Topic:"Planned Outage" in M12696

13 1 Specifically: 2 3 • Deliveries of Base NS Block and Make-up Energy exceeded 90 percent of Contract 4 Amounts every month and were over 100 percent in every month but September 5 in advance of the winter period10 2023 which fell short...

AI summary The document outlines the performance of NS Block and the LIL in terms of energy delivery and reliability. NS Block delivered more than 140% of the contracted amount, with strong delivery levels allowing NS Power to incorporate it into system planning. The LIL has demonstrated high reliability with an eqFOR below 3% since commissioning in April 2023.

NS Block Deferred Energy had been redelivered.[19](#page-13-0) 1 The following chart illustrates Deferred Energy from April 2023 through December 2025[20](#page-13-1) : b) Meeting the 12-Month Performance Threshold: Subject to Board relief...

AI summary The document discusses the delivery performance of energy, highlighting that the 12-month threshold was met despite planned outages and an extreme weather event. Supplemental Make-up Energy was completed in November 2024, and figures are provided in appendices. March 2024 fell below the monthly delivery threshold due to a combination of planned and unplanned outages.

approximately 19% of NS Power load requirements with total delivery levels 1 The month of April 2024 fell short due to extreme weather conditions (specifically 2 icing), causing damage to electrode wings on NLH transmission facilities that...

AI summary In April 2024, extreme weather caused damage to NLH transmission facilities, impacting NS Power load requirements. Despite this, NS Block deliveries exceeded the Contract Amount in most months, with the exception of September 2023, which was made up in October. Outages are a normal part of operations and are planned to occur during times of lower load and replacement energy costs.

Outage Days Affected Summary of LIL Outages July 2023 5 days Good Utility Practice: Preparation for software update, correction of identified deficiencies, and to test SCADA indication points. September 2023 10 days Good Utility Practice:...

AI summary The document outlines several outages related to the Maritime Link (LIL) system, including planned maintenance, software updates, and repairs due to icing and extreme weather events. It also references a regulatory order (M11009) regarding the disposition of holdback funds.

Further detail on these requested relief periods is outlined below and in Concentric's evidence at pages 21 to 23. • July 2023: The July planned outage was referenced in NSPML's Rebuttal Evidence (M11009) filed on June 15, 2023, regarding...

AI summary The document discusses a planned outage in July 2023 for the Labrador Island Link (LIL) Bipole, requested by NLH and coordinated with system operators. The outage is intended to perform software updates and improve reliability, and is supported by NSPML despite potential holdback ramifications. The timing was chosen to minimize customer impact during lower peak demand periods.

& lt;sup>25 Absent the extreme weather event that impacted March 30 and 31, March would have exceeded the 90 percent threshold set by the Board. 1 The July outage was planned, consistent with Good Utility Practice, and not related 2 to ass...

AI summary The planned July outage was consistent with Good Utility Practice and aimed to prepare for LIL software updates, which were necessary to enhance asset reliability and correct deficiencies. These updates were coordinated with system operators and were part of standard post-commissioning procedures.

Absent the 5-day July planned outage, Base NS Block delivery levels (excluding Make-up Energy) exceeded 97%, with most of the remaining 3% shortfall resulting from the wildfires in Quebec and Labrador that impacted regional operations. • S...

AI summary The document discusses the impact of a planned outage in September 2023 on Base NS Block delivery levels, noting that most of the shortfall was due to wildfires in Quebec and Labrador. The outage was part of regular maintenance and included various activities like valve inspections and preventative maintenance.

The Maritime Link monopole outage work in September was for regularly scheduled planned maintenance of Pole 1 and Pole 2 assets and timed to occur in conjunction 1 with NLH's LIL planned outage. The Maritime Link maintenance included 2 Ins...

AI summary The Maritime Link monopole outages in September and March 2024 were planned maintenance and corrective actions, respectively. These outages impacted the Make-up Energy and NS Block delivery. In April 2024, both poles of the LIL tripped offline due to significant ice accumulation, causing extraordinary damage.

1 Separately, on April 30, 2024, a planned bipole outage was taken to correct a 2 software deficiency relating to cable switching. 3 4 Absent the impact of the icing event and an unrelated planned outage on April 30th , 5 NS Block delivery...

AI summary On April 30, 2024, a planned bipole outage was conducted to address a software deficiency related to cable switching. NSPML requests relief from the 90% NS Block delivery condition for the affected months, citing the planned outage and an extreme ice event that impacted the LIL. Deliveries during the affected months were approximately 98% (excluding Make-up Energy) and reached 97% to 99% in the remaining days.

5.0 FUTURE ASSET MANAGEMENT EXPECTATIONS As previously stated, NSPML submits that the evidence of energy deliveries support cessation of the Holdback as of May 1, 2024. NSPML also submits that the Compliance Period is (and has been) reflec...

AI summary NSPML argues that the Holdback should be ceased as of May 1, 2024, citing evidence of energy deliveries. The Compliance Period is reflective of future performance, and NLH undertook planned outages outside of peak demand periods to ensure reliability and cost efficiency, including software updates and maintenance activities.

Date Filed: February 3 , 2026 Page 23 of 37 1 All reports from NLH (and confirmed by NSPML) are that these outages were successful. 2 Deliveries during the months of November and December 2024—the first two months of 3 the critical winter...

AI summary The document discusses planned outages on the LIL and Maritime Link, emphasizing their successful execution and the delivery of Deferred Energy during lower load periods. NSPML highlights operational efficiency and reliability, but notes that it cannot guarantee the timing or value of Deferred Energy delivery due to external energy pricing factors.

Taking all of this into account, NSPML submits that Nova Scotia customers should not be concerned by the planned outages in the non-winter months following the Compliance Period. To the contrary, and consistent with the pattern of deliveri...

AI summary NSPML argues that planned outages during non-winter months are not a concern for Nova Scotia customers, as energy delivery remains reliable and consistent with the ECA. Planned outages are conducted in accordance with Good Utility Practice, during lower demand periods, and energy is redelivered promptly. NSPML, NS Power, and NLH agree on scheduling non-critical outages during non-peak periods to benefit customers during winter.

ber and December is a pattern we support now and for the remainder of the ECA — performing work in the lower demand periods to enhance the performance of the assets in the more critical winter period. In terms of unplanned outages since th...

AI summary The text discusses planned maintenance during lower demand periods to improve asset performance during winter, and an unplanned outage related to bipole icing on NLH's transmission assets near Muskrat Falls in January 2025, which was remediated over several days.

1 asset trip. Redeliveries of shortfalls relating to this outage were completed in early 2 February. 3 4 Finally, in terms of the Maritime Link, since commencement of construction NSPML has 5 been managing its assets in accordance with Goo...

AI summary The text discusses the completion of redeliveries for an asset trip outage in early February and highlights the exceptional operational performance of the Maritime Link. It also mentions the status of holdback funds as of the end of 2025, with most related to planned outages and a small portion linked to an unplanned icing outage in January 2025.

After giving the matter careful consideration, if the Board determines that a Holdback should remain in place, NSPML proposes a separate process be created to assess what changes should be made to the existing holdback mitigation mechanism...

AI summary NSPML proposes a separate process to assess changes to the existing holdback mitigation mechanism if the Board determines a Holdback should remain. NSPML also requests the Energy Board consider factors such as planned outages and their impact on holdback disallowance when designing a continuing mechanism.

23 Q36. PLEASE DESCRIBE THE OUTAGES ON THE LIL SINCE THE COMPLIANCE 24 PERIOD ENDED. 25 A36. Since the Compliance Period ended, NLH has undertaken planned outages that were 26 appropriately scheduled outside of the higher demand winter per...

AI summary Since the Compliance Period ended, NLH has conducted planned outages outside of the higher demand winter period. The company's application provides a full description of the outages on the LIL.

3 TABLE 1: LIL OUTAGE HISTORY DATE LIL EVENT REASON FOR EVENT May 2024 Bipole outage troubleshoot, replace, and test DC current transformers July 2024 Single pole outages troubleshoot intermittent system alarms, replace faulty equipment En...

AI summary The table lists outages of the Maritime Link (LIL) system between May 2024 and September 2025, detailing the dates, events, and reasons for each outage, including troubleshooting, software updates, maintenance, and icing-related issues. The question asks whether the outages after the compliance period were considered a success.

7 A37. Yes. NLH reported that the outages were successful. Furthermore, any deferred energy that 8 accumulated during these outages has been entirely redelivered and customers have 9 received 100% of the annual NS Block Contract Amount, pl...

AI summary NLH confirmed that planned outages were successful, with all deferred energy redelivered to customers. Customers received 100% of the annual NS Block Contract Amount plus make-up energy. Planned outages occur during lower seasonal loads, and make-up energy is delivered shortly after accumulation as per commercial agreements.

15 Q41. HAS NSPML PREVIOUSLY REQUESTED RECOGNITION OF THE 16 REASONABLENESS OF THESE RECENT OUTAGES? 17 A41. Yes. In a Compliance Filing in Matter M11009, NSPML requested that the Board issue an 18 order confirming planned outage relief fo...

AI summary NSPML previously requested the Board to recognize the reasonableness of recent outages through a Compliance Filing in Matter M11009, seeking relief for outages in March, July, and September 2023. The Board's decision on the March outage has led NSPML to no longer seek relief for that specific event.

1 2 VI. NSPML SHOULD BE GRANTED ITS REQUEST FOR OUTAGE RELIEF IN DETERMINING WHETHER THE HOLDBACK CAN NOW BE TERMINATED 3 Q42. DO YOU BELIEVE THE JULY 2023 AND SEPTEMBER 2023 PLANNED 4 OUTAGES SHOULD BE EXCLUDED FROM THE CALCULATION OF THE...

AI summary The text discusses whether planned and unplanned outages should be excluded from reliability thresholds and whether NSPML can meet the 12-month requirement for terminating the holdback mechanism without adjusting performance thresholds. The response supports excluding the 2023 outages due to scheduled maintenance and the 2024 LIL outage due to extreme weather, and argues that NSPML likely cannot meet the 12-month requirement without adjustments.

NSPML Responses to Bates White Information Requests 1 c-d) 2 The Maritime Link's transfer capability and actual flow delivered at the Woodbine (NS) 3 converter station is provided in Attachment 1 for each hour of the compliance period. 4 5...

AI summary NSPML provides data on the Maritime Link's transfer capability and actual energy flow at the Woodbine converter station, including projected availability performance and underlying assumptions about energy availability and outages.

Throughout the World During 2007 – 2008" – Tables II A and II B The available outage data suggests that forced outages to the bipole attributed to converter station problems will occur between once every 2 years to once in 8 years. The dur...

AI summary The text discusses forced outages at the bipole converter station, noting that such outages occur between once every 2 to 8 years, with durations under three hours. These outages are not expected to significantly impact system reliability. The newest reporting system has not experienced such outages, suggesting possible technological improvements.

- 1: Hardwoods 50 MW CT retired in 2022 - 2: 1 x 50 MW CT added - 3: Stephenville 50 MW CT retired in 2024 - 4: 2 x 50 MW CT added - 5: 3 x 50 MW CT added - 6: 4 x 50 MW CT added - 7: 5 x 50 MW CT added - 8: Portland Creek at 23 MW and new...

AI summary The document outlines the retirement and addition of combustion turbines (CT) and combined cycle combustion turbines (CCCT) in the energy sector, along with historical data on transmission line outages on the Avalon Peninsula due to icing events. A two-week repair window is used for outage analysis, with refined calculations based on observed icing events.

Table 4-4: Reduced Power Capability Modes Element Failure Rate(f/yr) Repair Time(hrs) Downtime(hrs/yr) Scheduled Maintenance 2.0 72 144 Converter-Muskrat Falls 1.64 13.8 22.42 Pole 1 2.04 6.3 12.87 Pole 2 2.04 6.3 12.87 Converter-Soldiers...

AI summary Table 4-4 outlines reduced power capability modes, detailing failure rates, repair times, and downtime for various elements. It notes that forced outage rates (FOR) could increase if the station ground cannot be used for mono-polar operation when the Muskrat Falls electrode line is also unavailable.

NSPML Application to Review the Holdback Mechanism (NSEB M12696) NSPML Responses to Bates White Information Requests NON-CONFIDENTIAL Request IR-05 3 a) Please confirm that NSPML's requested relief associated with Good Utility Practice 4 i...

AI summary NSPML is requesting a review of the Holdback Mechanism and has responded to information requests regarding the LIL's performance, including its inability to operate at full capacity due to software issues and the classification of planned and extreme weather-related outages as good utility practice.

NSPML Responses to Bates White Information Requests 1 ii. Explanation of the "software update" and why the update was needed. 2 iii. If the LIL had been able to operate at 900 MW as designed, would the software 3 update have been needed? 4...

AI summary The document outlines a series of information requests related to a software update, deficiencies, testing, and outage costs associated with the Labrador-Island Link (LIL). It includes inquiries about routine maintenance, additional maintenance activities, and the impact of the outage on Nova Scotia ratepayers.

NON-CONFIDENTIAL 1 Request IR-08: 2 3 Please refer to Exhibit N-1, Attachment 1, page 61 , lines 4-5 4 ("…nor should [NSPML] be held accountable for planned outages on another transmission 5 line over which it has no operational control.")...

AI summary The response to Request IR-08 explains that NSPML should not be held accountable for planned outages on transmission lines it does not control, as it lacks operational authority over those facilities. NSPML's responsibility is limited to its own facilities and prudent contract management.

Chart 5: GT DAUFOP: Happy Valley Unit - 1 The Holyrood CT DAUFOP of 25.13% for the current period is above the near-term and resource - 2 planning analysis value of 4.90%, and indicates a decline in performance when compared to the previou...

AI summary The Holyrood CT DAUFOP (Derated Adjusted Utilization Forced Outage Probability) is reported at 25.13% for the current period, which is significantly higher than the near-term and resource planning analysis value of 4.90%. This indicates a decline in performance compared to the previous period and is discussed in Section 7.2.

3.0 Investigation Overview Issues with components of the LIL during ice events over the past five years have primarily caused damage to the electrode crossarms, OPGW tower peaks, and the electrode conductor. Investigations determined that...

AI summary The document discusses issues with the Labrador-Island Link (LIL) caused by ice events over the past five years, leading to damage on electrode crossarms and OPGW tower peaks. The root causes included overloading from ice accumulation and unbalanced ice loads, with some failures attributed to galloping. A capital project is planned for 2026 to address these issues.

NSPML Responses to Consumer Advocate Information Requests 1 month that resulted in excessive icing). Additional details to support the request for relief 2 due to good utility practice and exceptional circumstances can be referenced in the...

AI summary NSPML responded to consumer advocate information requests regarding outages in July 2023, September 2023, March 2024, and April 2024, stating that the work was rooted in good utility practice and necessary for system reliability and maintenance.

PARTIALLY CONFIDENTIAL 1 • NLH continues to operate Holyrood in the winter period which was not forecasted 2 in 2013. 3 • Although the generation capacity at Muskrat Falls is 824 MW, as the facility is 4 primarily run of river (with minima...

AI summary The text discusses planned outages at the Labrador Island Link (LIL) in July 2023, aimed at improving the reliability of the LIL through software updates and system testing. The outage was coordinated with system operators and scheduled during the summer to minimize impact on customers.

NSPML Responses to Consumer Advocate Information Requests 1 2 3 4 5 accordance with the 30-day outage coordination period previously established by the system operators for outages affecting the delivery of the NS Block, including planned...

AI summary NSPML explains that a July planned outage was consistent with Good Utility Practice and not related to asset commissioning. The outage was necessary for software updates to enhance asset reliability and was coordinated with system operators. The outage was also compared to similar outages at Maritime Link post-commissioning.

NSPML Responses to Industrial Group Information Requests 1 Request IR-01: 25 has never been decided on by the Board, and in no way 26 informed the Board's 2023 NSUARB 175 decision or 1 setting of the flexible relief available to NSPML in 2...

AI summary NSPML responds to information requests from an industrial group regarding the Board's 2023 NSUARB 175 decision, the definition of 'Good Utility Practice,' and how NSPML defines planned versus unplanned outages, including scenarios where outages may fall outside the proposed definition.

3 Forced Outages - DCCT Transformers (See NSEB IR-16 and IG IR-11): Start Date and Time End Date and Time Duration [h] Cause 6-1-23 17:00 6-2-23 0:00 7 DC Current Transformer Noise 6-27-23 0:00 6-27-23 9:00 9 DC Current Transformer Noise 1...

AI summary The document lists multiple forced outages related to DCCT transformers and other infrastructure, detailing dates, durations, and causes, including transformer noise, cable switching, lightning strikes, ice accumulation, forest fires, and software errors.

PARTIALLY CONFIDENTIAL 1 b) The below chart shows the planned annual maintenance outages for 2023, 2024, 2025 and 2 prospectively for 2026. As in previous years, there will be other, typically shorter duration 3 planned outages that will b...

AI summary The text outlines planned annual maintenance outages for 2023 through 2026, noting that some outages are scheduled in advance while others depend on component availability from suppliers, such as DC current transformers.

- 9 a) Please explain why the section of line at issue is designed for a maximum of 50 mm of radial 10 glaze ice and a combined wind and ice load of only 25 mm of radial glaze ice with 60 km/h 11 wind, given the climatic conditions prevale...

AI summary The document requests explanations regarding the design criteria for a power line section, specifically its ice and wind load capacity, and whether these were consistent with standards. It also inquires about past icing incidents, the duration and causes of a recent outage, and the impact of the icing event on energy deliveries. Engineering reports and corrective actions are requested.

Table 1: Outages Due to Extreme Icing (2020-2026) Date Location Description 2021- 11-25 Labrador East On November 25, 2021, at approximately 03:10 hours (AST), Hydro experienced an unplanned outage to customers in Labrador East. At the tim...

AI summary The text discusses two unplanned outages in Labrador East and Cartwright caused by extreme icing conditions, highlighting the impact of weather on infrastructure. It also references capital projects aimed at improving resilience through ice monitoring and reinforced designs.

1 c) Due to site conditions, limited access, and the extent of damage, repairs could not be undertaken immediately; the two impacted customers restored their service through their own backup power source. Repairs were completed and power w...

AI summary Two incidents involving power outages are described. The first occurred in 2021 due to site conditions and damage, with repairs completed on February 1, 2021. The second incident occurred on December 9, 2022, in Red Bay, caused by ice accumulation and damage to power lines and poles, with service restored using an emergency generator by December 11, 2022.

e ice at a density of 0.9 g/cm 3 (20.6 to 21.6 kg/m), and the damage likely occurred due to unbalanced ice loads from ice shedding. There were no other components damaged in this icing event. In March 2024 there was an icing event in south...

AI summary Multiple icing events between 2024 and 2025 caused damage to electrode crossarms and conductors in Labrador. Ice shedding led to unbalanced ice loads, resulting in failures at various locations. The damage was documented in Table 1, with a total of 30 electrode crossarms and 56 conductor locations affected.

Table of contents Executive summary ii Figure D-1: SEM backscatter image of a representative example of a zinc coated steel reinforcing strand for the intact conductor. The image shows the significant variation in the thickness of the zinc...

AI summary The document contains a table of contents and several figures and tables related to the inspection and analysis of a failed conductor following an incident on March 30, 2024. The content includes SEM images of zinc-coated steel reinforcing strands and tables summarizing damage and wire strand diameter measurements.

PARTIALLY CONFIDENTIAL 1 Request IR-13: 2 3 Reference: N-01 Application, Section 5.0 and Section 6.0, pages 23-27. 4 5 Preamble: The Application states that as of the end of 2025, approximately $15.3 million 6 in holdback funds relates to...

AI summary The document discusses a request regarding holdback funds related to planned outages by NSPML, with a response confirming that all outages were planned, despite some extending longer than expected. It also mentions short-duration forced outages that did not impact the monthly holdback threshold.

Operating Assumptions for Generating Facility Check box if applicable [ ] Operating Assumptions: [insert operating assumptions that reflect the charging behavior of the Generating Facility that includes at least one electric storage resour...

AI summary The text outlines operating assumptions for a generating facility, referencing Concentric's opinion on 'Good Utility Practice' and considerations for planned outages, including planning coordination, outage timing, and the nature of work performed during outages.

NON-CONFIDENTIAL 1 Response IR-24: a) Yes. While every situation must be assessed based on individual circumstances, in Concentric's view, the factors listed in subparts (i) through (v) are relevant considerations in evaluating whether a p...

AI summary Concentric acknowledges that factors listed in subparts (i) through (v) are relevant in assessing whether a planned outage aligns with good utility practice. They emphasize that planned outages should be coordinated with system operators, scheduled during lower system need, and tied to preventive or reliability-related work.

b) In addition to the factors identified in part (a), Concentric considers the following additional factors to be relevant in evaluating whether a planned outage falls within good utility practice: • Consistency with reliability objectives...

AI summary Concentric evaluates planned outages by considering their consistency with reliability objectives and coordination with regional system operators to ensure they align with broader system needs and enhance safe and reliable power system operations.

CONFIDENTIAL (Attachment Only) 1 Request IR-25: 2 3 Reference: N-01, Application, Attachment 1, Concentric Evidence. 4 Preamble: In responding to Q38, Concentric relies on NERC outage statistics and HVDC 5 benchmarking to support the view...

AI summary In response to Request IR-25, Concentric refers to NERC outage statistics and HVDC benchmarking to justify planned outages as normal and expected, and argues that the Board's monthly performance threshold for NS Block deliveries should account for such outages as part of good utility practice.

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).

NSPML Application to Review the Holdback Mechanism (NSEB M12696) NSPML Responses to NSEB Information Requests 1 Request IR-03: 3 Does NSPML have a schedule for planned outages? 4 (a) If not, why not? 5 (b) If so: 6 i. How far in advanced a...

AI summary NSPML has scheduled its 2026 annual planned maintenance outage for mid-September, with specific dates for each pole of the Maritime Link. The outage planning occurs approximately a year in advance and is finalized six months ahead, with additional outages requiring at least 30 days notice.

NSPML Responses to NSEB Information Requests 1 Request IR-12: 1 upgrades, all of which require equipment to be taken out of service to ensure worker safety 2 and system reliability. The act of scheduling and executing such outages in a con...

AI summary NSPML responds to NSEB information requests regarding planned outages and software issues with the Labrador Island Link. It argues that maintenance during planned outages is consistent with good utility practice and that software problems were not due to prior failures in adhering to good practice.

NON-CONFIDENTIAL 1 commissioning relate to the performance of the LIL should provide comfort that the Newfoundland 2 & Labrador System Operator, Canada's Independent Engineer and many others involved in the 3 commissioning of the LIL were...

AI summary The text discusses the commissioning process of the Labrador Island Link (LIL), highlighting the need for a July 2023 outage to address software issues discovered after its April 2023 commissioning. The software update introduced functionality problems, leading to a rollback to the previous working version.

- 1: Hardwoods 50 MW CT retired in 2022 - 2: 1 x 50 MW CT added - 3: Stephenville 50 MW CT retired in 2024 - 4: 2 x 50 MW CT added - 5: 3 x 50 MW CT added - 6: 4 x 50 MW CT added - 7: 5 x 50 MW CT added - 8: Portland Creek at 23 MW and new...

AI summary The document outlines the retirement and addition of combustion turbines and combined cycle combustion turbines, and discusses historical storm data affecting transmission lines on the Avalon Peninsula. It emphasizes the use of a 14-day repair window for outage analysis and the impact of icing events on transmission lines.

Table 4-4: Reduced Power Capability Modes Element Failure Rate(f/yr) Repair Time(hrs) Downtime(hrs/yr) Scheduled Maintenance 2.0 72 144 Converter-Muskrat Falls 1.64 13.8 22.42 Pole 1 2.04 6.3 12.87 Pole 2 2.04 6.3 12.87 Converter-Soldiers...

AI summary Table 4-4 outlines the reduced power capability modes, detailing failure rates, repair times, and downtime for various elements. It indicates that scheduled maintenance and converter failures contribute to forced outage rates (FOR), and the unavailability due to these factors is calculated at 0.81% and 1.64% respectively. If the station ground cannot be used for mono-polar operation, FOR increases slightly.

NSPML Responses to Small Business Advocate Information Requests 1 Request IR-01: commissioning performance, NSPML does not envision a circumstance or rationale that would support a holdback disallowance as it would not be reflective of any...

AI summary NSPML responds to information requests regarding holdback disallowance, unplanned outages, and financial figures for 2025. It argues that holdback disallowance is not justified unless due to imprudence by NSPML, and outlines the planned distribution of holdback amounts post-May 1, 2024.

1 configuration on Monday April 8, 2024."65 Separately, NSPML states that NLH 2 took an unrelated, one-day bipole outage on April 30, 2024 "to correct a software 3 deficiency relating to cable switching."66 Absent these outages, NSPML expl...

AI summary NSPML explains that unplanned outages, including a one-day bipole outage by NLH on April 30, 2024, impacted NS Block deliveries, which would have otherwise exceeded the 90% threshold. The reviewer agrees that without these outages, NSPML would have met the threshold but notes challenges in assessing 'good utility practice' due to subjectivity and multiple entities involved.

Q. Are there examples of conflicting information in NSPML's evidence regarding good - utility practice? - A. Yes. NSPML states that it "timed" its "regularly scheduled planned maintenance" on the - Maritime Link "to occur in conjunction wi...

AI summary NSPML's evidence shows conflicting information regarding good utility practice, specifically regarding the timing of maintenance on the Maritime Link in conjunction with NLH's planned outage. The evidence indicates no overlap between the LIL and Maritime Link outages, raising questions about the prudence of NSPML's practice.

Questions regarding the sufficiency of LIL's design do not support NSPML's position that the March-April 2024 outage was excused by extraordinary circumstances. - (a) Please confirm whether the March 2024 icing event exceeded the design-ba...

AI summary The text raises questions about whether the March-April 2024 outage on the LIL was caused by design limitations and whether this qualifies as an 'exceptional circumstance' under the Board's test, challenging NSPML's claim that the outage was excused by extraordinary circumstances.

Date Filed: June 11, 2026 CA (IG) Page 1 of 5 1 M12696 2 3 Reference: N-8, Evidence of John D. Wilson (CA), p.5. 4 5 6 7 8 (a) Please set out the full definition or standard that Mr. Wilson applied in determining whether Event 4 (the March...

AI summary The document includes questions regarding the definition of 'exceptional circumstances' in the context of an unplanned icing outage in March-April 2024 and whether regulatory, contractual, or legal precedents were considered. The response indicates that the determination is subjective and that 'good utility practice' standards are not the standard set by the Board.

11 Q10. BATES WHITE SPECIFICALLY QUESTIONS EACH OF THE PLANNED AND 12 UNPLANNED OUTAGES NOTED IN NSPML'S EVIDENCE. PLEASE RESPOND 13 TO THESE QUESTIONS FOR EACH OUTAGE THAT BATES WHITE 14 ADDRESSES. 15 A10. Mr. Musco acknowledges that he i...

AI summary The response acknowledges that Mr. Musco is not an engineer and therefore does not provide an independent engineering assessment of outage causation or transmission system performance. However, the response addresses each of the Labrador-Island Link outages discussed by Mr. Musco.

22 Q11. PLEASE DESCRIBE THE JULY 2023 OUTAGE AT ISSUE. 23 A11. The July 2023 outage was a planned LIL bipole outage. Bates White describes the outage 24 as involving software backup and validation activities, final software updates associa...

AI summary The July 2023 outage was a planned LIL bipole outage involving software backup, validation, and SCADA point verification. Bates White notes that without this outage, deliveries during July 2023 would have exceeded the Board's 90% threshold.

3 Q12. WHAT DOES MR. MUSCO ASSERT REGARDING THE JULY 2023 OUTAGE? 4 A12. Mr. Musco observes that the July 2023 outage involved software backup and validation 5 activities, software updates, SCADA point verification, testing associated with...

AI summary Mr. Musco asserts that the July 2023 outage involved activities such as software updates and SCADA verification, and questions whether these should have been addressed before commissioning, suggesting they may not align with good utility practice.

10 Q13. DO YOU AGREE WITH MR. MUSCO'S ASSESSMENT OF THE JULY 2023 11 OUTAGE? 12 A13. No. While I agree with Mr. Musco's description of the work that was performed during the 13 outage, I do not agree with his conclusion that the outage dem...

AI summary The respondent disagrees with Mr. Musco's assessment of the July 2023 outage, agreeing with the description of the work performed but not with the conclusion that it reflects a failure to follow good utility practice or that the work should have been completed prior to commissioning.

6 Q17. PLEASE DESCRIBE THE SEPTEMBER 2023 OUTAGE. - 7 A17. The September 2023 outage was a planned annual maintenance outage involving Pole 1, 8 Pole 2, and associated bipole facilities. The outage included inspections, testing, 9 preventa...

AI summary The September 2023 outage was a planned maintenance event involving Pole 1 and Pole 2, as well as associated bipole facilities. The outage included inspections, testing, and maintenance activities aimed at ensuring reliability. Bates White notes that without the outage, deliveries during September 2023 would have exceeded the Board's threshold.

13 Q18. WHAT DOES MR. MUSCO ASSERT REGARDING THE SEPTEMBER 2023 14 OUTAGE? 15 A18. Mr. Musco asserts that the September 2023 Maritime Link outage did not overlap with the 16 LIL outage and therefore questions whether the outages were coord...

AI summary Mr. Musco argues that the September 2023 Maritime Link outage did not coincide with the LIL outage, thus questioning the coordination of the outages as stated by the Company. His claim is based on operational availability data for the Maritime Link.

4 Q20. WHY DO YOU DISAGREE WITH THAT CONCLUSION? 5 A20. It is understandable why Mr. Musco, in reviewing the evidence shown in IR-03 Attachment 6 1, would conclude that there was no overlap between the LIL outage and the Maritime Link 7 ou...

AI summary The response explains that while Mr. Musco observed no overlap between the LIL outage and the Maritime Link outage based on specific data, the data only captures a portion of the overall outage sequence, suggesting potential discrepancies in the conclusion.

14 Q21. CAN YOU DESCRIBE THE OUTAGE SEQUENCE IN MORE DETAIL? 15 A21. The Maritime Link Pole 1 outage extended from approximately September 3 through 16 September 13. The outage then shifted to Maritime Link Pole 2 from approximately 17 Sep...

AI summary The text describes the sequence of outages for Maritime Link Pole 1 and 2, as well as LIL Pole 1, from September 3 to September 17. The outages overlapped during a significant portion of the maintenance period, with the LIL single-pole outage establishing the effective import limit into Nova Scotia.

14 Q22. WHAT CONCLUSION DO YOU DRAW FROM THIS OUTAGE SEQUENCE? 15 A22. The evidence demonstrates that the Maritime Link and LIL outages were coordinated and 16 did in fact overlap beginning on September 3, 2023. The reason that overlap is...

AI summary The outage sequence involving the Maritime Link and LIL was coordinated and occurred during a planned maintenance period. The continued energy delivery during the first phase was due to the remaining poles in the bipole HVDC system. The outage planning and coordination are deemed prudent and consistent with good utility practice.

1 Q23. DOES BATES WHITE IDENTIFY ANY IMPROPER MAINTENANCE DECISION 2 ASSOCIATED WITH THE SEPTEMBER 2023 OUTAGE? - 3 A23. No. Bates White does not identify maintenance that should not have been performed, 4 maintenance that was performed in...

AI summary Bates White does not identify any improper maintenance decisions associated with the September 2023 outage. Instead, they question the coordination of the outage, but this does not indicate a failure to follow good utility practice.

8 Q24. WHAT OCURRED IN MARCH 2024 WITH RESPECT TO THE LIL? 9 A24. In March 2024, NLH scheduled a two-day planned bipole outage on the LIL to facilitate 10 corrective maintenance activities. These activities included repairs to Optical Grou...

AI summary In March 2024, NLH conducted a two-day planned bipole outage on the LIL to perform corrective maintenance, including repairs to damaged infrastructure, mitigation of electromagnetic interference, and installation of ground potential rise mitigations.

15 Q25. HOW WOULD YOU CHARACTERIZE THIS OUTAGE? 16 A25. I would characterize this outage as a planned maintenance outage undertaken to address 17 identified equipment and system issues and to improve the long-term reliability and 18 operab...

AI summary The outage is characterized as a planned maintenance outage aimed at addressing equipment and system issues to enhance the long-term reliability and operability of the LIL. Such outages are considered a normal part of operating complex transmission facilities and align with good utility practice.

20 Q26. WHAT EFFECT DID THE OUTAGE HAVE ON NS BLOCK DELIVERIES? 21 A26. Based on the evidence filed by NSPML, the two-day planned outage reduced NS Block 22 deliveries during March 2024. However, NSPML demonstrated that absent the planned...

AI summary The two-day planned outage reduced NS Block deliveries during March 2024, but NSPML argued that deliveries would have exceeded the 90% threshold without the outage. The shortfall was attributed to temporary planned maintenance rather than operational limitations.

5 Q27. HOW IS THAT FACT SIGNIFICANT? 6 A27. In my opinion, it is significant because it demonstrates that the March 2024 delivery results 7 were affected by a discrete, planned maintenance outage rather than any fundamental 8 limitation in...

AI summary The significance of the March 2024 delivery results is attributed to a planned maintenance outage rather than a fundamental limitation in the LIL or Maritime Link, and these results are consistent with the benefits expected under the Board's holdback framework.

12 Q28. PLEASE DESCRIBE THE MARCH/APRIL 2024 ICING EVENT. 13 A28. The March-April 2024 event involved a forced LIL bipole outage resulting from a 14 significant icing event that caused physical damage to transmission facilities. The event...

AI summary The March-April 2024 icing event caused a forced outage of the LIL bipole due to physical damage from extreme weather conditions, affecting transmission facilities such as the electrode line, supporting structures, and the OGW. The event was not planned or a result of operational decisions.

1 Q29. WHAT DOES MR. MUSCO ASSERT REGARDING THE MARCH/ APRIL 2024 2 OUTAGE? 3 A29. Mr. Musco asserts that NLH's limited ability to handle certain icing conditions have been known for some time.21 4 He further suggests that whether the Marc...

AI summary Mr. Musco asserts that NLH's limited ability to handle icing conditions has been known for some time and that the March-April 2024 outage should not be considered an exceptional circumstance due to the known risks of severe icing in Labrador. He references the Haldar Report to question whether the outage qualifies for relief under the Board's exceptional circumstances provision.

1 Q40. WHY IS THAT DISTINCTION IMPORTANT? 2 A40. It is important because Bates White frequently identifies questions, concerns, or 3 observations regarding outage events without ultimately demonstrating that NSPML failed 4 the Board's test...

AI summary The distinction is important because the Board's framework does not consider the mere occurrence of an outage as sufficient to deny relief. Instead, it focuses on whether the outage resulted from imprudent conduct or exceptional circumstances beyond the utility's control. Bates White's testimony emphasizes outages without sufficient evidence of imprudent actions.

3 Q42. WHY IS THAT IMPORTANT? 4 A42. It is important because the existence of an outage is not evidence of imprudence. Electric 5 utilities routinely experience planned outages, forced outages, equipment failures, software 6 updates, inspe...

AI summary The response emphasizes that the existence of outages alone does not indicate imprudence by a utility. It highlights that utilities routinely experience various types of outages and that the key inquiry is whether the utility acted in accordance with prudent utility practice. The response also notes that the impact of the outages was minimal, as energy was still delivered to customers, and stresses that the focus should be on the quality of decisions and their impact, not just the existence of outages.

1. NSPML states on page 24, lines 3-5, “Moreover, the Deferred Energy that accumulated during these outages was entirely redelivered by December 25, 2024.” 1. What was the replacement cost of Deferred Energy delivered in December 2024 vers...

AI summary The text raises questions about the replacement cost of Deferred Energy during and after outages, the definition of 'reasonable time' for redelivery, and the circumstances and responsibilities related to an unplanned outage in January 2025. It also inquires about NSPML's management of its relationship with NLH to prevent future incidents.

29 was essentially eliminated in June 2024. 1 2 highlight any planned or unplanned outages from May 2023 to present that would not meet that definition. 3 (d) Does NSPML take any position regarding whether planned or unplanned 4 outages sh...

AI summary The text discusses questions regarding planned and unplanned outages related to the NSPML, including whether they should be considered cumulatively or on a singular basis, and how inclement weather events are defined as 'exceptional circumstances.' It also references a benefit figure for 2025 and asks whether assessment costs include FLG2 repayment obligations.

4136-3744-6758 1 Request IR-5: 2 Reference: N-01 Application, p. 15, lines 5–12; Appendix A and Appendix C page 36 of 3 37. 4 Preamble: The Application states that deliveries were over 100% (both NS Block and 5 Make Up Energy) in every mon...

AI summary The document requests detailed information about a 'winter readiness outage' in September 2023, including work items performed, the duration of the outage, the rationale for scheduling it in September, and whether similar outages occurred in 2024 and 2025. It also asks for confirmation of the exact MWh shortfall in September 2023 and what portion of the shortfall relates to expected Base Block energy.

24 (c) Confirm that the approximately 6,000 MWh (or 6,500 MWh) shortfall in 25 September 2023 was attributable solely to the planned outage, and was 26 not caused, in whole or in part, by any unplanned event, extreme weather 27 or any othe...

AI summary The text requests confirmation that a specific energy shortfall in September 2023 was due solely to a planned outage and not caused by other factors. It also asks about the consistency of shortfalls during annual planned outages and whether any planned outages in the last three years occurred when load and replacement energy costs were not lower.

19 Table at pages 17-18; and pages 23-25. 18 Reference: N-01 Application, Section 4.2, Relief for Planned and Unplanned Outages, 17 Request IR-7: 16 Block) was continuously satisfied throughout that period. 15 condition (net outstanding ba...

AI summary The document includes a request for explanations regarding the deferred energy balance increase and the interpretation of operational information related to the Board's holdback mechanism. It references the Application's Section 4.2, which includes a summary table of LIL outages.

- 21 relevant to the claimed Compliance Period, in which NSPML seeks relief from the - 22 compliance requirements. At pages 23-25, the Application summarizes the outages that - 23 followed the noted Compliance Period. - 24 (a) Please updat...

AI summary The text discusses an application by NSPML seeking relief from compliance requirements during a specific period, referencing outages that occurred during and after the Compliance Period. The application requests an updated summary of outages, including those from the LIL commissioning period to the present.

- 27 (i) the planned outage timeline as originally scheduled, 28 compared to the actual outage start and end dates, or 29 identify if unplanned; 1 (ii) the cause of each outage and whether within the control of 2 NSPML, NLH, or external; 3...

AI summary The text outlines a request for information regarding planned and unplanned outages, including their timelines, causes, affected assets, and impacts on delivery reliability and holdback funds. It also asks for outage schedule forecasts for the years 2023 to 2026.

- 28 (ii) whether this entire outage period related solely to the icing 29 incident, and if not, what else caused and/or was completed 30 during this period; and 1 (iii) the quantified reduction in Base NS Block deliveries 2 (excluding Mak...

AI summary The text outlines regulatory requests related to an icing event in March–April 2024, asking about the outage period's causes, quantified reductions in energy deliveries, and engineering reports. It also seeks information on outstanding punch list items and a discrepancy regarding the commissioning date of DC current transformers.

9 into early October as planned. 2 Reference: N-01 Application, Section 5.0, pages 23-24. Preamble: The Application describes a series of outages from July through October 2024, including: single pole outages in July to troubleshoot interm...

AI summary The text references a series of outages from July through October 2024, including software updates and maintenance activities, and requests confirmation on whether these outages were related to previously reported issues, the work required to address them, and the current status of any unresolved issues.

- 26 (b) Please explain why this evidence is characterized as "Rebuttal" evidence. 1 Request IR-20: 20 21 22 23 24 (i) The adequacy of planning and coordination in advance of the outage, including the timing and sufficiency of outage reque...

AI summary The document requests an explanation for why the evidence is classified as 'Rebuttal' evidence, focusing on the adequacy of planning and coordination prior to an outage, and the selection of outage timing.

28 was considered; 1 (iii) The nature of the work scope performed during the outage 2 — specifically, whether the work constituted preventive 3 maintenance, corrective maintenance arising from known 4 deficiencies, residual commissioning o...

AI summary The text outlines factors to consider when evaluating whether a planned or unplanned outage falls within Good Utility Practice, including the nature of the work performed, whether the outage was scheduled or deferred, and whether preventive maintenance programs were in place.

t any "planned outage" on the LIL represents good utility practice by NLH? If not, please explain how NSPML distinguishes between planned outages that are good utility practice and those that are not. - d) Is it NSPML's view that any outag...

AI summary The text consists of a series of questions posed to NSPML regarding the classification and implications of outages on the LIL, including planned outages, icing events, definitions of monopole and bipole outages, software updates, identified deficiencies, and the financial impact of outages on Nova Scotia ratepayers.

- i. Please provide a list and detailed explanations of all "routine maintenance" done during this outage. 1 ii. Were there any additional maintenance activities that occurred during the outage, 2 other than those identified in response to...

AI summary The document requests detailed information about routine maintenance during an outage, additional maintenance activities, planned maintenance timing, and the impact of the outage on Nova Scotia ratepayers. It also inquires about the technical causes of the outage and whether affected components performed as designed during an icing event.

cessity of the March 2024 outages. - b) Please provide all documents, workpapers, and analyses that the Witness relied upon to independently assess the details and necessity of the March 2024 outages. - Request IR-15: Please refer to Exhib...

AI summary The text contains a series of requests for information related to the March 2024 outages, the LIL's design and climate resistance, and the Witness's review of project financing agreements and outage reasonableness. These requests aim to assess the basis of the Witness's testimony and the supporting documentation.

- that the request to cease the Holdback Mechanism should be determined by whether "outages" - were reported by NLH to be "successful?" Please explain. - Request IR-19: Please refer to Exhibit N-1, Attachment 1, page 30 lines 17-18 - a) Is...

AI summary The text contains a series of requests for clarification regarding the Holdback Mechanism, software issues on the LIL, the initial period, hurdles in the Maritime Link proceeding, and the achievability of energy delivery targets. These requests are aimed at understanding the witness's position and supporting evidence.

in Exhibit N-1. 25. Please provide the expected availability (%) of the Muskrat Falls Generating Station, as modeled or assumed by NSPML in M05419. Please include the base case and any sensitivities for this assumption used in M05419. 26....

AI summary The text includes a series of questions directed at NSPML regarding the availability and forced outage rates of the Muskrat Falls Generating Station and the LIL, as well as definitions and distinctions related to monopole and bipole outages. It also asks for explanations of specific outages and software-related issues.

ly 2023 “Outage,” please provide: 1. Explanation of the referenced “software.” 2. Explanation of the “software update” and why the update was needed. 3. If the LIL had been able to operate at 900 MW as designed, would the software update h...

AI summary The document requests detailed information regarding the September 2023 outage on the Labrador Island Link (LIL), including the software involved, the reasons for the software update, identified deficiencies, corrections, and the impact of the outage on Nova Scotia ratepayers. It also asks about maintenance activities, outage timing, and independent diligence conducted by NSPML.

re each of these outages reflective of Good Utility Practice or explained by extraordinary circumstances? Please explain. 42. Is it NSPML’s view that, if a utility-owned asset has been poorly designed, and that such poor design leads to in...

AI summary The text contains a series of questions addressing NSPML's adherence to Good Utility Practice, including the impact of design flaws, contractual obligations, and the effects of outages and delivery delays on customers. It also references specific exhibits and inquires about the relevance of planned outages and prudence in utility operations.

ion line over which it has no operational control.”) Is the Witnesses’ position conditioned on whether the planned outage is prudent or otherwise consistent with Good Utility Practice? Please explain.

AI summary The question asks whether the witnesses' position on a planned outage is contingent on whether the outage is prudent or aligns with Good Utility Practice, seeking clarification on the basis of their stance.

1. Please refer to Exhibit N-1, Attachment 1, page 10, lines 7-9 2. Please describe the Witness’s efforts to independently verify that the planned outages “were conducted for necessary maintenance and system enhancements.” 3. Please provid...

AI summary The text contains a series of questions directed at a witness regarding the verification of planned outages, maintenance activities, and supporting documentation for various infrastructure projects, including the Labrador Island Link (LIL) and Muskrat Falls Generating Station. The questions focus on the witness's independent verification efforts and the documents used to support their claims.

pers, and analyses that the Witness relied upon to independently assess the details and necessity of the July 2023 outage. 14. Please describe the Witness’s efforts to independently verify the details and necessity of the September 2023 ou...

AI summary The text consists of a series of questions directed at a witness regarding their verification of outages in 2023 and 2024, as well as their reliance on documents and analyses, and their understanding of the Labrador Island Link (LIL) and its design standards.

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.

30 volumes affected. 1 2025 M12696 3 do you have any recommended objective criteria the Board could apply to 4 reduce subjectivity? 5 (c) Please confirm that you have not recommended that the Board grant 6 NSPML's request to end the holdba...

AI summary The text discusses a regulatory proceeding involving NSPML and Bates White, focusing on the timing and coordination of outages and maintenance work on the LIL and ML systems in September 2023. It requests clarification on whether the outages overlapped and whether ML maintenance completed before the LIL outage impacted capacity.

Delivery of 90% of the NS Block for 12 Consecutive Months Under the terms set out by the Board in its decision for Ml1009, NSPML is also required to demonstrate that Nova Scotia ratepayers have received, each month for 12 consecutive month...

AI summary NSPML must deliver 90% of the NS Block for 12 consecutive months as per Board decision Ml1009. During May 2023 to April 2024, NSPML fell below the threshold four times, citing planned outages, good utility practice, extreme weather, and an icing event as reasons for the shortfalls.

Good Utilitv Practice The SBA acknowledges that there are times when, in order to ensure that the facilities operate efficiently and safely, they must be taken off-line to accomplish important work. That may occur on a planned or an unplan...

AI summary The SBA argues that while planned and unplanned outages may be necessary for efficient and safe facility operations, the criteria for determining good utility practice should be more substantive than just having a technical reason for an outage. The SBA emphasizes the need to evaluate whether the work is necessary, whether it can be scheduled to reduce outage duration, and whether the number of outages can be minimized.

Summary The SBA respectfully submits that, while the first part of the test, namely the delivery of previously undelivered energy, appears to have been satisfied by March, 2023, whether NSPML has achieved the second requirement of the test...

AI summary The SBA argues that while NSPML may have met the first part of the test for releasing the Holdback Mechanism, it has not clearly met the second requirement of delivering 90% of energy in 12 consecutive months. The SBA also questions the justification for NSPML's request for WACC, suggesting it should be calculated based on NSPML's approved cost of debt.

5 3.2 All Down-Time was Consistent with "Good Utility Practice" and/or "Exceptional 6 Circumstances" 7 8 The sub-90% NS Block performance in the four months of the Compliance Period was 9 due to temporary Labrador Island Link (LIL) and Lab...

AI summary NSPML explains that sub-90% NS Block performance in the Compliance Period was due to planned outages on the Labrador Island Link (LIL) and Labrador Transmission Assets (LTA), which were consistent with good utility practice or exceptional circumstances. These outages included software updates, annual maintenance, and repairs following an ice storm.

Date Filed: July 9, 2026 Page 10 of 20 1 only approved for operation up to 170 MW during this period. Although this limited 2 the ability for the full Supplemental Energy amount to be imported off-peak and 3 limited the amount of Make-up E...

AI summary The text discusses outages and maintenance events affecting the Labrador Island Link (LIL) and NSPML's coordination with NLH, including an ice event in April 2024 and a planned outage in April 2024. These events impacted NS Block delivery, but NSPML argues that the outages were in accordance with good utility practice.

dence in design or maintenance. Also, when these incidents 25 occur, a responsible utility promptly dispatches the necessary resources to remedy the 26 outage, which is exactly what happened here. 27 28 In their evidence, Bates White raise...

AI summary The document argues that all downtime associated with the Labrador-Iceland Link (LIL) was consistent with good utility practice and that there is no evidence of imprudence in the work conducted by NLH during planned outages. The LIL was commissioned and accepted by regulatory bodies, and post-commissioning activities were standard for major projects.

threshold, instead requiring a longer period of consistent performance. Relief under the "good utility practice or exceptional circumstances" provision is a limited exception, not a broad exemption. Within the compliance filing provided in...

AI summary The Regulatory Board clarified that relief under the 'good utility practice or exceptional circumstances' provision applies only to the 12-month consecutive requirement, not the monthly 90% threshold. NSPML requested various forms of relief, including the release of holdback funds and relief during planned outages, but the Board's decision limited the scope of this relief.

Month Base Contract Delivery (%) Met 90% Threshold May 2024 62% No June 2024 99% Yes July 2024 86% No August 2024 0% No September 2024 44% No October 2024 83% No Consistent with the Post-Compliance Period delivery failures, the net outstan...

AI summary The document discusses the failure of NSPML to meet delivery thresholds in the Post-Compliance Period, leading to an increase in the net outstanding balance of undelivered energy. The delay in DCCT replacements and lack of documentation for this decision were highlighted as concerns. The Board warned against planning outages to circumvent holdback conditions, and the high outage rate since April 2024 is noted as concerning.

RELIEF FROM THE THRESHOLD REQUIREMENTS IS NOT WARRANTED The Board has allowed for a degree of flexibility for NSPML to meet the stated threshold obligations, to address the need for some margin of interruption that is " required due to goo...

AI summary The Board has not granted relief from threshold requirements for NSPML, emphasizing that relief is discretionary and must be justified by good utility practice or exceptional circumstances. The burden of proof was not met, and the evidence did not support the need for such relief.

Good Utility Practice Good utility practice is not limited to a single definition or universal standard and is not a standard of perfection. Rather, it includes a variety of reasonable approaches while adhering to industry regulations and...

AI summary Good utility practice is defined as reasonable approaches aligned with industry regulations and sound business practices. Planned outages are part of good utility practice, but not all qualify. The Regulatory Board emphasizes that not every outage automatically qualifies and that good utility practice must be assessed on specific facts and evidence for each month.

July 2023 Outage NSPML seeks good utility practice relief for the five-day planned LIL bipole outage in July 2023, characterizing it as a post-commissioning software and SCADA update outage required to enhance reliability. Base NS Block de...

AI summary NSPML requests relief for a July 2023 outage, claiming it was necessary for post-commissioning software updates. The Industrial Group argues that the outage was not routine and did not meet good utility practice standards, as the work was deferred commissioning rather than routine maintenance. Software issues continued to affect the LIL's performance, and the final software was installed months after the compliance period.

September 2023 Outage NSPML seeks good utility practice relief for September 2023, during which 10 days of LIL bipole outages were taken for planned annual maintenance, resulting in a Base NS Block delivers of 66%. The Industrial Group pre...

AI summary NSPML requested relief for the September 2023 outage, citing coordination between ML and LIL outages. However, evidence shows the outages occurred sequentially, not in parallel, raising doubts about whether the maintenance was optimized. The Industrial Group questions whether the claimed coordination was achieved, suggesting the outage may not have aligned with good utility practice.

March 2024 Outage NSPML also seeks good utility practice relief for March 2024 based on a planned two-day LIL bipole outage (March 26–27) to repair damage from an ice storm, including OPGW repairs and electromagnetic interference mitigatio...

AI summary NSPML seeks good utility practice relief for a March 2024 outage caused by a planned LIL bipole repair following an ice storm. The Industrial Group argues that corrective maintenance should not exempt NSPML from Consistent Deliveries requirements, as the outage was a result of prior system vulnerabilities and not routine maintenance.

1. September 2023 — The ML and LIL Bipole Outages Were Not Concurrent In NSPML's submission at page 11 (lines 8–29) and page 12 (lines 1–2), NSPML asserts that "additional evidence was provided by Concentric in their rebuttal to show that...

AI summary The document addresses the timing of the Maritime Link and Labrador Island Link (LIL) bipole outages in September 2023, clarifying that they were not concurrent. NSPML claims Concentric's rebuttal showed the outages were scheduled at the same time, but evidence indicates the Maritime Link outages ended before the LIL bipole outage began, and Concentric did not establish overlap during the relevant period.

2. Haldar Report and the Foreseeability of the March-April 2024 Outage In NSPML's submission (page 13, lines 16-29), NSPML submits that the Haldar Report merely "identifies opportunities to improve reliability in the future" and does not s...

AI summary NSPML argues that the Haldar Report does not indicate flaws in the original LIL design and that the March-April 2024 outage was due to exceptional circumstances. The Industrial Group emphasizes that the Haldar Report highlights known vulnerabilities, making the outage's failure mechanism foreseeable. The Bates White evidence supports this, showing prior awareness of icing-related risks.

1.0 INTRODUCTION NSP Maritime Link Incorporated (NSPML, Company) files this Reply Submission in response to the Submissions of the intervenors in this Application. NSPML repeats and relies on its initial submissions and evidence. NSPML sub...

AI summary NSP Maritime Link Incorporated (NSPML) submits that the conditions to end the Holdback have been met, citing that owed energy fell below 10% in March 2024 and that planned outages align with good utility practice. The Labrador Island Link (LIL) was commissioned in April 2023, and post-commissioning work is considered normal. An outage in March/April 2024 was attributed to extreme weather exceeding design parameters.

SBA Submission, July 9, 2026, page 3. 2024. In your view, does this mean that NSPML failed to meet the Board's "Reduction in Undelivered Volumes" threshold? A. No. My understanding of the Board's threshold is that once it is achieved – as...

AI summary The submission discusses NSPML's compliance with the Board's thresholds for ending the Holdback mechanism. It argues that NSPML met the 'Reduction in Undelivered Volumes' threshold and that the four months where the 90% NS Block delivery threshold was not met qualify for relief due to planned outages and maintenance.

event that exceeded design standards. Absent the outage, Concentric states that NS Block deliveries exceeded 98% in April. Bates White Evidence filed May 7, 2026, page 18.

AI summary The text references an event that exceeded design standards, leading to a significant outage. Concentric claims that NS Block deliveries exceeded 98% in April, according to evidence filed by Bates White on May 7, 2026.

nd coordinated for periods of lower load. [18](#page-13-0) 10 Indeed, the question should really be: Can anyone reasonably suggest 11 that the work should not have been carried out? Of course not. 12 13 The main counter argument appears to...

AI summary The text discusses the justification for outages during the commissioning of the Labrador Island Link (LIL), emphasizing that punch list items after commissioning are normal for complex projects. It refutes claims that the work should have been completed before commissioning and highlights that the LIL was validly commissioned in April 2023 with support from multiple entities.

Date Filed: July 23, 2026 Page 17 of 44 1 energy to Nova Scotia. Customers during this period were not impacted and planned 2 annual maintenance schedules for NSPML and NLH were coordinated. During this 3 period, the timing of the LIL bipo...

AI summary The text discusses planned maintenance outages for NSPML and NLH in September 2023, emphasizing that no party claimed the work was not good utility practice. The IG raised concerns about the lack of coordination between outages, but the explanation provided aims to alleviate these concerns.

In response to Industrial Group IR-9, NSPML has produced the LIL Strengthening Overview Report of NL Hydro which confirms that in total, there have been ten failure events on L3501/2 over the past five years; each was a localized issue aff...

AI summary The document discusses the structural failures of the LIL transmission line due to ice loading, referencing prior events and the Haldar Report, which identified known design vulnerabilities. The Industrial Group supports Bates White's conclusion that the 2024 outage was not excused by exceptional circumstances. NSPML disagrees with the Inspector General's position on the need for prior remediation.

13 Pre-2024 Weather Events Affecting the LIL 14 As the above ground portion of the LIL was constructed over eight years ago, it is not 15 surprising that there have been some weather impacts. As noted in NSPML's 16 submissions (including C...

AI summary The text discusses weather events affecting the Labrador Island Link (LIL) prior to 2024, noting that while there have been weather impacts, none resulted in complete transmission tower failures. The March/April 2024 event was more extreme than previous ones, but the damage was not classified as structural failure before this event.

1 NLH Response to Reliability Reports 2 NLH has not ignored reliability management for the LIL. In the first quote above from 3 the February 4, 2022 letter it is clear that NLH is taking a well-reasoned approach to 4 collect data and focus...

AI summary NLH is addressing reliability management for the Labrador Island Link (LIL) by collecting data, developing a capital plan, and making short-term improvements. The Haldar Report supports NLH's approach, emphasizing the need for long-term data collection before making modifications to infrastructure based on wind and ice loading data.

Date Filed: July 23, 2026 Page 34 of 44 1 Energy delivered during this period was worth more to customers than the Undelivered The March 2024 planned outage work relates to corrective maintenance arising from prior failures on the line, ra...

AI summary The document discusses a planned outage in March 2024 related to corrective maintenance on a line, arguing that Good Utility Practice includes more than just routine scheduled maintenance. NSPML asserts that Good Utility Practice encompasses various activities, and the IG Submission appears contradictory in its statements regarding repairs and derating by the System Operator.

16 3.13 Post Compliance Period DCCT Work 17 18 NSPML wishes to offer clarity on outages related to DCCT work completed by NLH in 19 Newfoundland on the LIL. At page 7 of its Submission, the IG accused NSPML of 20 purposefully delaying an o...

AI summary NSPML clarifies that it was not responsible for scheduling DCCT work on NLH assets and that delays were due to supply chain issues, not intentional avoidance of holdback conditions. NSPML asserts that it did not influence outage planning to avoid financial impacts and that no evidence supports the IG's accusation of intentional delay.