Topic:"Generator Interconnection" in M12524

Introduction This report has been prepared by Concentric Energy Advisors, Inc. ("Concentric") in response to a requirement by the Nova Scotia Energy Board ("NSEB" or "Board") to conduct a detailed review of Federal Energy Regulatory Commis...

AI summary This report, prepared by Concentric Energy Advisors, Inc., reviews FERC Order No. 2023 and compliance filings by Nova Scotia Power, Inc. in response to the Nova Scotia Energy Board's directive. It includes analyses of interconnection processes and recommendations for Nova Scotia, with considerations for the transition to the Nova Scotia Independent Energy System Operator.

n the United States.[5](#page-2-0) While FERC does not have authority in Canada, its policies and regulatory decisions provide a frame of reference for practices among Canadian transmission providers. Order 2023 represents the most compreh...

AI summary Order 2023 updates generator interconnection procedures in the U.S. and Canada, introducing structured cluster studies, tighter timelines, and financial readiness requirements. These reforms aim to improve efficiency, reduce uncertainty, and support the integration of new generation resources into the grid.

First-Ready, First-Served Cluster Study Process A primary area of focus within Order 2023 is the establishment of a "first-ready, first-served cluster study process", which requires transmission providers to group interconnection requests...

AI summary Order 2023 introduces a 'first-ready, first-served cluster study process' for interconnection requests, grouping them into annual clusters for simultaneous study to improve efficiency and reduce delays. Transmission providers prefer maintaining existing processes, while ISOs and RTOs argue the reform is incompatible with high interconnection volumes. Concentric recommends a semi-annual cluster study with a maximum of 10 applicants.

Transmission Heatmap To support prospective interconnection customers in identifying optimal points of interconnection, Order 2023 requires that transmission providers develop, maintain and publicly post available information on generator...

AI summary Order 2023 requires transmission providers to develop and maintain publicly accessible transmission heat maps to support interconnection customers. These maps must avoid disclosing sensitive information and be updated annually and following cluster studies. Nova Scotia currently lacks such a tool, but its development is recommended as part of interconnection reform.

Increased Study Deposits To prevent an inflow of speculative interconnection requests and alleviate the strain on transmission providers' resources, the Commission established a set of reforms in Order 2023 to increase financial commitment...

AI summary The Commission introduced reforms in Order 2023 to increase study deposits and readiness requirements for interconnection requests to prevent speculative applications and reduce strain on transmission providers. Nova Scotia's current structure aims to promote queue discipline, but Concentric recommends against adopting the Order's deposit framework, citing potential financial barriers for viable projects.

To address the effect of project withdrawals, Order 2023 included a withdrawal penalty framework for projects in which either the interconnection customer withdraws its interconnection request, the transmission provider deems the request t...

AI summary Order 2023 introduced a withdrawal penalty framework for interconnection projects in Nova Scotia, where penalties increase based on the stage of withdrawal. Transmission providers have requested deviations from this framework, and Concentric recommends against imposing additional penalties, as current practices are already similar to those outlined in the order.

Table 4: Withdrawal Penalty Calculation Under Order 2023 Interconnection Request Submission Cluster Study Cluster Restudy (if needed) Facilities Study Execution of LGIA or Request for Filing of Unexecuted LGIA Penalties are not applied to...

AI summary Table 4 outlines the withdrawal penalty calculation under Order 2023, specifying penalties based on the stage of the interconnection request process. Penalties increase from 2x the actual allocated cost during the Cluster Study phase to 20% of estimated network upgrade costs during the execution of the Long-Run Incremental Cost (LGIA) or request for filing of unexecuted LGIA.

Additional Changes Related to Order 2023 The key reforms in Order 2023 focus on improving the speed and efficiency of transmission providers' processing of interconnection requests. However, an interconnection queue is not utilized by ever...

AI summary The text discusses the interconnection processes used by transmission providers, focusing on ERCOT's 'connect and manage' approach and its implications. It contrasts this with systems like PJM and Nova Scotia's current practices, noting that while faster interconnections are possible, they come with increased operational risks. Concentric recommends against adopting the connect and manage model in Nova Scotia.

- Re: Cluster Study Participants . NSEB Staff asked about the number of participants required for a cluster study. Concentric recommended two cluster studies per year (one in January and one in July) containing a maximum of 10 applicants t...

AI summary NSEB Staff inquired about the number of participants required for a cluster study, to which Concentric recommended two cluster studies per year with a maximum of 10 applicants. Concentric also stated that feasibility studies are no longer needed with the implementation of transmission heat maps and cluster studies, and that interconnection customers must meet all progression milestones in Section 7.2 of the GIP.

Conclusion The purpose of this report is to present a review of Order 2023 to the Board and propose recommendations for the interconnection process in Nova Scotia. Below is a summarized list of the recommendations by Concentric. - R1. Esta...

AI summary This conclusion summarizes Concentric's recommendations for improving the interconnection process in Nova Scotia, including establishing cluster study opportunities, revising cost allocation methods, and enhancing information systems. The report was prepared in 2025 and contact details for further inquiries are provided.

Re: M12524 – Nova Scotia Power Incorporated – Concentric FERC Order 2023 Report Dear Ms. Henwood: IESO Nova Scotia's update letter of August 14, 2026 regarding the above noted matter provided in part the following: Regarding the interim in...

AI summary IESO Nova Scotia has completed and executed an interim interconnections administration agreement with Nova Scotia Power Incorporated, which was previously delayed. The agreement outlines the division of responsibilities under the current Board approved SGIP and has been finalized. A copy of the executed agreement is provided to the NSEB for information.

SGIP ADMINISTRATION AGREEMENT This Agreement is made this 18th day of August, 2026. BETWEEN:

AI summary The document outlines the SGIP Administration Agreement, made on August 18, 2026, between parties involved in the standard generation interconnection procedure. The agreement sets the framework for administering interconnection processes.

2. Division of Responsibilities. - 2.1 Without alteration to NS Power's lawful obligations, duties and responsibilities as set out in the SGIP, IESO NS hereby agrees to complete certain of NS Power's responsibilities, on its behalf, as set...

AI summary This section outlines the division of responsibilities between NS Power and IESO NS during the interim period, specifying which duties are transferred to IESO NS and which remain with NS Power. It also establishes the terms of the agreement, including its duration and the process for transitioning responsibilities.

5.1 General. - (a) The primary point of contact with Interconnection Customers regarding new and existing applications or requests under the SGIP shall be IESO NS. - (b) Notwithstanding the foregoing, the Parties shall at all times work co...

AI summary This section outlines the primary point of contact for Interconnection Customers under the SGIP, which is IESO NS. It also emphasizes collaboration between the Parties to transfer System Operator functions to IESO NS, process applications timely, and adhere to the SGIP and pre-existing agreements.

5.2 Existing Applications, Requests, and Deposits - (a) Any existing applications or requests by Interconnection Customers submitted to NS Power under the SGIP prior to the date of this Agreement which now fall within the duties, functions...

AI summary This section outlines the transition of existing applications, requests, and deposits related to interconnection under the SGIP from NS Power to IESO NS following the interim allocation of responsibilities. It details how deposits and security will be transferred or retained, with provisions for collaboration in case of impact on interconnection customers.

5.3 New Applications, Requests, and Deposits (a) All new applications or requests by Interconnection Customers under the SGIP, shall be submitted to IESO NS for review and processing together with any required deposits. Such deposits shall...

AI summary Section 5.3 outlines the process for submitting new applications or requests by Interconnection Customers under the SGIP, requiring submissions to IESO NS along with required deposits, which will be held and administered by IESO NS in accordance with the SGIP.

Facilities Studies - (b) The IESO NS shall engage NS Power in Interconnection System Impact Study results meetings. Within three (3) Business Days following the Interconnection System Impact Study results meeting, NS Power shall provide to...

AI summary The document outlines procedures for engaging NS Power in Interconnection System Impact Study results meetings, submitting Facilities Study Agreements, and handling new applications or requests related to interconnection facilities. These processes are governed by the SGIP and the IESO NS.

5.4 Interconnection Agreements - (a) Any agreement(s) with respect to a new application or request by an Interconnection Customer which must be executed by the Interconnection Customer under the SGIP shall continue to take the form of the...

AI summary This section outlines the process for executing Interconnection Agreements under the SGIP, specifying roles for IESO NS and NS Power, including drafting, countersigning, and delivery of agreements to Interconnection Customers.

6. Deposits – Transition & Allocation 6.1 Deposits Held by NS Power. Upon completion of any assessment, study, or any other scope of work for an Interconnection Customer for which a deposit is being held by NS Power but with respect to whi...

AI summary The section outlines procedures for handling deposits held by NS Power or IESO NS when work is performed by the other party. It specifies invoicing timelines and the allocation of deposit monies after work completion, in accordance with the SGIP.

Interim Allocation of Responsibilities GIP Section Party Responsible Definitions 1 N/A Scope and Application 2 Application of Standard Generator Interconnection Procedures (GIP) 2.1 System Operator and Transmission Owner Comparability 2.2...

AI summary The document outlines the interim allocation of responsibilities under the Standard Generator Interconnection Procedures (GIP). It specifies which parties are responsible for various sections, including the System Operator, Transmission Owner, and Interconnection Customer.

e-0-0"> 1 NSEB Decision, Re: In The Matter of a Review of Nova Scotia Power Incorporated's interconnections processes under s. 2C of the Electricity Act, June 11, 2024, p.23, para 43. (now under separate matter M12174 as established in the...

AI summary The document discusses the submission of Concentric's FERC Order 2023 report, which is a major deliverable under matter M10905. Revisions to the Standards Generator Interconnection Procedures (SGIP) are under review by the NSEB. The responsibility for transmission system interconnection processes is expected to transfer to the IESO-NS soon.

December 23, 2025 [[email protected]](mailto:[email protected]) [[email protected]](mailto:[email protected]) Blake Williams Mark Peachey Senior Director, Regulatory Director of Regulatory Nova Scotia Power In...

AI summary The Nova Scotia Energy Board is seeking comments on Concentric Energy Advisors' report on interconnection process recommendations following FERC Order 2023. The panel is considering whether NS Power or the IESO-NS should be responsible for implementing the recommendations.

FERC Order 2023 Recommendations Concentric's report Interconnection Process Recommendations for the Nova Scotia Electricity System Following Review of FERC Order No. 2023 and August 2025 Stakeholder Workshop provided the following recommen...

AI summary Concentric's report provides nine recommendations for improving the interconnection process in Nova Scotia's electricity system, including cluster study opportunities, cost allocation methods, and information system enhancements. IESO Nova Scotia accepts most recommendations, with additional commentary on four.

R1. Cluster Studies IESO Nova Scotia notes that the ability to conduct cluster studies has been in place in Nova Scotia for some time, as provided for under Section 4.2 of the Standard Generation Interconnection Procedures (SGIP), which pr...

AI summary IESO Nova Scotia explains that cluster studies are already permitted under the Standard Generation Interconnection Procedures (SGIP), allowing grouped studies based on Queue Position and electrical remoteness. While the Concentric report recommends a minimum of two cluster studies per year, IESO Nova Scotia emphasizes the need for flexibility to conduct additional cluster or one-off studies as needed.

R4. Transmission Capacity Heat Map IESO Nova Scotia appreciates the desire of parties to have increased visibility into the feasibility of various points of interconnection on the transmission system for new energy resources. IESO Nova Sco...

AI summary IESO Nova Scotia acknowledges the need for increased visibility into transmission system capacity for new energy resources and proposes fit-for-purpose methods to provide actionable data to potential interconnection customers.

R5. Study Deposit Structure This recommendation is related to the identified need in FERC Order 2023 to increase study deposits as a method of ensuring that only projects with a pathway to commercial operation are admitted to the System Im...

AI summary The recommendation relates to FERC Order 2023, which calls for increasing study deposits to ensure only viable projects are admitted to the System Impact Study queue. Concentric did not support this, arguing current levels are sufficient. IESO Nova Scotia acknowledges increased study costs due to EMT analysis complexity and plans to review the deposit structure and SGIP in 2026.

R6. Penalty Structure IESO Nova Scotia notes that the penalty structure recommendation by Concentric focuses primarily on transmission providers, with only the following brief reference to applicability to independent system operators (ISO...

AI summary IESO Nova Scotia notes that Concentric's penalty structure recommendation primarily targets transmission providers and only briefly mentions ISOs. Since some interconnection responsibilities have transferred to IESO Nova Scotia, it suggests that applying penalties to it may not be appropriate without further study. IESO Nova Scotia plans to reconsider this as part of its 2026 SGIP revisions.

Plan and Timeline Those recommendations that IESO Nova Scotia accepts, or is otherwise directed by the Board to adopt, may require revisions to interconnection documentation and processes, including the 5 Concentric Report, Interconnection...

AI summary The document discusses potential revisions to interconnection documentation and processes in Nova Scotia, based on recommendations accepted by IESO Nova Scotia or directed by the Board, referencing a specific report and stakeholder workshop.

SGIP. Those recommendations expected to require work to be fully implemented are listed in the table below, alongside a brief description of the requirements to adopt/complete. Recommendation Requirements Two Cluster Studies Per Year Syste...

AI summary The document outlines several recommendations related to the Standard Generation Interconnection Procedures (SGIP) that require amendments and further consideration, including system upgrade cost allocation, cluster study cost allocation, and the ISO penalty structure. Revisions to the SGIP and updates to interconnection processes documentation are needed.

… as the NSEB may appreciate, IESO Nova Scotia is in its early stages of formation and is working expeditiously to implement its mandate under the More Access to Energy Act (Nova Scotia) (the "Act"). It is foreseeable that further revision...

AI summary IESO Nova Scotia is in the early stages of formation and will revise interconnection processes documentation to reflect its role under the More Access to Energy Act. It plans to consult stakeholders and submit revisions to the NSEB by the end of 2026, potentially earlier. This process will occur alongside or after a Board review of Concentric's report in Matters M10905 and M12174.

– Annual Report, November 28, 2025. Development and completion of information tracking systems are expected on a similar timeline, as well as consideration of alternatives to a transmission heat map. Until the SGIP is revised and approved...

AI summary The document discusses the development of information tracking systems and the need for alternatives to a transmission heat map. It also outlines IESO Nova Scotia's interim solution for interconnection processes administration until the SGIP is revised and approved. IESO Nova Scotia will assume responsibility for reporting on interconnection processes under M12174.

April 22, 2026 VIA EMAIL Ms. Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: Ml2524 - Nova Scotia Power Inc., Concentric FERC Order 2023 Report On Octo...

AI summary This letter discusses the submission of the Concentric FERC Order 2023 Report by NS Power and the subsequent responsibility transfer to IESO-NS. IESO-NS accepted most recommendations with some exceptions and proposed a 2026 implementation timeline, though no cost estimates were provided. The SBA notes that an interim agreement between IESO-NS and NS Power has not yet been filed.

Review by the SBA IE SO-NS summarized the Concentric Report's nine recommendations and then described four that it would implement only with exceptions. Below are the SBA's comments with respect to IESO-NS positions: Rl: Cluster Studies: I...

AI summary The SBA reviews IESO-NS's response to the Concentric Report, noting concerns about the lack of stakeholder input and clarity on proposed changes. Specific issues include the flexibility in conducting cluster studies, the transmission capacity heat map, study deposit structure, and penalty structure for transmission study deadlines. The SBA emphasizes the need for stakeholder engagement and timely resolution.

Cluster Studies The SBA provided the following comments with respect to the IESO's February 12, 2026 comments on cluster studies: IESO-NS reserves the flexibility to conduct cluster studies for Interconnection Requests based on its profess...

AI summary The SBA raised concerns about the IESO's flexibility in conducting cluster studies, questioning whether the IESO may conduct as few as zero studies in a year. The IESO clarified that it intends to maintain a minimum of two studies per year but may conduct more as needed based on the number and nature of Interconnection Requests.

recommendations, its proposed exceptions to them and respond to feedback.[15](#page-4-1) In the IESO's February 12, 2026 comments, it provided the following regarding pending amendments to the SGIP: IESO Nova Scotia intends to consult stak...

AI summary The IESO plans to consult stakeholders on proposed revisions to the SGIP and related interconnection processes, aligning with Board initiatives on Matters M10905 and M12174. An interim agreement is being developed to clarify responsibilities between IESO Nova Scotia and NS Power until the SGIP is revised and approved by the NSEB, expected by Q1 2026.

Comments from the Consumer Advocate (CA) and the Small Business Advocate (SBA) were filed on April 22, 2026. The CA submitted comments on the following issues: - Concentric recommended adoption of the penalty structure established under FE...

AI summary The Consumer Advocate and Small Business Advocate submitted comments on April 22, 2026, addressing issues related to interconnection study penalties, cost allocation for network upgrades, SGIP revisions, and an interim agreement between IESO NS and NS Power. They raised concerns about subsidy risks and the need for stakeholder consultation.

- Regarding cluster studies, IESO NS clarified its intent to "reserve the ability to conduct more than two cluster studies a year, not less, based on the number and nature of Interconnection Requests (IR) received in a study window". It al...

AI summary IESO NS discusses its approach to cluster studies, transmission capacity mapping, study deposits, penalty structures, and interim agreements with NS Power. It highlights the flexibility in conducting cluster studies, the shift from heat maps to alternative solutions for transmission capacity, and the need to align study deposits with actual costs. It also mentions plans for SGIP amendments and stakeholder consultations in 2026.

s in the process of finalizing the agreement and expects it will be complete and entered into in May 2026. - In responding to potential additional costs to implement recommendations related to FERC Order 2023, the IESO confirmed there are...

AI summary The IESO NS is working on finalizing an agreement expected in May 2026, and confirmed no additional costs for implementing FERC Order 2023. The Board has directed IESO NS to file an update by August 14, 2026, on the SGIP revision process and the status of the interim interconnection agreement with NS Power.

August 14, 2026 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 Re: M12524 – Nova Scotia Power Incorporated – Concentric FERC Orde...

AI summary The Nova Scotia Energy Board has directed IESO Nova Scotia to provide an update by August 14, 2026, regarding the timeline for SGIP revisions and the status of an interim agreement on interconnection issues with NS Power. The SGIP is proposed to be renamed the TSIP to better reflect its updated scope and responsibilities.