Topic:"Prudency Reviews" in M12743

DATE FILED: July 7, 2026 Page 3 of 17 1 2.0 RESPONSE TO CA SUBMISSIONS 2 3 The CA's submissions raise three concerns and two recommendations, including: 4 5 • the prudency of replacing NS Power's prior PAM solutions with a SaaS-based alter...

AI summary The CA raises concerns about NS Power's decision to replace its prior PAM solution with a SaaS-based alternative, questioning the prudency of the move and the accounting implications. NS Power disagrees with recommendations to disallow AFUDC and amend the requested contingency.

Issues Raised by Intervenors The CA and SBA raised several similar concerns with NS Power's application. Intervenors questioned the prudence of replacing the existing on-premise PAM solution because it had not reached the end of its useful...

AI summary Intervenors raised concerns about the prudence of replacing NS Power's existing PAM solution, questioning the need for replacement as the system had not reached the end of its useful life. They also questioned the continued amortization of unused PAM assets. NS Power explained that the existing systems no longer receive vendor support and that cloud-based solutions are now the norm, justifying the replacement and use of amortization accounting as approved in GRA M12451.

Issues Raised by Intervenors The CA and SBA raised several similar concerns with NS Power's application. Intervenors questioned the prudence of replacing the existing on-premise PAM solution because it had not reached the end of its useful...

AI summary Intervenors raised concerns about the prudence of replacing NS Power's existing PAM solution, questioning the need to replace it before its useful life has ended. They also challenged the amortization of existing PAM assets, as they are no longer in use. NS Power explained that the existing PAM systems lack vendor support and that the new project uses a SaaS model that does not involve NERC data storage in the cloud.