-14: Late Day Trades delivered to Baileyville Price Less Emera NG Price $0.05 $0.05 $0.00 $0.00 $0.30 $0.00 $0.25 $0.00 $0.00 $0.00 $0.00 $0.00 $0.05 $0.05 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $1.00 $1.50 $0.00 $2.00 $0.00...
AI summary Figure VIII-14 presents a table of late day trades delivered to Baileyville, showing various prices and counterparties involved, with Emera Energy L.P. as a major participant. The data includes price details and maximum prices for different transactions.
XI.B.2.b. Dispatch to Manage Natural Gas Pipeline Pressure and Position Due to recurrent low gas pipeline pressure issues on the M&NP Mainline, NSPI faces a constraint on the use of natural gas at Tufts Cove and PHB, which is sometimes bin...
AI summary NSPI faces challenges managing natural gas pipeline pressure and position, leading to reduced generation output at Tufts Cove. Corrective actions include fuel switching and derating production. While modifying generator outputs is not a concern due to market conditions, the lack of documentation raises concerns about the economic management of pipeline positions.