N-1-(i)Terms of Reference - Tracked Changes
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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 IESO Nova Scotia under the More Access to Energy Act (MAEA). Key steps include stakeholder engagement, a Request for Proposals (RFP) with Dunsky, and collaboration with E3 on an ELCC study. The IRP process involves public consultation and regulatory directives, with a draft Terms of Reference finalized in April 2026.
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.
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) for the Integrated Resource Plan (IRP), comprising 8 members from diverse sectors. The TWG aims to provide technical input, with membership including organizations like NS Power, Efficiency One, and Net-Zero Atlantic. Meeting minutes will be publicly shared, and stakeholders are encouraged to submit expressions of interest for the NGO seat.
EVALUATION CRITERIA The IRP will assess a range of scenarios and sensitivities in order to develop a plan that is robust across a range of potential outcomes. Importantly, there must be a means for evaluating the scenarios and selecting a...
AI summary The IRP will use a least-cost objective, but also incorporate a scorecard to evaluate other criteria. The IESO cites Section 2(e) of the MAEA to support broader planning goals beyond cost, including sustainability and emissions reduction. A scorecard with stakeholder input will assess resource plans holistically, with the highest score determining the preferred plan.
TIMELINE The IRP is expected to be complete in December 2026. The below IRP schedule outlines the expected completion dates for key activities, planned stakeholder sessions with interested parties, and targeted dates for the dissemination...
AI summary The Integrated Resource Plan (IRP) is expected to be finalized in December 2026, with key activities including stakeholder sessions and dissemination of background reports.
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). A deadline was set for written comments on the ToR, indicating ongoing regulatory process activities related to energy planning frameworks.
November 2026 - Nov 2 Deadline for written comments on modelling results and draft action plan - Drafting of final IRP report
AI summary In November 2026, the deadline for written comments on modelling results and a draft action plan is set, alongside the drafting of the final Integrated Resource Plan (IRP) report.
102117Responses to Stakeholder TOR Feedback - IESO
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7. Feedback on pre-IRP studies The ToR appropriately allows for feedback on the pre-IRP studies.[17](#page-58-0) However, the timeline does not afford sufficient time to make any alterations to those studies and the underlying modeling wor...
AI summary The Terms of Reference (ToR) permit feedback on pre-IRP studies, but the timeline does not allow for alterations to the studies or their modeling. Stakeholders suggest adding a bullet point to the 'Assumption and Scenario Development' section to include sensitivities regarding pre-IRP study values, enabling stakeholder-recommended modeling scenarios.
8. Strengthening commitment to engage with stakeholders The ToR indicates that the IESO "intends to engage with stakeholders as it progresses through the different phases of the IRP."[19](#page-58-2) We recommend replacing the words "inten...
AI summary The document recommends replacing 'intends to' with 'will' in the Terms of Reference to emphasize the IESO's commitment to stakeholder engagement during the Integrated Resource Plan process. It also suggests enabling stakeholders to submit written information requests to the IESO.
1. Schedule Overall, it is reasonable for IESO Nova Scotia to focus the 2026 Integrated Resource Plan (IRP) on an updated resource planning model exercise. Developing confidence in the current resource development outlook is essential, par...
AI summary The text recommends delaying the 2027 Integrated Resource Plan (IRP) to allow thorough evaluation of technologies like synchronous condensers and dynamic line ratings, which could impact reliability. The 2026 IRP should focus on updated resource planning, with the 2027 IRP starting in September 2026 and taking 14-18 months to complete.
3. Pre-IRP Studies The IESO NS should consider holding workshops with the technical work group in advance of finalizing pre-IRP studies. It may be too late for this to occur in some or all cases, but this should be established as a practic...
AI summary The IESO NS is advised to hold workshops with the Technical Working Group prior to finalizing pre-IRP studies to ensure stakeholder engagement in the process.
4. Hybrid Peak Net Zero Atlantic has published "Mitigating the Impact of Building Electrification on Peak Demand in Atlantic Canada" in August 2025, and NS Power states that a Hybrid Heating study is underway, in which Net Zero Atlantic wi...
AI summary NS Power is conducting a Hybrid Heating study, citing a 2025 Net Zero Atlantic report and a 2026 load forecast showing 48 MW peak mitigation. However, the math suggests limited non-electric heat reduction, conflicting with provincial electrification policies. The TWG is advised to evaluate this in the IRP.
5. Decisional vs Deliberative The Dunsky analysis includes a well-characterized discussion of the benefits and drawbacks of decisional and directional IRPs. In particular, I agree with the concerns about inefficiencies and re-work of issue...
AI summary The text discusses the Dunsky analysis on decisional vs. directional Integrated Resource Plans (IRPs), recommending a hybrid approach. It emphasizes aligning IRPs with Requests for Proposal (RFPs) and suggests the Nova Scotia Energy Board (NSEB) review submissions to approve IRPs. Complex resource decisions may require separate capital applications for detailed analysis.
Objectives We appreciate that the listed objectives of the IRP recognize sustainability as a core system need, along with reliability and cost effectiveness. We also appreciate that the listed objectives recognize the need to support the s...
AI summary The text emphasizes aligning the IRP's objectives with sustainability, reliability, and cost-effectiveness, referencing the Environmental Goals and Climate Change Reduction Act and the More Access to Energy Act. It discusses the need to define 'sustainable' in the TOR, citing statutory definitions from the More Access to Energy Act and suggesting broader clarification if needed.
Conclusion Thank you for the opportunity to provide comment on the draft TOR. We look forward to future opportunities to engage in the 2026 IRP process. April 24, 2026 Mark Peachey Director, Regulatory Affairs IESO Nova Scotia mark.peachey...
AI summary The letter from Mark Peachey, Director of Regulatory Affairs at IESO Nova Scotia, thanks the recipient for the opportunity to comment on the draft Terms of Reference (ToR) and expresses anticipation for future involvement in the 2026 Integrated Resource Plan (IRP) process.
Stakeholder Input Timing Eastward notes that the time periods in the proposed IRP schedule for stakeholders to provide written comments following the engagement sessions for each of the draft assumptions and scenarios, preliminary modellin...
AI summary Eastward argues the proposed one-week comment period following IRP engagement sessions is insufficient, as stakeholders may need more time to process information and provide feedback. They recommend extending the period to 10 days after each of the three engagement sessions.
Evaluation Scorecard Eastward notes that for the first time in Nova Scotia IESO Nova Scotia is proposing to evaluate factors other than least cost as a part of the IRP, and as such has "provided an initial scorecard for stakeholders to con...
AI summary Eastward Energy critiques Nova Scotia IESO's proposed IRP evaluation scorecard, arguing that allocating 30% of the assessment to non-least-cost factors (GHG, technology risk, economic growth) risks affordability concerns. They recommend reducing this to 15% initially and request clarification on how economic growth metrics, such as job creation, will be quantified.
Questions and Comments - 1. Please confirm whether NS Power or the IESO will be providing updated avoided transmission - & distribution (T&D) costs and whether this will be developed as part of the IRP process? - 2. The IRP study period is...
AI summary Questions focus on the 2026 IRP process, including T&D cost updates, NPV evaluation criteria, DSM modeling expansion, and alignment with 2030 decarbonization targets. E1 recommends treating DSM as a first-order resource and incorporating intermediate DSM levels in the IRP.
Overall support I support IESO Nova Scotia's effort to establish an independent, transparent IRP process, and I appreciate the opportunity to comment on the Terms of Reference. For context, my background is in utility-managed EV charging p...
AI summary The commenter supports IESO Nova Scotia's independent, transparent IRP process and emphasizes the need to incorporate real-world demand-side resource behavior into the planning framework, based on their expertise in utility-managed EV charging programs and load flexibility coordination.
Sensitivity on winter stress events and DR availability DR performance is highly sensitive to the same conditions that create system stress, so the IRP should test this explicitly. Based on Dunsky's April 17 clarification, key stress varia...
AI summary The document emphasizes the need to explicitly model Demand Response (DR) availability during winter stress events in Nova Scotia's Integrated Resource Plan (IRP). It argues that DR performance degrades under cold conditions, increasing reliability risks, and cites the 2022 Winter Storm Elliott analysis as evidence. A sensitivity analysis for sustained cold events (e.g., -15°C) is recommended to align with resource adequacy assessments.
Dear Registrar, Marine Renewables Canada (MRC) is the national association for tidal, offshore wind, wave, and river current energy, representing a membership of over 215+ technology and project developers, suppliers, utilities, Indigenous...
AI summary Marine Renewables Canada (MRC) criticizes the 2026 Integrated Resource Plan (IRP) Terms of Reference for underestimating future electricity demand from industrial growth and electrification, arguing this risks inadequate long-term procurement signals for clean energy development.
Risk of Undershooting Demand The IRP should explicitly recognize the asymmetric risks of underestimating demand in a context of rapid electrification. Constraining electricity supply poses a significant risk to Nova Scotia's economic growt...
AI summary The IRP must address the risks of underestimating demand due to rapid electrification, as constrained supply could hinder economic growth and lead to costly fossil fuel reliance. Proactive planning and export opportunities are recommended to ensure long-term, optimal solutions and system flexibility.
Conclusion As Nova Scotia advances its energy transition, it is essential that the IRP Terms of Reference provide a framework that reflects system-wide value, anticipates growing demand, and aligns with climate and economic objectives. A m...
AI summary The document emphasizes the need for the IRP Terms of Reference to reflect system-wide value, align with climate and economic goals, and enable investment in renewable energy, including marine renewables. MRC acknowledges the opportunity to engage in the IRP process.
IESO Nova Scotia [[email protected]](mailto:[email protected]) April 24th 2026 RE: 2026 Integrated Resource Plan (IRP), Draft Terms of Reference (ToR) – Feedback from NRStor Incorporated (non-confidential) NRStor submits the following comments f...
AI summary NRStor Incorporated provides feedback on the IESO-NS's draft Terms of Reference for the 2026 IRP, emphasizing the importance of incorporating technical insights from its operational energy storage projects (e.g., Oneida Battery) into the ELCC study to refine storage assumptions for the IRP.
• Assessment Period o IESO-NS is proposing a study period of 2029 – 2053. NRStor proposes that the start of the assessment period be 2028, to reflect some of the 2030 Clean Power Plan early actions and priorities including the timeline of...
AI summary IESO-NS proposes a 2029–2053 assessment period, while NRStor advocates starting in 2028 to align with the 2030 Clean Power Plan, including the Trenton generating plant closure. NRStor emphasizes energy storage's role in wind modeling and seeks analysis on offshore wind's domestic economic opportunities.
Emissions As noted above, this first IRP presents an important opportunity for the IESO to demonstrate a clear and credible commitment to climate change mitigation and emissions reduction. While it is encouraging to see GHG Reduction inclu...
AI summary The text criticizes the proposed 10% weighting for GHG reduction in the IRP, arguing it is insufficient and risks being meaningless. It recommends increasing the weighting to 50% and clarifying prorating methodology. Full marks should be awarded to zero-emission sources, while non-compliant sources receive zero marks to align with 2050 climate goals.
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.
appreciate further clarity on how energy resources at the distribution-level will be considered in the 2026 IRP, and how that will interact with other processes (e.g., DERIR, NSPI Load Forecast etc). 4. The Clean Power Plan states that "…[...
AI summary The text requests clarity on integrating distribution-level resources into the 2026 IRP and their interaction with processes like DERIR. It advocates for the IRP Score Card to differentiate costs of imported fuels versus clean local electricity, aligning with the Clean Power Plan's goal of electrification to reduce bills and replace imported fuels.
- 1. Allow for more intensive stakeholder involvement in the selection of scenarios to be considered. This may include holding a few specific scenario slots to be defined fully by stakeholders. It would be useful to use the May 28th sessio...
AI summary Synapse recommends expanding stakeholder involvement in scenario selection for the 2026 IRP, using PLEXOS for extensive scenario modeling (15-20 scenarios), applying an iterative approach during July-August, and enabling written discovery to supplement NS IESO materials. These measures aim to enhance scenario analysis depth and adaptability.