Topic:"Performance Monitoring" in M12696

15 Q10. PLEASE PROVIDE A SUMMARY OF YOUR TESTIMONY. 16 A10. Section III of my testimony describes the holdback mechanism and my understanding on 17 why it was put in place by the Nova Scotia Utility and Review Board ("Board"). Section 18 I...

AI summary The testimony explains the holdback mechanism, the necessity of planned and unplanned outages for system reliability, and the need for NSPML to receive outage relief in performance metrics calculations. It emphasizes that outages are normal in utility operations and highlights the complexity of maintaining generation and transmission assets for Muskrat Falls energy delivery.

1 Q40. SHOULD THE HOLDBACK MECHANISM INCLUDE PROVISIONS THAT 2 SUPPORT ADHERENCE TO GOOD UTILITY PRACTICE? 3 A40. Yes. Regardless of the provisions of the holdback mechanism, NSPML and NS Power will 4 continue to operate their assets in ac...

AI summary The answer affirms that the holdback mechanism should include provisions supporting good utility practice. NSPML and NS Power argue that planned maintenance and proactive practices are essential to regulatory oversight and should be recognized in evaluating the Maritime Link's performance for termination of the holdback mechanism.

(Northwest), 345 (Southwest), 197 (Midwest), 363 (Northeast), 230 (Southeast), 317 (Peaking), 618 (Run-of-River), 158 (Federal), 384 (Nonfederal Public), 848 (Private), 793 (ISO/RTO), and 614 (Other). Out of all considerations, region made...

AI summary The text analyzes regional capacity factors for hydropower plants from 2006–2018, noting the Northwest region had the highest average (46%) and lowest variability, while the Southeast had the lowest except during 2013–2015 when Southwest droughts caused a sharp decline. Trends show Northeast capacity factors declining, Midwest increasing, and Northwest consistently above 40%.

8.0 Review of Hydro's Operational Experiences and Benchmarking This section presents a review of past line failures that NLH experienced during the operation of transmission line assets during the past 50 years. The objective here is to un...

AI summary This section reviews NLH's transmission line failures over 50 years, analyzing outage hours per 100km and comparing data with national averages (CEA) and CSA 60826-10 standards. It evaluates reliability on the Avalon Peninsula and against a Canadian utility's upgraded line under extreme ice loads.

PARTIALLY CONFIDENTIAL - Capacity of the NS Block has been at a level that allows NS Power (and now the IESO-NS) to treat the NS Block in the same manner as its other generation assets for short-, mid- and long-term planning. Yes, there ha...

AI summary NSPML argues that the NS Block's capacity is integrated with Nova Scotia's generation assets, resulting in minimal outage impacts and benefits exceeding costs. It notes that planned outages by NLH during non-winter periods have not caused system outages and that the holdback is tied to the Lower Churchill Project's performance.

NON-CONFIDENTIAL 1 Request IR-20: 2 3 Reference: N-01, Application, Attachment 1, Concentric Evidence, page 3 (pdf page 42), lines 4 9-14. 5 I provide my opinion that the period of May 2023 to April 2024 is the appropriate period 6 over wh...

AI summary The text discusses a regulatory request (IR-20) arguing that the period May 2023–April 2024 is appropriate for assessing Labrador-Island Link (LIL) performance, rejecting relief for outages and extreme weather. Concentric's response emphasizes regulatory frameworks that adjust metrics for extraordinary events, citing SAIDI/SAIFI reliability indices with 'Major Event Day' exclusions.

om the Large Generating Facility outside Transmission Provider's Transmission System, such request may require additional studies and upgrades in order for Transmission Provider to grant such request. - 4.2 Provision of Service. Transmissi...

AI summary The document outlines requirements for interconnecting a Large Generating Facility with the Transmission Provider's system, including potential studies and upgrades. It specifies performance standards aligned with regulations, clarifies that interconnection does not equate to transmission delivery service, and mandates FERC approval for amendments to the Large Generator Interconnection Agreement (LGIA).

A few reports on reliability and availability data can be found in the literature. However, cable operators today are less prone to publish such data. This is a disadvantage to the industry, as investors and insurance companies might need...

AI summary The text discusses the limited availability of reliability and availability data from cable operators, highlighting the disadvantage this poses to investors and insurance companies who require such information for accurate risk assessment. A few examples are mentioned.

NON-CONFIDENTIAL 1 Request IR-26: 2 3 Reference: N-01, Application, Attachment 1, Concentric Evidence, page 33/36 (pdf page 4 70) 5 Preamble: Concentric recommends that outage months should be "excluded from the 6 calculation of the 12-mon...

AI summary The document requests specific mathematical adjustments and worked calculations to exclude outage months from the 12-month reliability thresholds, focusing on months such as July 2023 and March 2024. It references the NSPML Application to Review the Holdback Mechanism (NSEB M12696).

RELIABILITY & AVAILABILITY ASSESSMENT OF THE HVDC ISLAND LINK Revision Nalcor Doc. No.: ILK-SN-CD-8000-EL-SY-0004-01 B1 Date Page SLI Doc.: No. 505573-480A-47ER-0017 00 10-Apr-2012 18 4 CONCLUSIONS & RECOMMENDATIONS

AI summary The document presents conclusions and recommendations from a reliability and availability assessment of the HVDC Island Link. It discusses the technical evaluation of the system's performance and reliability.

- NS Block, measured in MWh (excluding Make-up Energy), is received during each of 12 - consecutive months."[41](#page-18-1) In introducing this requirement, the Board also stated: - NSPML/NS Power may apply to the Board for relief if it c...

AI summary The requirement mandates NSPML to receive twelve consecutive months of NS Block volumes (excluding Make-up Energy) at least 90% of the total monthly volumes called for under the Energy and Capacity Agreement. This prevents over-reliance on Make-up volumes and ensures consistency and predictability in volume delivery.

III. Holdback Release - Q: Has NSPML met the Board's two conditions for meeting the monthly Holdback conditions? - A: No, not directly. In the 2023 Holdback proceeding, the Board set two quantified conditions for ending the Holdback. - The...

AI summary NSPML did not meet the Board's two conditions for ending the Holdback, including 90% energy delivery over 12 months and a 10% net outstanding balance. The Board allows relief for exceptional circumstances like maintenance or hydrological issues.

Request IR-2: - Reference: N-7, Evidence of Bates White, p. 28, lines 1-12 regarding conflicting information in - NSPML's evidence regarding good utility practice. - (a) In this section, please confirm: - (i) while NSPML asserted that LIL...

AI summary Request IR-2 challenges NSPML's assertion that LIL and ML outages were coordinated as evidence of good utility practice. It questions the timing of ML maintenance relative to LIL outages, whether maintenance was completed before LIL outages, and whether this demonstrates optimal scheduling and operational efficiency.

18 Q41. DOES BATES WHITE IDENTIFY A SPECIFIC ACTION THAT VIOLATED 19 GOOD UTILITY PRACTICE? 20 A41. No. Although Bates White raises questions regarding several planned and forced outages 21 that occurred during the Compliance Period, Bates...

AI summary Bates White does not identify a specific action that violated good utility practice, despite raising questions about outages. The response emphasizes that good utility practice does not require perfection and that utilities are expected to manage outages through proper planning and maintenance.

1 Q43. HOW SHOULD THE BOARD EVALUATE THE GOOD UTILITY PRACTICE 2 QUESTION? - 3 A43. In my opinion, the Board should focus on whether the evidence demonstrates that NSPML, 4 failed to act in a manner consistent with accepted utility practic...

AI summary The Board should evaluate whether NSPML failed to act in accordance with accepted utility practice by examining factors such as maintenance, reliability risks, and operational decisions. The record shows that NSPML engaged in planned maintenance, coordinated outages, and prudent operations, supporting a finding of good utility practice.

28 was considered; 1 (iii) The nature of the work scope performed during the outage 21 NERC/IEEE references cited) and the portions relied upon. 22 (b) Explain how these benchmarks are relevant to the Board's monthly performance threshold...

AI summary The text discusses a request for information regarding the methodology and calculations used by Concentric to adjust performance thresholds for NS Block deliveries during specific outage months. The request includes detailed steps for providing mathematical adjustments and worked calculations for several months.

- h) Please provide the actual annual availability (%) of the Muskrat Falls Generating Station for 2021, 2022, 2023, 2024, and 2025. - i) Please provide the forced outage rate (%) of the Muskrat Falls Generating Station for 2021, 2022, 202...

AI summary The text requests detailed operational data on the Muskrat Falls Generating Station (availability, forced outage rates, capacity, output) and clarifications on NSPML's stance regarding the Labrador Island Link (LIL) and Good Utility Practice. It also references Exhibit N-1 and matter M05419 for compliance and modeling assumptions.

ttachment 1, A36. Did the Witness conduct an independent review of the reasonableness of the LIL outages shown in Table 1? If so, please provide all documents, workpapers, and analyses the Witness relied upon in conducting such a review. 2...

AI summary The text contains a series of questions directed at a witness regarding the Labrador Island Link (LIL) outages, software issues, and the reasonableness of the Holdback Mechanism. It also asks for comparisons between planned outages and assumptions made during the Maritime Link proceeding (M05419), as well as an explanation of the Energy and Capacity Agreement's firm energy delivery targets.

25 this was considered. 1 Request IR-3: 2 Reference: N-8, Evidence of John D. Wilson (CA), p. 6, lines 17-22. 3 4 Q: Does the frequency of continued under-deliveries of the NS Block since April 2024 concern you? 5 6 7 8 A: Yes, the NS Bloc...

AI summary The text discusses concerns raised about the frequency of under-deliveries of the NS Block since April 2024 and the recommendation to end the Holdback effective April 2024. It also includes questions about potential actions in response to icing events and whether the return of holdback amounts should be conditional on completing those actions.

In my opinion, these four events meet the Board's standard for relief as they represent good utility practice (events 1-3) or exceptional circumstances (event 4).[7](#page-7-0) Again, NSPML encourages the Board to give strong weight to the...

AI summary The Company argues that four events meet the Board's standard for relief, representing good utility practice or exceptional circumstances. It also submits that customers were not harmed during the Compliance Period and that Make-up Energy deliveries exceeded contracted amounts, fulfilling the 'Consistent Deliveries' threshold.