05459Ecology Action Centre's comments on NSPI's Action Plan Status Report (IRP Update_ 10/8/2010
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To Whom It May Concern: Over the past year, several items have emerged in provincial and federal policy spheres that have the potential to have a direct impact on Plan A of the NSPI's 2009 IRP Update and subsequent IRP Action Plan update....
AI summary The document highlights that recent provincial and federal policy developments may impact Plan A of the NSPI's 2009 IRP Update and subsequent updates. The 2009 IRP Update was based on four pillars: investing in renewables, success in demand-side management (DSM), maintaining NSPI facilities, and gathering additional information for long-term planning.
Previously, IRP analysis has been improved and expanded through the inclusion of transmission cost information, updated emissions constraints and updated and expanded technology options (ibid).
AI summary The Integrated Resource Plan (IRP) analysis has been enhanced with the inclusion of transmission cost information, updated emissions constraints, and expanded technology options.
In this submission the EAC argues that: - 1. NSPI must more clearly and thoroughly articulate within the IRP how renewable sources of electricity (RE) or non-emitting imports will be undertaken by the utility within the next 5 to 10 years...
AI summary The EAC argues that NSPI must clarify its plans for renewable energy and coal phase-out in the IRP, support demand-side management, and invest in non-emitting technologies. They emphasize the need for aggressive action to meet provincial and federal climate goals, and for long-term planning that aligns with environmental and economic development aspirations.
The EAC advocates that this includes: - i. Strategic opportunities for import & electric and non-electric fuel substitution as well as including, - ii. A diversified and comprehensive array of DSM activities that will develop key sectors o...
AI summary The EAC advocates for strategic fuel substitution, diversified DSM activities, and inclusive DSM design to support Nova Scotia's green economy. It emphasizes the importance of aligning DSM with the IRP (2009) and incorporating new cost-effectiveness testing methods in future planning. The EAC also encourages stakeholder participation in evaluating biomass supply and technical constraints.
or Expressions of Interest. (emphasis added – while government has done so, the EAC continues to question the prudency and rational of the government's choices given outstanding issues argued above). This mandate review process would need...
AI summary The EAC questions the prudency of the government's choices in the mandate review process and suggests integrating environmental and non-cost variables into regulatory planning. It advocates for full-cost accounting approaches and greater consideration of carbon life cycle and greenhouse gas reduction targets within the UARB's processes. The EAC also encourages the UARB to ensure NSPI's IRP includes sustainability variables in scenario planning.
05627NSPI's Response to EAC's comments on NSPI's 2009 IRP Update - Action Plan Status Report 11/1/2010
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November 1, 2010 Nancy McNeil Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3 rd Floor PO Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: 2009 IRP Update – Action Plan Status Report – P-884/Matte...
AI summary Nova Scotia Power Inc. (NSPI) submitted a status report on the 2009 IRP Update Action Plan by August 4, 2010, as required. The Utility and Review Board (UARB) requested stakeholder comments, with Ecology Action Centre (EAC) providing feedback. NSPI is responding to EAC's comments, particularly regarding the relevance of the preferred reference Plan A.
EAC Comments EAC has filed a 19 page submission with the UARB. While the submission is made in response to the Board's request for comments on NSPI's August 4, 2010 Action Plan Status Report, many of the comments made are not related to th...
AI summary EAC submitted comments to the UARB regarding NSPI's August 4, 2010 Action Plan Status Report, but many comments were not related to the report or the IRP. EAC emphasized the need for NSP to clearly outline how renewable energy and non-emitting imports will meet 2010 renewable energy and GHG reduction goals, while addressing the phase-out of coal-based electricity.
Conclusion The 2009 IRP Update was largely consistent with the 2007 IRP. It confirmed that the assumptions made in the 2007 IRP were robust such that a 'no regrets' strategy was upheld. This means that changes in law, and decisions which o...
AI summary The 2009 IRP Update confirmed the 2007 IRP's assumptions and 'no regrets' strategy, emphasizing the role of fossil fuels and the need for continued exploration of demand-side management and renewable generation. The Reference Plan remains relevant, with limited external feedback, and the Company is encouraged to maintain flexibility in its planning.