Topic:"Rate Base" in M12696

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 The document contains a request from the Consumer Advocate to NSPML regarding the distribution of a retained holdback and the recovery of an additional $1.1 million in 'updated WACC consideration.' The request also inquires about the delay in applying for a review of the holdback mechanism and its impact on intergenerational equity.

3 b) Similar to part (a) above, the disputed RES penalty is not, in NSPML's opinion, relevant 4 to the assessment of whether the two conditions for termination of the holdback have been 5 satisfied.

AI summary NSPML argues that the disputed RES penalty is not relevant to determining whether the conditions for termination of the holdback have been met.

NSPML Responses to Industrial Group Information Requests 1 Request IR-05: 13 preceding months did not meet the 90% Base Block energy threshold. 14 (a) Does NSPML contend the 12 months immediately following the claimed 15 Compliance Period...

AI summary NSPML is responding to information requests regarding compliance with energy thresholds and the interpretation of operational data, including the holdback mechanism and deferred energy balance. The questions focus on whether specific time periods meet termination conditions and how recent data should be interpreted.

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 Responses to NSEB Information Requests 1 Request IR-01: 17 18 [38] NSPML's Compliance Filing calculations of the released holdback funds included WACC on balances owing. The Industrial Group opposed this aspect 19 of the calculations...

AI summary NSPML included WACC in the calculation of released holdback funds, which the Industrial Group opposed. The Board agreed that WACC should be applied to funds owing or receivable, recognizing the reciprocal nature of financing costs. NSPML also emphasized balancing obligations to provide the most benefit to Nova Scotians, particularly in maintaining the Maritime Link.

NSPML Application to Review the Holdback Mechanism (NSEB M12696) NSPML Responses to NSEB Information Requests 1 Request IR-03: 28 in turn share with the appropriate parties, including the NSIESO. 1 iii) The annual planned maintenance outag...

AI summary NSPML responded to NSEB information requests regarding the Holdback Mechanism application. They provided detailed information about planned maintenance outages and corrected a minor discrepancy in the WACC value used in Appendix B of the application, noting that no numerical adjustments are required.

NSPML Responses to Small Business Advocate Information Requests 1 Request IR-01: 15 b) In order to provide assurance that the Maritime Link is operating reliably, should the 16 timeframe for ending the Holdback not coincide or follow a yea...

AI summary NSPML responds to questions about the Maritime Link's reliability, the Holdback mechanism, and WACC. It states the Holdback should end in May 2024 and explains that unplanned outages are expected for electricity generation and transmission assets.

Q: Why might the Board wish to consider a different approach? - A: The Board may wish to consider whether NSPML recovering full WACC on deferred balances reflects risk-appropriate compensation. Where a utility's regulatory receivable is es...

AI summary The Board may consider using a debt-only carrying charge instead of WACC for NSPML's deferred balances, as the regulatory receivable is a risk-free asset. This approach is common in North American jurisdictions and aligns with recent financing arrangements involving Nova Scotia Power. The 21-month delay in recovery is seen as unusual, and the Board has discretion to apply this alternative method.

24 Q50. WHAT IS YOUR RECOMMENDATION TO THE BOARD? 25 A50. In my opinion, NSPML has satisfied the requirements established by the Board for 26 termination of the Holdback Mechanism.

AI summary The respondent recommends that the Board terminate the Holdback Mechanism, stating that NSPML has met the requirements established by the Board for such termination.

1 The reduction in undelivered volumes threshold is undisputed. The outage events 2 at issue were either consistent with good utility practice or resulted from exceptional 3 circumstances. Most importantly, the purpose of the Holdback has...

AI summary The document discusses the reduction in undelivered volumes threshold and the termination of the Holdback Mechanism, noting that outage events were consistent with good utility practice or due to exceptional circumstances, and that the purpose of the Holdback has been achieved.

- 2 holdback. - 3 The Application's Appendix D introduces a capitalised, defined term "Good Utility - 4 Practice," sourced from Concentric's interpretation of the Joint Operations Agreement - 5 (JOA). In Section 1.0, Introduction, lines 7-...

AI summary The document discusses the continuation of a holdback mechanism by the Board until specific conditions are met, including the delivery of 90% of the NS Block and a net outstanding balance of undelivered energy below 10% of the annual contracted amount, with flexibility for outages and exceptional circumstances.

- iii. If the LIL had been able to operate at 900 MW as designed, would the timing and/or duration of this outage been different? Please explain. - iv. Please provide all materials NSPML received from NLH regarding this outage, work done d...

AI summary The text includes a series of questions regarding an outage related to the LIL (likely a power line or facility) and its potential impact on operation, costs, and diligence conducted by NSPML. The questions focus on whether the outage could have been avoided, the materials received, independent assessments, and cost implications for ratepayers.

30 volumes affected. 1 2025 M12696 8 deliveries and the potential for extended outages (e.g. 6-week bipole outage scenarios). 9 (a) Is Bates White able to quantify the expected frequency of such events? If 10 so, please provide any analysi...

AI summary The proceeding addresses the potential frequency of extended outages, such as a 6-week bipole outage, and the financial impact on ratepayers if such events occur after the holdback mechanism is terminated. Bates White is asked to quantify the frequency of these events and analyze their financial implications.

1 this aspect of the calculations because the payment of WACC was not 2 explicit in the Board's prior holdback decisions. 3 4 [39] Where funds are owed but not yet paid, either between utilities, or 5 between a utility and its customers, t...

AI summary The document discusses the recovery of financing costs (WACC) for holdback funds owed to NSPML, emphasizing that the Board historically allowed for WACC recovery when funds were owed to customers. NSPML agrees with this approach, noting that the timing of the holdback filing did not prejudice the regulatory process.

d to pay for replacement cost energy would be paid over to NSPML. This holdback mechanism will continue in each and every month during 2022 and then will be reviewed by the Board in January of 2023. [32] The fact that today's customers are...

AI summary The document discusses the holdback mechanism implemented by Nova Scotia Power Maritime Link (NSPML) to address intergenerational equity concerns related to the Maritime Link project. The holdback is intended to ensure that current customers contribute to the replacement cost of energy, with the mechanism being reviewed by the Board in 2023. The Board believes this approach will not jeopardize NSPML's ability to service its federal loan-guaranteed debt.

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.

NO INTEREST ON POST-COMPLIANCE PERIOD HOLDBACK AMOUNTS In the alternative, should the Board find that the evidence supports termination of the Holdback effective May 1, 2024, the Industrial Group submits that NSPML should not be entitled t...

AI summary The Industrial Group argues that NSPML should not recover interest on post-compliance holdback funds due to its delayed application. NSPML delayed filing its application for over 20 months, leading to over $15.3 million in withheld funds and over $1 million in accumulated interest. The Industrial Group claims this delay is unreasonable and should not be compensated by ratepayers.

CONCLUSION The Industrial Group respectfully requests that the Board: - 1. Reject NSPML's request to terminate the Holdback retroactively to May 2024 on the basis that: - (a) NSPML has not demonstrated full compliance with the Board's hold...

AI summary The Industrial Group requests the Board to reject NSPML's retroactive termination of the Holdback due to non-compliance with conditions and lack of justification for relief. Alternatively, if termination is granted, they argue that NSPML should not receive WACC on post-Compliance Period holdback amounts due to delays in the application.