Topic:"Prudency Review" in M12550

NON-CONFIDENTIAL 1 Request IR-1: 2 Reference: 3 (a) At page 11, Midgard states it assessed "whether the Project, as proposed, is justified, 4 reasonable, and aligned with regulatory expectations for prudent utility investment". Please 5 ex...

AI summary Midgard explains that NSEB regulatory expectations are based on the prudency standard from 2005 NSUARB 27, which defines prudence as the standard of care a reasonable person would exercise under the same circumstances. Midgard does not adjudicate prudency but provides an objective, evidence-based record for the Board.

Request IR-2: - Reference : It appears that Midgard assessed "Overall Project Prudence & Ratepayer Interest" - under three categories: Project Execution Strategy (page 21), Project Controls & Governance (page - 27) and Assessment of Cost R...

AI summary Midgard's response to Request IR-2 highlights three evidentiary gaps identified in its prudence review of a project: lack of a formal make-versus-buy analysis, judgment-based cost estimates without historical calibration, and unsubstantiated labor hour escalations. Midgard emphasizes that alignment with regulatory expectations is determined by the Board, not itself.

Midgard Response IR-3: a) Midgard confirms that a 30% reduction in labour hours will reduce the total capital cost of the Project. As stated in Section 5.1.1 at page 32 of its Evidence Report: "Considering the lack of comparative data prov...

AI summary Midgard recommends a 30% reduction in labour hours to align capital cost estimates with a technically supportable baseline. The labour subtotal from NSPI's budget is $1,411,802, excluding non-labour items. The prudence of capital costs is determined by the Board.

DATE FILED: April 10, 2026 Page 3 of 22 1 In its evidence, Midgard provided its analysis and assessment of NS Power's application, and 2 found that the Company's material procurement practices were competitive and justified and 3 indirect...

AI summary Midgard evaluated NS Power's application, finding procurement practices competitive and justified but recommending a 30% reduction in labour estimates and improved reporting. Midgard addressed intervenor questions on prudency, emphasizing an evidence-based approach rather than a specific prudency test. NS Power is submitting rebuttal evidence to Midgard's conclusions.

July 13, 2026 Lana Myatt [[email protected]](mailto:[email protected]) Manager, Regulatory Capital Nova Scotia Power Inc. PO Box 910 1223 Lower Water Street Halifax, NS B3J 3S8 Dear Ms. Myatt: M12550 – To obtain a cost reasonablene...

AI summary Nova Scotia Power Inc. (NS Power) submitted a revised capital approval form for the RTU Replacements Program – Phase 6, reducing the project budget from $5,959,515 to $4,665,372 following a Board directive to reduce labour hours by 13%. The Board approved the revised request.

1 2025 M12550 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by Nova Scotia Power Incorporated to obtain a 5 cost reasonableness review of NS Power – CI C0051815 - 6 $5,959,515 –...

AI summary The Nova Scotia Energy Board has issued an information request to Midgard Consulting Inc. and Protech Engineering Inc., asking them to clarify what they consider to be the Nova Scotia Energy Board's 'regulatory expectations' for prudent utility investment and the test or standard they applied for prudence in assessing the RTU Replacements Program – Phase 6.

1 2 M12550 3 NOVA SCOTIA ENERGY BOARD 4 5 6 IN THE MATTER OF: The Public Utilities Act, R.S.N.S. 1989, c.380, as amended 7 8 9 IN THE MATTER OF: To obtain a cost reasonableness review of NS Power - CI 11 C0051815 – $5,959,515 - RTU Replace...

AI summary The Nova Scotia Energy Board is requesting information regarding the cost reasonableness review of NS Power's RTU Replacements Program, Phase 12 6, as outlined in the 2025 ACE Plan Decision. The request is directed to Michael Walsh of Midgard Consulting and is due by March 18, 2026.

M12550 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, R.S.N.S. 1989, c.380, as amended IN THE MATTER OF: To obtain a cost reasonableness review of NS Power - CI 11 C0051815 – $5,959,515 - RTU Replacements Program – Ph...

AI summary The Nova Scotia Energy Board is requesting responses regarding Midgard Consulting's conclusions on the cost-effectiveness of NSPI's use of internal resources versus external resources in the RTU Replacements Program. The Board is seeking recommendations for addressing past failures and future actions.

April 24, 2026 VIA EMAIL Ms. Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M12550 - To obtain a cost reasonableness review of NS Power - CI C0051815...

AI summary NS Power submitted a revised cost estimate for the RTU Phase 6 project, which was previously rejected due to a significant increase in costs and insufficient justification. The Nova Scotia Energy Board established M12550 to allow Midgard Consulting to review the project's costs and management processes.

July 13, 2026 Lana Myatt [[email protected]](mailto:[email protected]) Manager, Regulatory Capital Nova Scotia Power Inc. PO Box 910 1223 Lower Water Street Halifax, NS B3J 3S8 Dear Ms. Myatt: M12550 – To obtain a cost reasonablene...

AI summary Nova Scotia Power Inc. (NS Power) submitted a revised capital approval form for the RTU Replacements Program – Phase 6, reducing the project budget from $5,959,515 to $4,665,372 following a Board directive to reduce labour hours by 13%. The Board approved the revised budget request.