Topic:"Prudency Reviews" in M12696

NSPML Responses to Industrial Group Information Requests 1 Request IR-03: 2 3 a) Reference: N-01 Application, page 9. 4 a. The Application states that as a direct result of NLH's delivery 5 performance prior to commissioning of the LIL, NS...

AI summary NSPML responds to a request regarding holdback-related disallowances totaling over $30 million and a $10 million penalty related to Renewable Energy Standards. NSPML states that the disallowances are not directly relevant to the Board's conditions for termination but are provided for context. The figure is accumulated from 2018 to April 2023 and was settled through an audit and Board Order M11009.

PARTIALLY CONFIDENTIAL 1 While NSPML does not consider Holdback issues while planning outages, the design of 26 Application, NSPML has requested termination of the holdback mechanism and, in the 27 alternative if the Board determines that...

AI summary NSPML has requested the termination of the holdback mechanism and, if it continues, a separate mitigation process. The application seeks approximately $16.5 million, including deferred interest and WACC calculations. The Board is asking for explanations regarding the interest claim and verification of the figures in Appendix B.

NSPML Application to Review the Holdback Mechanism (NSEB M12696) NSPML Responses to Industrial Group Information Requests

AI summary NSPML is applying to review the holdback mechanism as part of the NSEB M12696 proceeding, responding to information requests from the Industrial Group. The process involves regulatory scrutiny of the mechanism's terms and implications for cost recovery and rate design.

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.

its challenges? - A. Yes. The Board intentionally did not define "exceptional circumstances," leaving that - task to NSPML.[82](#page-28-3) Neither NSPML nor Witness Powers provide a direct definition. Instead, - NSPML and Witness Powers h...

AI summary The Board did not define 'exceptional circumstances,' leaving NSPML and Witness Powers to focus on weather as an indicator. However, determining severity is subjective. Witness Powers failed to conduct independent reviews of LIL outages and maintenance activities. Harsh weather conditions, as noted by NLH's expert Haldar & Associates, impact the LIL's reliability, complicating distinctions between design-known conditions and new extreme events.

- Q: Mr. Wilson, please state your name, occupation, and business address. - A: I am John D. Wilson. I am the Vice President of Grid Strategies LLC, Bethesda, MD. - Q: Summarize your professional education and experience. - A: I received a...

AI summary John D. Wilson, Vice President of Grid Strategies LLC, has extensive experience in utility regulation, including testimony in over seventy-five proceedings and work with the Consumer Advocate. He has expertise in cost-effectiveness, prudency reviews, and rate design.

Date Filed: June 11, 2026 CA (IG) Page 1 of 5 1 M12696 2 3 4 (c) If so, does Mr. Wilson consider this prior history in relation to the same asset relevant to whether the March-April 2024 event constitutes "exceptional circumstances"? Pleas...

AI summary The text contains a series of questions and responses related to a regulatory proceeding in Nova Scotia. It addresses whether prior history of an asset, design standards, and prior reports on vulnerabilities are relevant to determining if an event constitutes 'exceptional circumstances.'

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. 23 from the comparison cost of the Maritime Link. If so, please provide a 24 detailed...

AI summary The text references a reduction in the Deferred Energy balance and requests detailed information on costs related to the Maritime Link, including workpapers and models. It also mentions a penalty and holdback-related disallowances, referencing specific application pages and requests for clarification.

e held to a standard, as Bates 25 White seems to invite, of justifying both the prudence of NSPML's operations, as well 26 as NLH's independent conduct. Date Filed: July 9, 2026 Page 14 of 20 1 To this end, the fact that the LIL has not me...

AI summary The text discusses the need to evaluate NSPML's operations and the LIL's performance in meeting reliability standards and delivering the 'original bargain' to Nova Scotia customers. It emphasizes the importance of arms-length contracts and the context of the Holdback, which was established to address intergenerational equity concerns.

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.

- tower designs. The icing in March / April 2024 was approximately four times greater than prior icing in the same region. - That the Haldar Report does not question the prudence of the initial engineering design of the NLH transmission st...

AI summary NSPML submits that the conditions to end the Holdback have been met, citing that owed energy fell below the 10 percent threshold in March 2024 and that the Labrador Island Link was commissioned in April 2023. The company argues that post-commissioning work is standard practice and does not indicate poor performance. The Consumer Advocate and Bates White support ending the holdback, while the Small Business Advocate defers to the Board on relief for months below the 90 percent delivery threshold.

15 SBA Submission, July 9, 2026, page 5. 16 NSEB Decision M11009, October 4, 2023, paragraph 93. In addition, in setting the criteria to end the Holdback, it was well known that, due to the period of under-delivery prior to commissioning o...

AI summary NSPML argues that it has met the conditions to end the Holdback, pointing to the delivery of 100% of contracted energy, including Make-up Energy, and strong performance during critical winter months. It emphasizes that the Commercial Agreements do not require fixed delivery commitments and that the Holdback is no longer necessary as the original terms of the agreement have been fulfilled.