Topic:"Integrated Resource Plan" in M11307

KEY FINDINGS Based on the common themes observed, the following are the key guiding principles to inform the Action Plan and Roadmap Items: - Variable renewable capacity additions are required to meet the 2030 targets. Up to 1500MW of addi...

AI summary Key findings emphasize the need for 1500MW additional wind, 200MW solar, and 100-900MW firm capacity by 2030. Battery storage (≥100MW) and the Reliability Tie are critical across scenarios. The Atlantic Loop reduces costs/emissions with government support. Synchronous condensers and SMRs (late 2030s) address system reliability and decarbonization. NS Power updated its 2020 IRP based on 2023 modeling.

Item 2b: Data Collection Continue to collect detailed data, including data on the quantity, flexibility and hourly load shape of incremental electrification demand, to assist with further system planning work. Updated 14 IRP Action Plan an...

AI summary The document emphasizes the need to collect detailed data on electrification demand, including quantity, flexibility, and hourly load shape, to support system planning. It references the Atlantic Clean Power Roadmap and updates to the Integrated Resource Plan (IRP) Action Plan.

ITEM 5: FEDERAL CLEAN ELECTRICITY REGULATIONS (CER) Track the ongoing development of the Federal Clean Electricity Regulations (CER). In particular, monitor for changes to carbon pricing policy or limitations on use of gas and oil-fired ge...

AI summary The document emphasizes tracking the Federal Clean Electricity Regulations (CER), focusing on potential changes to carbon pricing policies and restrictions on gas and oil-fired generation beyond those addressed in the evergreen Integrated Resource Plan (IRP).

Bates White Economic Consulting's Comments On Nova Scotia Power, Inc.'s Evergreen IRP Action Plan & Roadmap Update Presented to: The Nova Scotia Utility and Review Board Prepared by Vincent Musco Collin Cain M10504 September 8, 2023

AI summary Bates White Economic Consulting submitted comments on Nova Scotia Power, Inc.'s Evergreen IRP Action Plan & Roadmap Update to the Nova Scotia Utility and Review Board. The document, prepared by Vincent Musco and Collin Cain, addresses regulatory matters related to the IRP under matter number M10504.

Introduction These comments address Nova Scotia Power's August 2023 updated Action Plan and Roadmap items from its 2023 Evergreen Integrated Resource Plan (IRP). NSPI's modeling exercise in the Evergreen IRP update reflects critical input...

AI summary Nova Scotia Power's updated 2023 Evergreen IRP reflects policy changes including 80% renewable energy by 2030, coal phase-out by 2030, and increased wind power procurement. The analysis considers hydrogen as a potential fuel, excludes near-term interprovincial energy imports, and retains 2020 capacity contribution estimates for clean resources. Synapse supports the IRP's methods but notes reservations.

2. Overview NS Power's Evergreen IRP represents substanfial forward progress in the ufility's planning acfivifies. Many of the concerns that we had at the conclusion of the 2020 IRP have been addressed in a reasonable manner. The range of...

AI summary NS Power's Evergreen IRP shows progress but delays key projects due to investment limits, risking higher costs. The ACE Plan acknowledges urgency for ECEI projects by 2030, yet they're excluded from 5-year capital forecasts. Grid-enhancing technologies and dynamic line ratings are deferred, while economic dispatch software is slated for 2024–2025 to support clean energy transition.

H. Hydrogen Producfion We recommended that NS Power include development of a conceptual hydrogen producfion tariff in the IRP acfion plan, to provide potenfial projects with an indicafion of potenfial pricing and terms, even ifsuch a tarif...

AI summary The text discusses a recommendation for NS Power to develop a conceptual hydrogen production tariff as part of its Integrated Resource Plan (IRP) action plan. NS Power responded by proposing to monitor the hydrogen industry's development instead. Critics argue this approach is passive and insufficient, urging NS Power to commit to creating a tariff within one to two years for potential hydrogen producers.

Key Themes There were several common key themes noted in the submissions provided by both Board consultants and participants, which can be broadly categorized as follows: - Reflections on the Evergreen IRP Analysis - Specific Recommendatio...

AI summary The submissions from Board consultants and participants identified two key themes: reflections on the Evergreen IRP Analysis and specific recommendations for future analysis and action plan items.

Reflections on the Evergreen IRP Analysis General Comments on the Update Process, Reasonability of Analysis and Key Findings Comments from Board Counsel's consultants and many participants were generally positive with respect to the qualit...

AI summary Board Counsel consultants Synapse and Bates White generally support the Evergreen IRP Update's analysis and key findings, though Synapse notes limitations. Both emphasize the need for ongoing monitoring of factors like hydrogen industry development impacting electricity demand and low-carbon fuel supply.

The Atlantic Loop A prominent issue arising from participant feedback, and indeed a focus throughout the Evergreen IRP process, was the potential impact of the Atlantic Loop project. In particular, stakeholders submitted comments highlight...

AI summary Stakeholders raised concerns about the Atlantic Loop project's risks, urging NS Power to develop alternatives if it isn't feasible by 2030 to meet decarbonization targets. NS Power's planning assumes the project won't be available by 2030, relying on the CE1-E1-R2 scenario from the Evergreen IRP. The company will continue exploring regional integration opportunities post-2030 while aligning with stakeholder-recommended actions.

Hydrogen Analysis & Tariff Development The CA and the SBA referenced the need for the assessment of future hydrogen development (load, generation) in Nova Scotia (SBA) and the need for tariff development to support hydrogen production in t...

AI summary The document outlines the need for assessing future hydrogen development and creating tariffs to support hydrogen production in Nova Scotia. The Evergreen IRP evaluated hydrogen plant impacts and included a roadmap item on tariff development. However, specific hydrogen projects and tariff structures are managed separately by NS Power and stakeholders, with ties to the IRP through Roadmap Items 3, 8, and 11.

simultaneously. As part of the 2019 Planning Reserve Margin and Capacity Value Study (Capacity Study), which informed the 2020 IRP, Energy and Environmental Economics (E3) calculated the diversity benefit of having both battery and renewab...

AI summary The 2019 Capacity Study, informing the 2020 IRP, quantified diversity benefits of combining battery storage with wind/solar, crediting 4.8 MW in 2030 for wind + storage. Solar + storage benefits were excluded from PLEXOS modeling due to the 2019 study's focus on wind + storage, with minimal solar inclusion in early IRP stages.

Specific Recommendations: Future Analysis & Action Plan Items All Source RFP Process Bates White and Grid Strategies on behalf of the Consumer Advocate recommend all source RFP processes to acquire generation and infrastructure assets deem...

AI summary The Consumer Advocate recommends all-source RFP processes to meet decarbonization targets, while NS Power anticipates multiple procurements, some managed by the Province. NSUARB approval is required for capital investments, with stakeholder engagement. The Electrification Study will be published in 2023, and wind integration studies will address curtailment reduction and system reliability.

w a strategic plan established by an IRP is operationalized and commercialized is not part of the scope of that exercise as confirmed in the Terms of Reference (ToR) approved for the 2020 IRP process: The IRP is a comprehensive public util...

AI summary The Integrated Resource Plan (IRP) serves as a non-binding, directional roadmap for Nova Scotia Power's long-term electricity strategy, emphasizing flexibility to adapt to future uncertainties. Resource needs proposed for NSUARB approval are justified as 'no regrets' investments aligned with IRP outcomes. NRR acknowledges common near-term decisions across IRP scenarios.

M11307 - Evergreen IRP Updated Action Plan and Roadmap - 2023 On August 8, 2023, NS Power filed its 2023 Evergreen IRP - Updated Action Plan and Roadmap (Evergreen IRP Update). The panel assigned to this matter is Roland A. Deveau, K.C., V...

AI summary NS Power filed its 2023 Evergreen IRP Update on August 8, 2023, refining its 2020 IRP to align with Nova Scotia's 2030 environmental targets. The update reflects changes in environmental policy, load, and resource assumptions, supported by stakeholder engagement and modeling scenarios to advance a decarbonized electricity strategy.

ANALYSIS AND FINDINGS NS Power must meet important environmental targets by 2030, which include phase-out of coalfired generation and achieving 80% of its sales from renewable resources. The successful execution of the Evergreen IRP Update...

AI summary NS Power must achieve 2030 environmental targets, including phasing out coal and 80% renewable sales. The Evergreen IRP Update was supported by intervenors as transparent and thorough, though the Board emphasizes the need for ongoing adaptation due to evolving policies and technologies. Recent developments include Nova Scotia's 2030 Clean Power Plan and federal Clean Electricity Regulations.

August 31, 2023 [[email protected]](mailto:[email protected]) Mark Peachey, LL.B. Manager, Capital Filings Nova Scotia Power Inc. 1223 Lower Water Street P.O. Box 910 Halifax, NS B3J 2W5 Dear Mr. Peachey: M11307 – Nova Scotia P...

AI summary Nova Scotia Power Inc. submitted its 2023 Evergreen IRP Action Plan and Roadmap Update. The Board invites stakeholder comments with a submission timeline: Board Counsel Consultants by September 8, Participants by September 26, and NS Power's reply by October 10. Panel members include Roland Deveau, Richard Melanson, and Steven Murphy.

RE: M11307 – NRR Comments on Evergreen Update NRR has reviewed the results of NS Power's latest Evergreen Update to the 2020 IRP Action Plan and Roadmap filed August 8, 2023, as well as comments offered by Bates White and by Synapse on thi...

AI summary NRR has reviewed NS Power's Evergreen Update to the 2020 Integrated Resource Plan (IRP) Action Plan and Roadmap, along with comments from Bates White and Synapse. This response outlines NRR's evaluation of the update and associated feedback.

Commercial Sensitivity NSP has made the IRP process more opaque than necessary by shielding numbers used in assumptions on the grounds of commercial sensitivity. As this is not a UARB proceeding, stakeholders have no way to contest this la...

AI summary NSP is criticized for making the IRP process opaque by withholding numbers due to commercial sensitivity, limiting stakeholder scrutiny. NRR acknowledges UARB's confidentiality measures but highlights the absence of Quebec negotiation details as undermining process confidence.

Solar, Storage and Battery Capacity interplay Synapse addresses this issue more comprehensively in its comments on the Evergreen update, and NRR agrees with Synapse that correctly identifying the need for capacity is paramount for all subs...

AI summary Synapse and NRR emphasize the critical need for accurate capacity identification in IRP runs, citing unresolved issues in the initial analysis that failed to provide a clear ELCC for solar, storage, and battery technologies. This omission risks delaying UARB approval of new capacity due to lingering doubts about necessity.

Planning Reserve Margin Discussion of reserve capacity was largely absent this IRP iteration, though it was present in previous exercises. NSP has modeled a continued use of 20% planning reserve margin, but NRR does not accept this without...

AI summary The discussion on Planning Reserve Margin (PRM) in the Integrated Resource Plan (IRP) highlights NSP's proposal of a 20% PRM, which NRR rejects without intervenor consensus and Board scrutiny. Adjusting PRM to 16% could avoid constructing a combustion turbine, emphasizing the need for thorough discussion on reserve margin values.

James MacDuff Direct +1 (902) 444 8619 [email protected] 1969 Upper Water Street Suite 1300 McInnes Cooper Tower - Purdy's Wharf Halifax NS Canada B3J 2V1 Tel +1 (902) 425 6500 Fax +1 (902) 425 6350 Our File: 179164 September...

AI summary Port Hawkesbury Paper LP (PHP) supports Synapse and Bates White's comments on Nova Scotia Power Inc.'s 2023 Evergreen Integrated Resources Plan, emphasizing the need for a flexible approach to regional integration, mitigation of renewable energy integration costs, further study of hybrid peak mitigation scenarios, and addressing implications of Federal Clean Energy Regulations.

1. Integration of New Renewable Energy With respect to the first item in particular, PHP specifically notes Synapse's comment at page 4 of its report: "Action Item 3d is development of a procurement strategy for solar and wind resources, a...

AI summary PHP supports Synapse's emphasis on developing a renewable procurement strategy and addressing curtailment risks for wind and solar. The IRP may underestimate wind energy integration, requiring urgent studies to minimize costs and curtailment. NSPI's ongoing studies (Roadmap Item 1, 2023) should be prioritized and shared with IRP participants promptly.

2. Hybrid Peak Mitigation, Battery Storage, and New Fast-Acting Generation On the issue of ongoing study of the hybrid peak mitigation scenario, PHP notes NSPI's stated support at page 4 of its responses to stakeholder comments for a multi...

AI summary PHP supports a third-party-led multi-stakeholder process to analyze hybrid peak mitigation but raises concerns about Synapse's uncertainty regarding battery storage's capacity value and the need for updated IRP analysis before committing to CT additions by 2029–2030.

3. Federal Clean Energy Regulations NSPI's roadmap item 5 indicates in part tracking the development of the Federal Clean Energy Regulations and monitoring for limitations on the use of gas and oil-fired generation beyond those already con...

AI summary NSPI and PHP discuss the potential impact of Federal Clean Energy Regulations on Nova Scotia's natural gas peaking capacity, critical for reliable electricity supply. PHP supports NSPI's efforts to comment on draft regulations to ensure amendments align with provincial needs.

Conclusion Finally, PHP notes Bates White's comments on page 3 of its report that should all the resources that the IRP calls for to be in place by 2030 be pursued, "such an aggressive schedule and scope of resource additions will place a...

AI summary PHP emphasizes the need for transparency, collaboration, and cooperation among NSPI, market participants, and the Board to achieve Nova Scotia's 2030 renewable energy targets. It highlights the challenges of the IRP's aggressive resource procurement schedule and urges the Board to stress these requirements in its comments on the NSPI IRP Action Plan.

Fast Acting Generation and Coal to Gas Conversions NSPI Action Plan Item 3c includes the initial development of approximately 300MW of new fastacting generating capacity by 2027 and an additional 300-600MW by 2030, to address growing deman...

AI summary NSPI plans to develop 300-900MW of fast-acting generation by 2030, emphasizing fuel flexibility and hydrogen. Synapse questions the robustness of coal-to-gas conversions and battery storage, while Eastward supports natural gas and hydrogen as critical for reliability. The IRP Evergreen Update highlights the need for flexible resources to integrate renewables.

Energy efficiency (EE) and demand response (DR) may be undervalued in NSPI analysis As noted above, the updated IRP requires significant buildout of new resources and capital costs have been very volatile in recent years. EE and DR program...

AI summary The document argues that energy efficiency (EE) and demand response (DR) programs are undervalued in Nova Scotia Power's (NSPI) analysis of the Integrated Resource Plan (IRP). EE and DR offer stable costs and can delay new infrastructure, yet recent U.S. research highlights their potential in decarbonizing energy portfolios. NSPI is urged to integrate these resources more comprehensively in future planning.

RE: Energy Storage Canada Submission on 2023 Evergreen IRP Action Plan & Roadmap Update (M11307) Energy Storage Canada (ESC) is the national trade association dedicated to accelerating the deployment of energy storage projects and technolo...

AI summary Energy Storage Canada (ESC) submitted comments to Nova Scotia Power Inc. and the Nova Scotia Utility and Review Board regarding the 2023 Evergreen IRP Action Plan & Roadmap Update (M11307), emphasizing their participation in stakeholder sessions and advocating for energy storage deployment.

Appendix: ESC Submission on 2023 Evergreen IRP Action Plan & Roadmap Update (M11307) - 1. " In the Nova Scotia context with the expected increase in variable renewable energy resources, expansion of transmission ties, and phase out of coal...

AI summary ESC argues that energy storage will play a critical role in Nova Scotia's energy future due to increasing renewables and coal phase-out. They highlight storage's contributions to firm capacity, peak shaving, and reduced wind curtailment, noting the current IRP underestimates its potential due to modeling limitations.

Recommendations - 5. Energy storage can be the solution to so many of the challenges that Nova Scotia must navigate to realize the coal phase-out, and 80% renewable electricity, by 2030 targets. There are many energy storage projects and/o...

AI summary ESC recommends a more comprehensive review of energy storage in future IRPs, arguing current plans understate its potential. They propose an IRP Roadmap Item to explore both short- and long-duration technologies, emphasizing stakeholder input to address technical, policy, and market factors.

IN THE MATTER OF: NS Power 2023 Evergreen IRP Action Plan and Roadmap Update M11307

AI summary The document pertains to NS Power's 2023 update to its Evergreen Integrated Resource Plan (IRP) Action Plan and Roadmap, filed under matter number M11307. It outlines regulatory proceedings related to the company's strategic energy planning and resource allocation initiatives.

3.2 Base Plus DSM Modeling - The IRP scenarios modeled the inclusion of both Base and Modified Mid DSM buildouts but only - included one Base Plus DSM scenario, namely CE1-E1-R1 BPDSM. The absence of an evaluation of - Base Plus DSM within...

AI summary The IRP scenarios evaluated Base and Modified Mid DSM buildouts but omitted comprehensive Base Plus DSM analysis. This limits stakeholder understanding of DSM performance between Base and Modified Mid levels, potentially leading to suboptimal economic outcomes. E1 previously requested inclusion of Base Plus DSM in core scenarios, which was not fulfilled.

3.4 DSM Beyond Energy Efficiency The 2022 Evergreen IRP only considered energy efficiency and demand response as DSM resources. "Base DSM" only considered energy efficiency. To the extent other DSM (e.g., distributed energy resources) acti...

AI summary The 2022 Evergreen IRP limited DSM to energy efficiency and demand response. Other DSM activities (e.g., distributed energy resources) were excluded from modeled savings and expenditures. The text recommends treating these future DSM initiatives as distinct from the 2022 IRP's DSM outcomes.

James R. Gogan Direct +1 (902) 563 5920 [email protected] 292 Charlotte Street Suite 300 Sydney NS Canada B1P 1C7 Tel +1 (902) 563 1000 Fax +1 (902) 563 1113 Our File: 226626 September 26, 2023 Nova Scotia Utility and Review Bo...

AI summary EfficiencyOne, represented by James R. Gogan of McInnes Cooper, submits comments on Nova Scotia Power's 2023 Evergreen Integrated Resource Plan (IRP) Action Plan and Roadmap Update, filed August 8, 2023, as part of the regulatory proceeding M11307.

October 10, 2023 Ms. Crystal Henwood 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: M11307 Evergreen IRP Reply Submission Dear Ms. He...

AI summary Nova Scotia Power Incorporated (NS Power) requests an extension until October 17, 2023, to submit its reply to the NSUARB's Evergreen IRP proceeding, citing the need to address feedback from Board counsel consultants and participants. The proceeding includes submissions from Grid Strategies, EfficiencyOne, and other stakeholders.

October 10, 2023 [email protected] Mark Peachey, LL.B. Manager, Capital Filings Nova Scotia Power Inc. 1223 Lower Water Street P.O. Box 910 Halifax, NS B3J 2W5 Dear Mr. Peachey: M11307 – Nova Scotia Power Inc. – 2023 Evergreen IRP Ac...

AI summary Nova Scotia Power Inc. requested an extension to file its Reply Submission for the 2023 Evergreen IRP Action Plan and Roadmap. The Board approved the extension, setting the new deadline as October 17, 2023.

K 1 HO (Tel) 902-485-4311 (fax) 902-485-6475 (Email) [email protected] August 14, 2023 Peter Gregg, President and CEO Nova Scotia Power PO Box 910 Halifax, Nova Scotia B3J 2W5 Dear Mr. Gregg: I am writing on behalf of the Municipal C...

AI summary Brian Cullen, representing Pictou County's Municipal Council and Climate Advisory Committee, expresses concern over Nova Scotia Power's potential use of heavy fuels at decommissioned coal plants by 2030, arguing it contradicts climate goals. Peter Gregg responds that the Integrated Resource Plan (IRP) oversees the transition, suggesting consideration of alternatives.

n of our coal fired generating units to heavy fuel oil (HFO). Peter Gregg asked that I respond to you as I, along with my team, manage the Integrated Resource Plan (IRP) that oversees this transition. The potential fuel conversion to HFO i...

AI summary NS Power discusses transitioning coal-fired units to HFO and natural gas as part of its Integrated Resource Plan (IRP) to meet 2030 decarbonization targets. The IRP emphasizes the need for diverse energy solutions, including renewables, storage, and firm generation to ensure grid reliability and support 80% renewable integration.

mailto:[email protected]); [Christina Campbell;](mailto:[email protected]) [Collin Cain](mailto:[email protected]); [Collins, Keith](mailto:[email protected]) [Montgomery](mailto:taylor@washingtonm...

AI summary NS Power submitted an updated Appendix A to its Evergreen IRP Reply Submission to the NSUARB, correcting an omission of responses to Energy Storage Canada's comments. The submission was initially missing these responses, and the corrected version is now attached. The contact for this matter is Mark Peachey.

M11307 – Nova Scotia Power Inc. – 2023 Evergreen IRP Action Plan and Roadmap On December 8, 2023, NS Power filed copies of the Wind Integration Study and Electrification Strategy Report with the Board in accordance with the corresponding E...

AI summary NS Power submitted the Wind Integration Study and Electrification Strategy Report to the Board in December 2023, per the Evergreen IRP Action Plan. The Board acknowledges a February 2024 technical conference with stakeholders and requests NS Power to file presentations from that event.

M11307 - Evergreen IRP Updated Action Plan and Roadmap - 2023 On August 8, 2023, NS Power filed its 2023 Evergreen IRP - Updated Action Plan and Roadmap (Evergreen IRP Update). The panel assigned to this matter is Roland A. Deveau, K.C., V...

AI summary NS Power filed its 2023 Evergreen IRP Update to refine its long-term electricity strategy, aligning with Nova Scotia's 2030 environmental targets and updated policy contexts. The update follows the 2020 IRP process and includes stakeholder engagement, revised assumptions, and modeling scenarios reflecting changes in environmental policy, load, and resource factors.

ects that will be required to meet the 2030 targets. It is also important that NS Power continue to engage with federal and provincial government agencies to monitor and implement policy developments. Further, NS Power must not delay or de...

AI summary The Board mandates NS Power to continue the Evergreen IRP process without delay, ensuring alignment with 2030 targets and timely submission of the next IRP Update by January 31, 2025. NS Power is also directed to engage with federal/provincial agencies on policy developments.

Plan on December 9, 2024. As directed by the Board in its Decision letter, and subsequently in its Decision regarding the 2024 10-Year System Outlook report of January 16, 2025 (M11764), NS Power has 1 NSUARB Letter, Re: M11307 - Evergreen...

AI summary NS Power intends to submit an updated 2025 Integrated Resource Plan (IRP) Action Plan by April 30, 2025, following the NSUARB's directive in Decision M11764 regarding the 2024 10-Year System Outlook report. The update aims to provide stakeholder transparency on progress since The Path to 2030 report.

Effective Load Carrying Capability (ELCC) Study Scope Memo February 6, 2025 In its Decision letter of May 23, 2024, regarding NS Power's 2023 Evergreen IRP Update (Matter M11307), the Board highlighted certain Synapse recommendations and s...

AI summary The Nova Scotia Utility and Review Board directed NS Power to update its ELCC study to assess interactive effects of wind, solar, battery storage, and demand response. NS Power supports the update, plans to develop a scope of work by year-end, and proposes three study topics: resource interaction analysis, demand response ELCC recalibration, and seasonal ELCC assessment. The Board emphasized refining diversity benefits and aligning with current programs.