HomeRate DesignM08929Evidence
Topic/Matter Intersection

Topic:"Rate Design" in M08929

Matter: P-884 - Nova Scotia Power Inc. (NSPI) - Integrated Resource Planning (IRP) and M08059--Generation Utilization and Optimization
121 passages 15 documents

Rate Design across all matters →

N-1Demand Response Potential Study for 2021-2045 7 passages
Section 27
Figure 1-1. Summary of Project Scope ..................................................................................................... 16 Figure 2-1. Customer Segments by Sector ............................................................

AI summary The text lists figures from a report analyzing energy efficiency (EE) technical potential, customer segmentation by sector, residential and BNI segments, end-use electricity consumption, and sectoral electricity savings in Nova Scotia. Key themes include EE potential, residential/commercial segmentation, and electricity consumption trends.

Section 45
Eligible Customer DR Option Brief Description End Use Classes Electric Furnace 3 Residential Heat Pump 4 Control of electric loads by a thermostat Direct Load Control (DLC) Small Commercial and/or load control switch. HVAC 5 Small Industri...

AI summary The text outlines various demand response (DR) options available to eligible customers, including Direct Load Control (DLC) and BNI Curtailment, detailing their mechanisms, applicable customer classes, and associated costs or benefits.

Section 149
urther. Mapping between NS Power rate classes to those used in the DR study are provided in Figure 10-3. Figure 10-3. Mapping Between Nova Scotia Power Rate Class and DR Study Customer Class Mapped Customer Class in DR Potential Study Nova...

AI summary The text discusses the mapping of Nova Scotia Power rate classes to customer classes used in a demand response (DR) study, as well as the segmentation of BNI customers into building types based on DnB business classifications. This mapping is illustrated in Figures 10-3 and 10-4.

Section 167
considered for all customer classes to shift facility load during peak demand periods. EV control includes reduction in EV load through charging interruptions during the peak demand period. CPP applies to all customer classes and impact ra...

AI summary The text discusses demand response strategies, including Critical Peak Pricing (CPP) and Automated Demand Response (Auto-DR), which aim to shift load during peak demand periods. It highlights how CPP can be used with or without enabling technology, and how Auto-DR allows for automatic load reduction in response to signals from the utility company.

Section 183
-50% No change -15% Industrial, and Interruptible Source: Navigant analysis For CPP specifically, Navigant assumed that the CPP rate is offered as “default with opt-out” under the high scenario, while both base case and low scenario assume...

AI summary The analysis discusses the assumptions made regarding the Critical Peak Pricing (CPP) rate under different scenarios. In the high scenario, CPP is assumed to be a default with opt-out, leading to lower unit impacts compared to the base and low scenarios, which assume an opt-in approach. This is supported by findings from the Brattle Group's database of pricing programs.

Section 220
Load Forecast 1. Energy forecast Nova Scotia Power forecasts 2. Demand forecast Customer Accounts Forecast Nova Scotia Power forecasts Customer Demographics Nova Scotia customer surveys and other primary and secondary sources Measure-level...

AI summary The document outlines the inputs and assumptions used in energy and demand forecasting by Nova Scotia Power, including fuel shares, equipment shares, inflation rates, discount rates, and retail electricity rates. It also mentions the use of past program evaluations and line loss factors from DSM programs.

Section 282
electric vehicles for peak All Electric vehicles. • Auto-DR demand reduction. enabled Use of BTM batteries for Behind the Meter load shifting and/or (BTM) Battery All BTM batteries. curtailment during peak Storage demand periods. 15 This i...

AI summary The text discusses the integration of electric vehicles and behind-the-meter battery storage as demand response (DR) options, highlighting their potential for demand reduction and load shifting during peak periods. It also outlines the development of programmatic assumptions for dynamic pricing strategies, such as critical peak pricing and peak time rebates.

N-2Hydro Asset Study - REDACTED 7 passages
Section 581
KE/E' ^d/Dd ^hDDZz&KZ^^ dZ d/Z D EdK>/'d/KE^;ZKͿ^dhz;LJ^LJƐƚĞŵͿ   //͘ y hd/s ^hDDZz džĂŵŝŶĂƚŝŽŶƐĂŶĚĚĞƌŝǀĂƚŝŽŶƐŽĨĐŽŶĐĞƉƚƵĂůƉůĂŶƐĂŶĚƌĞůĂƚĞĚĐŽƐƚĞƐƚŝŵĂƚĞƐĨŽƌĚĞŵŽůŝƚŝŽŶƐĂƚϯϭŚLJĚƌŽ ŐĞŶĞƌĂƚŝŽŶƐŝƚĞƐŚĂǀĞďĞĞŶ...

AI summary The document discusses the importance of rate mechanisms, cost recovery, and the implications of fuel cost adjustments on utility operations in Nova Scotia. It outlines the challenges in managing energy efficiency programs, ensuring fair cost allocation, and addressing regulatory considerations in utility planning and operations.

Section 590
Ϯ     REDACTED (CONFIDENTIAL INFORMATION REMOVED) REDACTED Hydro Asset Study Appendix C Page 9 of 143  EKs^Kd/WKt Z/E͘Ͳ,zZKWZKhd/KE ^/d  KDD/^^/KE/E' ^d/Dd ^hDDZz&KZ^^ dZ d/Z D EdK>/'d/KE^;ZKͿ^dhz;LJ...

AI summary The document discusses the evaluation of hydro asset studies, emphasizing the importance of accurate cost recovery mechanisms and the potential impacts of delayed rate adjustments. It highlights concerns related to the alignment of base rates with actual costs and the need for proper financial planning in utility operations.

Section 625
ŶĚƌĞůĂƚĞĚƉĂƌƚƐŵĂLJĨĞƚĐŚĂƐŵƵĐŚĂƐ ƐĂůǀĂŐĞǀĂůƵĞ͘dŚĞƌĞĨŽƌĞ͕ƌŽƚŽƌ͕ƐƚĂƚŽƌ͕ƐŚĂĨƚƐĂŶĚŽƚŚĞƌŵŝƐĐĞůůĂŶĞŽƵƐƉĂƌƚƐŽŶƐƵĐŚĂƵŶŝƚŵĂLJ ŚĂǀĞĂƚŽƚĂůƐĂůǀĂŐĞǀĂůƵĞŽĨĂďŽƵƚ ƚ   ϮϬϬƚŽŶŵŽďŝůĞĐƌĂŶĞŵĂLJďĞŶĞĞĚĞĚƚŽŚĂŶĚůĞĂŵŽĚĞƌĂ...

AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on rate structures and cost recovery, highlighting the need for alignment between base rates and actual costs. It also references the importance of regulatory oversight and stakeholder engagement in addressing these issues.

Section 708
ĨŽƵŶĚĂƚŝŽŶƐƵďƐƚƌƵĐƚƵƌĞƚŽĂĨĞǁĨĞĞƚďĞůŽǁŶĞǁĨŝŶŝƐŚĞĚŐƌĂĚĞ ĞůĞǀĂƚŝŽŶ͘^ƚŽĐŬƉŝůĞĚĞďƌŝƐĂƐǁŚĞƌĞĂƉƉƌŽƉƌŝĂƚĞĨŽƌĚŝƐƉŽƐĂů͘ x ŝƐƉŽƐĂů ŽĨ ĐŽŶƐƚƌƵĐƚŝŽŶ ĂŶĚ ĚĞŵŽůŝƚŝŽŶ ĚĞďƌŝƐ ʹ ƚƌĂŶƐƉŽƌƚ ƐĞůĞĐƚĞĚ ŵĂƚĞƌŝĂů ƚŽ Ă ĚĞƐŝŐŶĂƚĞĚ Ěŝ...

AI summary The text discusses issues related to fuel cost adjustments and their impact on rate structures, including the need for mechanisms that align base rates with actual costs, and the challenges posed by delays in rate adjustments. It also touches on the evaluation of asset studies and the implications of energy efficiency and demand-side management programs.

Section 820
ƐƐƵŵĞĚ ƚŚĂƚ ƚŚĞƌĞ ǁŝůů ďĞ ŶŽ ŽƵƚƐƚĂŶĚŝŶŐ ĂƐďĞƐƚŽƐ ĂďĂƚĞŵĞŶƚ Žƌ ŽƚŚĞƌ ŚĂnjĂƌĚŽƵƐŵĂƚĞƌŝĂůƐŽƌĞŶǀŝƌŽŶŵĞŶƚĂůŝƐƐƵĞƐĂƚƚŚŝƐƐŝƚĞƚŚĂƚǁŽƵůĚĂĚǀĞƌƐĞůLJĂĨĨĞĐƚĚĞŵŽůŝƚŝŽŶ ƉůĂŶŶŝŶŐ͘EŽƚĞƚŚĂƚƚŚĞƌĞŝƐĂŵƉůĞŵĂƚĞƌŝĂůůĂLJĚŽǁŶĂƌĞĂĂǀĂŝů...

AI summary The text discusses the need for improved energy efficiency and conservation measures, including the implementation of a demand-side management plan and the importance of ensuring that rate structures are aligned with actual costs. It also touches on the role of regulatory oversight and the need for proper stakeholder engagement in the process.

Section 918
/E' ^d/Dd ^hDDZz&KZ^^ dZ d/Z D EdK>/'d/KE^;ZKͿ^dhz;LJ^LJƐƚĞŵͿ   x /ŶĨŝůů ĨŽƵŶĚĂƚŝŽŶ ƐƵďƐƚƌƵĐƚƵƌĞ ĞdžĐĂǀĂƚŝŽŶ ǁŝƚŚ ĐŽŵƉĂĐƚĞĚ ĐůĞĂŶ ŐƌĂŶƵůĂƌ ŵĂƚĞƌŝĂů ƚŽ ƚŚĞ ƚĂŝůƌĂĐĞ ĐŽĨĨĞƌĚĂŵ͘dŚĞĐŽĨĨĞƌĚĂŵĐĂŶƌĞŵĂŝŶŽŶĐĞŐƌĂ...

AI summary The text discusses the importance of aligning base rates with actual costs to avoid perverse incentives, the need for accurate forecasting and planning in utility operations, and the implementation of programs to improve energy efficiency and affordability. It also outlines the challenges in managing resources and ensuring regulatory compliance.

Section 1013
^d/Dd ^hDDZz&KZ^^ dZ d/Z D EdK>/'d/KE^;ZKͿ^dhz;LJ^LJƐƚĞŵͿ   ǁŝůů ďĞ ƌĞŵŽǀĞĚ ďLJ ŽƚŚĞƌƐ͘ /ƚ ŝƐ ĂůƐŽ ĂƐƐƵŵĞĚ ƚŚĂƚ ƚŚĞƌĞ ǁŝůů ďĞ ŶŽ ŽƵƚƐƚĂŶĚŝŶŐ ĂƐďĞƐƚŽƐ ĂďĂƚĞŵĞŶƚŽƌŽƚŚĞƌŚĂnjĂƌĚŽƵƐŵĂƚĞƌŝĂůƐŽƌĞŶǀŝƌŽŶŵĞŶƚĂů...

AI summary The document discusses the challenges of implementing a fuel-cost-adjustment mechanism, emphasizing the need for alignment between base rates and actual costs to avoid perverse incentives. It highlights the importance of accurate forecasting and the role of regulatory oversight in ensuring equitable and effective energy management practices.

N-4Draft Terms of Reference 1 passage
Section 67
of AREA’s position. We remain open to discussing such at NSPI’s earliest convenience so that AREA and NSPI can resolve the issues before the IRP’s official start to ensure a more streamlined process. • The Purpose states that this exercise...

AI summary The text outlines AREA's concerns with the Integrated Resource Planning (IRP) process, emphasizing the need to align objectives with least-cost strategies, address stakeholder concerns regarding time constraints, and ensure the process benefits ratepayers rather than NSPI. It highlights issues with the current assumptions and timeline for stakeholder engagement.

N-8NSPI Letter update on IRP process 4 passages
Section 51
s ¬ E3 focuses on all segments of the electricity sector and their interconnectedness with the rest of the energy economy in order to provide holistic analysis and recommendations for our clients E3 has five defined DERs & Rates Clean Ener...

AI summary E3 provides holistic analysis and recommendations across the electricity sector, focusing on distributed energy resources, rate design, and clean energy technologies. They work through five working groups to foster innovation and cross-fertilization of best practices.

Section 61
on until system demand is lower IRP Update Appendix 1 Page 44 of 487 12 Attachment 4 - Pre-IRP Deliverables Page 13 of 34 Retail Rate Structures ¬ Reforms to existing retail rate structures will be necessary to enable both electrification...

AI summary The text discusses the need for reforms to retail rate structures to support electrification and renewable energy. It outlines the basic anatomy of a resource plan, including energy and capacity needs, with a focus on the planning reserve margin in Nova Scotia, which is set at 20% above peak load.

Preamble
overed by potential defined number of NSP and funding system peak events where available. 1 Customer behavior-based peak shifting also through residential time of use, commercial time of use, and critical peak pricing rates. IRP Update App...

AI summary The text discusses customer behavior-based peak shifting through time-of-use rates and presents data on EV supply equipment and smart charger demand response enrollment and costs, highlighting financial figures and program implementation.

Party Question/Comment & Response
asthe2014IRP. TOUandprogramrewards ǦGMP$10monthlybillcredit.

AI summary The text references the 2014 Integrated Resource Plan (IRP) and mentions a $10 monthly bill credit as part of TOU and program rewards, likely related to energy efficiency or demand response initiatives.

N-92020 Integrated Resource Plan 9 passages
1.2 Nova Scotia Power's System Transformation p. p. 0
reliability and rate stability. This is not new thinking for the utility. When natural gas first became available in Nova Scotia in 1999, Nova Scotia Power converted the three units at the Tufts Cove Generating Station to utilize this newl...

AI summary Nova Scotia Power has historically transitioned to natural gas and wind energy, reducing emissions. Recent infrastructure, including interconnections with New Brunswick and the Maritime Link HVDC project, enhances grid reliability and supports long-term rate stability through access to zero-carbon electricity.

1.8 Overview of Key Findings p. p. 13
ources identified in this IRP, incremental greenhouse gas savings will grow. Across the scenarios, the greenhouse gas reduction achieved by switching to a heat pump increases to 87-95 percent by 2045. The trend for electric vehicles is sim...

AI summary Nova Scotia Power's IRP projects significant GHG reductions (87-95% by 2045) through heat pumps and EVs, aligning with SDGA net-zero goals. Electrification reduces rate pressures while enabling decarbonization. Comparator scenarios fail to meet SDGA targets.

1.9.1 Action Plan p. pp. 25-26
electricity rates for customers. Nova Scotia economic resource plans it can support provincial decarbonization while Power proposes several Action Plan items from this IRP related to electrification: - a. Initiate an Electrification strate...

AI summary The document outlines an Electrification Strategy aimed at supporting provincial decarbonization while maintaining rate stability. It proposes initiatives such as data collection on electrification demand, AMI implementation, and a Thermal Plant Retirement Plan. These actions are part of the Integrated Resource Plan and are subject to NSUARB oversight.

2.2 Objectives of the IRP p. pp. 28-30
2.2 Objectives of the IRP As a regulated utility with an obligation to serve customers, planning for the future is a responsibility and requirement for Nova Scotia Power. The IRP is a long-term planning exercise that establishes the direct...

AI summary Nova Scotia Power's Integrated Resource Plan (IRP) outlines long-term objectives focused on developing a robust, risk-weighted, lowest-cost electricity strategy that ensures safe, reliable, and affordable energy delivery while supporting provincial decarbonization. The IRP also includes an Action Plan and Roadmap for implementation and emphasizes collaborative, transparent planning processes with stakeholder engagement.

3.2 Maintaining Affordability p. p. 31
3.2 Maintaining Affordability As reflected in the Terms of Reference for this IRP, in addition to the traditional metric of minimization of cumulative present value of annual long-term revenue requirements over the 25 year planning horizon...

AI summary The 2020 Integrated Resource Plan (IRP) considers affordability by analyzing the magnitude and timing of electricity rate effects across different scenarios, such as Electrification, DSM, and DER. Affordability is influenced by system load levels and cost recovery mechanisms, with uncertainty increasing over the planning horizon. Nova Scotia Power provides 10-year rate impact analyses to address risks associated with long-term projections.

4.1.1 Base Load Forecast p. p. 52
4.1.1 Base Load Forecast The Base Load Forecast relies on demographic and economic indicators (e.g. population and economic growth), historical sales data, weather variables (e.g. cooling degree days and heating degree days), and other fac...

AI summary The Base Load Forecast considers demographic, economic, and weather factors to predict energy demand. Nova Scotia Power's largest customer, Port Hawkesbury Paper LP, transitioned to the ELIADC Tariff in 2020, which includes Active Demand Control to manage load and reduce costs. The NSUARB recognized the ELIADC Tariff's benefits in system flexibility and cost management.

5.3.4 Assessing Relative Rate Impacts p. p. 73
ad changes associated with electrification, distributed resource assumptions, and energy efficiency measures. Nova Scotia Power took the following approach: Nova Scotia Power took following approach: - 1. Begin with the forward looking sup...

AI summary Nova Scotia Power outlines a method for assessing relative rate impacts by starting with revenue requirements from the Integrated Resource Plan and adding fixed costs from the 2014 General Rate Application Test Year. A system rate is calculated by dividing total revenue requirements by total sales, and annual rate changes are determined and averaged over the analysis period.

6.5 Relative Rate Impacts p. pp. 93-94
6.5 Relative Rate Impacts In addition to comparing the NPVRR metrics, Nova Scotia Power also developed a simplified rate impact model to compare the relative rate impacts of each scenario. This analysis approximates the resource plan impac...

AI summary Nova Scotia Power developed a simplified rate impact model to compare the relative rate impacts of different scenarios, incorporating factors like electrification, DSM level, and resource strategy. The model's results are visualized in Figure 52 and detailed in Section 5.3.4.

Initiate a Thermal Plant Retirement, Redevelopment and Replacement Plan including: p. pp. 112-113
Initiate a Thermal Plant Retirement, Redevelopment and Replacement Plan including: - Develop a plan for the retirement and replacement of Trenton 5, targeting 2023, while identifying required replacement capacity and energy in parallel. Be...

AI summary The document outlines a plan to retire and replace thermal plants, including a depreciation study, redevelopment of natural gas turbines, wind procurement targeting 50-100 MW by 2025, and a demand response strategy targeting 75 MW by 2025. It also mentions the calculation of avoided costs for DSM scenarios.

N-9-(i)Appendices A-N 76 passages
Section 180
Distributed Resources 3.2C Accelerated Net Zero 2045 High Electrification / Max DSM Regional Integration Table 7 – Preliminary Scenario and Resource Strategy Combinations Additionally, several potential sensitivities to be tested on key po...

AI summary The text discusses the impact of electrification, demand-side management (DSM), and distributed energy resources (DER) on customer rates through a model analyzing changes in cost and load. It suggests that higher electrification could lower unit costs to serve customers by increasing revenue from additional sales, despite higher load.

Section 181
• Develop an opening bundled service rate for comparison purposes; and • Recognize the additional fixed cost contribution provided by additional sales from higher levels of electrification. • The Company has taken the following approach: •...

AI summary The Company is developing an opening bundled service rate by incorporating forward-looking supply-side and demand-side revenue requirements from the Integrated Resource Plan (IRP) and adding fixed costs from the 2014 Test Year. Additional fixed cost recovery from increased electrification sales is calculated using an FCR/MWh factor, and annual rate changes are determined based on the net revenue requirement and total sales.

Section 182
Annual rate changes are calculated as the change in the rate year-over-year. A simple (i.e. non cumulative) average rate change is created by averaging rate changes over the analysis period. • The analysis employs a number of simplifying a...

AI summary The document discusses the methodology for calculating annual rate changes, including simplifying assumptions such as uniform FCR distribution and proportional load changes from electrification. It also mentions updates to model inputs and parameters, including the assumption of $0/MWh additional FCR and the use of a 'system average' rate estimate.

Section 662
eves NSPI has not fully incorporated our request to study alternative, lower costs of capital and if the use of such enables Nova Scotia to decarbonize quicker than using NSPI’s ownership assumptions. Paul Chernick, President of Resource I...

AI summary The document discusses concerns regarding NSPI's approach to incorporating alternative, lower costs of capital and its impact on decarbonization. It also highlights issues with the inequitable treatment of renewable generation's ELCC and suggests financial benefits for ratepayers through the sale of surplus environmental attributes to other sectors.

Section 664
NSPI system is measured by the marginal ELCC and is currently at 11%, meaning that each additional MW of wind contributes 0.11 MW of firm capacity to PRM requirements. In its recent 2020 Annually Adjusted Rates Application filed with the N...

AI summary The NSPI system's marginal ELCC is currently at 11%, indicating that each additional MW of wind contributes 0.11 MW of firm capacity to PRM requirements. NS Power proposed using a 32% capacity contribution factor for wind generation in 2020, based on past approvals, but has since revised its methodology to a 17% factor for existing wind resources. A pre-IRP study on ELCC calculations will influence future capacity contribution factors for billing purposes.

Section 665
IRP process is completed, NS Power will revisit justification for the continued applicability of the 32 percent capacity contribution factor for BUTU billing purposes.” We wish to specifically note that the 2020 IRP process is not the appr...

AI summary The document discusses the inappropriateness of using the Integrated Resource Plan (IRP) process to determine the capacity contribution factor for the Back-Up/Top-Up (BUTU) Tariff. It emphasizes that the IRP is a generic planning tool and not a rate design process. The BUTU Tariff is tied to specific non-Nova Scotia Power generation facilities and should be addressed separately.

Section 682
would like to better understand these assumptions or see them aligned with other sources. 8 National Renewable Energy Laboratory, Annual Technology Baseline: Electricity, Natural Gas Plants (2019). John D. Wilson and Paul Chernick • Resour...

AI summary The text discusses the inclusion of distributed energy resources (DERs) in modeling, emphasizing the need to account for both full costs and non-energy benefits such as reduced line losses and backup service, or alternatively, just the costs paid by NS Power reduced by T&D benefits if non-energy benefits cannot be estimated.

Section 724
nvenience charging, because no provincial or utility first line of Table 2. policy exists to motivate any other behavior. 3. Analytical methods 3.2.2. Scenario: Time of day charging Nova Scotia has in place a ‘‘time of day” (TOD) residenti...

AI summary The text discusses the analysis of electricity consumption patterns related to electric vehicles (EVs) in Digby, Nova Scotia, and the impact of a 'time of day' (TOD) residential electricity tariff. It assumes a 10% adoption rate for EVs and examines how EV drivers may respond to the TOD tariff by delaying charging until after 23 h.

Section 728
Nova Scotia Power TOD Rates in electricity markets. In Digby, the constraint of interest is power Workdays Dec 1 - Feb 28 export on transmission line L-5533 (see Fig. 1). When the WEC field is at maximum generating capacity (30 MW), and th...

AI summary The text discusses Nova Scotia Power's Time of Day (TOD) rates and how real-time monitoring and signaling on a transmission line could be used to manage EV charging, particularly during low load periods to avoid export limitations.

Section 900
1 As of February 2019, NS Power has been aware of an error in the avoided T&D calculations it had 2 been providing to EfficiencyOne and the DSMAG since 2016, which appears to result in the 3 avoided costs being understated by a factor of 3...

AI summary NS Power has been aware of a significant error in avoided T&D cost calculations provided to EfficiencyOne and the DSMAG since 2016, which may have understated costs by a factor of 30 to 100. EfficiencyOne highlights the potential impact on the 2020 IRP process if this issue is not addressed, as it could lead to sub-optimal DSM selections.

Section 904
e sensitivity 25 the DSM Potential Study has to predicted temporal conditions. For example, building stock 26 forecasts that drive participation (in part), are based on temporally sensitive Statistics Canada data 27 that varies by year. 28...

AI summary The DSM Potential Study relies on temporally sensitive Statistics Canada data for building stock forecasts, which influence participation rates. This data varies by year and impacts the accuracy of predictions in the 2019 Rate and Bill Impact Analysis and Model.

Section 947
d consider the development of an approach 26 and alternate methodology than currently exists for the calculation. This process will occur in 27 parallel with the IRP and will conclude during the course of the IRP. EfficiencyOne appreciates...

AI summary EfficiencyOne comments on Nova Scotia Power's 2020 Integrated Resource Plan (IRP), emphasizing the need for an improved methodology to calculate avoided transmission and distribution costs. They note that these costs will not be included in the IRP model and stress the importance of accurate avoided cost assessments for planning decisions.

Section 1016
. There needs to be specificity as to how the revenue requirements will be determined for fillllual expenditures, ie multi-year amortiz.ation. A question that then arises is whether it is a variable. The SBA believes that the incorporation...

AI summary The SBA raises concerns about the revenue requirements for multi-year amortization and the exclusion of distributed generation in the IRP. They emphasize the need for further discussion on DSM and DER integration, as well as the modeling of customer economics and solar policies.

Section 1060
istributed Resources scenario will provide (Distributed because won’t be selected by model due to cost is a information as to the potential impacts of these Energy shortcoming. Needs to be recognition of existence of technologies will have...

AI summary The text discusses the integration of distributed energy resources (DER) in Nova Scotia Power's Integrated Resource Plan (IRP), including the need to evaluate BTM thermal energy storage, the economic signals influencing customer adoption of DER, and the impact of DER on peak energy requirements. It also highlights the cost competitiveness of energy thermal storage (ETS) and the importance of testing solar ratemaking and net metering policies.

Section 1102
Category Participant Comment NSP Response 1.2 Analysis Plan CA - Resource Insight Revise to bill effects metric (customers more NS Power will use the 10-year NPV Evaluation Criteria concerned about bills than rates): evaluation criteria as...

AI summary The document discusses revisions to evaluation criteria for resource planning, emphasizing the importance of billing effects over rate effects and ensuring that reliability requirements are met. NS Power agrees to use a 10-year NPV evaluation method and will not consider plans that fail to meet reliability standards.

Section 1136
SENSITIVITY ANALYSIS Increase in Low capital Renewable Energy cost of Standard policy wind Low capital Low pricing of import cost of energy storage High High pricing of pricing of natural gas import energy Carbon Fuel security tax/pricing...

AI summary The document outlines a sensitivity analysis focusing on renewable energy standards, capital costs, and pricing of imported energy, as well as carbon tax and fuel security. It also proposes evaluation criteria for an integrated resource plan, emphasizing the minimization of revenue requirements and rate impacts over a 25-year period.

Section 1185
would likely be very little on-peak generation during a winter peak event, especially if rate design is updated to utilize the smart meters NS Power is installing. Based on an email exchange with Chris Milligan following up on the April 8...

AI summary The text discusses NS Power's use of a 2015 NYSERDA report for EV load assumptions, questioning the accuracy of applying the study to NS Power's load forecast. Concerns are raised about the mismatch between NYSERDA data and NS Power's assumptions, particularly regarding on-peak and off-peak load figures, and the lack of clear explanation for how EV charging profiles are mapped to the baseline forecast.

Section 1363
tween options. If the variation in end effects among cases appears to be correct, but the magnitude is overstated, NS Power should consider shifting to a shorter end effect period (e.g., 10 or 15 years), or eliminating it altogether. Distr...

AI summary The text discusses concerns about the end effect period in NS Power's modeling and the exclusion of distributed energy resource (DER) costs in specific cases. It suggests shortening the end effect period or eliminating it and highlights the need to account for bottom-of-the-meter (BTM) costs associated with DERs, which are not captured in the NPVRR calculation.

Section 1365
incorporate some BTM costs into its reported cost metric, we suggest using a modest placeholder value. If Plexos produces marginal hourly energy costs, those could be used for the assumed DER load shape. Otherwise, NS Power might use some...

AI summary The text discusses the challenges of incorporating bottom-of-the-meter (BTM) costs, the limitations of using NPVRR and partial generation cost metrics for comparing energy plans, and the need for a more meaningful bill metric. It also highlights the importance of considering T&D cost sensitivities and the need for more detailed computation methods for capital investments in the long-term Plexos model.

Section 1537
Those BTM costs do not fit neatly into the NPVRR calculation, since they do not represent utility revenue requirements. Nor should the full cost of DERs comparable to the utility costs, since DERs (especially paired solar and storage) prov...

AI summary The text discusses challenges in comparing different energy plans due to divergent load forecasts and the limitations of the NPVRR metric in reflecting benefits from electrification and demand-side management. It also mentions the difficulty in incorporating BTM costs into NPVRR calculations and suggests using placeholder values or marginal energy costs for estimation.

Section 1539
July 2020 Category Comment # Comment NS Power Response T&D CA-05 NS Power staff explained that the projection of revenue The Avoided T&D cost estimates, being developed requirements excludes T&D costs, which would be affected in parallel t...

AI summary The document includes comments from the Consumer Advocate regarding the exclusion of T&D costs in revenue requirement projections and requests for more detail on how revenue requirements for supply-side options are computed in the long-term Plexos model. NS Power responds by noting that Avoided T&D cost estimates are being developed in parallel with the IRP.

Section 1588
Basic information has been provided relating to the Inclusion of DER scenarios was determined through envisioned costs for renewable DERs - described as consultation with stakeholders on the Analysis Plan "$1.6-2.5B" on an NPV basis. These...

AI summary The document discusses the inclusion of DER scenarios in the Integrated Resource Plan (IRP), noting that envisioned costs for renewable DERs are $1.6-2.5B on an NPV basis but have not been directly included in any modelling scenario. Current solar PV programs do not leverage ratepayer investment, and DER investment costs are outside the utility model for IRP analysis.

Section 1592
Demand E1-05 6. Allow the introduction of Demand Response (DR) in 2021, In the Final Portfolio Study NS Power offered the Response 2025, 2030, and 2035. This would provide a better balance DR resources in 2021/2025/2030. In all scenarios,...

AI summary The text discusses the introduction of Demand Response (DR) in Nova Scotia for 2021, 2025, 2030, and 2035, aiming to improve balance and consistency in model runs and better estimate DR value. It also requests clarification on how DR was modeled, including assumptions about capacity and the DR profile provided by Efficiency One.

Section 1643
Distributed Quest-01 DERs are considered a reduction in system demand without The NEM arrangement allows customers to offset Resources a cost to the system. How does this assumption fit within the their consumption with the production from...

AI summary The text discusses the consideration of distributed energy resources (DERs) as a reduction in system demand and questions how this assumption aligns with Enhanced Net-metering requirements. It also mentions NS Power's exploration of DERs through the NS Smart Grid project and the potential benefits of resiliency and reliability from DERs.

Section 1664
d going forward. The Company should provide metrics to help provide insight on affordability of each portfolio, perhaps showing annual cost of electricity impacts utilizing nominal capital cost carrying charges. Generally, the more capital...

AI summary The document discusses the need for NS Power to provide metrics on the affordability of its portfolio and the reliance on imported power. It emphasizes the importance of transparency regarding capital investment requirements and long-term electricity costs.

Section 1709
its 4 & 5 7. Complete sustaining capital profile review based on observed unit utilization 8. Input two sustaining capital cost profiles for coal units – aligned with 2030 and 2040 retirement dates I R P D R A F T F I N D I N G S , R O A D...

AI summary Nova Scotia Power has developed a simplified rate impact model based on the optimized Integrated Resource Plan (IRP) resource plans, considering inputs like partial revenue requirements, load forecasts, and assumptions about marginal contributions of load changes. The model is illustrative and approximate, with actual rates expected to differ due to various factors.

Section 1735
18 Nova Scotia Power IRP Final Report Appendix K Page 86 of 264 N PV PA RT I A L R E V E N U E R EQ U I R E M E N T CO M PA R I S O N Low Electrification Mid Electrification High Electrification Low Electrification Mid Electrification High...

AI summary The document compares revenue requirements and rate impacts across different electrification scenarios. Higher electrification with DSM investments reduces customer rates over time, while significant DER penetration increases rate pressure. Coal closures in 2030 and 2040 have similar long-term impacts, but the 2030 closure creates additional pressure in the 2030s without mitigation.

Section 1823
wing this issue in the IRP and using that as an input into its submission for capital investment at Mersey. It is appropriate that there be a thoughtful discussion of the findings so that it is clear what evidence may be drawn from the IRP...

AI summary The document discusses the Integrated Resource Plan (IRP) and its implications for capital investment at Mersey. It highlights the need for a thorough discussion of the hydro system value and the retirement analysis of Mersey, including post-2045 costs and risks. Additionally, it critiques the rate impact model for incorrectly removing incremental fixed cost recovery, which may exaggerate rate impacts.

Section 1825
Nova Scotia Power IRP Final Report Appendix K Page 182 of 264 Comments on latest IRP materials Page 9 of 13 These charts demonstrate that NSP’s rate impact model exaggerated the overall trend in rate increases and also exaggerated the diff...

AI summary The document critiques Nova Scotia Power's rate impact model, stating that it overestimates the overall trend in rate increases and the differences between model scenarios. The analysis is provided by John D. Wilson and Paul Chernick of Resource Insight, Inc.

Section 1830
higher levels of electrification studied in the IRP, but that such programs have not yet been studied or costs developed. RII recommends that NS Power include in its action plan an “order of magnitude” estimate for the level of cost that m...

AI summary RII recommends that NS Power include an estimate of the cost customers might bear to promote electrification in its action plan. While increased electricity sales from electrification can reduce upward pressure on rates and help with carbon reductions, determining the exact investment needed to avoid rate increases is uncertain. Benefits beyond rate impacts, such as cost savings and carbon reduction, should also be considered.

Section 1878
limits), or higher demand growth/electrification (potentially resulting in breaches of emissions limits). It is recommended that this type of analysis is considered further. [Refer section 4] • NSP’s continued adherence to allowing further...

AI summary The text criticizes NSP for its approach to integrating wind capacity with capital-intensive batteries and synch comps, suggesting it leads to higher costs for consumers. It recommends considering alternative analyses and adopting best practices used in other systems with high levels of intermittent renewable generation.

Section 1895
integration will require careful and strategic consideration and coordination with other jurisdictions in the region to ensure Nova Scotia stakeholders receive the intended benefits. 3. Rate Impacts In its Updated Modeling Results and Draf...

AI summary The document discusses the importance of rate impacts and electrification scenarios in Nova Scotia’s long-term planning. It highlights the need for stable and predictable electricity rates, especially for industrial customers. NS Power’s new demand response service and the continued need for firm capacity resources are emphasized as key factors in achieving an environmentally and economically sustainable electricity future.

Section 1898
ding for several years, it is possible that cost declines for wind capacity or other factors could advance the timeline for wind development, hastening the need for a solution to the reliability need. DAYMARK ENERGY ADVISORS 370 MAIN STREE...

AI summary The text discusses the need for coordination with New Brunswick for the Reliability Tie and Regional Integration as part of Nova Scotia Power's Integrated Resource Plan, and highlights the importance of a clear interpretation of rate impact analysis under high electrification scenarios.

Section 1899
particularly related to the rate impact under high electrification scenarios. This slide was accompanied with important discussion during the stakeholder session which provided context on rate trends. We recommend that NSP provide sufficie...

AI summary The text discusses the need for NSP to provide context in the Integrated Resource Plan (IRP) regarding the rate impact of electrification scenarios and the importance of a data collection program on electrification. It also highlights the need for a more thorough examination of the potential and cost of Demand Response resources beyond the 75 MW target.

Section 1907
Two sensitivities were added examining high and low sustaining capital costs for existing thermal units, and a third was completed which examined a high cost sensitivity on pricing for Natural Gas and Import prices, since those resources w...

AI summary The text discusses the addition of sensitivities examining capital costs for thermal units and natural gas pricing in the context of the Integrated Resource Plan (IRP). It also addresses a question regarding the difference between the 'relative rate impact comparison' slide and individual model run results, and mentions PLEXOS co-optimizing energy dispatch and ancillary services.

Section 1944
(18) RII recommends that the findings include an explicit discussion of the hydro system NS Power will consider the suggested potential changes to replacement energy cost calculations after the value and the retirement analysis of Mersey i...

AI summary RII recommends that the findings include a discussion of the hydro system's value and the retirement analysis of Mersey, particularly post-2045 costs and risks. NS Power will consider changes to replacement energy cost calculations after the IRP. There is a discussion on rate impact models and average rate calculations.

Section 1987
Rate effects E1 (7) The rate effect metrics (10-year NPVRR and estimated rates) will not contribute to Per the Terms of Reference, minimization of Net Present Value (NPV) is the primarily metric for achieving the general purpose of the IRP...

AI summary The document discusses the rate effect metrics used in the Integrated Resource Plan (IRP) process, emphasizing that the Net Present Value (NPV) of Resource Replacement (NPVRR) and estimated rates should not be the primary metric for evaluating future plans. Instead, the focus should be on minimizing NPV, with other metrics like the magnitude and timing of electricity rate effects being of increasing importance. The Rate Impact model is presented as a simplified tool to illustrate rate pressure when comparing plans.

Section 1988
Further, the IRP provides the only opportunity for analysis of the long-term revenue requirement associated with the NS electricity system. This long-term view is critical in determining the lowest cost electricity system into the future,...

AI summary The Integrated Resource Plan (IRP) is crucial for analyzing the long-term revenue requirements of Nova Scotia's electricity system and determining the lowest cost electricity system. The UARB emphasized the importance of the IRP in utilizing both supply-side and demand-side resources to reliably serve Nova Scotia's electrical needs at the lowest long-term cost to ratepayers.

Section 2004
Nova Scotia Power IRP Final Report Appendix K Page 251 of 264 According to the Rate impact Comparison (Select Scenarios), it is shown that High Electrification scenarios 2.2 C and 2.2 C S1 achieve lower rates as compared to select Low and...

AI summary The document discusses the rate impact of electrification scenarios, showing lower rates in high electrification scenarios. It also highlights the need for decommissioning Trenton 5 and preparing for the retirement of coal units, including regulatory approval processes.

Section 2064
Preserving such flexibility will also enable NS Power to consider any subsequent changes in technology and/or government policy, as well as the results of ongoing costing analysis of generation and transmission options. These items will im...

AI summary The text discusses the importance of flexibility in NS Power's long-term planning, considering technological and policy changes, as well as the impact of electrification on future rates. It highlights the use of IRP partial revenue requirements to model rate impacts and the value of comparing different electrification scenarios.

Section 2067
with a new demand response service that allows the utility to better operate its electricity NS Power also agrees that the IRP has shown that DR resources, as modeled in the IRP, have economic system for the benefit of all customers. The 2...

AI summary The text discusses the importance of demand response (DR) resources in Nova Scotia Power's Integrated Resource Plan (IRP), emphasizing their economic value and the need for continued collaboration. It also highlights the need for NS Power to better support findings in the IRP with specific modeling references. The text mentions the ongoing work related to system inertia and wind stability.

Section 2072
P’s plan for a reliable and economic supply portfolio, the Company should emissions intensity, and dispatch flexibility). prepare a specific timeline and plan for the steps required in Action Plan Item #1 to ensure that this is a feasible...

AI summary The document discusses the need for a specific timeline and plan to ensure the feasibility of delivering benefits assumed in the Integrated Resource Plan (IRP). It also highlights the value of the rate impact model developed by NSP to assess the implications of various supply portfolios for customers, particularly under high electrification scenarios.

Section 2078
ic implications NS Power Acknowledges these points. Wolfville associated with high levels of Distributed Energy Resource (DER) adoption. By 2040, the Policy models suggest that high DER uptake could increase electricity costs by 10%, or 2...

AI summary NS Power acknowledges concerns about the potential increase in electricity costs due to high DER adoption by 2040, which could rise by 10%. The current rate design creates a cross-subsidy between self-generating and non-self-generating customers, and revisions to rate structures may be necessary to address this and improve price signals for self-generation.

Section 2122
it to development of T&D cost forecasts for several of the different scenarios involving electrification and DSM at varying levels. This will be necessary to inform those program investment decisions. Status of Board Requirements Optimal p...

AI summary The document discusses the development of T&D cost forecasts for various electrification and DSM scenarios, and NS Power's position on the optimal planning reserve margin, referencing an audit recommendation and the E3 study from 2019.

Section 2135
pressure on rates that may be created by differing levels of electrification. The model presented in the Draft IRP Report may exaggerate the rate impacts overall, and the differences among the cases. John D. Wilson and Paul Chernick • Reso...

AI summary The comment highlights an issue with the rate impact model in NS Power's Draft IRP Report, specifically the incorrect deduction of incremental fixed cost recovery from the revenue requirement, leading to potentially misleading rate estimates. The commenter recommends correcting this in the model and throughout the report.

Section 2136
on of the model, and is illustrated below. RII recommends that NS Power revise the rate impact model and correct its application throughout the Draft IRP Report and in its modeling results slide deck. Treatment of existing non-fuel revenue...

AI summary RII recommends that NS Power revise its rate impact model and correct its application in the Draft IRP Report and modeling results. RII questions the assumption that non-modeled costs remain consistent during the planning horizon and argues that a more complex model is needed to distinguish rate impacts by customer class.

Section 2137
and documents. RII does not agree that this adjustment accomplishes the stated goal. A significantly more complex model would be required to appropriately distinguish rate impacts by customer class. John D. Wilson and Paul Chernick • Resou...

AI summary Resource Insight, Inc. disagrees with the adjustment proposed by NSP, arguing that a more complex model is needed to distinguish rate impacts by customer class. They also recommend including a sensitivity analysis to account for uncertainty in NSP’s rate impact forecast.

Section 2138
s remains an increasing revenue requirement under every scenario. The suggested, or some similar sensitivity analysis, will provide an indication of the uncertainty in NS Power’s rate impact forecast. Revised rate impact model findings Bel...

AI summary The analysis indicates that NS Power's rate impact model overstates the rate increase trends and differences between scenarios. It also highlights an error in the model's calculation of fixed cost recovery and system rate, which undermines the support for the Low DSM investment level in the Draft IRP Report.

Section 2149
2. Enables better grid management; and 3. Reduces negative environmental impacts. As well, RAP’s four key principles for maximizing electrification benefits should be followed. 3. EfficiencyOne is well-positioned to administer initiatives...

AI summary The document outlines the benefits of electrification, the role of EfficiencyOne in administering electrification initiatives, the importance of consistency in IRP secondary metrics, and the economic benefits of DSM energy efficiency programs. It also emphasizes the need for stakeholder-driven processes and the use of RAP principles.

Section 2152
Risk Analysis 12. Create and include a roadmap item to carefully monitor and estimate the expected capital costs, inclusive of transmission, distribution, energy and capacity, and reliability upgrades associated with a regional interconnec...

AI summary The text discusses risk analysis related to capital costs for a regional interconnection strategy, the inclusion of DSM in the IRP, and the need for an 'evergreen' IRP process with three-year updates. It also mentions the need for clarity in statements about emissions reductions and the use of the term 'cost-effective'.

Section 2162
Demand Response Strategy targeting 75 MW of capacity, for deployment by 2025. Available resource cost, flexibility, and reliability may inform pursuit of additional Demand Response capability.11 We agree with this recommendation in the Act...

AI summary The document outlines a Demand Response Strategy targeting 75 MW of capacity by 2025, emphasizing its cost-effectiveness and flexibility. EfficiencyOne is recommended to administer demand response programs, and the strategy development is to proceed through the DSMAG. The Integrated Resource Plan (IRP) uses a least-cost, least-risk portfolio approach as its primary evaluation criterion.

Section 2167
2. The inability to assess the weighting relationship between the primary objective of developing a plan that seeks to minimize the cumulative present value of the annual revenue requirements over the 25-year planning horizon (adjusted for...

AI summary The text discusses challenges in the Integrated Resource Plan (IRP) process, particularly the lack of clarity in evaluating secondary metrics such as GHG emissions and rates. It highlights concerns about the methodology used for rate analysis and suggests minimizing objective decision-making based on secondary metrics to ensure a focus on the lowest-cost path for the electricity system.

Section 2168
s analysis are presented on pages 112 and 113 of the draft IRP report, while the methodology is presented on pages 98 and 99. There are issues associated with the use of rate effects, which are specific examples of the general issues descr...

AI summary The document discusses concerns with the use of rate effects in the Integrated Resource Plan (IRP) context, highlighting issues such as the methodology being overly simplistic and applied unevenly. It also raises concerns about the potential prejudice to other rate-making exercises and the inappropriateness of discussing affordability in the IRP rather than in DSM planning.

Section 2169
en description of the methodology for its rate analysis as part of the final report was provided, as well as results and analysis. The methodology documented in the Draft Report has a number of flaws: - Its treatment of fixed costs differs...

AI summary The text critiques the methodology used in the Draft Report for rate analysis, pointing out several flaws, including inconsistent treatment of fixed costs, incorrect assumptions about cost recovery, and failure to consider transmission and distribution avoided costs. It also highlights that the Rate and Bill Impact Analysis (RBIA), developed through stakeholder consensus, has been used and refined since 2013.

Section 2170
ell considered by stakeholders. The Application of Rate Effects Despite rate effects forming a secondary evaluation metric in the whole of the IRP, the Draft Report has used of the metric to: 1. Demonstrate that increasing levels of electr...

AI summary The text critiques the use of rate effects as a secondary evaluation metric in the Integrated Resource Plan (IRP), arguing that it has been used inconsistently, particularly in relation to electrification and demand-side management (DSM). It highlights concerns about the lack of exploration of various factors affecting rate trajectories and calls for revisions to the Action Plan.

Section 2197
3 POTENTIAL CAUSES OF OVERFORECASTING To be clear, the pattern of overcasting is not unique to BC Hydro. Our research reveals that other utilities and system operators also persistently and substantially overestimate long-term requirements...

AI summary The text discusses the issue of overforecasting in long-term energy planning, noting that it is not unique to BC Hydro. It highlights risk asymmetry bias, where reliability has historically taken precedence over cost-effectiveness and environmental concerns. With changing market conditions, overforecasting now leads to unnecessary investments and rate increases, impacting the low-carbon electrification transition.

Section 2213
6. What would the impact on electricity demand be if the thermal and electrical energy demand of the existing building stock was reduced by 50% rather than by the levels assumed in the E3 scenario analysis? 7. If greater building efficienc...

AI summary The text presents a series of questions regarding the impact of energy efficiency and electrification on electricity demand, building energy expenditures, residential heating systems, and housing stock characteristics. It also inquires about scenarios involving accelerated efficiency and electrification, and the consistency of minimizing electricity rates with total energy service costs.

Section 2301
ower has committed to an evergreen process and Electricity), the scale, and implications for appreciates the feedback. integration of other renewables; • New assumptions on the cost and value of renewable energy resources, including onshor...

AI summary The document outlines various assumptions and findings related to renewable energy integration, including the cost and value of onshore and offshore wind, solar PV, and energy storage, as well as initial outcomes from the NS Power Smart Grid project and the value of Time Varying Pricing.

Section 2343
We suggest that this is a significant finding which should be included in the “Key Findings” of the study. Wind Capacity Natural Forces One can identify two broad “clusters” of scenarios, NS Power agrees that the size and pace of wind buil...

AI summary The text discusses two clusters of wind capacity build-out scenarios, with NS Power agreeing that the pace and scale of wind installations depend on capital costs, integration assumptions, and demand levels. NS Power has committed to further studies to determine the optimal cluster for minimizing costs for ratepayers.

Section 2383
RAP’s four key principles for maximizing electrification benefits should be followed Efficiency One E1 are positioned to administer electrification The development and administration of future Item 3 -6 initiatives electrification programs...

AI summary The document discusses Efficiency One's role in administering electrification initiatives and Demand Response programs. It highlights NS Power's agreement on the economic viability of Demand Response and the need for a stakeholder-driven electrification strategy. It also mentions the use of consistent metrics in the IRP process.

Section 2385
P a g e 42 45 Nova Scotia Power IRP Final Report Appendix L Page 123 of 125 Category Participant Comment NS Power Response stakeholder engagement has improved the overall process. NS Power agrees with the modifications to Action Plan Item...

AI summary Efficiency One comments that affordability discussions should remain within DSM planning and criticizes the rate impacts methodology as flawed. NS Power agrees with modifications to Action Plan Item 2e and updated the Final Report accordingly, stating that affordability is a criteria for evaluating DSM procurement.

Section 2416
Town of See comment on overall Finding 1. Wolfville 1b. Increased electricity sales due to electrification AREA No comment n/a can help to reduce upward pressure on electricity CA Supportive but with recommendations for 2 adjustments to 20...

AI summary The text discusses the impact of increased electricity sales due to electrification on electricity rates and carbon reduction. It highlights the importance of managing peak demand and energy requirements, and supports Nova Scotia Power's approach to rate impacts in the IRP while suggesting adjustments to the calculation of fixed cost recovery.

Section 2419
FINDING STAKEHOLDER STAKEHOLDER COMMENT REFERENCE impact forecasts in other venues. Nonetheless, RII inclusion with the Final recommends that NS Power make two changes to its rate Report. impact model. RII understands that the purpose of t...

AI summary RII recommends that NS Power make changes to its rate impact model, suggesting that the model may exaggerate rate impacts from electrification. Other stakeholders provided no comment on the finding.

Section 2420
JFS Hydrostor No comment n/a Natural See comments on overall Finding 1. Forces PHP Supportive of use of rate impact analysis: 2020-09-18; p.2/2 ‘In its Updated Modeling Results and Draft Findings, NS Power developed a rate impact calculati...

AI summary The document discusses feedback from various stakeholders on NS Power's rate impact analysis and long-term strategy. PHP and SBA support the use of rate impact models to assess the implications of different energy portfolios, emphasizing the importance of rate stability for industrial customers.

Section 2421
3/3 -‘We appreciate NSP developing the rate impact model to help assess the implications of various portfolios Page 7 of 43 Nova Scotia Power IRP Final Report Appendix M Page 8 of 43 Nova Scotia Power IRP Summary of Stakeholder Comments sp...

AI summary The text acknowledges the development of a rate impact model by NSP to assess the implications of various portfolios, as part of the IRP Final Report and stakeholder comments on findings, action plan, and roadmap.

Section 2423
FINDING STAKEHOLDER STAKEHOLDER COMMENT REFERENCE for customers (Slide 31). We believe this provides important information in the consideration of various strategies. The summary of results provided in the draft Findings presentation (Slid...

AI summary The stakeholder provides feedback on the draft Findings presentation, emphasizing the importance of communicating the implications of rate impact analysis on customers, particularly regarding Finding 1b, which discusses the effect of increased electricity sales due to electrification on electricity rates and carbon reductions.

Section 2491
FINDING STAKEHOLDER STAKEHOLDER COMMENT REFERENCE PHP No comments n/a SBA No comments n/a Town of No comments n/a Wolfville 3b Nova Scotia Power’s existing combustion AREA No comments n/a turbine resources provide economic benefit to CA Su...

AI summary Nova Scotia Power's combustion turbine resources are deemed economically beneficial and sustainable through the planning horizon with current levels of capital investment. The Electric Resource Assessment Model (RII) recommends further evidence in the FAM audit proceeding regarding the performance of these resources.

Section 2495
FINDING STAKEHOLDER STAKEHOLDER COMMENT REFERENCE Halifax No comments n/a Regional Municipality Hendricks No comments n/a Heritage Supportive with ongoing monitoring: 2020-11-13; p. 5/5 -‘With respect to the existing CTs, NSPI has stated t...

AI summary Heritage Gas supports ongoing monitoring of the existing LFO-fired CTs due to concerns about their reliability and the inconclusive data on the impact of sustaining capital investments. This is based on an audit report that highlighted potential issues with the units.

Section 2510
FINDING STAKEHOLDER STAKEHOLDER COMMENT REFERENCE resource cost, flexibility, and reliability may inform pursuit of additional Demand Response capability. We agree with this recommendation in the Action Plan in principle, in that near-term...

AI summary The stakeholder comments discuss the potential of Demand Response (DR) to provide cost savings compared to other short-term peaking resources. The Board's approval of NS Power's Extra Large Industrial Active Demand Control Tariff is highlighted as an innovative rate structure.

Section 2511
Control Tariff. This innovative rate structure, developed following extensive collaboration with the utility, provides NS Power with a new demand response service that allows the utility to better operate its electricity system for the ben...

AI summary The document discusses the Control Tariff, an innovative rate structure developed with NS Power to enhance demand response services. The 2020 Integrated Resource Plan (IRP) highlights the continued importance of firm capacity resources for NS Power's system, underscoring the value of demand response approaches.

Section 2530
cost that might be tolerable for its customers to bear to promote electrification. As noted in the draft findings, “Increased electricity sales due to electrification can help to reduce upward pressure on electricity rates while facilitati...

AI summary The text discusses the potential cost of promoting electrification and its impact on electricity rates, noting that increased electricity sales can help reduce upward pressure on rates while supporting carbon reductions. The design and costing of programs related to electrification are outside the scope of the Integrated Resource Plan (IRP).

Section 2532
ACTION PLAN ITEM STAKEHOLDER STAKEHOLDER COMMENT REFERENCE below) to identify the impacts on rates that might result from plausible levels of program investment in electrification. Given the diversity of the possible futures, RII recognize...

AI summary The stakeholder suggests that the Board should consider the impacts of program investment in electrification on rates and encourages the consideration of benefits such as cost savings and carbon reduction. An estimate of the annual investment causing upward pressure on rates is requested.

Section 2533
whole can be captured in a total resource cost test. While this is clearly beyond the scope of the IRP, we encourage NS Power to acknowledge – perhaps with an illustrative graph – that these benefits exist, to avoid creating the impression...

AI summary The text discusses the importance of acknowledging the benefits of electrification beyond rate considerations, suggesting the use of a definition and principles from the Regulatory Assistance Project (RAP). It also mentions the potential role of EfficiencyOne in administering electrification initiatives.

Section 2545
Recommends RPF to determine cost of new wind to system. 2020-11-13; p. 1/8 Work should fully consider alternative operational strategies 2020-11-13; p. 6/8 SBA SBA: Supports 2020-09-18; p. 2/3 4. Create a Demand Response Strategy targeting...

AI summary The text recommends developing a Demand Response Strategy targeting 75 MW of capacity by 2025, linked to the Electrification Strategy. It mentions leveraging existing initiatives like NS Power’s Smart Grid Project, Time Varying Pricing, and the ELIADC tariff. The SBA supports the strategy but suggests further examination of cost potential.

Section 2583
Request / Directive Originator Status NS Power Comments 2018 FAM Audit Recommendation IX-1 Bates White Complete PHP is no longer served on the Load Retention Tariff. Subsequent to this FAM Audit (f) Explicitly address the effect of PHP loa...

AI summary The 2018 FAM Audit Recommendation IX-1 discusses the effect of PHP load on resource planning and tariff structures. NS Power notes that PHP is no longer served under the Load Retention Tariff and is now served under the Extra-Large Industrial Active Demand Control Tariff. PHP is considered a priority interruptible customer and does not contribute to firm capacity requirements.

Section 2597
Request / Directive Originator Status NS Power Comments Recommendation XIV-5: NSPI should perform a standalone Bates White n/a Biomass as a component of the renewable analysis to determine the value of the Biomass Plant to FAM electricity...

AI summary Bates White recommended that NSPI perform an analysis to determine the value of the PH Biomass Plant to FAM customers, considering its operation without PHP load. NSPI accepted the recommendation and planned to incorporate the analysis into the 2019 IRP. The Board later approved the ELIADC tariff, removing PHP’s explicit access to the biomass plant’s generation.

N-10Comments - Bates White 2 passages
Section 35
or will be electric by 2050 and 50% of all vehicle sales will be electric by 2040. The “low” case assumed “continuation of the current pace of growth in building and transportation electrification.”58 We recognize that, throughout the IRP...

AI summary The document discusses uncertainty in electrification trajectories for heating and transportation sectors, influenced by provincial policy, rate design, and stakeholder debates. Heating electrification faces equity and accounting challenges, while transportation electrification lags due to low EV adoption and varying policy outcomes. Projections for EV penetration by 2030 range from 13% to 32%.

Section 37
ge 1. 60 Ibid. 61 Ibid., Figure ES-1. 62 2020 IRP Report, pages 112 to 113. 19 Bates White Comments On NSPI Final IRP Report As for the pursuit of “beneficial” electrification, we see this as an issue that may be exogenous to NSPI’s decisi...

AI summary Bates White comments on NSPI's Final IRP Report, noting that beneficial electrification depends on legislative and regulatory actions, while NSPI's evaluation framework for electrification is reasonable. Stakeholders debated resource cost assumptions in the IRP, prompting sensitivity analyses on wind and battery storage costs.

N-11Comments - Synapse 2 passages
Section 48
te strategies,24 the efforts planned as part of the Roadmap would be better elevated to Action Plan status. iv. Electrification Strategy • Item # 2 of NSPI’s Action Plan includes encouragement of beneficial electrification and data collect...

AI summary The document discusses the need to elevate electrification strategies to an Action Plan and highlights the importance of analyzing the impact of electrification on the transmission and distribution system. It suggests that rate structures, such as time-of-use and critical peak pricing, can help mitigate peak load increases from electrification.

Section 49
k pricing rates after deployment of automatic metering infrastructure (AMI) and commencement of any time-of- use or critical peak pricing rates pursuant to NSPI’s Time Varying Pricing Application. Synapse Energy Economics, Inc. Analysis of...

AI summary The text discusses the impact of deploying automatic metering infrastructure (AMI) and implementing time-of-use and critical peak pricing rates on peak load management and electrification. It emphasizes the opportunity to mitigate peak load increases from heating electrification and the need for NSPI to focus on programs that minimize peak load addition while maximizing off-peak consumption.

N-13Comments - E1 1 passage
IRP Results p. p. 15
IRP Results - 1. Scenario 2.0C is identified as the Reference Plan because it achieves the primary IRP objective of determining the least-cost plan (lowest NPVRR w/end effects) to ratepayers using current assumptions and inputs. Due to the...

AI summary Scenario 2.0C is designated as the Reference Plan for its least-cost approach to ratepayers under current assumptions, though DSM investment may align more with Mid-DSM. The IRP's rate analysis is criticized for limited scope, focusing only on DSM and electrification, and not aligning with the DSM RBIA. E1's RBIA is recommended for comprehensive rate impact assessments.

N-14Comments - CA 1 passage
1) Longer-term electrification program costs p. pp. 13-14
1) Longer-term electrification program costs Electrification is a key part of most greenhouse gas reduction strategies. We expect (and NS Power appears to agree) that some program funding would be required to achieve the higher levels of e...

AI summary Electrification is critical for GHG reduction, requiring program funding. NS Power estimates up to $10.8M annual investment in electrification without rate increases, balancing cost-to-customer concerns and carbon reduction benefits. Halifax's goals and undetermined program designs are highlighted.

N-15Comments - SBA 6 passages
F. Lack of Distributed Generation Integration p. p. 0
F. Lack of Distributed Generation Integration Distributed generation ("DG") is also not fully integrated into the IRP evaluation and considerations. The SBA acknowledges that there is a difficulty in having the IRP fully evaluate the merit...

AI summary The SBA highlights that NSPI's IRP fails to integrate distributed generation (DG) into evaluations, ignoring total resource costs, revenue impacts from behind-the-meter generation, and benefits like T&D savings and resiliency. NSPI must improve DG penetration forecasting and model electrification impacts for better T&D planning.

A. Limitation on Conclusions that can be Drawn from the IRP Analysis p. p. 0
A. Limitation on Conclusions that can be Drawn from the IRP Analysis The SBA has been supportive throughout the IRP process for a focus on recognizing that a resource plan must reflect the province's policies regarding decarbonization. Con...

AI summary The SBA cautions that the IRP analysis may underestimate costs and system investments needed for electrification, lacks rate design considerations, and assumes zero transmission/distribution costs. While acknowledging electrification's decarbonization benefits, the SBA stresses uncertainties in timing, cost allocation, and unaddressed infrastructure needs.

B. Metrics - NPV Partial Revenue Requirements, Rate Impacts p. p. 0
B. Metrics - NPV Partial Revenue Requirements, Rate Impacts The primary metric of partial revenue requirement minimization over a long horizon was calculated PVRR utilizing a real levelized capital cost recovery factor in modeling. The SBA...

AI summary The text discusses metrics for partial revenue requirements and rate impacts, emphasizing the need for clarity on capital cost recovery methods (nominal vs. levelized). The SBA requests additional metrics, including affordability analysis via kWh costs, long-term capital investment breakdowns, and imported power reliance. NSPI acknowledges limitations in current rate impact metrics and highlights the importance of financial viability assessments.

VIII. Specific Comments on Selected Key Findings p. p. 0
VIII. Specific Comments on Selected Key Findings The SBA has extracted the text of several key findings and offers comment on those below. The absence of comments on any findings should not be taken as the SBA agreeing with the findings no...

AI summary The SBA comments on findings related to electrification's impact on rates and carbon reduction, noting that increased electricity sales from electrification could lower average unit costs but actual rate design determines final impacts. The IRP analysis highlights managing peak/energy growth, with BJ scenarios showing reduced energy requirements but unchanged peak demand. The SBA stresses that promotional rates may not affect customer payments and cost allocation could vary significantly.

IX. Specific Comments on Action Plan p. p. 0
ans it can support provincial decarbonization while reducing upward pressure on electricity rates for customers. NS Power proposes several Action Plan items from this IRP related to electrification: - 2a. Initiate an Electrification Strate...

AI summary NS Power proposes an Electrification Strategy to support provincial decarbonization while maintaining rate stability, focusing on transportation and building electrification. The SBA recommends EOne, not NSPI, should lead electrification efforts, arguing NSPI's role as champion is unsuitable.

3. Initiate a Thermal Plant Retirement, Redevelopment and Replacement Plan including: p. p. 0
3. Initiate a Thermal Plant Retirement, Redevelopment and Replacement Plan including: - 3a. Develop a plan for the retirement and replacement of Trenton 5, targeting 2023, while identifying required replacement capacity and energy in paral...

AI summary NS Power proposes retiring thermal plants, developing replacement strategies, and integrating demand response. The SBA emphasizes the need for regulatory approvals and deeper DSM integration into planning. Key actions include coal retirement, wind procurement, and aligning rate redesign with IRP goals.

N-17Comments - Sierra Club Canada Foundation 2 passages
Responses and Recommendations Summarized p. p. 0
Responses and Recommendations Summarized Overarching Theme IRP Response Relevance Recommendations Premium tariffs and subsidized tariffs People in energy poverty should not be expected to pay the same energy rates as the wealthy Develop a...

AI summary The document discusses themes such as energy poverty, economies of scale, and investor returns. It highlights the need for premium and subsidized tariffs to support those in energy poverty and suggests a consolidated coal retirement plan to reduce costs. It also addresses the need to avoid placing investment risk on ratepayers.

IRP Responses p. p. 0
r concerns and input were included. There was no consultation with participants to design the participation process. Stakeholders were not well informed about how to participate in a meaningful way. It remains to be seen whether the input...

AI summary The text highlights inadequate stakeholder consultation in the IRP process, limited economic variables in the IRP scope (e.g., clean-tech subsidies, economic development), and calls for better metrics to account for climate damage costs. It also suggests exploring premium/subsidized tariffs to address energy poverty and proposes a Universal Service program.

N-18Response to Comments - NSPI 1 passage
IRP Final Report Comments – Bates White p. pp. 13-35
Combustion Turbines Finding (2c) (3a) (3b) Roadmap (3) Overall, NSPI's work in this area was responsive to our recommendation, and we agree that the outcome of the modeling suggests sustaining the existing units. Going forward, however, th...

AI summary The document discusses the evaluation of combustion turbines by NSPI, noting that while the outcome of the IRP screening analysis supports sustaining existing units, the Board cautions against assuming perpetual operation or full customer funding for capital investments. Concerns are raised about the simplistic modeling and potential discrepancies between forecasts and actual performance.

78518Letter enclosing DSM Potential Study 1 passage
Stakeholder Comment How Comment was Addressed p. p. 0
Stakeholder Comment How Comment was Addressed Provide information regarding the source of inputs and assumptions E1 provided sources for inputs (including incremental costs) along with the Draft Potential Study Report on July 15, 2019. (in...

AI summary Stakeholders requested information on the sources of inputs and assumptions, including incremental costs, which E1 provided in the Draft Potential Study Report. Another stakeholder suggested using updated avoided costs, but E1 argued against it, citing the need for a rigorous regulatory process and stakeholder review.

81474Letter from Bruce Cameron re reponse to initial run on scenarios 1 passage
Section 2 p. pp. 0-1
o the value of DERs, especially when combined with storage. However, we believe there will likely be the need for additional discussions on these matters, and how to incorporate them into the Roadmap. Also, several NS Municipalities have e...

AI summary The text highlights the importance of discussing DERs and their integration with storage into the Roadmap. It also raises questions about whether Community Solar PV Gardens align with the model's definition of DERs, noting interest from NS Municipalities in this concept.

Disclaimer: These summaries were generated by AI from the filings they describe. We take care to make them accurate, but errors are possible - and they aren't advice. Only the filings themselves are the record: if you're relying on something here, confirm it against the source documents or the Nova Scotia Energy Board's own record. Full disclaimer →