N-36Reply Evidence of Colin Fitzhenry and Michael Gorman, on behalf of PHP
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NOVA SCOTIA ENERGY BOARD ) ) ) ) ) ) ) ) ) ) ) ) ) ) IN THE MATTER OF THE PUBLIC UTILITIES ACT and IN THE MATTER OF AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable Above-the-Line Tari...
AI summary This document is a reply evidence submission by Colin T. Fitzhenry and Michael P. Gorman on behalf of Port Hawkesbury Paper LP in a proceeding under the Public Utilities Act regarding an application by Nova Scotia Power Incorporated for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable to Port Hawkesbury Paper. The matter number is M12661, dated July 8, 2026.
Q IS MR BOWMAN'S PROPOSAL CONSISTENT WITH THE BOARD DIRECTIVES THAT COST OF SERVICE AND RATE DESIGN BE BASED ON NON-DISCRIMINATORY RATEMAKING PRINCIPLES? A No. While we are not attorneys, our understating is that the Board operates under a...
AI summary The response argues that Mr. Bowman's proposal is inconsistent with the non-discriminatory rate-making principles mandated by the Nova Scotia Public Utilities Act. It also rejects his recommendation to allocate demand costs to PHP based on its average demand, citing unfair cost distribution. Additionally, the proposal to provide NS Power with practical control of PHP load during constrained conditions is deemed unreasonable, as it disregards PHP's operational constraints.
Q DO YOU AGREE WITH MR. BOWMAN'S RECOMMENDATION THAT THE BOARD COMPLETELY REJECT ALL MODIFICATIONS PROPOSED BY PHP, INCLUDING THE R/C RATIO OF 1.0? A No. Mr. Bowman's flat rejection of PHP's core proposals is entirely inequitable. For exam...
AI summary The respondent disagrees with Mr. Bowman's recommendation to reject all modifications proposed by PHP, including the R/C ratio of 1.0. They argue that an R/C ratio of 1.0 ensures rate fairness and compliance with the Public Utilities Act, as it prevents PHP from subsidizing other customer classes without justification.
Q DO YOU AGREE WITH INTERGROUP THAT THE R/C RATIO OF 1.04373 WAS AN "INTEGRAL CONSIDERATION" 17 OF THE SETTLEMENT AGREEMENT AND CANNOT BE ALTERED WITHOUT UNDERMINING THE AGREEMENT? A No. InterGroup's position attempts to lock PHP into an i...
AI summary The respondent disagrees with InterGroup's assertion that the R/C ratio of 1.04373 is an integral consideration of the settlement agreement. They argue that the agreement includes mechanisms allowing for challenges and adjustments, and that enforcing the 4.373% premium would create an inequitable subsidy to other customer classes. An R/C ratio of 1.0 is deemed fair under the Public Utilities Act.