N-1NSPI Cost Allocation Proposal - 2016-2018 DSM Plan
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1 3.0 NS POWER'S POSITION 2 3 The current 25/75 per cent split between system cost and participant cost was agreed to 4 by stakeholders to the 2009 Settlement Agreement. It appropriately recognizes that rate 5 class benefits from DSM progr...
AI summary NS Power argues the 25/75 cost split between system and participant costs for DSM programs aligns with cost-of-service principles, as participating classes benefit most. They propose maintaining this split but suggest exceptions for Enabling Strategies when benefits exceed $100,000 or are tied to historical averages, reducing tracking requirements.
5 4.1 DSM net contract price 2016-2018 6 In its Decision6 7 to approve the 2016-18 DSM Plan, the Board stated as follows: 8 9 The Board approves a DSM Plan for 2016-2018 in the aggregate amount 10 of $102,150,000. Approved spending is $33,...
AI summary The Board approved a DSM Plan for 2016-2018 with a total spending of $102,150,000, allocating $33,210,000 in 2016, $34,020,000 in 2017, and $34,920,000 in 2018. The net contract price for this period is capped at $93,631,970, as outlined in Schedule B of the Supply Agreement approved in October 2015.
DATE FILED: October 30, 2015 Page 8 of 12 6 2016-2018 DSM Plan, UARB Decision 2015 NSUARB 204, M06733, August 12, 2015, page 1. 7 2016-2018 DSM Plan, UARB Order 2015 NSUARB 204, M06733, October 7, 2015. 8 The 2017 payments owing by NS Powe...
AI summary The text discusses the financial adjustments related to the 2016-2018 DSM Plan, referencing UARB decisions and orders, and outlines how payments to E1 by NS Power will be adjusted based on under-spending and surplus funds from previous years.
DATE FILED: October 30, 2015 Page 11 of 12 1 4.5 Rate Smoothing Adjustment _ _ _ _ _ COLUMN Α В С D E F Table 1 Table 2 FORMULA Column H Column K A + C System Benefit C total expenditu classes using CO re allocated to (75% of the tot direc...
AI summary The document presents a Rate Smoothing Adjustment table with various rate classes and their associated expenditures and relative shares. It shows how system benefit costs are allocated across different customer classes, with residential and general demand classes having the highest shares.
N-4NSPI (Consumer Advocate) Responses to IR-1 to IR-14 - Redacted
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NON-CONFIDENTIAL - 1 Given there is significant uncertainty around apportionment of the actual costs between rate - 2 classes, the Company has proposed a simplified methodology based on historical averages. If - 3 the customer classes can...
AI summary The company proposes a simplified cost allocation methodology based on historical averages due to uncertainty in apportioning costs between rate classes. It seeks consensus with E1 and its consultant for alternative methods, with NS Power aligning recovery to any consensus approach. The proceeding references matter number NSUARB M07151.
CONFIDENTIAL (Attachment Only) 1 Request IR-4: 2 3 Please provide a calculation that shows the allocation of Enabling Strategies expenditures 4 by rate class using the program benefits as a method for calculation enabling strategies as 5 r...
AI summary A request (IR-4) asks for a calculation method to allocate Enabling Strategies expenditures by rate class using program benefits, as recommended by Elenchus in a May 7 Memorandum. The response directs to a partially confidential attachment for details.
REDACTED DSM Cost Allocation and Recovery CA IR-4 Attachment 1 Page 1 of 12 COLUMN Α В С D E F G Н Program Cost Recovery by Bo enefits System Benefits Combined Class and 25% $8,302,500 Participant Benefits 75% $24,907,500 Total 1 100% $33,...
AI summary The document outlines the allocation and recovery of DSM (Demand Side Management) program costs, with 25% allocated to system benefits and 75% to participant benefits. It details how costs are distributed across generation, transmission, and energy-related factors, along with the financial breakdown by rate class.
NON-CONFIDENTIAL 1 Request IR-6: 2 3 On Page 3 of the Elenchus memo, the issue of double charging of expenditures assigned to a 4 rate class is raised by Elenchus in the following paragraph. 5 6 7 8 9 10 11 12 13 14 15 16 17 In principle,...
AI summary The document discusses concerns about double charging of expenditures assigned to a rate class, raised by Elenchus. NS Power responds that it does not believe double charging is a significant concern under its proposed methodology, as EfficiencyOne ensures only directly assignable costs are assigned through the regulatory process.
N-6NSPI (Industrial Group) Responses to IR-1 to IR-15 - Redacted
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MONTHLY SYSTEM COINCIDENT PEAKS: REQUIREMENTS, SALES, AND LOSSES BY RATE CLASS IN MWh PER HOUR 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Annual Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Peak 3CP Small General 6.5 6....
AI summary The document presents monthly system coincident peak data for 2016, detailing energy requirements, sales, and losses by rate class (e.g., Small General, Large Industrial) in MWh per hour. Totals show varying peak demand across months, with annual figures highlighting seasonal trends and differences between rate classes.
CONFIDENTIAL (Attachment Only) 1 (3) The recovery by Nova Scotia Power Incorporated from its customers 2 of the amount of charged to it by the franchise holder, as permitted by 3 subsection (2), must be deferred, and must be recovered by N...
AI summary Nova Scotia Power Inc. (NSPI) must defer and recover costs over an eight-year period starting January 1, 2016, as permitted by subsection (2). The recovery includes charges from the franchise holder, to be recouped through its rate base.
Universal Parameters Effective Interest Rate 7.8% Amortization Period 8 Years Year Min Max 2014 0.500% 1.50% 2015 0.00% 2.00% 2016 0.00% 2.00% Legend: Manual Input Dropdown Input Output Cell Documentation (click the buttons to view): Assum...
AI summary The document presents universal parameters including an effective interest rate of 7.8% and an 8-year amortization period. It also includes a table with minimum and maximum values for different years. The document is part of a redacted attachment related to DSM cost allocation and recovery.
AI summary The text provided is not available for analysis. The context references an amortization schedule for unmetered services in a Nova Scotia regulatory proceeding, involving entities like NSPI and NSUARB, with acronyms related to utility regulation and rate applications.
DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Industrial Group Information Requests 1 Request IR-14: 2 3 (a) With respect to the "no allocation" option, discussed at page 6, please elaborate 4 upon the "potential inequ...
AI summary The document addresses two information requests regarding DSM cost allocation and recovery. It discusses potential inequities under the 'no allocation' option and confirms that NSPI is suggesting no allocation until the next GRA. It also clarifies that the COS apportionment approach includes all components of the DSM allocation methodology.
N-8NSPI (Multeese) Responses to IR-1 to IR-15 - Redacted
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DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Multeese Information Requests 1 Request IR-2: 4 regarding DSM cost recovery for the 2017 through 2019 period until the earlier of NS 5 Power filing a General Rate Applicati...
AI summary NSPI is responding to information requests regarding DSM cost recovery for 2017-2019, noting uncertainty in forecasting revenue and costs beyond 2016. The UARB may defer recovery of DSM costs, and NSPI has not determined if it will apply for deferred recovery of 2017 and 2018 costs.
CONFIDENTIAL (Attachment Only) 1 Request IR-14: 2 3 In Appendix A, referencing the column labelled "2015 DSM Plan Amortized over 8 years", 4 5 (a) Please confirm that these costs are based on the full amount of approved 6 expenditures capp...
AI summary Request IR-14 seeks clarification on NSPI's 2015 DSM Plan amortization, calculation of 2016 costs, carrying cost adjustments, and variance significance between allocation methods. NSPI confirms costs are capped at $35M and refers to attachments for detailed calculations and variances. The proceeding involves DSM cost allocation and recovery under NSUARB M07151.
2015 DCRR Annual Amount Amortization by Rate Class (2016 ‐ 2024) Rate Class 2015 DCRR Amount Accumulated Interest 2016 2017 2018 2019 2020 2021 2022 2023 Total 34 Oct‐17 $18,444,035 $0 $46,110 ($270,002) $0 $18,220,143 $1,466,584 $46,110 $...
AI summary The table presents the 2015 DCRR Annual Amount Amortization by Rate Class from 2016 to 2024, showing the distribution of amounts across different rate classes, accumulated interest, and annual amortization figures over time.
65462Board Decision Letter - DSM Cost Allocation and Recovery
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M07151 - Nova Scotia Power Inc. - DSM Cost Allocation and Recovery (E-R-15) \ 1 The Board's letter of December 3, 2015 directed NSPI to provide details regarding specific cost recovery and accounting treatment of the following DSM componen...
AI summary The Nova Scotia Utility and Review Board directed NSPI to detail DSM cost recovery and accounting for 2014-2018 programs, RSA, DCRR, and balance adjustments. The EPIA Act extended DSM contracts to 2019, limited expenditures to $34.05M, and imposed rate-stability restrictions. NSPI announced it would not file a General Rate Application for three years, seeking only fuel cost adjustments below inflation through 2019.
NSPI's Filing Dated December 18, 2015 In its December 18, 2015 letter, NSPI stated: - 1) One-eighth of the 2015 program cost will be expensed in its 2016 operating costs. - 2) The 2016 DSM program costs will be absorbed in existing rates a...
AI summary NSPI outlined cost management strategies for DSM programs, proposing to expense 2015 and 2016 program costs in operating expenses, deferring 2017-2019 cost recovery decisions, and suggesting three options for addressing the 2014 RSA. It also proposed methodologies for true-ups and allocation of DSM funds, including alignment with COS or E1 program budgets.
Participant Submissions Submissions were received from the Consumer Advocate ("CA"), the Small Business Advocate ("SBA"), the Industrial Group, and E1. 1 Document: 245123 1 None of the parties disagreed with NSPI's proposal to absorb the 2...
AI summary The Consumer Advocate (CA) and Small Business Advocate (SBA) oppose NSPI's proposal to recover 2017-2019 DSM costs via additional rates, arguing existing rates suffice. The Industrial Group insists NSPI must file rate changes by April 30, 2016, and opposes extending the DSM cost recovery deadline. E1 supports NSPI's Cost of Service approach for DSM cost allocation.
NSPI's Reply Submission dated Feb 23, 2016 In response to participant submissions, NSPI noted the following: - a) Program costs should be allocated in alignment with E1 's budgets, then compared against actual DSM expenditures on an annual...
AI summary NSPI outlines responses to regulatory submissions, proposing program cost allocation aligned with E1 budgets, rate smoothing adjustments via rate changes, Enabling Strategies methodology, treating 2016 DSM costs as operating expenses, and deferring 2017-2018 DSM cost decisions until a GRA filing or June 30, 2016.
Board Decision The Board understands that 2013 and 2014 Balance Adjustments have been rolled into the 2015 and 2016 DSM programs, respectively, and accepts that approach. Regarding treatment of the 2015 DSM program costs, which are being a...
AI summary The Board approves NSPI's proposal to recover 2015 DSM program costs over 8 years, with one-eighth recovered as 2016 operating costs and the rest via financing. It rejects deferring 2017-2019 DSM cost decisions. NSPI failed to file required details by November 30, 2015, despite prior directives. The Board's Order M06733 mandated this filing.
63955Letter to the Board re 2016 DSM
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-relationship between cost allocation and cost recovery, the Board will defer setting a timetable for stakeholder participation on both of those matters pending receipt of NSPl's November 30th filing. On November 9, 2015, the Province of N...
AI summary The Province of Nova Scotia's 2015 electricity plan emphasizes rate stability through a 2017-2019 Rate Stability Period, including fuel cost forecasting, limited rate increases, and new legislation. The Board defers stakeholder participation on cost allocation and recovery until NSPI's November 30 filing.
efficiency charges will be included. 1 The Plan provides that new legislation will be introduced in Fall, 2015 to enable rate stability, innovation and competitively priced community solar. Following the changes to electricity policy, NS P...
AI summary Nova Scotia Power Inc. (NSPI) plans to absorb 2016 Demand Side Management (DSM) costs without rate adjustments, citing new legislation for rate stability and community solar. NSPI seeks to defer DSM cost recovery discussions for 2017-2019 and requests a filing extension. DSM expenses are unique due to caps, refunds, and multi-year benefits.
evenue requirement. For the DSM proposed accounting treatment and cost recovery recommendation for the 2017-2019 period, NS Power requests the Board extend the date for filing its proposal as follows: - (1) If NS Power determines that an a...
AI summary NS Power requests the Board's approval to incorporate 2016 DSM cost recovery in its financials and defer 2017-2018 DSM cost recovery. It proposes filing deadlines contingent on a non-fuel-related rate increase application and allocates variances based on cost of service. The submission includes a footnote referencing 2014 variance allocation.
64256Submission from NSPI re DSM Cost Recovery
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December 18, 2015 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: Nova Scotia Power Inc. – DSM Cost Recovery – M07151/E-R...
AI summary Nova Scotia Power Inc. (NS Power) submitted its 2016 DSM cost recovery proposal to the Utility and Review Board (UARB), citing legislative changes from the provincial electricity plan. The UARB requested additional details on specific DSM components, including rate-smoothing adjustments and balance adjustments, and noted no consensus among parties. NS Power argues the approved DSM quantum of $102.2 million should be fully recovered as a flow-through expense under the Public Utilities Act.
2015 DSM Amounts In 2015, legislative changes restructured the way that DSM is delivered to NS Power's customers as well as the period costs are recovered. DSM program costs were determined by legislation and recovery of the associated cos...
AI summary Legislative changes in 2015 restructured DSM delivery for NSP, deferring costs over eight years. DSM was set at $35M plus 2013 balance, with NSP expensing 2016 amortization.
2016-2018 DSM Program Costs On November 10, 2015, following the changes to Nova Scotia's electricity policy, the Company announced that it will not apply for a General Rate Application for 2016. This means that for the 2016 period NS Power...
AI summary NS Power announced in 2015 it would absorb 2015-2016 DSM program costs into existing rates without a General Rate Application. Uncertainty remains for post-2016 costs, with a legislative deadline of April 30, 2016, to determine rate increases. NS Power deferred a decision until a rate application or June 30, 2016, citing unresolved cost absorption plans.
2014 Rate Smoothing Adjustment In its 2014 DSM Cost Recovery Rider Application, Efficiency One's (E1) predecessor, Efficiency Nova Scotia Corporation (ENSC), realized that the Small General and Large General classes would experience revenu...
AI summary In 2014, Efficiency Nova Scotia Corporation (ENSC) applied for a DSM Cost Recovery Rider, leading to revenue increases for certain classes. The UARB approved a rate smoothing adjustment allowing over-recovered classes to loan funds to under-recovered ones, reducing the DCR Rider impact. Under-recovered classes agreed to repay with interest (2015–2017). The 2015 Settlement Agreement deferred repayment details to the 2016–2018 DSM plan. NS Power proposed options to resolve inter-class imbalances, including reallocation, true-up during rate applications, or fuel cost filings.
DCRR Amounts currently in rates This item is addressed above in comments re: 2016 – 2018 DSM Program Costs
AI summary The document references a prior discussion on 2016–2018 DSM Program Costs, indicating that the topic of DCRR amounts in rates has been previously addressed in the regulatory proceeding. No new claims or data are presented in this specific text fragment.
True Up Proposals Although true ups do not have a direct impact on NS Power, the Company supports the manner in which true ups were managed when DSM was recovered through a rate rider. Essentially, a customer class rate rider amount was ba...
AI summary NSP supports managing true ups through rate riders, proposing contract periods instead of annual rebalancing to allow cost-effective DSM programs. However, 2015-2016 lacks specific class rate riders, creating no baseline for budget allocation. Three alternatives—cost of service allocation, actual DSM alignment, and no allocation—are presented. NSP opposes true up mechanisms hindering E1's energy savings goals.
Traditional DSM Allocation This proposal would allocate DSM funds in accordance with E1's DSM program budget. Once the DSM program has been delivered, the actual costs would be compared to assess any imbalance. Although this aligns with ho...
AI summary The proposal allocates DSM funds based on E1's program budget, comparing actual costs post-delivery to identify imbalances. While aligning with the rate rider formula, it differs as funds aren't collected based on the E1 budget. The initial allocation is deemed flawed but establishes a baseline for E1's program obligations if budget variances occur.
64370Multeese Consulting-BCC (NSPI) IR-1 to IR-15
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Request IR-3: - 18 On page 3 of the December 18 submission, it is stated with respect to 2015 DSM costs that the - 19 Company will expense the 2016 amortization amount in its 2016 operating costs. Also on page - 20 3, it is stated with res...
AI summary The request seeks confirmation that NSPI's 2016 amortization and DSM program costs will be fully recovered from customers by year-end, based on their submission stating 2016 costs will be expensed and absorbed into existing rates.
Request IR-4: - 26 On page 3 of the December 18 submission, NSPI proposes to defer a determination regarding - 27 DSM cost recovery for the 2017 through 2019 period until the earlier of NS Power filing a General - 28 Rate Application or Ju...
AI summary NSPI proposes deferring DSM cost recovery for 2017-2019 until a GRA filing or June 30, 2016, despite legislation requiring a GRA by April 30, 2016. The request asks if NSPI's non-filing would imply absorbing 2017-2018 costs like 2016 and full recovery by 2018. Additional requests address rate smoothing adjustments, DORR amounts, and 2013-2014 balance adjustments.
Request IR-8: - 2 Regarding True-Ups, NSPI proposes truing up at the end of the contract period and states that - 3 "At the end of such period, imbalances could either be worked into the next DSM contract period - 4 or rebalanced separatel...
AI summary NSPI proposes handling DSM contract imbalances via true-ups at contract end, either carrying imbalances into the next contract period or rebalancing during rate applications. Questions seek clarification on implementation, rebalancing processes, and whether customer rates would be adjusted.
Request IR-9: - 11 12 The last paragraph on page 4 of the December 18 submission notes an issue with respect to 2015 and 2016. On page 5, three potential alternatives are introduced with the sentence "In order - 13 to further examine this...
AI summary The December 18 submission discusses issues with 2015 and 2016, presenting three alternatives. Request IR-9 seeks clarification on whether these alternatives apply only to those years.
Request IR-10: - 17 Regarding the first alternative (cost of service) on page 5 of the December 18 submission, - a) Please confirm that this option would identify the difference between budget and actual expenditures and distribute that di...
AI summary Request IR-10 seeks clarification on the 'cost of service' alternative in a December 18 submission. It asks whether the approach in footnote 4 would distribute budget-actual expenditure differences across classes and how this would impact customer rates.
Request IR-11: 26 27 28 considering whether any initial budget should be set or imbalance calculated during this period". In the subsequent paragraph, it is noted that "there is merit in considering that, for 2016 forward until the next GR...
AI summary Request IR-11 seeks clarification on the timeframe for initial budget and imbalance calculations, noting consideration of not tracking DSM variances by class from 2016 until the next GRA. The No Allocation alternative's timeline (2015 through next GRA) is questioned, with requests for explanation.
Request IR-14: - 19 In Appendix A, referencing the column labelled "2015 DSM Plan Amortized over 8 years", - a) Please confirm that these costs are based on the full amount of approved expenditures capped at $35 million, unadjusted for act...
AI summary Request IR-14 asks NSPI to clarify the calculation and assumptions behind the 2015 DSM Plan amortization, including how the 2016 portion was calculated, the impact of a 3% carrying cost, and whether the variances between traditional and cost of service allocation methods are considered insignificant.
64371Industrial Group (NSPI) IR-1 to IR-15
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Request IR-2: (a) Please outline any differences in what was proposed by NSPI in its October 30, 2015, Cost Allocation Proposal, its November 30, 2015, letter to the Board and its December 18, 2015, letter to the Board. (b) If there are di...
AI summary The document requests clarification on differences in NSPI's cost allocation proposals from October 2015 to December 2015, including rationales for changes. It references NSPI's support for a 25/75 system/participant cost split for DSM programs and a 2016-specific cost-of-service allocation approach. Discrepancies between these methods are highlighted, along with requests for data on demand and energy figures.
Request IR-11: - At p.4, NSPI states that "imbalances could either be worked into the next DSM contract period - or rebalanced separately during rate applications." - (a) Please explain what is meant by "worked into". Is this a financial -...
AI summary NSPI states imbalances can be 'worked into' the next DSM contract period or rebalanced during rate applications. The regulator seeks clarification on whether 'worked into' refers to financial reconciliation or modifying DSM programs to adjust efficiency measure delivery across customer classes.
Request IR-13: - …[W]ould allocate DSM funds among customer classes in the same manner as NS Power allocates earnings above its approved rate of return – allocate based on NS power's cost of service. Any true ups would be based on this all...
AI summary The text discusses allocating DSM funds using NS Power's cost-of-service model, mirroring how earnings above approved rates are distributed. It references a 75% class cost/25% system cost allocation, citing customer representatives' prior agreement as a 'reasonable proxy.' Questions probe the methodology's application, definition of terms, and whether a 25/75-based allocator would be constructed.
Request IR-14: - (a) With respect to the "no allocation" option, discussed at page 6, please elaborate upon the "potential inequities" and how these could be monitored and mitigated/addressed. - (b) Please confirm that NSPI is only suggest...
AI summary The request seeks clarification on the 'no allocation' option's potential inequities and mitigation strategies, and confirms NSPI's proposal to defer allocation until the next GRA.
64376Consumer Advocate (NSPI) IR-1 to IR-14
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Request IR-3: Please explain exactly what historical data was used and how it was used in dollar terms to allocate Enabling Strategies expenditures by rate class in NSPI's proposed allocation of Enabling Strategies expenditures.
AI summary The request seeks clarification on the historical data used by NSPI to allocate Enabling Strategies expenditures by rate class in dollar terms. It specifically asks for an explanation of the methodology and data sources employed in the proposed allocation of these expenditures.
Request IR-4: Please provide a calculation that shows the allocation of Enabling Strategies expenditures by rate class using the program benefits as a method for calculation enabling strategies as recommended by Elenchus in the May 7 Memor...
AI summary The request asks for a calculation allocating Enabling Strategies expenditures by rate class using program benefits as a method, as recommended by Elenchus in their May 7 Memorandum.
Request IR-6: On Page 3 of the Elenchus memo, the issue of double charging of expenditures assigned to a rate class is raised by Elenchus in the following paragraph. In principle, the entire amount of Enabling Strategies is intended to sup...
AI summary Elenchus raises a concern about potential double charging of expenditures in rate classes due to the allocation of Enabling Strategies costs. They argue that rate classes with identifiable expenses may be charged twice—once for direct costs and again for general expenses. The text requests NS Power to explain whether they view this as a significant concern.
Memorandum To: Julie-Ann Vincent, Efficiency Nova Scotia From: Andrew Frank Date: May 7, 2014 Re: Enabling Strategies Allocation This memo is prepared in response to your requests to review our advice provided in February 2012 on the alloc...
AI summary This memo from Andrew Frank to Efficiency Nova Scotia reviews prior advice on Enabling Strategies cost allocation and updates recommendations based on a year of experience. It addresses invoice allocations to rate classes and revises cost allocation methods for Enabling Strategies.
1 REVIEW OF DIRECT ALLOCATION OF ENABLING STRATEGIES INVOICES We have reviewed a sample of invoices provided, being sure to examine some invoices which were assigned to each of the rate classes. The sample turned up many invoices assigned...
AI summary A review of invoices for enabling strategies found many assigned to 'All Rate Classes' with costs like IT development, DSM planning, and marketing. These costs impact multiple rate classes. Invoices assigned to specific rate classes were appropriately allocated in reasonable proportions.
allocation if one is available. If a direct allocation does not exist, or is not practical, then we would consider an appropriate allocator to use as a proxy for the benefit derived by the rate class. In evaluating the methodology for allo...
AI summary The document reviews the allocation of Enabling Strategies (ENS) costs, noting that 71% of expenditures are not directly tied to specific rate classes, contrary to initial expectations. Residential class allocation is distinct, while non-residential allocations face challenges due to program-specific targeting. ENSC's data highlights the need to revise prior allocation recommendations.
64869Submission - Small Business Advocate
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VlAEMAIL February 16, 2016 Ms. Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Dear Ms. Friis: Re: Nova Scotia Power Inc. - DSM Cost Allocation and R...
AI summary Nova Scotia Power Inc. (NSP) submitted DSM cost recovery proposals to the Utility and Review Board, following legislative changes from 'Our Electricity Future' plan. The Board requested additional details on cost allocation, leading to the Nova Scotia Small Business Advocate (SBA) commenting on NSP's methodology, advocating for a revised 75% class cost/25% system cost allocation beyond 2016 and clarifying impacts of proposed methods.
SBA Recommendations The SBA recommends that NSP apportion 2016 DSM costs to the individual rate classes in accordance with El's DSM program budget for 2016 after applying the initial 75% customer class cost and 25% system cost allocation....
AI summary The SBA recommends NSP allocate 2016 DSM costs using the 'Traditional DSM Allocation' method (75% customer class, 25% system cost), aligning with El's 2016 DSM budget of $33.21M and Board decision M067332. It supports a true-up mechanism against El's actual costs but opposes NSP's proposed rate-base-based allocation method.
SBA Observations Why should NSP allocate costs based on El's DSM budget allocation? NSP's Dec 18th Filing discusses two cost allocation methodologies: Cost of Service and Actual DSM Alignment 3 • NSP illustrates the results of allocation m...
AI summary The SBA argues that NSP should allocate costs based on El's DSM budget rather than the Cost of Service methodology, as the latter could lead to over/under recoveries exceeding $1 million for certain rate classes. The SBA acknowledges the assumption that El's budget better reflects actual expenditures but contends that the Cost of Service approach introduces discrepancies and undermines rate stability.
All of which is hereby agreed to this 2nd day of December 2014 Nova Scotia Power Incorporated Consumer Advocate Dal 200 Per: DAULD LAND RILLAND Peri Small Business Advocate Industrial Group • Managel . Per; Per: NANCY RUBIN Municipal Elect...
AI summary The document outlines an agreement from December 2, 2014, regarding the determination by the Board in response to an application that revises the treatment of revenues recovered in relation to deferral accounts, or in the event of a material change in law affecting the Company's regulatory framework and cost structure.
5. The FAM incentive will continue to be suspended in 2015. ( ( ( 6. Excepting with respect to the S. 21 deferral account amounts in 2015, it is agreed that any ratepayer group shall be entitled to apply to the UARB for a determination of...
AI summary The FAM incentive is suspended in 2015. Ratepayer groups can apply to the UARB for determination on the treatment of fully amortized NS Power deferral accounts, with consultation required from NS Power before filing such applications.
5. The FAM incentive will continue to be suspended in 2015. ( ( 6. Excepting with respect to the S. 21 deferral account amounts in 2015, it is agreed that any ratepayer group shall be entitled to apply to the UARB for a determination of th...
AI summary The FAM incentive is suspended in 2015. Ratepayer groups can apply to the UARB for determination on the treatment of fully amortized NS Power deferral accounts, with consultation required from NS Power before filing such applications.
NON-CONFIDENTIAL 1 Request IR-7: 2 3 Please confirm whether each of the alternatives NSPI presents for consideration on pp. 5-6, 4 as well as the reference on page 7 to "additional variations that could be considered", 5 presume that the t...
AI summary NSP responds to IR-7 by clarifying that its proposed alternatives (Cost of Service Allocation, Actual DSM alignment, No Allocation) do not presume the 75%/25% cost allocation for true-up under the 'No Allocation' method. The Company confirms the allocation applies only to the first two alternatives.
64870Submission - Industrial Group
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2015 AND 2016 DSM AMOUNTS NSPI has indicated that it will be able to absorb the 1/8 share of the 2015 DSM spending and the 2016 DSM budget in its general rates and so, asks for approval to expense these in its 2016 operating costs. 2015 DS...
AI summary NSPI proposes to expense 2015 and 2016 DSM amounts in its 2016 operating costs, having already deferred and amortized the 2015 spending over eight years. EfficiencyOne has suggested a potential agreement to reduce financing costs, which could save over $9 million over eight years. The Industrial Group supports reducing the carrying costs of the deferred DSM expense and recommends discussions between NSPI and E1 to achieve this.
2017-2019 DSM EXPENSE RECOVERY NSPI has requested that any determination on cost recoveryof the 2017-2019 DSM expenses be deferred to the general rate application ("GRA") filing or June 30, 2016 , if there is no GRA application. It has off...
AI summary NSPI requests deferral of 2017-2019 DSM expense recovery to the GRA filing or June 30, 2016, citing forecasting uncertainties and legislative requirements. DSM costs are integrated into general rates, with 2019 capped at $34.05M by legislation. NSPI argues uncertainty in revenue forecasts precludes April 30, 2016, determination, while the Board retains discretion to defer DSM costs.
2014 RATE SMOOTHING ADJUSTMENT Appendix B to NSPI's October 30, 2015 letter sets out the outstanding amounts owing and to be repaid as of the end of 2015. There were two "borrowing" classes (Small General and Large General) and four "lendi...
AI summary The 2014 Rate Smoothing Adjustment involves outstanding repayment amounts between borrowing and lending classes as of 2015. NSPI proposes three options for reallocation or true-up adjustments, while the Industrial Group opposes converting funds to efficiency services and advocates for three-year recovery with interest. E1's program challenges and NSPI's lack of discussion with E1 are noted.
3.0 NS POWER'S POSITION The current 25/75 per cent split between system cost and participant cost was agreed to by stakeholders to the 2009 Settlement Agreement. It appropriately recognizes that rate class benefits from DSM programs are hi...
AI summary NS Power defends the 25/75 split of DSM costs between system and participant classes, aligning with cost-of-service principles and the 2009 Settlement Agreement. It argues that participating classes should bear 75% of DSM costs due to direct benefits, while non-participating classes cover external benefits. DSM allocation is integrated into the COS framework, with true-ups handled via GRA filings.
True-Up As regards the true-up, NSPI outlines three possible approaches: - 1) Traditional method (also called "actual DSM alignment"); - 2) Cost of Service; and - 3) No Allocation. NSPI stated that it supports the manner in which true-ups...
AI summary NSPI proposes three true-up approaches: traditional method, cost of service, and no allocation. It advocates aligning true-ups with three-year contract periods (e.g., 2016-2018) instead of annual rebalancing. The Industrial Group agrees, citing alignment with E1's targets. The traditional method allocates DSM variances across classes, while the cost-of-service approach distributes costs based on rate base proportions. NSPI notes potential fairness concerns with allocating DSM budgets to commercial/industrial classes.
ENABLING STRATEGIES As outlined in its October 30, 2015, letter, NSPI proposes to maintain the current cost allocation methodology but proposes a change to the methodology for Enabling Strategies that would limit the need for tracking by r...
AI summary NSPI proposes maintaining the current cost allocation methodology for Enabling Strategies but suggests limiting tracking by rate class. Exceptions include full allocation to rate classes for strategies exceeding $100,000 in cost or those attributable to historical averages pre-2014.
CONCLUSION To summarize, the Industrial Group recommends: - 1. the Board acknowledge NSPI may properly expense the first year of 2015 DSM costs and all of 2016 DSM costs as operating expenses in 2016; - 2. the Board direct NSPI and E1 to u...
AI summary The Industrial Group recommends that the Board acknowledge NSPI's 2015-2016 DSM cost expensing, direct cost reduction discussions, adjust deferred cost amortization, align DSM cost inclusion with GRA timelines, use BCF for RSA true-ups, retain the current DSM allocation methodology, and accept NSPI's Enabling Strategies proposal. These recommendations address rate design, deferred costs, and DSM implementation.
64871Submission - Consumer Advocate
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1. Recovery of 2017-18 DSM Costs At page 2 of its submission of December 18, 2015, NSPI states: On November 10, 2015, following the changes to Nova Scotia's electricity policy, the Company announced that it will not apply for a General Rat...
AI summary NSPI claims it can absorb 2015-2016 DSM costs into existing rates but has not determined if this applies beyond 2016. The Consumer Advocate disputes NSPI's assertion that 2016-2018 DSM costs are not already in rates. The Board's M07151 decision emphasized that all of NSPI's costs, not just DSM costs, determine rate increases.
The Board further noted: As noted earlier, in 2014 approximately $53 million was in rates in the DSM rider. By Order of the Board, at the request of the various customer classes, those funds which were not needed for DSM in 2015 because of...
AI summary The Board noted that $53 million from the DSM rider in 2014 was used for excess fuel costs in 2015 but remains in rates as a DSM charge. NSPI proposes to recover 2017-2018 DSM costs if not covered by current rates, while the Consumer Advocate argues the funds are sufficient and opposes additional rate revenue requests.
2. True-up of 2015 and 2016 DSM Expenditures At page 5 of its submission of December 18, 2015, NSPI states: The issue for 2015 and 2016 is that there is no specific class rate rider nor is there a similar allocation for DSM in NS Power's g...
AI summary NSPI argues that without a specific rate rider for DSM in 2015-2016, there is no baseline for allocating budgets to rate classes, making true-up calculations impossible. The Consumer Advocate counters that the 2014 rate rider allocation of $53 million provides a valid starting point for comparing actual DSM expenditures and adjusting budgets accordingly.
3. Allocation of Enabling Strategies Costs At page 6 of its 2016-2018 DSM Plan Cost Allocation Proposal dated October 30, 2015, NSPI proposes the following with respect to cost allocation of Enabling Strategies expenditure: Specifically, t...
AI summary NSPI proposes allocating Enabling Strategies costs using a 25/75 split, with exceptions for rate classes benefiting from high-cost strategies or historical data. The Consumer Advocate opposes this, citing concerns about double-counting and advocating for Elenchus' program-benefit-based allocation. NSPI dismisses double-counting as insignificant but provides no evidence, while Elenchus' 2014 memo highlights risks of overcharging rate classes.
64872Submission - EfficiencyOne
5 passages
Allocation of 2015-2018 Program Costs EfficiencyOne supports the Cost of Service Allocation approach provided by NS Power for the allocation of 2015 to 2018 DSM costs. As indicated below, this approach, in EfficiencyOne's view, would: (a)...
AI summary EfficiencyOne supports NS Power's Cost of Service Allocation approach for 2015-2018 DSM costs, citing alignment with legislation, societal benefits, short-term cost recovery, and rate stability. NS Power, under the Public Utilities Act, provides DSM activities to reduce energy demand. The methodology reflects broader recognition of DSM's non-participant benefits and aligns with the 'beneficiary pays' principle.
Allocation of Enabling Strategies As a result of an Elenchus recommendation made in 2012, EfficiencyOne directly allocates the participant benefit portion of Enabling Strategies investments.[8](#page-2-0) In its October 30th filing to the...
AI summary The document discusses the allocation of Enabling Strategies investments, with NS Power proposing a 75/25 split for DSM programs. Elenchus recommends allocating based on rate class share of all program investment, citing risks of double-counting. EfficiencyOne supports Elenchus's 2014 methodology, noting that NS Power's approach may exacerbate allocation issues. A reexamination of Elenchus's 2012 recommendation is referenced, along with cross-references to regulatory filings.
Conclusion In summary, EfficiencyOne offers the following recommendations: - adopt the Cost of Service Allocation approach, provided by NS Power, for the allocation of DSM costs; - adopt NS Power's proposal to true up after each three-year...
AI summary EfficiencyOne recommends adopting NS Power's Cost of Service Allocation approach, triennial true-ups, Elenchus' 2014 methodology for Enabling Strategies, and recovering RSA amounts via GRA or Base Cost of Fuel. The text references a regulatory proceeding involving DSM cost allocation and recovery mechanisms.
Memorandum To: Julie-Ann Vincent, Efficiency Nova Scotia From: Andrew Frank Date: May 7, 2014 Re: Enabling Strategies Allocation This memo is prepared in response to your requests to review our advice provided in February 2012 on the alloc...
AI summary The memo from Andrew Frank to Julie-Ann Vincent discusses reviewing cost allocations for Enabling Strategies and invoice allocations to rate classes, with updates based on a year of experience.
2 REVIEW OF ENABLING STRATEGIES COST ALLOCATION In response to your request to review the Enabling Strategies allocation methodology, we have reviewed the recommendation provided by Elenchus in February 2012. Email: [email protected]; dir...
AI summary Elenchus reaffirms its 2012 recommendation that Enabling Strategies costs should be allocated using the System/Participant Benefit approach, aligning with Nova Scotia's approved methodology. This method allocates 75% of costs based on customer class benefits, with proportional allocation as a fallback. Elenchus finds no evidence to challenge this approach's validity.
64925Reply Submission - NSPI
6 passages
Cost Allocation The IG and the CA appear to support the traditional approach to cost allocation. This approach is most simply described as collection of DSM costs based on the DSM budget with a 25% allocation to system benefits and a 75% s...
AI summary The IG and CA support the 'Traditional Approach' to DSM cost allocation, which splits costs 25% to system benefits and 75% to class participation, with a true-up mechanism. This mimics the defunct DSM Cost Recovery Rider (DCRR) via embedded rates. The approach is detailed in NS Power's submission (M07151).
2016 – 2018 Cost Allocation In accordance with the Consensus Agreement dated June 16, 2015 and approved by the Board in its decision dated August 12, 2015, the parties agreed to refer the issue of cost allocation methodology to the Demand...
AI summary The 2016–2018 cost allocation methodology for DSM in Nova Scotia was referred to the DSM Advisory Group, which failed to reach consensus. NS Power proposed a Traditional Approach, aligning DSM budgets with E1's figures and ensuring customers pay only for achieved energy savings. The Board's 2015 decision and Consensus Agreement guided the process, with NS Power emphasizing alignment with rate class representatives and avoiding impacts on E1's cost-effectiveness.
Rate Smoothing Adjustment In its submission dated December 18, 2015, NS Power proposed three separate options for the rebalancing of the 2014 Rate Smoothing Adjustment (RSA) or Inter‐class Loan. The Company noted that the RSA could be reba...
AI summary NS Power proposed three options to rebalance the 2014 Rate Smoothing Adjustment (RSA) via DSM programming, the next GRA, or the 2017-2019 Fuel Stability Plan under the Electricity Plan Implementation (2015) Act . The Industrial Group (IG) opposed using DSM for rebalancing, advocating instead for three-year rate recovery of the true-up, with interest, via GRA or BCF. No party supported NS Power's alternate proposals, leading NS Power to suggest incorporating the RSA into the Fuel Stability Plan proceeding.
True‐up period The CA, SBA and the IG each expressed support for a true‐up between budget and actual DSM costs. As noted above, NS Power proposes that DSM revenues be trued up against actuals in accordance with how the previous true‐up mec...
AI summary The CA, SBA, and IG support truing up DSM costs annually. NS Power proposes using the DCRR mechanism to align recoveries with actual costs annually, tracking variances for future rate settings. SBA advocates annual true-ups, but NS Power cannot adjust general rates outside GRA processes if DSM is classified as non-fuel, though annual tracking will still occur.
Post 2016 DSM Cost Recovery The CA and the IG have opposed NS Power's proposal to defer its decision on the accounting treatment of post 2016 DSM cost recovery until June 30, 2016. The CA has done so on the basis that current rates contain...
AI summary Nova Scotia Power Inc (NSPI) sought to defer a decision on post-2016 DSM cost recovery until June 30, 2016, but the Consumer Advocate (CA) and Industrial Group (IG) opposed this, arguing current rates already fund DSM costs and NSPI failed to justify the deferral. NSPI countered that existing rates do not explicitly cover DSM expenses and requested additional time for the Utility and Ratepayer Board (UARB) to rule on the matter.
Conclusion NS Power notes that many of the cost allocation issues before the Board in this matter pertain to how DSM costs are divided amongst and collected from the various rate classes. The Company recommends as follows: - The Board conf...
AI summary NS Power outlines DSM cost allocation recommendations, requesting confirmation of 2015/2016 cost recovery, a timeline for 2017-2018 submissions, and adoption of the 'Traditional Approach' methodology. True-ups will be annually adjusted via GRA, with enabling strategies aligned to prior proposals. The Company acknowledges intervenor contributions.
65462Board Decision Letter - DSM Cost Allocation and Recovery
4 passages
M07151 - Nova Scotia Power Inc. - DSM Cost Allocation and Recovery (E-R-15) \ 1 The Board's letter of December 3, 2015 directed NSPI to provide details regarding specific cost recovery and accounting treatment of the following DSM componen...
AI summary The Nova Scotia Utility Board directed NSP to detail DSM cost recovery and accounting for 2015-2018 programs, RSA, DCRR, and balance adjustments. The EPIA extended DSM to 2019, limited expenditures to $34.05M, and imposed rate stability. NSP announced no General Rate Application for three years, focusing on fuel cost adjustments.
NSPI's Filing Dated December 18, 2015 In its December 18, 2015 letter, NSPI stated: - 1) One-eighth of the 2015 program cost will be expensed in its 2016 operating costs. - 2) The 2016 DSM program costs will be absorbed in existing rates a...
AI summary NSPI outlined its approach to DSM program costs, proposing deferral of 2017-2019 cost recovery decisions, three options for addressing the 2014 RSA, and methods for true-up adjustments. It emphasized aligning DSM funding with the 2013/2014 BA and supporting a DSM contract-period-based true-up methodology over annual rebalancing.
Participant Submissions Submissions were received from the Consumer Advocate ("CA"), the Small Business Advocate ("SBA"), the Industrial Group, and E1. 1 Document: 245123 1 None of the parties disagreed with NSPI's proposal to absorb the 2...
AI summary Participants including the Consumer Advocate (CA), Small Business Advocate (SBA), Industrial Group, and E1 submitted views on NSP's proposal to absorb DSM costs. CA opposed additional rate revenue for 2017-2019, SBA supported a 25/75 allocation split, the Industrial Group emphasized rate filing deadlines, and E1 endorsed NSP's Cost of Service approach for DSM cost allocation.
Board Decision The Board understands that 2013 and 2014 Balance Adjustments have been rolled into the 2015 and 2016 DSM programs, respectively, and accepts that approach. Regarding treatment of the 2015 DSM program costs, which are being a...
AI summary The Board approved NSP's proposal to recover 2015 DSM program costs over eight years, with one-eighth recovered in 2016 and the rest via financing. It denied deferring 2017-2019 DSM cost decisions and cited non-compliance with filing deadlines. NSP's incomplete submission on 2017-2019 costs was noted, with a reference to Board Order M06733.