Topic:"Integrated Resource Plan" in M08929

lder until April 5, 2019. The following table highlights specific stakeholder comments and how EfficiencyOne has addressed these: Stakeholder Comment How Comment was Addressed Stakeholders should have the Draft scenarios were provided to s...

AI summary Stakeholders requested inclusion of a no-incentive scenario in energy efficiency planning, which EfficiencyOne addressed by providing draft scenarios for review. The discussion highlights use of the Program Administrator Cost (PAC) test for cost-effectiveness screening, with Navigant offering an alternative economic potential analysis to the DSMAG.

importance of stakeholder participation in the Potential Study process, and has considered all feedback provided by stakeholders. EfficiencyOne intends to respect the filing date of August 14, 2019, established by the UARB, for the Final 2...

AI summary EfficiencyOne commits to respecting the August 14, 2019 filing deadline for the 2019 DSM Potential Study and participating in the 2020 Integrated Resource Plan (IRP) process. The study, prepared by Navigant, emphasizes stakeholder feedback and engagement in the DSM planning process.

Yates Annapolis Report - Site Decommissioning Estimate Summary Appendix E Strum Report - Estimation of Wetland Alteration Permitting Costs Appendix F Boreas Report - Hydro Asset Costing Document 14 5 REDACTED (CONFIDENTIAL INFORMATION REMO...

AI summary Nova Scotia Power (NS Power) is required to maintain 40% renewable generation by 2020 under Nova Scotia’s Renewable Energy Standards (RES), achieved partly through hydro power producing approximately 1 terawatt-hour annually. The Hydro Asset Study provides inputs for the next Integrated Resource Plan (IRP) and Depreciation Study, detailing the status of 17 hydro systems with 31 powerhouses and 50 generating units.

1 The Hydro Study outlines the assumptions and methodology used to determine these 2 values. The assumptions outline inclusions and exclusions pursued for the Hydro Study. 3 4 The Hydro Study, which includes Appendices A - F, provides the...

AI summary The Hydro Study details NS Power's methodology for calculating sustaining and decommissioning costs of hydro systems, including forecasted expenses and their inclusion in an Integrated Resource Plan (IRP). Costs outlined do not account for replacement energy or system-wide value, which will be addressed in the IRP process.

7 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Hydro Asset Study REDACTED System Sustaining Decommissioning Annual Generation GWh Paradise $7,130,000 $64,190,000 21 Roseway $4,566,000 Sheet Harbour $33,440,000 $55,460,000 44 Sissiboo $16,29...

AI summary The document outlines sustaining and decommissioning costs for several hydroelectric assets in Nova Scotia, including annual generation data. It also references NS Power's plan to evaluate battery storage technologies in the next Integrated Resource Plan (IRP), citing the 2018 ACE Plan Decision.

Peak Demand Analysis ............................................................................... 49 29 Figure 24: 18 Month Load and Capacity Assessment ................................................................................ 50...

AI summary NS Power's 2019 10-Year System Outlook report outlines load forecasts, DSM updates, generation expansion plans, and environmental compliance. It addresses infrastructure planning, regulatory requirements, and renewable energy projections under the NS Power System Operator (NSPSO) mandate.

regulatory requirements, as well as 17 forecast compliance in Section 6. This section also includes projections of the 18 level of renewable energy available. 19 20 • A Resource Adequacy Assessment in Section 7. 21 22 • A discussion of tra...

AI summary The document outlines the NSPSO system plan, covering transmission investment, DSM programs, generation planning, and new generating facilities. It references the 2019 Ten-Year System Outlook and the UARB-directed IRP process, with pre-IRP deliverables nearing completion by July 31, 2019.

lined several pre-IRP analyses. To date, NS Power has 5 held two sessions with interested parties and is on track to complete its pre-IRP 6 deliverables for July 31, 2019. 2 M08059, UARB Decision Letter, Generation Utilization and Optimiza...

AI summary NS Power is progressing with pre-Integrated Resource Plan (IRP) analyses, having held stakeholder sessions and aiming to complete deliverables by July 31, 2019. The 2019 load forecast, based on the Statistically Adjusted End-Use (SAE) model and econometric industrial forecasts, informs energy planning and Net System Requirement (NSR) projections.

PO Box 910 ● Halifax, Nova Scotia ● Canada ● B3J 2W5 December 16, 2019 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit “M” Halifax, NS B3J 3S3 Dear M...

AI summary Nova Scotia Power Inc. (NS Power) reports completion of the Pre-IRP phase, submission of the Pre-IRP Final Report, and development of the 2020 Integrated Resource Planning (IRP) Draft Terms of Reference (TOR) with consultants Synapse Energy Economics and Bates White Economic Consulting. Stakeholder feedback was solicited on the draft TOR.

(E3) as its primary consultant for the IRP process. 1 Transmission investments include “poles and wires” as well as stability resources such as synchronous condensers and static var compensators. 3 IRP Terms of Reference Consultation Appen...

AI summary The 2020 Integrated Resource Plan (IRP) aims to develop a risk-weighted least-cost electricity strategy ensuring reliability, decarbonization through non-emitting resources, and customer affordability. It also seeks to create an action plan for implementation and establish a collaborative, transparent resource planning process in Nova Scotia.

5 IRP Terms of Reference Consultation Appendix A Page 7 of 12 Developing An Electricity Strategy for the Future The IRP process will seek to identify the least-cost, least-risk portfolio. Traditionally, the primary decision criterion used...

AI summary NS Power's Integrated Resource Planning (IRP) process aims to identify the least-cost, least-risk electricity portfolio over 25 years, using cumulative revenue requirement minimization as the primary metric while also evaluating reliability, emissions reduction, and plan robustness. Key considerations include rate impacts, grid stability, and decarbonization alignment.

Sept 30 2020 10 IRP Terms of Reference Consultation Appendix A Page 12 of 12 11 IRP Terms of Reference Consultation Appendix B Page 1 of 14 Stakeholder Issue Stakeholder Comments NS Power Response Category E1 Objectives It is encouraging t...

AI summary Stakeholders E1 and EAC commend NS Power's alignment of the IRP with climate change and decarbonization goals, noting appreciation for flexibility in objectives. NS Power confirms no changes are required to the IRP Terms of Reference.

licy landscape in the next year. I believe that the second objective and the ‘signposts’ give some of that flexibility. HRM Objectives As the IRP and HalifACT 2050 both move No changes required. forward to adoption, I would like to explore...

AI summary HRM seeks alignment between the Integrated Resource Plan (IRP) and HalifACT 2050 objectives, emphasizing decarbonization and electrification. NS Power acknowledges HRM's engagement in the IRP process. The discussion focuses on regulatory collaboration for climate goals.

E1 Metrics The draft TOR specifies that the Analysis This is an item which will be addressed Plan will establish how six secondary as part of the Analysis Plan. This item metrics will be used as evaluation will be considered as part of the...

AI summary The draft TOR outlines six secondary metrics for evaluating the IRP, alongside the primary metric of cumulative present value of annual revenue requirements. Secondary metrics like 'flexibility' and 'robustness' are harder to quantify, potentially causing contention. Stakeholders will comment on assumptions and the Analysis Plan as per the Q1 2020 Schedule in the TOR.

, while recognizing the differences among supply plans in terms of accommodating changes of the first type. Page 5 of 14 IRP Terms of Reference Consultation Appendix B Page 6 of 14 IRP TERMS OF REFERENCE – STAKEHOLDER COMMENTS Stakeholder...

AI summary A stakeholder comments that the IRP TOR lacks emphasis on reliability analysis, critical for assessing capacity benefits of renewables, storage, and the Maritime Link. NS Power agrees, stating reliability contributions will be addressed in the analysis plan and input assumptions.

or contribution equivalent to 150-MW steam units that require a 20% reserve), rather than a mix of approaches. HRM Constraints / Will NSP validate its key assumptions? If NS Power will validate the IRP’s key Assumptions so, will it compare...

AI summary The document discusses NS Power's validation of Integrated Resource Plan (IRP) assumptions and stakeholder engagement processes. It raises concerns about equitable energy access as technologies develop, with NS Power stating the IRP focuses on lowest-cost strategies compliant with regulations rather than detailed access considerations.

Plan consideration at the conclusion of the IRP. Page 6 of 14 IRP Terms of Reference Consultation Appendix B Page 7 of 14 IRP TERMS OF REFERENCE – STAKEHOLDER COMMENTS Stakeholder Issue Stakeholder Comments NS Power Response Category AREA...

AI summary A stakeholder argues that the IRP's focus on minimizing revenue requirements should prioritize cost to rate payers, while NS Power maintains the IRP is ownership-agnostic and focuses on required resources over the long term.

8 of 14 IRP TERMS OF REFERENCE – STAKEHOLDER COMMENTS Stakeholder Issue Stakeholder Comments NS Power Response Category SBA Scenarios NSP should include, within scenarios or NS Power agrees with this comment. sensitivity, significant poten...

AI summary Stakeholder SBA requests NS Power to include significant potential breakthroughs in scenarios or sensitivity analyses within the IRP. NS Power agrees, stating this is addressed in their Process & Deliverables steps, including establishing an analysis plan and developing input assumptions through stakeholder engagement.

may be raised during the stakeholder consultation process. E1 Outputs The TOR should specify whether avoided The methodology for calculating the costs of transmission and distribution avoided costs of transmission and due to DSM will be an...

AI summary The Terms of Reference (TOR) must clarify whether avoided transmission/distribution costs from Demand Side Management (DSM) are inputs or outputs of the Integrated Resource Plan (IRP). NS Power expects these calculations to occur outside the IRP model, while environmental compliance costs are inherently included in IRP optimization due to environmental constraints.

Natural Forces Services Inc. 1801 Hollis Street Suite 1205 Halifax NS B3J 3N4 T: (902) 422 9663 F: (902) 422 9780 Doreen Friis January 6, 2020 Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3...

AI summary A letter from Natural Forces Services Inc. to the Nova Scotia Utility and Review Board regarding the 2020 Integrated Resource Plan Terms of Reference. The document does not include specific arguments or claims but references the regulatory process.

Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit “M” Halifax, NS B3J 3S3 RE: 2020 Integrated Resource Plan Terms of Reference Dear Ms. Friis,

AI summary The Nova Scotia Utility and Review Board sent a letter referencing the '2020 Integrated Resource Plan Terms of Reference' to Ms. Friis. The document establishes procedural context for a regulatory proceeding related to energy planning.

Thank you for your letter, entitled ‘M08929 - Integrated Resource Planning’ dated December 19, 2019. Having reviewed the Draft Terms of Reference’ (“ToR”) in respect of the Integrated Resource Plan (“IRP”), and the related stakeholder comm...

AI summary The response to NS Power's Integrated Resource Plan (IRP) ToR supports alignment with SDGA goals, flexibility in strategy development, and long-term affordability. It criticizes the current IRP decision criterion for not prioritizing greenhouse gas emissions reduction and urges explicit stakeholder review timelines. The stakeholder supports examining coal unit replacement by 2030/2040 and earlier.

Nicole Godbout Director, Regulatory Affairs Nova Scotia Power Inc. 1223 Lower Water Street PO Box 910 Halifax, NS B3J 2W5 Via email: [email protected] And Crystal Henwood Administrative Assistant to Doreen Friis, Regulatory Affairs...

AI summary Envigour Policy Consulting Inc., representing QUEST and Marine Renewables Canada, requests greater detail on technology price uncertainty in Nova Scotia Power's Integrated Resource Plan. They emphasize the need for models to determine economic thresholds for renewable energy and distributed resources over a 25-year planning horizon.

, on behalf of its clients, stated that it had reviewed the proposed Terms of Reference and is generally satisfied with the wording and approach and 1 Exhibit N-4. January 17, 2020 D. Friis provided a few additional comments for considerat...

AI summary NS Power and Natural Forces discuss the Terms of Reference (TOR) for the Integrated Resource Plan (IRP). Natural Forces criticizes NS Power's focus on minimizing revenue requirements in IRP modeling, arguing that greenhouse gas emissions reduction should be a primary criterion. NS Power reaffirms using revenue requirements as the primary metric but acknowledges other considerations.

Party Question/Comment & Response 1.1 E1 The Federal government released a draft of new national clean fuel standards, including liquid fossil fuels and solid fossil fuels. Will these regulations be considered for the IRP modelling, assumi...

AI summary The Federal government's draft clean fuel standards will be considered in NS Power's Integrated Resource Plan (IRP) during the Assumptions Development phase. Envigour inquires if the IRP process will address risks and benefits of distributed energy resources (DERs), with NS Power confirming input opportunities during the Assumptions Development and Analysis Plan phase. Topic 2 discusses Planning Reserve Margin (Capacity Study).

Party Question/Comment & Response 2.1 Bates White ...we recommend that NSPI apply more conservative – i.e., lower – PRM values in its IRP evaluations… It is our view that the IRP process should be focused on ways to minimize the costs impo...

AI summary Bates White recommends NSPI use lower PRM values in its IRP to minimize customer costs and avoid excess capacity risks. NS Power responds that lower PRM may not reduce costs due to factors like emissions constraints, citing Synapse GUO modeling showing optimal portfolios often include excess capacity for economic or emissions benefits.

ow-cost scenarios to identify common elements; these common elements are understood to be robust to a wide range of potential futures and can be incorporated into a no regrets Action Plan and Roadmap. The IRP analysis has shown that combus...

AI summary The IRP analysis identifies combustion turbines as the lowest-cost domestic source of new firm capacity, emphasizing their role in integrating renewables and reducing GHG emissions. Demand Response programs and battery storage are also highlighted, though the latter's capacity substitution is limited by duration. Existing Nova Scotia Power resources and redevelopment options are considered for low-cost, low-emission generation.

Nova Scotia Power IRP Final Report Appendix A Page 1 of 64 Deep Decarbonization in Nova Scotia: Phase 1 Report Nova Scotia Power Inc. February 2020 Nova Scotia Power IRP Final Report Appendix A Page 2 of 64 Deep Decarbonization in Nova Sco...

AI summary The document is an appendix from Nova Scotia Power's Integrated Resource Plan (IRP) Final Report, focusing on deep decarbonization in Nova Scotia. It includes corrections to figures and tables due to unit conversion errors, emphasizing that these errors do not affect the underlying system modeling. The report is part of Phase 1 of the decarbonization strategy.

Total Energy by Fuel 1.88 3% All Buildings Subsectors 62.59 100% +Building Shell is modeled to represent potential deep home retrofits and other measures which significantly reduce space conditioning demands. By itself a Building Shell sto...

AI summary The text discusses Nova Scotia Power's Integrated Resource Plan (IRP) reference scenario, modeling energy efficiency measures like 'Building Shell' retrofits reducing space heating demand by 20%. It categorizes energy uses (Residential/Commercial 'Other') and notes E3's role in modeling efficiency scenarios.

27 P a g e © 2020 Energy and Environmental Economics, Inc. Nova Scotia Power IRP Final Report Appendix A Page 33 of 64 Table 5. Representation of 2016 Transportation Energy Consumption by Subsector in Nova Scotia Subsector Modeling Approac...

AI summary The document presents a table detailing Nova Scotia's 2016 transportation energy consumption by subsector, including long/short wheelbase light-duty vehicles, heavy-duty trucks, aviation, and others. It references the 'Reference Scenario' in section 2.5.4.2 of the Nova Scotia Power IRP Final Report, focusing on energy use distribution across transportation categories.

lover 0.73 1% All Transportation Subsectors 74.48 100% 2.5.4.2 Reference Scenario The main driver of energy reductions in the Reference scenario are continued federal Light Duty Vehicle (LDV) Corporate Average Fuel Economy (CAFE) Standards...

AI summary The Reference Scenario analysis highlights federal LDV CAFE Standards as key drivers for energy reductions, with Canada continuing improvements through 2026. Electric passenger vehicles and CNG trucks are modeled, though freight truck energy demands remain significant. E3's analysis underpins Nova Scotia Power's IRP Final Report.

29 P a g e © 2020 Energy and Environmental Economics, Inc. Nova Scotia Power IRP Final Report Appendix A Page 35 of 64 Figure 15. Stock Rollover from the Reference Scenario and Building Electrification Scenario: Light Duty Vehicles 2.5.4.3...

AI summary The document discusses vehicle decarbonization through electrification in Nova Scotia's Integrated Resource Plan (IRP), focusing on Light-Duty Vehicles (LDVs). It outlines mitigation scenarios involving hybrid-electric and zero-emission vehicles (ZEVs) like battery electric (BEV) and plug-in hybrid electric (PHEV), with Table 6 detailing key measures for three scenarios.

Introduction ....................................................................................................................... 4 Assessment of IRP Compliance with FAM Audit Recommendations ......................... 4 A. Recommendatio...

AI summary The document assesses compliance with FAM audit recommendations on the Integrated Resource Plan (IRP), emphasizing regular planning, reserve margin determination, transparent peak load forecasting, and stakeholder input. It highlights the need to evaluate natural gas infrastructure, biomass plant value, and combustion turbine analysis, alongside addressing cost-benefit assessments and load effects.

g combustion turbines differ substantially from new combustion turbines. ................................................................................................................. 15 3. Battery storage is not limited from providing...

AI summary The document discusses combustion turbine differences, battery storage capacity, and IRP results highlighting reliance on firm imports and regional transmission. It addresses electrification uncertainties, sensitivity to resource costs, and NSPI's Action Plan evaluation, emphasizing the need for competitive procurement and substantiating investment decisions.

get Planning Reserve Margin. In other words, a PRM of less than 9%/20% can be ‘more optimal’ and should be continue to be evaluated as part of future procurement efforts and the IRP evergreen process. 3. Provide Transparent Peak Load Forec...

AI summary The text discusses evaluating lower Planning Reserve Margins (PRM) below 9%/20% as optimal in future procurement and the IRP process. It praises NSPI for transparent peak load forecasting, incorporating diverse scenarios to address past overestimations. The recommendation emphasizes considering all investment alternatives, including demand-side management, transmission expansion, and renewable resources, as part of the IRP.

l transportation and handling infrastructure, decommissioning costs, NSPI’s return of and on capital related to each plant, and FAM cost impacts, among potentially many others.31 In our view, NSPI complied with this aspect of our recommend...

AI summary The text discusses NSPI's compliance with recommendations regarding sustaining capital costs, O&M costs, and decommissioning. NSPI adjusted forecasts, including a high-cost scenario advancing coal retirement and retiring a gas unit. The importance of these assumptions in shaping the optimal resource plan is emphasized, with examples like Trenton 5's low capacity factors and high sustaining costs.

e likely not an intentional omission, it is worth underscoring the fact that sustaining the existing thermal units incurs costs that are otherwise avoidable if those units are mothballed or shut down. The IRP modeling made certain assumpti...

AI summary The text discusses NSPI's Integrated Resource Plan (IRP) assumptions about sustaining existing thermal units, noting that higher-than-expected sustaining costs could undermine the IRP's preferred portfolio, shifting retirement timelines for coal and gas steam units. It also highlights differences between NSPI's existing and new combustion turbines in cost and capacity roles.

lopment of a “Regional Integration Strategy” as its number one action item in its Action Plan.56 This is crucial, as time is of the essence in pursuing regional solutions due to the risks noted above. In addition, in light of the risks ass...

AI summary The text emphasizes the urgency of developing a 'Regional Integration Strategy' as a top priority. It recommends three actions for NSPI: implementing a circuit breaker in its evergreen process if regional solutions stall, avoiding linking thermal retirements to the strategy's success, and using competitive procurement (e.g., all-source RFPs) to ensure timely and economic capacity replacement.

Analysis of Nova Scotia Power’s 2020 Integrated Resource Plan Recommendations on Key Findings, Action Plan, and Roadmap Elements Prepared for Counsel to Nova Scotia Utility and Review Board December 23, 2020 AUTHORS Bob Fagan Devi Glick Sh...

AI summary This document analyzes Nova Scotia Power’s 2020 Integrated Resource Plan, focusing on scenario planning, modeling assumptions, and results. It addresses load forecasting, demand-side management, and electrification strategies, prepared for the Nova Scotia Utility and Review Board. Key sections include modeling methodologies and outcomes from Synapse Energy’s analysis.

...................................................................5 3.2. Synapse PLEXOS Modeling ............................................................................................. 12 4. COMMENTS AND RECOMMENDATIONS ON KEY FINDI...

AI summary Synapse was engaged by the Nova Scotia Utility and Review Board Counsel in 2019 to analyze Nova Scotia Power Inc.'s 2020 Integrated Resource Plan (IRP). The work included reviewing pre-IRP studies, collaborating on scenario development, using PLEXOS modeling, and evaluating NSPI's assumptions about load forecasts, wind power costs, transmission issues, and energy efficiency/demand response alternatives.

, and sensitivity to input assumptions that can understandably be subject to uncertainty (sometimes considerable uncertainty such as forecasting the pace of increased electrification in the Province). However, defining an eventual final se...

AI summary The text discusses NSPI's use of scenarios and sensitivity analysis in its Integrated Resource Plan (IRP), noting that defining scenarios does not guarantee comprehensive coverage of all possibilities. It highlights uncertainty in assumptions like electrification rates and clarifies that NSPI treats all modeling runs as scenarios, even when labeled 'sensitivity.' The analysis acknowledges limitations but emphasizes valid insights from the modeled scenarios.

6 Max - Savings from Base (Base minus Max) 43 6 2 4 6 9 11 12 13 14 -23 9 2 7 NPV 2021- 2045, $ Sensitivity - at $50/ton millions Value, $ millions (2021 real) Mid - Savings from Base (Base minus Mid), $ millions 171 9.8 3.9 5.4 7.7 11.0 2...

AI summary The text evaluates the financial and environmental impacts of different demand-side management (DSM) scenarios, highlighting that additional carbon reductions beyond allocated emissions could yield significant benefits. However, the 'Max DSM' scenario increases emissions due to reliance on coal and delayed wind energy adoption. NPV calculations use a $24/ton carbon value and a 4.42% real discount rate.

3 and Roadmap elements #6 and #3) and the overall evergreen process (Roadmap element #8) should continuously review cost and benefit assumptions concerning the retention timeline for the coal units. Demand Response We support all efforts t...

AI summary The text discusses the need to review cost and benefit assumptions for coal unit retention timelines, supports expanding cost-effective demand response resources, and notes alignment between Synapse PLEXOS modeling results and NSPI's analyses, with minor numerical differences due to modeling execution variations.

ducting our own modeling runs. The final results from Synapse’s modeling did not materially change our overall perspective on the most important aspects of NSPI’s Action Plan and Roadmap direction. 4. COMMENTS AND RECOMMENDATIONS ON KEY FI...

AI summary Synapse acknowledges NSPI’s Action Plan and Roadmap as reasonable but highlights gaps in addressing key factors from IRP analyses. Recommendations focus on modifying the Roadmap to enhance analytical support and adaptability during implementation.

value attributed to earlier (than NSPI’s “reference” Scenario 2.0C)15 installations of the wind resource can be considered as a credit to the actual cost of such earlier installations. • Finding 2a. Reliability Tie as Key Enabling Transmis...

AI summary NSPI argues the Reliability Tie is a key transmission resource enabling in-province wind generation without external reliance. Findings note earlier coal retirements are incrementally costly but have similar long-term rate impacts. The Reliability Tie is positioned as a critical first step for regional interconnection.

David S. MacDougall Direct +1 (902) 444 8561 [email protected] 1969 Upper Water Street Suite 1300 Purdy's Wharf Tower II Halifax NS Canada B3J 2V1 Tel +1 (902) 425 6500 Fax +1 (902) 425 6350 Our File: 179164 January 20, 20...

AI summary Port Hawkesbury Paper LP comments on Nova Scotia Power Inc.'s Final Integrated Resource Plan Report, noting a shift toward renewable energy and decoupling of energy and capacity resources in a carbon-constrained paradigm. The report, filed with the Nova Scotia Utility and Review Board, outlines future planning strategies.

179164 January 20, 2021 Consistent with the modelling findings of the IRP Report and as the Board is aware, PHP has been working for some time on the development of a potential large scale wind project to support a portion of its electrici...

AI summary PHP is advancing a large-scale wind project, influenced by the IRP Report and the Federal government's carbon reduction strategy. Synapse Energy Economics analyzed the impact of valuing incremental carbon reductions on resource builds and revenue requirements, highlighting their significance in the context of the IRP.

EfficiencyOne IN THE MATTER OF: The Public Utilities Act - and - IN THE MATTER OF: Nova Scotia Power 2020 Integrated Resource Plan M08929 EfficiencyOne Comments FILED January 20, 2021

AI summary EfficiencyOne submitted comments in a regulatory proceeding under the Public Utilities Act regarding Nova Scotia Power's 2020 Integrated Resource Plan. The filing date is January 20, 2021, and the matter is designated M08929.

s in Nova Scotia. Given this, E1 considers it critical that a broad stakeholder - driven approach be used for the development of any Electrification Strategy produced as part of the - IRP Action Plan. - Further, as electrification costs ar...

AI summary E1 emphasizes the need for a stakeholder-driven approach in developing Nova Scotia's Electrification Strategy as part of the IRP Action Plan. It also argues that electrification costs should be incorporated into ongoing IRP updates to ensure ratepayer-focused least-cost planning.

Data Access and Transparency - 10. Data accessibility and transparency, specifically of key modelling data, including model inputs, remain areas of opportunity for future IRP processes in Nova Scotia. - E1 appreciates the opportunity to pr...

AI summary The text highlights opportunities for improving data accessibility and transparency, particularly regarding key modelling data inputs, in future Integrated Resource Plan (IRP) processes in Nova Scotia. E1 acknowledges the opportunity to provide comments on these matters.

A. Long-term Electrification Investment Strategy NS Power is to be commended for making electrification a central part of its IRP. The IRP provides appropriate policy, business, and analytic support for its Action Plan for electrification....

AI summary NS Power's Integrated Resource Plan (IRP) supports electrification, requiring increased investments in full electrification and T&D. Mersey's ELCC value is questioned.

1) Longer-term electrification program costs Electrification is a key part of most greenhouse gas reduction strategies. We expect (and NS Power appears to agree) that some program funding would be required to achieve the higher levels of e...

AI summary Electrification is critical for GHG reduction, requiring program funding. NS Power estimates up to $10.8M annual investment in electrification without rate increases, balancing cost-to-customer concerns and carbon reduction benefits. Halifax's goals and undetermined program designs are highlighted.

C. Value of Greenhouse Gas Reductions The vast majority of the model results indicate that it will be cost-effective for NS Power to operate with lower CO2 emissions than required by regulation and law. These emissions reductions have valu...

AI summary NS Power's models suggest cost-effectiveness in reducing CO2 emissions below regulatory requirements, using a shadow price for CO2 in dispatch. However, forecasting this price is challenging. The Board is advised to include this in future IRP modeling to align planning with dispatch decisions.

January 20, 2021 VIA EMAIL Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M08929 - NS Power's Integrated Resource Plan (...

AI summary The Small Business Advocate (SBA) participated in NS Power Inc's (NSPI) stakeholder engagement process for its Integrated Resource Plan (IRP). The SBA acknowledges NSPI's collaboration and notes that stakeholder feedback was incorporated into the IRP Final Report, which is described as comprehensive.

II. IRP Process Comments

AI summary The section discusses the Integrated Resource Plan (IRP) process, involving entities like NS Power Inc and the Small Business Advocate. It focuses on regulatory considerations related to resource planning and stakeholder input.

IV. IRP Recommended NSPI Resource Prioritization

AI summary The section outlines the Integrated Resource Plan's (IRP) recommended prioritization of resources for NS Power Inc. (NSPI), focusing on strategic allocation of energy generation, grid modernization, and demand-side management initiatives.

A. NSPI Favoured resources In the IRP NSPI has set out a prioritization of resource development activities. The SBA notes that the focus and action items appear to be on the continued utilization of existing generation assets; the retireme...

AI summary NSPI's IRP prioritizes existing generation assets, coal fleet retirement, and regional integration through transmission and imports. The SBA highlights these focus areas, while the IRP emphasizes incremental renewables and challenges in system inertia and interconnection reliability, citing lessons from past projects like Maritime Link and Muskrat Falls.

B. Reliance on Natural Gas Stepping back and looking at the big picture, the SBA notes that it is surprising how much the IRP includes investment in natural gas burning assets. The SBA acknowledges that any movement from coal fueled genera...

AI summary The SBA expresses concerns about NSPI's reliance on natural gas in the IRP, warning that investments in natural gas assets may become stranded if non-emitting alternatives emerge. It questions the economic assumptions behind coal-to-gas conversions, existing peaking generation refurbishments, and new natural gas capacity, urging NSPI to prioritize low-carbon options and delay investments until non-emitting technologies mature.

C. Renewable Resource Development In the IRP NSPI assumes onshore wind is the primary renewable resource as part of the future portfolio. Other areas on the Atlantic coast of North America are focusing on offshore wind to provide resource...

AI summary NSPI's IRP prioritizes onshore wind, but questions arise about offshore wind's benefits and cost sensitivity. The SBA highlights system integrity issues in the renewable integration study, urging expansion and near-term investments. Sensitivity modeling and offshore wind cost tracking are recommended.

D. Absence of Energy Storage in the Plan Energy storage is perhaps the one resource, across the whole electric utility industry, which is at its most dynamic point of technological development. Advances in battery energy storage are fundam...

AI summary The text highlights the lack of energy storage consideration in NSPI's Integrated Resource Plan (IRP), noting its dynamic technological development and critical role in transportation electrification. It criticizes the IRP for not evaluating future battery storage costs or monitoring large-scale projects to ensure peaking capacity without system risks, suggesting a lack of foresight.

A. Limitation on Conclusions that can be Drawn from the IRP Analysis The SBA has been supportive throughout the IRP process for a focus on recognizing that a resource plan must reflect the province's policies regarding decarbonization. Con...

AI summary The SBA cautions that the IRP analysis may underestimate costs and system investments needed for electrification, lacks rate design considerations, and assumes zero transmission/distribution costs. While acknowledging electrification's decarbonization benefits, the SBA stresses uncertainties in timing, cost allocation, and unaddressed infrastructure needs.

B. Coordination with New Brunswick The prospect of Regional Integration is enticing, as it suggests the ability to efficiently manage our electricity needs, with a strong backup from New Brunswick and beyond. However, the term 'integration...

AI summary The text discusses challenges in regional electricity integration with New Brunswick, highlighting potential risks to Nova Scotia's Integrated Resource Plan (IRP) if New Brunswick declines participation. It emphasizes the need for stakeholder engagement and caution in relying on cross-provincial collaboration to ensure ratepayer interests are protected despite conflicting demands.

sustaining capital investment. Economic justification as part of a capital application will be required to confirm decision to pursue Mersey hydro redevelopment,following the completion of the IRP. The SBA would like to see NSPI prepare a...

AI summary The SBA urges NSPI to develop a least-cost strategy for Mersey hydro redevelopment and integrate DSM into planning. DSM programs under the Base profile are most economical per the EfficiencyOne 2019 study, with peak demand mitigation emphasized. Sensitivities show varying impacts on NPVRR, GHG, and capacity requirements across DSM levels.

missions intensity, and dispatch flexibility. This work will proceed in parallel with the wind procurement strategy (Action Item 3d, below) and will include supporting transmission planning studies. The SBA finds the action item surroundin...

AI summary The SBA criticizes the premature focus on the regional integration strategy without prior regulatory approval, warning of high costs and uncertainty about energy availability. Electrification is highlighted as a key IRP component, with NS Power proposing related action items to support decarbonization and rate stability.

RE: M08929 – NSPI Integrated Resource Planning – IRP Report Comments Heritage Gas has reviewed the 2020 Integrated Resource Plan ("IRP"), distributed to stakeholders on November 27, 2020, and notes that the IRP foresees a significant incre...

AI summary Heritage Gas reviews the 2020 IRP, noting its projected increased reliance on natural gas for reliability during low renewable periods and peak loads. It emphasizes natural gas's role in providing ancillary services to support renewable integration, raising specific concerns about the IRP's assumptions.

Critique Synopsis The IRP fails to deliver a useful foundation for which to build an actionable climate strategy, primarily due to inadequate planning and faulty methodology. Thus, the final product is a "roadmap" and "action plan" with a...

AI summary The Integrated Resource Plan (IRP) is criticized for inadequate planning and methodology, failing to integrate with broader climate solutions. SCCF argues NSP's plan prioritizes fossil fuels over clean energy, misses PACE financing opportunities, and requires independent review and regulatory reform to address environmental and health concerns.

IRP Responses IRP Presentation (Inadequate Presentation): The IRP is scattered with poorly presented and misleading information, buzzwords, and bias. The author(s) should instead take a neutral stance as to what NSP has done historically,...

AI summary The IRP is criticized for inadequate presentation, bias, and failure to align with climate goals. It lacks detailed SDGA goals, misses opportunities for federal funding, and includes fossil fuel repurposing instead of DER/DSM. The IRP should prioritize climate science and coal shutdown by 2030.

undertaken within this process. The comments and observations by the various stakeholders appeared to be heard and incorporated into subsequent documentation and drafts by NSPI, which is appreciated. The IRP Final Report filed by NSPI is c...

AI summary Stakeholders' input was incorporated into NSPI's IRP process, with the SBA noting effective engagement and alignment of the IRP with NS Power's strategy. The SBA and PHP confirmed the value of stakeholder dialogue and agreement with the IRP's direction.

M08929 - Nova Scotia Power Inc. -Integrated Resource Planning and Generation Utilization and Optimization (P-884) In its letter of October 25, 2018 in matter M08059, the Board directed Nova Scotia Power to undertake certain studies conside...

AI summary Nova Scotia Power Inc. was directed by the Board to complete pre-IRP studies, including reserve margin, resource options, renewable integration stability, and demand response analyses, to inform its 2020 Integrated Resource Plan (IRP). The IRP aims to identify the lowest-cost 25-year strategy balancing supply/demand resources, reliability, and legislative requirements. The Board approved the IRP's Terms of Reference in January 2020 after stakeholder feedback.

ntified the following nine recommendations which need to be undertaken as the first phase of an IRP process, in order to ensure the completeness and accuracy of input assumptions used in the analysis:

AI summary The document identifies nine recommendations as the first phase of an Integrated Resource Planning (IRP) process, aimed at ensuring the completeness and accuracy of input assumptions for analysis in generation utilization and optimization.

May 17, 2019 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: NS Power 2020 Integrated Resource Plan (IRP) – Pre-IRP Works...

AI summary The Nova Scotia Utility and Review Board directed NS Power to complete its 2020 Integrated Resource Plan (IRP) by mid-2020, with pre-IRP analyses due by July 31, 2019. Key deliverables include studies on loss of load expectations, resource options, demand response assumptions, and transmission requirements for renewable integration.

l be addressed by E1's Potential Study (Synapse recommendations 6, 8, and 9 will be addressed in the broader IRP analysis process (e.g. during assumptions development or in the modeling phase itself). NS Power has been providing Board staf...

AI summary NS Power is updating the Board on progress with pre-IRP deliverables, planning workshops to engage stakeholders, and requesting the Board to circulate the update to gather interest in participation. Workshops are scheduled for May, June, and July 2019, with deliverables expected by July 31, 2019.

January 9, 2020 VIA EMAIL Ms. Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Friis: Re: M08929 - Comments on Draft Terms of Reference for IR...

AI summary The Small Business Advocate (SBA) confirms no further comments on Nova Scotia Power Inc.'s (NSPI) Draft Terms of Reference for an Integrated Resource Plan (IRP), acknowledging prior feedback was addressed in NSPI's filing.

Envigour stated: Envigour Policy Consulting Inc. has been retained by QUEST and Marine Renewables Canada as their consultant in this matter. We have reviewed the Draft Terms of Reference Document and are generally satisfied with the wordin...

AI summary Envigour suggests including detailed uncertainty analysis on technology price declines in the Integrated Resource Plan (IRP). NS Power agrees but asserts this is addressed via 'signposts' in the Strategy. The Board approves the Terms of Reference (TOR) but urges NS Power to consider Envigour's feedback during the IRP process.

Nicole Godbout Director, Regulatory Affairs Nova Scotia Power Inc. 1223 Lower Water Street PO Box 910 Halifax, NS B3J 2W5 Via Email: [email protected] And Crystal Henwood Administrative Assistant to Doreen Friis, Regulatory Affairs...

AI summary The letter from Nova Scotia Power Inc. and the Nova Scotia Utility and Review Board discusses the need to reassess the integration of Distributed Energy Resources (DERs) in the Integrated Resource Plan (IRP). It highlights concerns that current assumptions undervalue DERs' contributions when combined with storage and emphasizes the need for further analysis and discussion on incorporating these factors into the Roadmap.

munity Solar PV Gardens. It would be useful to discuss whether this concept is the same as DERs from the model's perspective and, if not, how it may be considered as well. - 2. The model did not select several potential technologies such a...

AI summary Bruce Cameron raises questions about the IRP model's treatment of community solar PV gardens, unselected technologies like offshore wind, tidal, and hydrogen, reliance on natural gas (CCGT), and the economic impact on NS GDP. He seeks clarification on model assumptions, reliability risks, and sourcing of goods/services.

July 28, 2020 Via Email Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Dear Ms. Henwood, Re: Re: P-884 - M08929, NS Power's Integrated Resour...

AI summary NS Power updates the NSUARB on progress with its Integrated Resource Plan (IRP), including modeling results, stakeholder feedback, and a request for additional time to address comments. The company emphasizes transparency and ongoing engagement with the Board and stakeholders, aiming to finalize the IRP by September 30, 2020.

ome further analysis in relation to key issues raised by the parties, and to allow for the appropriate engagement on the final milestones for the project leading to the completion of the final report. To that end, NS Power is seeking Board...

AI summary NS Power requests an extension to file its Final Report from September 30, 2020, to October 30, 2020, citing the need for additional analysis and stakeholder engagement. Adjusted milestones for the Integrated Resource Plan (IRP) process are outlined, with the final report submission shifting to October 30, 2020.

August 10, 2020 VIA E-MAIL Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax, Nova Scotia B3J 3S3 Dear Ms. Henwood: Re: P-884 – Nova Scotia Power Inc. (NSPI...

AI summary NSPI requested an extension to file its final report, with stakeholder comment periods approved. Halifax's HalifACT 2050 climate plan emphasizes electrification (EVs, heat pumps, solar) and grid modernization, requiring collaboration with NSPI to meet 2050 decarbonization targets.

a significant issue, as is the continued collaboration between HRM and NSPI to ensure the electrical distribution system in HRM can accommodate the changes that are needed to achieve our 2050 targets. Considering the above, HRM wants to gi...

AI summary HRM requests an extension of deadlines for reviewing the Draft Findings and Action Plan and Draft IRP Report, citing the need for a thorough review to align with climate goals. They emphasize the importance of sufficient time to ensure the IRP accommodates HRM's Climate Action Plan.

M08929 - Nova Scotia Power Inc.'s Integrated Resource Plan (IRP) (P-884) Thank you for your letter of August 10, 2020, regarding the IRP timeline. Halifax Regional Municipality (HRM) is requesting that the Board extend the response times f...

AI summary Halifax Regional Municipality (HRM) requested an extension for submitting the Draft IRP Report, citing the need to assess integration of the HalifACT 2050 report. The Board declined, stating stakeholders have ample opportunity to engage through existing processes, including a September 2020 workshop.

A Potential Pathway To enable a transparent and inclusive process, we suggest an annual or semiannual extended workshop on climate change and clean technology policies and programs informed by expert views on trends for electricity technol...

AI summary The text proposes annual/semiannual workshops on climate change and clean tech policies, emphasizing declining costs of wind, solar, storage, and crossover fuels like RNG and hydrogen. Workshops would involve stakeholders, experts, and not-for-profits, with outcomes informing the Integrated Resource Plan (IRP) and enabling regular updates to address technological and policy changes.

October 30, 2020 Via Email Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Dear Ms. Henwood, Re: Re: P-884 - M08929, NS Power's Integrated Res...

AI summary Nova Scotia Power Inc. (NS Power) requests an extension until November 27, 2020, to file its Final Integrated Resource Plan (IRP) report with the Nova Scotia Utility and Review Board (NSUARB), citing the need to address stakeholder feedback on the draft IRP. The Board previously extended the deadline from September 30 to October 30, 2020.

M08929 - NS Power's Integrated Resource Plan (P-884) NS Power filed its Integrated Resource Plan on November 27, 2020. The Board understands that there has been extensive consultation with Interested Parties in connection with the preparat...

AI summary NS Power submitted its Integrated Resource Plan (IRP) on November 27, 2020. The Board will not formally approve the plan but seeks stakeholder input to create a complete record, with comment deadlines set for December 23, 2020, January 20, 2021, and February 16, 2021. The Board panel includes Peter W. Gurnham, Roland A. Deveau, and Steven M. Murphy.

M08929 - Nova Scotia Power Inc. -Integrated Resource Planning and Generation Utilization and Optimization (P-884) In its letter of October 25, 2018 in matter M08059, the Board directed Nova Scotia Power to undertake certain studies conside...

AI summary Nova Scotia Power (NSP) was directed by the Board to complete pre-IRP studies addressing Synapse and Bates White reports. The Final Pre-IRP Report included studies on reserve margins, resource options, renewable integration stability, and demand response. The IRP aims to identify the lowest-cost 25-year plan balancing supply-demand options, reliability, and legislative requirements. NSP sought approval for its 2020 IRP Terms of Reference, which the Board granted in January 2020.