Topic:"Rate Design" in M11927

r n a os CI # 50518 - HYD Ruth Falls Main Dam Refurbishment Consulting 246,562 1,877,234 1,630,672 Offsetting costs as dictated by the Fisheries Act Authorization. Additional costs for studies associated with confirmation of the improvemen...

AI summary The document outlines the consulting costs associated with the Ruth Falls Main Dam Refurbishment project, including expenses related to environmental permits, fish passage upgrades, archaeological assessments, and mitigation efforts with the Mi'kmaq. These costs are dictated by the Fisheries Act Authorization and environmental permits.

CI 50518 CA IR-5 Attachment 19 Page 174 of 423 REDACTED (CONFIDENTIAL INFORMATION REMOVED) 3 # Indicators Condition Choices Data Definitions/Explanations Protection and off road vehicles appear to effectively exclude or divert visitors and...

AI summary The text outlines various indicators and condition choices related to environmental protection, consumptive uses, domestic wells, and calcareous fen within a specific area. It includes data on wildlife disturbance, sustainable consumptive uses, proximity of domestic wells, and calcareous fen identification.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO (NSUARB M11927) NSPI Responses to The Consumer Advocate Information Requests 1 However, NS Power does not expect this high end estimate to be required by DFO and, as 2 such, the Compan...

AI summary NS Power estimated a budget of $500,000 for offsetting the environmental impact of the Ruth Falls Main Dam Refurbishment Project, based on feedback from DFO. An additional $500,000 was included as a contingency for potential additional offsetting requirements during the regulatory review and Crown consultation process.

REDACTED 1 (b) Please refer to CA IR-13, part (c). 2 3 (c) In the original submission KMKNO Capacity Payments were budgeted and added to the 4 "Consulting" cost code in the amount of $ instead of a dedicated "Mi'kmaq 5 Engagement" cost cod...

AI summary The document discusses the budgeting of KMKNO Capacity Payments under the 'Consulting' cost code rather than a dedicated 'Mi'kmaq Engagement' code. It also addresses archaeological costs for the Ruth Falls Project and legislative requirements for the sale of hydro assets, including approvals from the Public Utilities Act and federal legislation.

CONCEPTUAL LEVEL - OPINION OF PROBABLE CONSTRUCTION COST ASSUMES (2) 7 MONTH CONSTRUCTION SEASONS (COST IN $2017) ITEM# ITEM DESCRIPTION QUANTITY UNIT PRICE ($) UNIT TOTAL ($) TOTAL ($) WALKWAY MOUNTING CONNECTIONS 1 LS $ 24,000 $ 24,000 C...

AI summary The text presents a conceptual-level opinion of probable construction costs for a project, assuming a 7-month construction season with costs estimated in 2017 dollars. The table outlines various construction items, including walkway mounting connections, concrete disposal, and fish passage modifications, along with associated costs and a 20% contingency.

REDACTED Description Increase in costs (in Thousands) ADDITIONAL SCOPE: NEW PERMITTING REQUIREMENTS Fish Passage upgrades $1,630 Engineering support for environmental permit $15 application Barn Swallow nest removal $11 Pre-tree clearing n...

AI summary The text outlines various cost increases associated with a project, including fish passage upgrades, archaeological engagement, and extended construction timelines. The table details specific line items with associated costs, such as engineering support, environmental permits, and construction-related expenses.

CI 50518 NSUARB IR-12 Attachment 4 Page 9 of 57 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Ruth Falls Dam Refurbishment S 35(2)(b) Fisheries Act Authorization Supporting Information #1 Monitoring Activities personnel. The system will be m...

AI summary The document outlines NS Power's plan for water management during the Ruth Falls Dam refurbishment, including continuous downstream discharge to maintain fish passage and comply with regulatory requirements. The proposed system has been used successfully by the Halifax Regional Municipality, and NS Power intends to seek a variance from ECC for modifications to flow releases.

Data Report 7716: Ruth Falls Watershed, NS Page 22 of 22 # recs CITATION 1 1 McKendry, Karen. 2016. Rare species observations, 2016. Nova Scotia Nature Trust, 19 recs. NatureServe Canada. 2018. iNaturalist Butterfly Data Export . iNaturali...

AI summary The document presents a list of citations related to biodiversity observations and specimen data in the Ruth Falls Watershed, Nova Scotia. It includes records from various researchers, institutions, and personal communications, focusing on rare species and ecological data.

NON-CONFIDENTIAL 1 Request IR-4: 2 3 Refer to N-1 ATO, page 3 of 10, para 2. Extended Construction Timeline, in which the 4 Company concluded that the extended timeline led to increased project costs, including 5 increased material costs,...

AI summary The response to Request IR-4 explains that increased material costs were driven by changes in steel and other commodity prices since 2018, as well as the need to meet environmental regulatory requirements. A scope change was necessary to improve fish passage at Ruth Falls dam, which added additional costs not included in the original ACE 2019 filing.

2.2.3 Conclusion - In Midgard's opinion NS Power was acting reasonably in its interactions with NSECC. The delays associated - with the watercourse alteration permit issuance appear to stem from issues that originally initiated with the -...

AI summary Midgard concludes that NS Power acted reasonably in its interactions with NSECC, with delays in watercourse permit issuance primarily attributed to DFO's FAA process. NS Power has not detailed the breakdown of its cost overages related to environmental permitting, but the root cause appears to be DFO requirements.

- 4 Two submitted applications (the original Gaspereau and Tusket applications) in which refurbishment 5 or remediation of a dam was associated with archaeological costs on the order of $150,000 - 6 $200,000. - 7 Was likely well into its p...

AI summary The text refers to two applications involving the refurbishment or remediation of dams (Gaspereau and Tusket) where archaeological costs were estimated between $150,000 and $200,000. These costs were later significantly increased in the ATO applications.

5.1.1 NS Power Submission - The Project involves the refurbishment of the Ruth Falls Main Dam's water-retaining structures, with five - alternatives reviewed during the conceptual design phase: [45](#page-29-1) - 1. Option 1: Replace the e...

AI summary NS Power submitted a proposal for the refurbishment of the Ruth Falls Main Dam, presenting five design alternatives. Option 4 was selected due to its cost-effectiveness. NS Power argues that re-evaluation of the options was unnecessary because all would be similarly impacted by delays in the Fisheries Act Authorization and environmental permitting.

6.2.2 Scope Increases - Overall Midgard concludes that the cost increases due to scope change are reasonable. Fish passage - modifications and additions are the result of DFO requirements, and therefore out of NS Power control. This - acco...

AI summary Midgard concludes that cost increases from scope changes are reasonable, primarily due to DFO requirements for fish passage modifications, which are outside NS Power's control.

6.4.1 Considered Alternatives - Despite Project costs increasing by 113% and $8.2M, NS Power has not re-evaluated its decision to not - consider a decommissioning option. Midgard understands the stated justifications for this (that the Pro...

AI summary Midgard argues that despite a 113% increase in project costs and an additional $8.2M, NS Power has not reconsidered its decision to exclude a decommissioning option. Midgard suggests that the NSUARB should have had the opportunity to evaluate whether a decommissioning option would be in the best interest of ratepayers.

Table 3: Nova Scotia CPI Trend19 Table 4: Canada IPPI Trend20 Table 5: Ruth Falls Archaeological Costs24 Table 6: Comparison of Recent Project Archaeological Costs25 Table 7: Ruth Falls Main Dam Refurbishment Variance Summary28 Table 8: 20...

AI summary The document presents a series of tables detailing various cost-related data, including archaeological costs, labour costs, materials costs, administrative overhead, and other expenses associated with projects such as the Ruth Falls Main Dam Refurbishment and the 2019 ACE and ATO applications.

5.2.4 Conclusion - As Midgard noted in Section [3.1.2,](#page-19-2) NS Power was facing an environment of dramatically increasing costs - between its Original Application and the ATO Application. On its face this would not appear to fully...

AI summary Midgard highlights an 87% increase in material costs for NS Power between the 2019 ACE Application and the ATO Application, attributing it to inflation and potential misclassification of costs. The increase is in line with the overall project cost increase, but clarity is needed to determine the reasonableness of the material costs.

Table 15: ATO Application Costs – Contracts[54](#page-34-1) Description Total Estimate ($) General Contract - LNTP $1,136,916 Mobilization / Demobilization $125,000 Environmental Management $25,000 Water Controls $60,000 Concrete Works $1,...

AI summary Table 15 presents the estimated costs for various contracts related to the ATO application, including items like general contracts, environmental management, construction supervision, and upgrades to fishway systems. The total estimated cost is approximately $6.25 million.

is the official figure submitted for regulatory review. However, Midgard recommends that NS Power reconcile this discrepancy to ensure clarity in the reported costs. M08984, NSPI 2019 ACE Plan, Exhibit N-2(C), CI 50518, p. 4 of 4. M11927,...

AI summary The document discusses NS Power's efforts to reconcile discrepancies in reported costs and mentions delays in the DFO Fisheries Act Authorization process affecting the Ruth Falls main dam refurbishment. Despite safety concerns limiting cost minimization, the rubber dam control building was completed by September 2022, reducing deferral costs.

5.3.5 Conclusion - 1. Contracts: The $2,689,000 increase in contract costs reflects the expanded project scope and evolving requirements, including fish passage upgrades, construction supervision, and archaeological mitigation. While the $...

AI summary The conclusion discusses the reasons for increased contract and contractor administrative overhead (AO) costs, attributing them to expanded project scope, regulatory delays, and environmental permitting. Midgard concludes that these cost increases are reasonable, except for archaeological costs, which may not be a valid reason for variance.

7.3.2 Potential Additional Cost Increases - Midgard is concerned that the Project remains exposed to several risk areas (environmental compensation - costs, archaeological costs, and geotechnical risks) that have the potential to cause add...

AI summary Midgard is concerned that the Project may face additional cost increases due to environmental compensation, archaeological, and geotechnical risks. These risks could lead to cost overages beyond current contingency allowances and Class 1 error bounds. Midgard suggests that an analysis of a decommissioning option could provide more clarity on potential cost overruns.

NON-CONFIDENTIAL - a) As stated in the quoted passage, Midgard has not made any assumptions regarding how much of the - b) See IR Response 14(b). Response IR-15: - c) Yes. Regardless of whether the costs were incurred in responding to DFO...

AI summary Midgard acknowledges that the $4.4 million in cost overages is attributed to interactions with DFO or NSECC, primarily due to delays caused by DFO requirements. These delays were exacerbated by NS Power's inability to provide finalized design drawings and contractor documentation, resulting from shifting project designs and schedules.

CI 50518 – HYD Ruth Falls Main Dam Refurbishment - $15,445,508 (ATO) (NSUARB M10632) Midgard Consulting Inc. Responses to Industrial Group Information Requests 1 Request IR-16: 4 5 overstated, and are in line with previously estimated amou...

AI summary Midgard Consulting Inc. responds to information requests regarding the HYD Ruth Falls Main Dam Refurbishment project, noting that archaeological costs were significantly overstated and may not have materially affected the original decision on the capital expenditure.

- Response IR-31: - a) Midgard considers NS Power's July 2025 start time reasonable, despite the reported six-month FAA - delay. As noted in Midgard's response to IR-11(b), NS Power's phased approach mitigates evolving - DFO requirements,...

AI summary Midgard finds the July 2025 start time for NS Power's project reasonable despite a six-month FAA delay, noting a phased approach helps manage evolving DFO requirements. However, Midgard expresses concerns about potential delays, environmental offsetting costs, and the possibility of significant cost overruns, citing historical examples like Tusket and Gaspereau.

12 While Midgard ultimately concludes that the archaeological costs sought for approval in the Ruth 13 Falls ATO are not overstated, and are in line with other projects, Midgard concludes that NS Power 14 ought to have known the archaeolog...

AI summary Midgard concludes that NS Power's archaeological costs for the Ruth Falls ATO are not overstated but were significantly underestimated, particularly in categories such as Contracts, Consulting, and Mi'kmaq Engagement, suggesting there may not be a valid reason for the variance.

CI 50518 – HYD – Ruth Falls Main Dam Refurbishment ATO – Reply Evidence Redacted 1 previous archaeology completed on the Sheet Harbour Hydro System, a low density of submerged 2 archaeological sites were identified. 3 4 The Wright's Dam Re...

AI summary The document discusses the archaeological costs associated with the Ruth Falls Main Dam Refurbishment ATO, noting that these costs were necessary to put the asset into service and were not unreasonable. It highlights collaboration with the Mi'kmaq of Nova Scotia and lessons learned from previous projects.

1 4.0 DECOMMISSIONING 2 3 In its evidence, Midgard states: 4 …despite Project costs increasing by 113% and $8.2M, NS Power has not re-5 evaluated its decision to not consider a decommissioning option. Midgard 6 understands the stated justi...

AI summary Midgard argues that NS Power should have considered decommissioning the Ruth Falls Dam and Powerhouse, despite increased project costs, and that the NSUARB should have evaluated this option for ratepayer benefit. NS Power responded by analyzing decommissioning costs based on existing data and forecasts from 2025 to 2035.

CI 50518 – HYD – Ruth Falls Main Dam Refurbishment ATO – Reply Evidence Redacted 1 5.0 POTENTIAL ADDITIONAL COST INCREASES 2 3 Midgard states that it is concerned that there are several areas where the project remains exposed 4 to risk for...

AI summary Midgard raises concerns about potential additional cost increases due to environmental, archaeological, and geotechnical risks beyond contingency allowances. NS Power responds by stating they have been working with the Confederacy of Mainland Mi'kmaq and DFO to address these concerns, including submitting an updated Fisheries Act Authorization with a revised offsetting plan.

REDACTED Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M11927 Nova Scotia Power Inc. - CI 50518 – HYD Ruth Falls Main Dam Refurbishment – $15,445,508 (ATO) Compliance...

AI summary NS Power received the Fisheries Act Authorization for the Ruth Falls Main Dam Refurbishment project and has prepared a Net Present Value analysis comparing refurbishment to decommissioning options. The Company plans to file an amended application once the authorization is obtained.

AMENDED HEARING ORDER In Nova Scotia Power's (NS Power) 2019 Annual Capital Expenditure (ACE) Plan proceeding, the Board approved NS Power's capital application for CI 50518 – HYD Ruth Falls Main Dam Refurbishment, in the amount of $7,244,...

AI summary The document outlines an amended hearing order for Nova Scotia Power's request to overspend on the HYD Ruth Falls Main Dam Refurbishment project. The Board has approved a paper hearing and granted Midgard Consulting Inc. additional time to submit evidence. The proceeding involves an Authorization to Overspend (ATO) of $8,201,086, increasing the total capital cost to $15,445,508.

1.1 Project Background [5] In 2015, NS Power engaged Kleinschmidt as a consultant to assess the design adequacy of NS Power's Sheet Harbour Hydro System's water retaining structures. The assessment evaluated the structures' stability under...

AI summary In 2015, NS Power commissioned Kleinschmidt to assess the Sheet Harbour Hydro System's water retaining structures, which led to a 2019 ACE Plan approval for a project addressing deficiencies in the Ruth Falls Dam. The current ATO application requests an increase from the originally approved amount due to increased environmental permitting, extended timelines, and archaeology and Mi'kmaq engagement costs.

2.0 EVIDENCE AND SUBMISSIONS [8] One of the three primary reasons identified by NS Power in the ATO application for the project cost variance is related to additional environmental permitting requirements. Out of the total $8.2 million ATO...

AI summary NS Power's ATO application includes a request for additional funds due to environmental permitting requirements, particularly related to the Ruth Falls Reservoir project. The changes to the Fisheries Act in 2018 necessitated obtaining a Fisheries Act Authorization (FAA). The project's cost was submitted for Board approval in 2019, even though permits had not yet been obtained, as this is a common practice during the preliminary design phase.

t increase in archeological costs, the Industrial Group underscored the need for an economic assessment and perhaps even an alternative that is more cost-effective while offering longer-term benefits. [48] The Industrial Group also agreed...

AI summary The Industrial Group emphasized the need for an economic assessment of archaeological costs and questioned the cost-effectiveness of the proposed refurbishment project. They recommended delaying approval of the ATO until a more thorough analysis of alternatives is conducted, citing insufficient evidence of the project's benefit to ratepayers and the lack of a FAA permit.

3.2 Preferred Refurbishment Option [65] In approving NS Power's 2019 ACE Plan, the Board agreed with NS Power that Option 4 was the preferred and most economic refurbishment alternative for the project. As noted above, NS Power's CEJC expl...

AI summary The Board approved NS Power's 2019 ACE Plan, finding that Option 4 remains the preferred refurbishment option. NS Power did not update its economic analysis due to expected uniform cost increases from FAA and extended timelines, and no other parties challenged this reasoning.

3.3 Approval of Refurbishment Project Costs [67] The Board recognizes that the current ATO application represents a significant cost increase compared to the original Board-approved project cost. However, Midgard concluded that project cos...

AI summary The Board acknowledges a significant cost increase in the ATO application for the refurbishment project but finds that increases related to environmental permitting and the FAA are reasonable. However, Midgard highlights ongoing risks related to environmental, archaeological, and geotechnical costs that could exceed the contingency allocation.

complete the offsetting work. The updated costs filed in NS Power's amended ATO application are reflective of the proponent's unit cost rate to complete the required offsetting as established by DFO. NS Power also addressed Midgard's recom...

AI summary NS Power updated its ATO application with revised costs for offsetting work based on DFO-established rates. It also addressed Midgard's recommendation regarding construction timelines, noting that alternative access routes eliminated the need for certain infrastructure. NS Power clarified that decommissioning of the Ruth Falls development would not affect the upstream Sheet Harbour Hydro System, hence the term 'partial decommissioning'.

Although the costs of the Project have increased since receiving Board approval, the primary justification of the Project remains the same: refurbishment of the Ruth Falls Main Dam water-retaining structures (embankments, spillway and slui...

AI summary The text discusses the increased costs of a dam refurbishment project and requests clarification on the justification for the project, the consideration of alternative options such as selling or decommissioning the asset, and the calculation of additional contingency costs related to potential offsetting costs from DFO.

AMENDED HEARING ORDER In Nova Scotia Power's (NS Power) 2019 Annual Capital Expenditure (ACE) Plan proceeding, the Board approved NS Power's capital application for CI 50518 – HYD Ruth Falls Main Dam Refurbishment, in the amount of $7,244,...

AI summary Nova Scotia Power applied for an Authorization to Overspend on the HYD Ruth Falls Main Dam Refurbishment project. The Board approved the original capital application in 2019 and has now set an amended timetable for the proceeding, allowing Board Counsel Consultants to submit additional evidence.

1 2 page 50, line 17)? If not, why not? If so, how do these other cost increases impact the analysis? 3 (c) Are there additional cost implications in relation to the four-year storage of 4 these rubber dams outside prior to their installat...

AI summary The text discusses questions raised regarding cost implications of storing rubber dams for four years before installation, the savings from early acquisition of these dams, and the reasonableness of storage and inspection costs if NSPI caused project delays. It also addresses archaeological cost estimates for the Ruth Falls project and whether they were appropriately estimated.

10 Request IR-23: 11 Reference: N-9, page 44 lines 8-14. With respect to the Mi'kmaq observer costs, as noted in Section 4.1 above Midgard considers that NS Power could have known at the time of its ACE submission that its archaeological c...

AI summary Midgard concludes that the increased Mi'kmaw engagement costs associated with NSPI's ACE submission are reasonable. The question focuses on whether NSPI should have known these costs would be higher and the basis for Midgard's assumption, particularly in relation to the Fisheries Act amendments and archaeological costs.

- Reference: N-9, page 51, lines 14-20. - 9 Midgard quotes NSPI with respect to how it determined the contingency amount. Please confirm - 10 the source of this statement. - Request IR-27: - Reference: N-9, Revised Report, page 52, lines 1...

AI summary NS Power and Midgard discuss the contingency budget for offsetting requirements in a project. NS Power uses a 20,000 m² estimate at $25/m², resulting in a $500,000 contingency. Midgard supports this as a prudent measure, but questions the rationale behind NS Power's unit rate selection.

sed 10 offsetting was considerably less for Ruth Falls" and that "the costs / m 2 was considerably higher". 11 The DFO then asked NSPI to update the offsetting plan "based on the discussion". - 12 (a) Has Midgard reviewed these communicati...

AI summary The DFO raised concerns about the offsetting plan for Ruth Falls, noting higher costs per square meter compared to other projects. Midgard is being asked to review and explain its position on the discrepancies, including whether it has considered the DFO's communications and the spreadsheet outlining the differences.

- 28 (f) How are offsetting measurements usually determined on hydro projects 29 such as this? (g) Has Midgard considered the DFO's concerns with respect to "high 7 8 (d) If there are additional delays in receiving the FAA, would this furt...

AI summary The text includes questions about offsetting measurements on hydro projects, concerns from the Department of Fisheries and Oceans (DFO), potential delays in receiving the Federal Assessment Agreement (FAA), and the reasonableness of refurbishment costs. It also references a request for information (IR-32) and a specific page reference.

Possible Decommissioning Nova Scofia Power states in its original applicafion that it considered five different opfions for carrying out the refurbishment that was required to the dam, spillway and sluiceway and chose the opfion that was m...

AI summary Nova Scotia Power considered refurbishment as the most cost-effective option for the Ruth Falls dam but did not reassess this decision or evaluate decommissioning costs in its application. Midgard Consulting suggested decommissioning might not be economic, but the Consumer Advocate recommends including decommissioning as an option in future applications.

Delivered by E-mail Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 3rd Floor, 1601 Lower Water Street PO Box 1692, Unit "M" Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M11927 - NSPI - CI 50518 – HYD Ruth...

AI summary The Industrial Group opposes the approval of NSPI's ATO for the Ruth Falls Main Dam Refurbishment, citing a significant cost increase due to delays in environmental permitting and a lack of diligence in the original application. They argue that NSPI should resubmit with a more thorough analysis of alternatives or have the application placed in abeyance.

y requirements for the IDF and earthquake loading conditions.[8](#page-3-2) However, the application as filed does not properly allow for a review of the updated economic justification of the project. To determine whether a project is just...

AI summary The document states that there is insufficient evidence to assess whether the project remains economically justified. The Board would need to consider alternatives such as decommissioning, but NSPI has not provided a full analysis of these options, despite requests from the Industrial Group. Midgard emphasizes the importance of reviewing decommissioning as part of the economic justification process.

is $84.5 million but there are limited details on how this was calculated, and the data used is outdated. There is further reference to the Depreciation Study, which is not yet available for review. The Industrial Group further submits tha...

AI summary The Industrial Group argues that there is insufficient evidence to support that the project remains in the best interest of ratepayers, citing outdated cost data and a lack of updated cost comparisons. NSPI claims that re-evaluation was unnecessary due to uniform cost increases from environmental permitting, but the Industrial Group and Board staff have requested this information, which remains unanswered.

e amounts noted, however, do not account for the $1.4M increase in costs. Nor does this acknowledge the fact that the costs for "contracts" have also dramatically increased by $2.6M.[70](#page-14-8) In response to an Industrial Group IR re...

AI summary The document argues that the amounts applied for are not the lowest reasonable cost to ratepayers, citing a significant increase in material costs and the lack of evidence that competitive procurement was used for some items. The application record does not provide sufficient justification for the cost increases, which far exceed average inflationary increases.

been in a position to provide any type of reasoned estimate of the additional cost as a result of those potential changes, but that docs not mean that they should not have identified it as a concern. The uncertainty as to the future approv...

AI summary The SBA argues that NS Power should provide regular updates to the Board regarding project delays and costs related to fisheries infrastructure and archaeological expenses. Concerns include uncertainty about DFO approval and past overspending on archaeological work.

Economic Justification: Considering Alternative Refurbishment Options The IG has been critical of the fact that the project justification for this application has not changed. NS Power agrees that the 'Justification' section of the applica...

AI summary The Industrial Group (IG) criticizes NS Power for not updating the project justification in the ATO application, while NS Power defends it as standard practice. The IG also questions whether the recommended option is truly the lowest cost for customers. The application is based on safety concerns from a Dam Safety Review, with the need to address structural issues at the Ruth Falls dam.

Midgard views "NS Power's actions in navigating these challenges as generally prudent, in its attempts to respond to DFO's requests in the face of an evolving regulatory environment."16F 17 Further, projecting that an FAA would be required...

AI summary Midgard Consulting Inc. acknowledges NS Power's efforts in addressing DFO's evolving regulatory requirements but notes that the extensive fish passage improvements mandated by DFO could not have been reasonably foreseen at the time of the original FAA application. These requirements were only identified after multiple reviews and would have required significant cost adjustments not predictable at the time.

2.0 EVIDENCE AND SUBMISSIONS [8] One of the three primary reasons identified by NS Power in the ATO application for the project cost variance is related to additional environmental permitting requirements. Out of the total $8.2 million ATO...

AI summary NS Power attributed part of its ATO request to additional environmental permitting requirements, including a Fisheries Act Authorization. Bill C-68, passed in 2019, required these permits. NS Power submitted the project cost for approval in 2019 before obtaining necessary permits, a common practice during the preliminary design phase.

t increase in archeological costs, the Industrial Group underscored the need for an economic assessment and perhaps even an alternative that is more cost-effective while offering longer-term benefits. [48] The Industrial Group also agreed...

AI summary The Industrial Group highlighted concerns regarding the economic assessment of archaeological costs and the lack of detailed decommissioning information provided by NS Power. They recommended delaying the ATO approval until a more thorough analysis of alternatives is conducted and additional requirements are addressed.

3.2 Preferred Refurbishment Option [65] In approving NS Power's 2019 ACE Plan, the Board agreed with NS Power that Option 4 was the preferred and most economic refurbishment alternative for the project. As noted above, NS Power's CEJC expl...

AI summary The Board approved NS Power's 2019 ACE Plan, recognizing Option 4 as the preferred and most economic refurbishment alternative. NS Power did not update its 2019 economic analysis, citing similar cost increases across all options and constructability/safety concerns. Midgard found NS Power's reasoning reasonable, and the Board accepts this, reaffirming Option 4 as the preferred option.

3.3 Approval of Refurbishment Project Costs [67] The Board recognizes that the current ATO application represents a significant cost increase compared to the original Board-approved project cost. However, Midgard concluded that project cos...

AI summary The Board acknowledges a significant cost increase in the ATO application for the refurbishment project but accepts that increases related to environmental permitting and the FAA are reasonable. However, risks such as environmental compensation, archaeological, and geotechnical costs remain, which could add millions to the project cost beyond the allocated contingency.

of when specific capital expenditures over the eleven-year timeframe of the decommissioning option would be made. The lack of this information also limits the ability to test NS Power's cost estimate. [82] Considering this, the Board is co...

AI summary The Board is concerned that the current ATO proceeding does not include a full comparison of the Ruth Falls decommissioning option. The Board has put the application on hold until NS Power receives the FAA from DFO and will require a detailed NPV analysis comparing decommissioning with refurbishment in the amended application.

- has an NPV that is approximately $50.4 M greater than the decommissioning alternative: Alternative After Tax WACC PV of Revenue Requirement PV of EVA / NPV Rank (based on PV of RR) IRR Disc Pay Α Dam Refurbishment 5.81% -21,926,086 12,51...

AI summary The text presents a comparison of two alternatives—Dam Refurbishment and Partial Decommissioning—based on financial metrics such as NPV, IRR, and discount payback period. The Dam Refurbishment alternative has a significantly higher NPV compared to the decommissioning option, which is highlighted as a key consideration in the analysis.

Unit Rates for Offsetting The IG expresses concern about the unit rate used for offsetting by NS Power, stating: …while the gross area of degraded fish habitat to be offset is now certain, the unit rate and its validity remain unclear.[6](...

AI summary The IG raises concerns about the validity of the unit rate used for offsetting by NS Power, noting that while the area of degraded fish habitat is known, the rate remains unclear. The initial rate of $25/m2 was an estimate used for budgeting, and updated costs reflect the unit rate from the proponent's proposal.

estimated cost of decommissioning the entire Sheet Harbour system, even accounting for inflation. This is suggestive of a much broader issue with the potential for dam decommissioning in Nova Scotia. The Industrial Group expressed similar...

AI summary The document discusses concerns raised by the Industrial Group regarding the estimated costs of decommissioning the Sheet Harbour system and the lack of justification for offsetting unit cost rates used by NS Power. The Industrial Group recommends using the original cost estimate and suggests cost management and reporting requirements.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 2 Appendix A Page 1 of 1 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Account NSEB Approved Amount Spend-to-Date Contingency/ Unbudgeted Spend-to-Date Comments $8,074.00 $8,074.0...

AI summary The document outlines a contingency report for the Ruth Falls Main Dam Refurbishment, detailing approved amounts, actual spending, and unbudgeted expenditures. Key items include additional costs for water supply arrangements, meals, Mi'kmaq engagement, and administrative overheads. The report highlights discrepancies in cost allocations and the need for contingency funds.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 3 Appendix A Page 1 of 1 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Account NSEB Approved Amount Spend-to-Date Contingency/ Unbudgeted Spend-to-Date Comments Sponsor/Other Dona...

AI summary The document outlines contingency and unbudgeted spending related to the Ruth Falls Main Dam Refurbishment project, including adjustments for incorrect cost code applications, additional meal costs for community engagement and fish rescue operations, and increased Mi'kmaq engagement expenses.