Topic:"Infrastructure Planning" in M12854

2026 Integrated Resource Plan Terms of Reference May 22, 2026

AI summary The 2026 Integrated Resource Plan outlines the terms of reference for a regulatory proceeding in Nova Scotia, dated May 22, 2026, focusing on energy resource planning and regulatory processes.

INTRODUCTION The Integrated Resource Plan (IRP) is a comprehensive planning exercise focused on evaluating energy system adequacy to meet future electricity demand. An IRP assesses both supply-side and demand-side resources within the cont...

AI summary The Integrated Resource Plan (IRP) transitioned from Nova Scotia Power Inc. to the Independent Energy System Operator of Nova Scotia (IESO) under the More Access to Energy Act (MAEA). Key activities include stakeholder engagement, an ELCC study, and development of the IRP Terms of Reference (ToR) with feedback from 17 stakeholders. The ELCC study, mandated by the Nova Scotia Energy Board (NSEB), aims to assess resource capacity values.

OBJECTIVES The objectives of IESO Nova Scotia's first IRP are: - Develop a robust long-term electricity system plan that is reliable, sustainable, and cost-effective covering the next 20 to 30 years; - Evaluate the range of energy resource...

AI summary IESO Nova Scotia's first IRP aims to create a 20-30 year reliable, sustainable, and cost-effective electricity plan, evaluate energy resources (including non-electric options like hybrid heating systems), identify near-term procurement needs, assess capital investments, and align with provincial sustainability and emissions reduction goals under the Environmental Goals and Climate Change Reduction Act.

PROCESS IESO Nova Scotia is proposing following an approach which builds on the process that was successfully used in previous IRP studies in Nova Scotia. [Figure 1](#page-4-0) depicts the phases of the IRP Process with stakeholder engagem...

AI summary The document outlines Nova Scotia's Integrated Resource Plan (IRP) process, emphasizing stakeholder engagement and pre-IRP studies. Key studies include the ELCC analysis, hybrid-heating research, and DSM potential assessments. The Terms of Reference (ToR) guide the IRP's execution, including evaluation criteria and timelines.

Technical Working Group IESO Nova Scotia is proposing the establishment of a technical working group to collaborate with throughout the IRP. The focus of the TWG will be to provide technical input on the overall approach to the analysis. I...

AI summary IESO Nova Scotia proposes a Technical Working Group (TWG) to provide technical input on the Integrated Resource Plan (IRP). The TWG includes representatives from regulatory bodies, utilities, NGOs, and Indigenous groups. Net-Zero Atlantic was selected for the NGO seat after a selection process. Meeting minutes will be publicly shared to ensure transparency.

KEY QUESTIONS In the NSEB's order for IESO Nova Scotia's Approval of its Proposed Expenditure and Revenue Requirement for the Test Year Ending March 31, 2026 (M12412), the following direction was provided for this IRP: "IESO Nova Scotia is...

AI summary The NSEB directed IESO Nova Scotia to address specific issues in its Integrated Resource Plan (IRP), including analyzing new resource costs, regional system approaches, and emissions-linked modeling. Three additional key questions focus on decarbonization targets, offshore wind opportunities, and Mersey Hydro redevelopment.

TIMELINE The IRP is expected to be complete in December 2026. The below IRP schedule outlines the completion dates for key activities, planned stakeholder sessions with interested parties, and targeted dates for the dissemination of backgr...

AI summary The Integrated Resource Plan (IRP) is scheduled for completion in December 2026, with key activities, stakeholder sessions, and background report dissemination dates outlined in the provided timeline.

March 2026 • Mar 31 – Dunsky IRP Review Report and draft ToR published

AI summary On March 31, 2026, the Dunsky IRP Review Report and draft Terms of Reference (ToR) were published, marking a key milestone in the regulatory process for Nova Scotia's Integrated Resource Plan.

April 2026 - Apr 17 Stakeholder engagement session - o Topics: Dunsky IRP Review Report and the ToR - Apr 24 Deadline for written comments on the ToR

AI summary In April 2026, a stakeholder engagement session focused on the Dunsky IRP Review Report and Terms of Reference (ToR), with a deadline set for April 24 for written comments on the ToR.

November 2026 - Nov 2 Deadline for written comments on modelling results and draft action plan - Drafting of final IRP report

AI summary The November 2026 timeline includes a deadline for written comments on modelling results and a draft action plan, alongside the drafting of the final Integrated Resource Plan (IRP) report.

2026 Integrated Resource Plan Draft Terms of Reference March 31, 2026May 22, 2026

AI summary The document outlines the draft terms of reference for the 2026 Integrated Resource Plan, dated March 31, 2026, to May 22, 2026. No substantive content is provided beyond the title and dates, suggesting it is a placeholder or introductory framework for the plan.

OBJECTIVES The objectives of IESO Nova Scotia's first IRP are: - Develop a robust long-term electricity system plan that is reliable, sustainable, and cost-effective covering the next 20 to 30 years; - Evaluate the range of energy resource...

AI summary The objectives of IESO Nova Scotia's first Integrated Resource Plan (IRP) include developing a long-term, reliable, and cost-effective electricity system, evaluating energy resources (including non-electric options), identifying procurement needs, supporting sustainability goals, and calculating avoided costs for demand-side management.

PROCESS IESO Nova Scotia is proposing following an approach which builds on the process that was successfully used in previous IRP studies in Nova Scotia. Figure 1Figure 1 depicts the phases of the IRP Process with stakeholder engagement a...

AI summary IESO Nova Scotia outlines an IRP process with stakeholder engagement at each phase, referencing pre-IRP studies like the ELCC study and DSM Potential Study. The process includes defining terms such as 'sustainable development' and 'sustainable prosperity' based on Nova Scotia legislation, with studies led by IESO, Nova Scotia Power, Net Zero Atlantic, and EfficiencyOne.

ASSESSMENT PERIOD For this IRP, IESO Nova Scotia is proposing a study period of 2029 – 2053. This 25-year period encompasses the implementation dates of several key Federal and Provincial policies that must be considered when developing a...

AI summary IESO Nova Scotia proposes a 25-year assessment period (2029–2053) for the Integrated Resource Plan (IRP) to align with federal and provincial decarbonization policies, including 80% renewable electricity by 2030, coal phase-out by 2030, and Canada's Clean Electricity Regulations (CER) effective 2035. The period allows for modeling resource additions, retirements, and the Reliability Intertie's in-service date (2028) while maintaining consistency with prior IRPs.

KEY QUESTIONS In the NSEB's order for IESO Nova Scotia's Approval of its Proposed Expenditure and Revenue Requirement for the Test Year Ending March 31, 2026 (M12412), the following direction was provided for this IRP: "IESO Nova Scotia is...

AI summary The Nova Scotia Energy Board (NSEB) directed IESO Nova Scotia to address specific issues in its Integrated Resource Plan (IRP), including cost analysis for new supply-side resources, regional system modeling, ELCC portfolio updates, demand response scenarios, and emissions linkage. Additional key questions focus on decarbonization targets, offshore wind opportunities, and Mersey Hydro redevelopment.

March 2026 Mar 31 – Dunsky IRP Review Report and draft ToR published

AI summary On March 31, 2026, the Dunsky Integrated Resource Plan (IRP) Review Report and draft Terms of Reference (ToR) were published, outlining the review process and next steps for the IRP.

December 2026 Dec 10 – Publication of final IRP report

AI summary The document notes the publication of the final Integrated Resource Plan (IRP) report on December 10, 2026, marking a key milestone in Nova Scotia's energy planning process.

APPENDIX A – DRAFT IRP SCORECARD Least Cost (8070%) – Measured as the cumulative total 25-year Net Present Value (NPV) of the modelled capacity expansion and production costs plus end effects. The resource plan with the lowest total NPV, i...

AI summary The draft IRP scorecard evaluates resource plans using four criteria: Least Cost (NPV of costs), GHG Reduction (emissions), Technology Risk (reliance on unproven tech like SMRs), and Economic Growth (job creation). Scores are normalized against optimal benchmarks for each category.

Integrated Resource Plan Terms of Reference Comments May 22, 2026

AI summary This document outlines the Terms of Reference for the Integrated Resource Plan regulatory proceeding in Nova Scotia, dated May 22, 2026. It serves as a framework for stakeholder input and discussion on resource planning, though the content of the proceeding itself is not detailed in the provided text.

On March 31, 2026 IESO Nova Scotia published on its public website the draft Terms of Reference (ToR) for its inaugural IRP. An email was sent to IESO Nova Scotia's Integrated Resource Plan (IRP) stakeholder list informing them the draft T...

AI summary IESO Nova Scotia published the draft Terms of Reference for its inaugural Integrated Resource Plan (IRP) and sought stakeholder feedback. Seventeen submissions were received, and IESO Nova Scotia provided responses to the feedback, including questions from a virtual stakeholder session. Non-IRP related comments were not addressed in this document.

APRIL 17 STAKEHOLDER SESSION QUESTIONS Question/Comment Response How will the IESO design and apply its primary and secondary metrics—such as the newly proposed collaborative scorecard—to rigorously test the "preferred plan," ensuring that...

AI summary Stakeholders asked how the IESO will use primary and secondary metrics, including a collaborative scorecard, to evaluate and select the preferred resource plan. The response indicates that all resource plans will be scored out of 100, and the highest scoring plan will be identified as the preferred plan, with potential for additional scenarios if needed.

Decisional vs Deliberative (…)_ In the context of Nova Scotia, I recommend that the "hybrid" approach be taken. Specifically, the IRP should include – as attachments or separate filings – requests to proceed with proposed RFPs that are sup...

AI summary The text recommends a hybrid approach for Nova Scotia's Integrated Resource Plan (IRP), suggesting that proposed RFPs supported by the IRP should be included as attachments or separate filings. Complex decisions requiring power flow modeling should use a separate capital application process. IESO Nova Scotia acknowledges the Consumer Advocate's recommendation.

BATES WHITE Question/Comment Response The ToR states: "An IRP assesses both supply-side and demand-side resources within the context of the Nova Scotia planning environment, including all applicable Federal and Provincial environmental pol...

AI summary The document discusses the Terms of Reference (ToR) for the Integrated Resource Plan (IRP), with a focus on clarifying the planning horizon. The ToR currently states a 20- to 30-year planning period, but the IESO clarifies that the intended planning horizon is 25 years, from 2029 to 2053, with the mention of 20- to 30-year horizons being a misinterpretation.

The term "sustainable" is used throughout the ToR, including in two separate IRP objectives. We understand that the term is used in section 2(e) of the More Access to Energy Act, but the ToR would benefit from a definition of the term, giv...

AI summary The document discusses the need for clearer definitions of terms like 'sustainable' and 'integrated electricity system' in the Terms of Reference (ToR) for the Integrated Resource Plan (IRP). It also raises concerns about the placement of an objective related to updating avoided cost calculations for demand-side resources, suggesting it should be moved or rephrased to align with statutory requirements under the More Access to Energy Act.

this IRP objective to include all resource cost assumptions. The ToR would benefit from additional specificity regarding the pre-IRP studies that have been commissioned by the IESO, which will allow stakeholders to plan their resources for...

AI summary The document discusses revisions to the Terms of Reference (ToR) for the Integrated Resource Plan (IRP), including adding specificity regarding pre-IRP studies, incorporating sensitivities into assumption development, and improving stakeholder engagement language. Stakeholders also raised concerns about meeting participation limits and the need for written requests for information.

the first technical working group meeting on May 13th guidelines were established and agreed to that allow members to designate an alternate representative in order to allow for continuity of support throughout the process. The ToR propose...

AI summary The Technical Working Group established guidelines for alternate representatives to ensure continuity. The TOR proposed a 70% cost and 30% non-cost weighting for resource portfolios, but stakeholders recommended increasing the cost weighting. In response, IESO Nova Scotia adjusted the scorecard, increasing cost to 80% and reducing economic growth and technology risk to 5% each.

EAST COAST ENVIRONMENTAL LAW these categories or, at minimum, consider reductions to their weights in the evaluation process. The ToR would benefit from additional language explaining how the load forecast (and scenarios) will be developed...

AI summary The document discusses feedback on the Terms of Reference (ToR) for an Integrated Resource Plan (IRP), including suggestions to improve clarity on load forecasting, fuel supply considerations, and grid reliability modeling. Responses indicate that these issues will be addressed during the assumption and scenario development phase of the IRP with input from stakeholders and technical working groups.

Energy Storage Canada noted that "The Draft Terms of Reference outline a structured and methodical approach that is well suited to the scale and complexity of the planning exercise ahead. The clarity of the objectives, analytical framework...

AI summary Energy Storage Canada praised the Draft Terms of Reference for their structured and methodical approach, clarity of objectives, and commitment to evidence-based planning. They did not provide further questions or feedback on the ToR.

INDUSTRIAL GROUP Question/Comment Response The economic growth metric (proposed to be weighted 10%) is stated to reflect the total number of jobs created. This metric risks overstating benefits to NS while ignoring electricity cost The wei...

AI summary The Industrial Group raises concerns about the economic growth metric's weighting and its potential to overstate benefits by ignoring electricity cost impacts on industry and export sectors. In response, the IESO acknowledges the concern but suggests limiting the initial analysis to direct job creation and reducing the metric's weighting.

NOVA SCOTIA POWER Question/Comment Response In addition to the near-term resource procurement identification (3 – 5 years) and the long-term resource plan identification, NS Power also recommends the IRP as the source of identifying capita...

AI summary Nova Scotia Power recommends using the Integrated Resource Plan (IRP) to identify capital work for existing resources, such as the Mersey Hydro System, ahead of or following procurement windows. The IESO has updated the IRP objectives to include identifying capital investment ranges for existing resources to support a reliable, least-cost power system in Nova Scotia.

NRSTOR Question/Comment Response NRStor welcomes the multiple opportunities for stakeholder feedback in the IRP process. We propose that non-confidential stakeholder feedback be posted online for greater transparency, as is done in other j...

AI summary NRStor suggests improving transparency by posting non-confidential stakeholder feedback online during the IRP process, similar to practices in Ontario. They also offer targeted outreach to energy storage developers and industry representatives to provide up-to-date market intelligence for accurate economic modeling in the IRP.

SMALL BUSINESS ADVOCATE Question/Comment Response The Draft TOR does not include explicit discussion of risk Scenarios and sensitivities will be used to vary and test analysis, aside from the "Technology Risk" factor included in different...

AI summary The Small Business Advocate (SBA) raises concerns about the Draft Terms of Reference (TOR) for the Integrated Resource Plan (IRP), emphasizing the need for explicit risk considerations and clarity in the scoring methodology. The IESO Nova Scotia responds by acknowledging the need for stakeholder engagement and updating the TOR to address these issues.

and seeking feedback from stakeholders on them was to help refine this approach. The Draft TOR states that an additional element of the IRP to "Determine the economic opportunity for domestic use of energy from offshore wind" (p. 10). Econ...

AI summary The draft Terms of Reference (TOR) for the Integrated Resource Plan (IRP) includes an analysis of the economic opportunity for domestic use of energy from offshore wind, which is not a conventional element of an IRP. The TOR should be more explicit about the objective, scope, and methodology of this analysis. IESO Nova Scotia acknowledges that this is the first time incorporating such secondary considerations and that the approach may need to evolve.

SOLAR NOVA SCOTIA Question/Comment Response SNS would appreciate it if stakeholder feedback on the ToR, and during subsequent steps in the IRP process, were made available to all stakeholders for transparency. Yes, stakeholder feedback wil...

AI summary SNS requests greater transparency in stakeholder feedback during the IRP process and suggests aligning the definition of 'energy resources' with the More Access to Energy Act. IESO Nova Scotia clarifies that the definition in the MAEA does not limit resource types but provides examples. SNS also raises concerns about the 2026 IRP's potential to re-scope or re-weight energy resources, particularly at the distribution level, and calls for additional stakeholder consultation.

Further details on how distribution-level energy resources will be considered in the IRP will be reviewed during the Assumptions and Scenarios phase of the IRP. SNS would appreciate further clarity on how energy resources at the distributi...

AI summary SNS seeks clarity on how distribution-level energy resources will be integrated into the 2026 IRP and how they will interact with other processes. SNS recommends incorporating fuel cost sensitivities and differentiating between imported fuel costs and clean local electricity in the Draft IRP Score Card. IESO Nova Scotia notes that fuel transportation costs are already included in modeling. The Province's Clean Power plan aims to reduce reliance on imported fuels by 2030 through domestic renewable energy.

SYNAPSE Question/Comment Response To ensure transparency - especially given the likelihood that no IESO Nova Scotia recognizes this request and will provide input stakeholders will run PLEXOS - it is critical to release all input and outpu...

AI summary The stakeholder requests transparency by releasing all input and output data in Excel format for the IRP process, emphasizing the importance of machine-readable data for analysis. They also request the ELCC study and related capacity cost studies to be released at least one week before the May 12th stakeholder session. The IESO Nova Scotia responds that the ELCC study report will be available after the session, but meeting materials will be provided beforehand. The Dunsky Report on the IRP process is being led by IESO Nova Scotia.

Introduction Bates White appreciates the opportunity to provide these comments to the Independent System Operator of Nova Scotia ("IESO") regarding its March 31, 2026 Draft Terms of Reference ("ToR") related to the IESO's 2026 Integrated R...

AI summary Bates White provides comments to the IESO on its March 31, 2026 Draft Terms of Reference for the 2026 Integrated Resource Plan process, addressing eleven areas of concern.

1. IRP planning and modeling horizon The ToR states: "An IRP assesses both supply-side and demand-side resources within the context of the Nova Scotia planning environment, including all applicable Federal and Provincial environmental poli...

AI summary The ToR for the IRP emphasizes a 20-30 year planning horizon for Nova Scotia's power grid, but stakeholders recommend clarifying the base case (e.g., 25 years) and retaining flexibility for the Reliability Intertie's in-service date. The ToR's current focus on 2029-2053 is tied to the Reliability Intertie's 2028 in-service date, though delays may require adjustments.

2. Model scenarios The ToR states that "IESO Nova Scotia will strive for a reduced set of crisp, focused scenarios which (a) are designed to support key decisions, (b) are anchored around one 'most likely' base case, (c) represent holistic...

AI summary The ToR's language on model scenarios is criticized for being vague and restrictive, with concerns about limiting scenarios to a 'reduced set' and overemphasizing a 'most likely' base case. Stakeholder consultation is recommended, and transparency in data sharing is emphasized.

5. Avoided cost calculation may be better suited elsewhere in the ToR Developing an updated avoided cost calculation for demand-side resources makes sense and is akin to ensuring the IRP uses up-to-date, credible cost assumptions in assess...

AI summary Updating avoided cost calculations for demand-side resources in the IRP is recommended but should not be an IRP objective. The text proposes either removing the objective and addressing it in 'Assumption and Scenario Development' or expanding the IRP objective to include all resource cost assumptions.

6. Pre-IRP studies specification The ToR indicates that there will be multiple "Pre-IRP Studies," but identifies just one—the ELCC study. Nova Scotia Power, Inc.'s ("NSPI's") 2019-2020 IRP featured several pre-IRP studies, including those...

AI summary The Terms of Reference (ToR) for Pre-IRP studies lacks specificity, only explicitly mentioning the ELCC study. NSPI's prior IRP included diverse studies like renewable integration and demand-side programs. The ToR requires greater detail to enable stakeholder engagement and feedback on commissioned studies.

Comments on IESO Nova Scotia 2026 IRP Draft Terms of Reference

AI summary The document outlines comments on the IESO Nova Scotia's 2026 Integrated Resource Plan (IRP) Draft Terms of Reference (ToR). It focuses on regulatory processes and the development of the IRP, which guides energy planning and resource allocation in Nova Scotia.

2. Technical Work Group Membership Overall, IESO Nova Scotia has proposed a reasonable membership roster for the 2026 IRP technical work group. I concur that the membership should be small in order to facilitate deep engagement. Similar co...

AI summary IESO Nova Scotia's proposed membership for the 2026 IRP technical work group is deemed reasonable, with a recommendation to include a stakeholder representative for renewable energy development based on the Dunsky assessment. Concerns about potential bias from selecting individual resource developers are acknowledged, but the process benefits are considered greater.

East Coast Environmental Law Comments on Draft Terms of Reference for the NS IESO's 2026 Integrated Resource Plan East Coast Environmental Law is pleased to provide the following comments on the draft Terms of Reference ("TOR") for the NS...

AI summary East Coast Environmental Law provides comments on the draft Terms of Reference for the NS IESO's 2026 Integrated Resource Plan, focusing on the IRP's objectives, evaluation criteria, and key questions posed in the draft TOR. Comments are limited to these areas.

Evaluation Criteria We agree that evaluation criteria should be designed to identify least-cost resource planning options, but we also agree that identifying least-cost options should not be the sole objective of NS IESO integrated resourc...

AI summary The text supports the NS IESO's integrated resource planning approach, emphasizing least-cost options while advocating for broader evaluation criteria aligned with sustainability and GHG reduction goals. It endorses stakeholder consultation on a proposed scorecard method but requests further details before commenting on its use.

Re: IESO Nova Scotia 2026 Integrated Resource Plan ("IRP") Draft Terms of Reference Eastward Energy Inc. ("Eastward") appreciates the opportunity to provide the following comments on IESO Nova Scotia's draft Terms of Reference for its 2026...

AI summary Eastward Energy Inc. provides comments on IESO Nova Scotia's draft Terms of Reference for its 2026 Integrated Resource Plan, signaling engagement in the regulatory process for energy planning in Nova Scotia.

Technical Working Group With respect to the Technical Working Group ("TWG") Eastward notes that "The TWG shall retain the option to invite representatives from member and non-member organizations to participate and offer expert opinion whe...

AI summary Eastward emphasizes its expertise in non-electric energy resources and seeks TWG participation in the IRP to contribute to the integrated electricity system. The TWG retains authority to invite external experts on specific topics.

Role of the IRP The Dunsky report noted that the question of whether the IRP results should be directional or decisional was a matter for consideration. The draft Terms of Reference indicate that the final IRP report outlining modelling as...

AI summary The Dunsky report considers whether the IRP should be directional or decisional. The draft Terms of Reference require the IRP report to be filed with the NSEB under the More Access to Energy Act. Eastward supports a directional IRP focused on near-term (3-5 year) resource procurement, while project-specific approvals under the Public Utilities Act remain required.

Introduction - The Independent Energy System Operator Nova Scotia (IESO) has initiated its first Integrated - Resource Plan (IRP) which is being carried out over 2026. On March 31, 2026 the IESO shared its - draft Terms of Reference with s...

AI summary The IESO has initiated its first Integrated Resource Plan (IRP) in 2026, sharing draft Terms of Reference with stakeholders and holding a session for comments. EfficiencyOne (E1) provided feedback on the IRP Terms of Reference.

RE: Draft Terms of Reference for the 2026 Integrated Resource Plan Energy Storage Canada (ESC) appreciates the opportunity to provide comments on the Draft Terms of Reference for IESO Nova Scotia's 2026 Integrated Resource Plan (IRP). As t...

AI summary Energy Storage Canada (ESC) supports Nova Scotia's 2026 Integrated Resource Plan (IRP) process, emphasizing energy storage's role in reliability, affordability, and decarbonization. ESC highlights storage's flexibility and resilience benefits as Nova Scotia transitions from coal and integrates renewables and nuclear imports. They offer technical expertise to refine modelling and resource evaluations.

Industrial Group To the IRP Team – On behalf of the iG, we have reviewed the comments previously filed and offer one additional consideration not yet addressed: First, we share the concern of BW regarding weighting of non-least cost factor...

AI summary The Industrial Group (IG) supports using long-term NPV as the primary determinant for the preferred resource plan in Nova Scotia's Integrated Resource Plan (IRP). It criticizes the proposed 10% weighting of the economic growth metric for overstating job creation benefits while ignoring electricity cost impacts on industries and export sectors. The IG urges explicit prioritization of NPV over non-cost metrics in the Terms of Reference (TOR) and final IRP, emphasizing affordability and reliability constraints.

Karl Leuschen Hi IRP Team, Below are my written comments on the Draft Integrated Resource Plan Terms of Reference, submitted ahead of the April 24 deadline discussed at the April 17 stakeholder engagement session.

AI summary Karl Leuschen submits written comments on the Draft Integrated Resource Plan Terms of Reference ahead of the April 24 deadline, referenced in the April 17 stakeholder engagement session. The comments address the ToR for the IRP process.

Capacity value of demand response resources Demand response can displace supply at peak, but its capacity value is often overstated when planning models rely on enrolled/nameplate capability without accounting for operational constraints....

AI summary Demand response (DR) capacity is often overstated in planning models that ignore operational constraints. The ToR should require IRP to use effective capacity metrics, including design-day conditions, net capacity post-snapback, availability rates, and duration limits. Overestimating DR as firm capacity risks misjudging supply-side needs, as highlighted by Dunsky's emphasis on plan robustness.

IRP scorecard: treatment of demand-side resources I support the move beyond pure least-cost optimization. The multi-criteria scorecard (Least Cost 70%, GHG Reduction 10%, Technology Risk 10%, Economic Growth 10%) is a meaningful improvemen...

AI summary The text supports a multi-criteria IRP scorecard (70% least cost, 10% GHG reduction, 10% technology risk, 10% economic growth) as an improvement over the 2020 IRP. It argues that the technology risk metric fails to reward proven demand-side resources over speculative supply-side ones (e.g., SMRs) and that economic growth metrics exclude local DR program jobs. Recommendations include adjusting technology risk scoring and expanding job-count methodologies.

1701 HOLLIS ST. 12th FLOOR, HALIFAX, NS B3J 3M8 (902) 422-9663 NATURALFORCES.CA IESO Nova Scotia April 24, 2026 1791 Barrington St. Suite 1010 Halifax, NS B3J 3K9 RE: IESO's Draft Terms of Reference To whom it may concern; On behalf of Nat...

AI summary Natural Forces submits comments on the IESO's draft Terms of Reference for the 2026 Integrated Resource Plan, emphasizing that cost assessments should align with asset lifespans, sustainability must be prioritized, and risk evaluation should include factors like fuel price variability and geopolitical risks. It also advocates for broader environmental impact assessments, local economic considerations, and explicit energy security measures.

• Process - o Operating Costs : NRStor is encouraged by IESO-NS's proposal in the draft ToR to include operating and maintenance costs in addition to capital costs when evaluating existing and candidate resources, as directed by M12412. -...

AI summary NRStor recommends including operating costs in resource evaluations, advocating for technology-neutral grid service criteria, enhanced stakeholder transparency, targeted outreach to energy storage developers, and adopting a Societal Cost Test (SCT) to align with provincial climate goals. These proposals aim to improve the Integrated Resource Plan (IRP) process and ensure alignment with the Clean Power Plan and More Access to Energy Act.

Nova Scotia Power TOR Section Details/Component NS Power Feedback/ Questions Objectives All objectives listed in the TOR NS Power supports the objectives noted in the TOR. In addition to the near-term resource procurement identification (3...

AI summary Nova Scotia Power supports the objectives outlined in the Terms of Reference (TOR) and recommends using the Integrated Resource Plan (IRP) to identify capital work for existing resources. They also mention the Mersey Hydro System as an example of a decision point for rebuild or partial decommissioning.

Below are PHP comments on the ToR: - Transmission and distribution, as well as needed ancillary services, are key parts of the development of the grid that do not appear to be included in the IRP, as was the case for the previous IRP. The...

AI summary PHP emphasizes the need to include transmission, distribution, and ancillary services in the IRP, advocate for building on prior IRP findings, reduce scenario complexity while retaining sensitivities, and ensure stakeholder representation. They request adequate time for review, integration of the 10-year system outlook, and inclusion of large-scale projects in the IRP scorecard.

Written Comments on the 2026 Integrated Resource Plan Terms of Reference (dated March 31, 2026 The following key points are provided for consideration:

AI summary The document outlines written comments on the 2026 Integrated Resource Plan Terms of Reference, indicating key points for consideration. Specific details of the comments are not provided in the excerpt.

1. Objectives - Bullet point 5 references the provincial legislation Environmental Goals and Climate Change Reduction Act - The IRP states that the assessment period covers 2029-2053 - The Clean Electricity Regulations (CER), will be in ef...

AI summary The document emphasizes updating the Objectives section of the IRP to explicitly reference the Clean Electricity Regulations (CER) and the Environmental Goals and Climate Change Reduction Act. It recommends aligning with CER's 2050 emissions targets early to avoid future costs and position Nova Scotia as a climate leader. Compliance with these Acts is mandated, and the IESO is urged to lead by example.

Diversity The current scorecard appears to evaluate generation options in isolation (in silos) . It is unclear how the IESO intends to use these individual scorecard results to inform a diversified long term resource strategy . For example...

AI summary The current scorecard evaluates generation options in isolation, raising concerns about how results will inform a diversified resource strategy. The text emphasizes the need for resource diversity (solar, wind, hydro, etc.) and recommends clarifying how scorecard outcomes translate into procurement decisions ensuring system reliability and resilience.

IRP should include robust consideration of risks The Draft TOR does not include explicit discussion of risk analysis, aside from the "Technology Risk" factor included in the draft score card description provided in Appendix A. The IRP shou...

AI summary The Draft TOR lacks explicit risk analysis beyond 'Technology Risk' in Appendix A. The IRP should incorporate considerations of load forecast, resource capital costs, policy changes, fuel prices, and other risks early in the process to define appropriate risk assessment methodologies.

Scenario/sensitivity analysis should provide foundation for action plan and signposts The Draft TOR notes that the IRP "will strive for a reduced set of crisp, focused scenarios" (p. 5). The SBA agrees with the priority of focusing on a so...

AI summary The Draft TOR emphasizes a limited set of focused scenarios for the IRP, but the SBA stresses that scenarios must be sufficiently expansive to address key uncertainties, such as the Reliability Intertie's Phase 2, offshore wind development, and inter-provincial transmission from a recent MoU. These factors could significantly impact IRP outcomes and inform the action plan.

Score card approach should be informed by stakeholder engagement [1] [https://news.ontario.ca/en/release/1007115/ontario-secures-groundbreaking-national-energy-corridor](https://can01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fnew...

AI summary The Draft TOR's proposed score card approach for portfolio optimization lacks clarity on scoring elements and portfolio creation. Concerns include arbitrary metrics (e.g., 1 point deduction for 5% NPV from emerging tech) and potential over-reliance on prescriptive methods. The IESO is urged to engage stakeholders during the IRP process to refine the approach.

TOR should clarify economic development analysis The Draft TOR states that an additional element of the IRP to "Determine the economic opportunity for domestic use of energy from offshore wind" (p. 10). Economic development analysis is not...

AI summary The Draft TOR includes an unclear economic development analysis for offshore wind in the IRP. The analysis's objective, scope, and methodology require clarification to ensure it appropriately influences the resource portfolio. Melissa MacAdam highlights this gap in the TOR's formulation.

in the amount of electrical energy or capacity that Nova Scotia Power Incorporated would otherwise be required to supply to its customers, or; vi) any other prescribed activities, plans or programs". If the intent for the 2026 IRP is to sc...

AI summary SNS recommends stakeholder consultation if the 2026 IRP redefines 'energy resources' to de-emphasize distribution-level resources like strategic electrification. The MAEA mandates IESO-NS to plan for energy resources and demand-side management, but roles for distribution-level resource consideration in the IRP remain unclear.

Synapse Comments on NS IESO Terms of Reference – 2026 IRP April 24, 2026 Synapse Energy Economics, independent consultant to the NS Energy Board, provides these comments on NS IESO's Terms of Reference ("ToR"). The objectives of the IRP ar...

AI summary Synapse Energy Economics emphasizes the importance of robust modeling and transparency in the 2026 Integrated Resource Plan (IRP), suggesting Excel data releases for analysis and noting that in-person TWG meetings are not critical. They stress understanding plan differences over finalizing a single preferred plan.

June 9, 2026 [email protected] Mark Peachey, LL.B. Director of Regulatory IESO Nova Scotia 1791 Barrington Street, Suite 1010 Halifax, NS B3J 3Y8 Dear Mr. Peachey: M12854 – IESO Nova Scotia – Integrated Resource Plan - 2026 Terms of...

AI summary IESO Nova Scotia submitted revised Terms of Reference for its Integrated Resource Plan (IRP), emphasizing reduced scenarios aligned with the Dunsky report. The Nova Scotia Energy Board stresses the need for robust planning across potential outcomes, referencing M12412's directive on IRP requirements.