Topic:"Rate Design" in M12661

2.2 Demand Charge - In accordance with the Company's Cost of Service Study (COSS), demand-related costs are proposed to be allocated to the ELID Tariff class based on PHP assigned demand at the time of the three coincident peaks (3CP). Rec...

AI summary The document discusses the allocation of demand-related costs to the ELID Tariff class based on PHP's demand during three coincident peaks (3CP), proposing a fixed charge using historical 65 MW data. NS Power disagrees with PHP's argument for using 8 MW, citing the GRA Settlement Agreement and cost-of-service treatment. Proposed 2026/2027 demand charges are $12.872 and $14.310 per kVA/month, respectively.

- ELID Tariff includes provision for PHP load to be held as Operating Reserve as required by system - conditions. The interruptible notification processes, penaltiesfor non-compliance, etc. are the same - as the LIIR provisions.

AI summary The ELID Tariff includes provisions for PHP load to be held as Operating Reserve as required by system conditions. The interruptible notification processes and penalties for non-compliance are the same as those under the LIIR provisions.

DATE FILED: December 29, 2025 Page 11 of 19 1 2.7 Billing Provisions 2 3 In recognition of the large revenue associated with service to PHP, the ELID Tariff retains the 4 ELIADC provisions for weekly billing. 5 6 2.8 Tariff Term 7 8 As an...

AI summary The document outlines billing provisions and tariff terms related to PHP Wind Ltd. (PHPW) under the ELID Tariff. It discusses the inclusion of PHP in NS Power's fuel hedging portfolio and the notice period required for PHP to transition to a different tariff. The document also references the Power Sales Agreement between NSPI and PHPW, detailing energy sales and delivery obligations.

4.0 CONCLUSION - Development and approval of the Extra Large Industrial Dispatchable Tariff will mark an - important milestone in the evolution of service to the province's largest electricity consumer. PHP - has progressed from a customer...

AI summary The conclusion highlights the development of the ELID Tariff as a milestone for PHP, transitioning from load retention to embedded cost-based service. It emphasizes increased fixed cost contributions, price stability, and simplified regulatory processes through year-end benefit calculations. The tariff leverages PHP's load flexibility for customer value and builds on two decades of stakeholder collaboration.

EXTRA LARGE INDUSTRIAL DISPATCHABLE TARIFF Page 1 of 8 (25,000 kVA and over) Rate Code X The Extra Large Industrial Dispatchable (ELID) Tariff is an Above-the-Line (ATL) embedded costbased tariff wherein the Company will dispatch the load...

AI summary The ELID Tariff is an ATL embedded cost-based rate structure where NS Power dispatches Port Hawkesbury Paper LP's load to manage demand, reduce costs, and return savings to the customer. Charges are determined via General Rate Applications or regulatory proceedings, with annual year-end calculations under the Dispatchable Rider.

EXTRA LARGE INDUSTRIAL DISPATCHABLE TARIFF Page 2 of 8 (25,000 kVA and over)

AI summary This document outlines the Extra Large Industrial Dispatchable Tariff, applicable to industrial customers with a demand of 25,000 kVA and over. It provides details about the specific rates and conditions for this category of customers.

MINIMUM MONTHLY CHARGE The minimum monthly charge shall be the monthly Demand Charge and the Customer Charge.

AI summary The minimum monthly charge is defined as the sum of the monthly Demand Charge and the Customer Charge, establishing a baseline billing structure for customers.

AVAILABILITY This tariff is applicable to transmission-connected customers having a regular monthly peak metered demand of at least 25,000 kVA. The customer must own the transformation facilities, and no transformer ownership credit is app...

AI summary The tariff applies to transmission-connected customers with a monthly peak demand of at least 25,000 kVA. Customers must own transformation facilities, and no transformer ownership credit is provided.

POWER FACTOR CORRECTION Under normal operating conditions, an average power factor over the entire billing period, calculated for kWh consumed and lagging kVAR-h, as recorded, of not less than 90% lagging for the customer load shall be mai...

AI summary The document outlines power factor correction requirements, specifying that customers must maintain an average power factor of at least 90% lagging over the billing period. If this is not met, adjustment factors will be applied to the energy charge.

INTERRUPTIBLE RIDER TO THE ELID TARIFF (RATE CODE X) The Customer will receive a per month per kilovolt ampere reduction in demand charge for billed interruptible demand as shown in the table below. The billed interruptible demand is defin...

AI summary The interruptible rider to the ELID tariff provides a monthly reduction in demand charges based on billed interruptible demand, which is the difference between contracted firm demand and total billing demand. No credit applies if billing demand is equal to or less than contracted firm demand.

Extra Large Industrial Dispatchable Tariff Application – Attachment 1 (25,000 kVA and over) Rate Code X (4) Failure to comply in whole or in part with a requirement to interrupt load will result in penalty charges. The penalty will be comp...

AI summary Attachment 1 outlines penalty charges for Extra Large Industrial Dispatchable customers failing to comply with load interruption requirements. Penalties include a Threshold Penalty based on firm billing costs and a Performance Penalty calculated via a formula involving $15/kVA and $30/kVA multipliers. The structure aims to enforce compliance with load management obligations.

Order of Interruptibility In the event an interruption call is required in order to avoid shortfalls in system electricity supply, interruptible load will be called upon to provide capacity to NS Power in the following order: - (1) Generat...

AI summary The Order of Interruptibility outlines the priority sequence for interrupting load during electricity supply shortfalls, starting with Generation Replacement and Load Following Tariff, followed by Extra Large Industrial Dispatchable Tariff, Shore Power Tariff, and finally the Interruptible Rider to the Large Industrial Tariff. NS Power may adjust this order if necessary.

As compensation for providing this service, the Customer will receive a per month per kilovolt ampere reduction in demand charge for billed interruptible demand as shown in the table below. ELID Priority Interruptible Credit reduction per...

AI summary The Customer will receive a monthly reduction in demand charge per kilovolt ampere for interruptible demand, effective January 1, 2026 and 2027, with rates of $0.764 and $0.767 respectively.

DISPATCHABLE RIDER TO THE ELID TARIFF (RATE CODE X) Customers taking service under the ELID Tariff will also be subscribed to this Dispatchable Rider (DR). Under this Rider, NS Power will be able to actively manage the Customer's load in a...

AI summary The Dispatchable Rider (DR) under the ELID Tariff allows NS Power to manage customer load via an Operating Procedure, applying Interruptible Rider terms for load above firm contracted levels. Savings from dispatch flexibility are credited to customers annually, calculated by comparing actual system costs to a high load factor baseline scenario.

WHEREAS - A. Nova Scotia Power ("NS Power"), along with the Consumer Advocate ("CA"), Small Business Advocate ("SBA"), counsel for the Industrial Group, representing CKF Inc., Crown Fibre Tube Inc., Irving Shipbuilding Inc., K + S Windsor...

AI summary NS Power and customer representatives (including advocates, industrial groups, and municipal utilities) collaborated on a 2026-2027 GRA through meetings, information sharing, technical conferences, and settlement discussions. The process involved standardized filings and expert consultant support, aiming to resolve the GRA on agreed terms.

2026-2027 General Rate Application Settlement Agreement

AI summary The document outlines the 2026-2027 General Rate Application Settlement Agreement, which pertains to the regulatory process for setting electricity rates in Nova Scotia.

2026-2027 General Rate Application Settlement Agreement Extra Large Industrial Dispatchable Tariff Application – Attachment 4 Page 10 of 21 GRA Element Settlement Terms Cost of Capital and Earnings Band a) An overall return on equity of 9%...

AI summary The 2026-2027 General Rate Application Settlement Agreement outlines terms for the Extra Large Industrial Dispatchable Tariff Application. Key elements include maintaining a 9% return on equity, a 40% equity thickness, amendments to the DSM Rider, and removal of the Weather Normalization Mechanism request.

2025 DSM Cost Recovery Rider Charges Effective: January 1, 20265January 1, 2026 The Demand Side Management Cost Recovery Rider (DCRR) charges, along with its components, (PCR) and (BA), for the period from the approved effective date of Ja...

AI summary The 2025 DSM Cost Recovery Rider (DCRR) charges, including Program Cost Recovery (PCR) and Balance Adjustment (BA), apply from January 1, 2025, to December 31, 2025. The BA2 calculation for 2023, based on revenue versus DSM costs, will be applied annually from 2028–2031. The Approved DSM Term refers to the full DSM Plan period (e.g., 2023–2026, 2027–2031).

- 4 NS Power's proposed design of the ELID does not reasonably reflect the 5 firm and interruptible service provided to PHP under the proposed ELID 6 Tariff. PHP does not support the Company's ELID rate design. If the Board 7 prefers NS Po...

AI summary PHP objects to NS Power's proposed ELID rate design, arguing it does not reflect the actual service provided and results in over-recovery. PHP recommends adjusting the design to reflect NS Power's cost of service and align the tariff with updated energy sales forecasts for accuracy.

2 Q PLEASE DESCRIBE NS POWER'S PROPOSED ELID TARIFF FOR PHP. 3 A NS Power is requesting approval of an Extra Large Industrial Dispatchable ("ELID") 4 Tariff for PHP, to be available on, or before, January 1, 2027, following the termination...

AI summary NS Power proposes an ELID Tariff for PHP, replacing the expiring ELIADC Tariff. The ELID includes a Dispatchable Rider allowing NS Power to curtail PHP's load above 8 MW to reduce system costs and ensure reliability. PHP retains 8 MW firm demand rights, with NS Power prioritizing other customers during curtailments.

15 Q HOW IS NS POWER PROPOSING TO PRICE SERVICE UNDER THE ELID? 16 A NS Power states that its proposed ELID rate is patterned after its LI tariff. We have 17 provided a comparison of its Large Industrial Tariff Rate pricing and the ELID in...

AI summary NS Power is proposing to price service under the ELID based on its Large Industrial (LI) tariff. A comparison between the LI tariff and the ELID is provided in Table 1.

3 Q HOW SHOULD THE ELID TARIFF BE CHANGED TO MORE EQUITABLY REFLECT 4 PHP'S FIRM AND INTERRUPTIBLE SUPPLY? 5 A The ELID provides both firm service and interruptible service to PHP. The cost of firm 6 service is based on NS Power's COS, whi...

AI summary The ELID tariff should reflect PHP's firm and interruptible supply by allocating capacity costs based on NS Power's cost of service (COS), including the Planning Reserve Margin (PRM). Interruptible demand beyond firm levels does not incur additional capacity costs as it can be curtailed during shortages.

1 Q IF NS POWER'S PROPOSED ELID TARIFF RATE DESIGN IS PREFERRED BY THE 2 BOARD, HOW SHOULD IT BE MODIFIED TO REFLECT NS POWER'S COST OF 3 PROVIDING SERVICE TO PHP? 4 A If NS Power's structure of the ELID is adopted, PHP will pay for NS Pow...

AI summary If NS Power's ELID tariff is adopted, PHP's interruptible demand should be credited at NS Power's marginal capacity cost ($13.107/KVA) to reflect the avoided cost of adding new peaking resources. This aligns PHP's interruptible load with NS Power's capacity needs during peak periods, ensuring fair cost allocation between PHP and firm customers.

4 Q DESCRIBE THE PHP INTERRUPTIBLE SERVICE CREDIT? 5 A The PHP Interruptible Service Credit is a component of the ELID Tariff that provides a 6 monthly reduction in demand charges when the customer's load is curtailed. According 7 to NS Po...

AI summary The PHP Interruptible Service Credit reduces demand charges for ELID Tariff customers when load is curtailed. NS Power proposed $7.638/kVA (2026) and $7.667/kVA (2027) credits, with a 10% priority addition for ELID under the Order of Interruptibility, which would prioritize ELID interruptions over Large Industrial Tariff customers.

ted 2019 Supply Options Study conducted for NS 12 Power by E3). This value represents the Levelized Cost of Capacity for a "proxy" 100 13 MW Simple Cycle Combustion Turbine using 2019 nominal dollars. 14 Under the proposed ELID, PHP receiv...

AI summary The proposed ELID tariff grants PHP a $7.667/KVA credit for interruptible load, below NS Power's avoided capacity costs ($13.107/KVA). This creates a subsidy where PHP effectively pays NS Power for firm capacity needed by other customers, deeming the proposed tariff unreasonable. The text questions whether setting the interruptible credit at NS Power's full avoided cost would eliminate PHP's capacity charges for interruptible service.

12 Q WHAT DO YOU RECOMMEND THIS BOARD APPROVE AS THE APPROPRIATE 13 R/C RATIO APPLICABLE TO PHP IN THIS PROCEEDING? 14 A We would recommend that an R/C ratio of 1.0 be applied to PHP's rate calculation 15 under the proposed ELID tariff. PH...

AI summary The BOARD recommends an R/C ratio of 1.0 for PHP under the ELID tariff, arguing PHP as a new customer class should pay its full cost to serve without subsidizing or being subsidized by other classes.

Education Background and Work Experience In 1983, Mr. Gorman received a Bachelors of Science Degree in Electrical Engineering from Southern Illinois University, and in 1986, he received a Masters Degree in Business Administration with a co...

AI summary Mr. Gorman holds a B.S. in Electrical Engineering and an MBA in Finance. His career includes roles at the Illinois Commerce Commission, Merrill-Lynch, and Brubaker & Associates, Inc. (BAI), where he conducted financial modeling, utility analyses, rate case testimony, and energy supply evaluations for electric, gas, and steam services.

14 Q. Please explain why PHP is interested in NS Power's Application for an 15 Extra Large Industrial Dispatchable Above-the-Line Tariff. 16 17 A. PHP is currently a below-the-line customer that is billed for the highest priced 18 marginal...

AI summary PHP, a below-the-line customer, seeks an above-the-line tariff for greater energy cost predictability amid volatile marginal pricing. This would reduce risks from uncertain power availability and support long-term investments, especially with their new wind facility under a fixed-price PPA. The tariff would provide stability against hourly pricing fluctuations.

NON-CONFIDENTIAL 1 Request IR-2: 2 3 Please refer to Exhibit N-1, Attachment 4, and Exhibit N-3, page 8 lines 25-27. 4 5 (a) If PHP's request is granted to update the forecast energy requirements for PHP in 6 2026 and 2027, would the chang...

AI summary NSPI responds to questions about PHP's request to update 2026-2027 energy forecasts, stating reduced PHP load would increase fuel costs for other ATL customers by ~0.5%. References to CA IR-2 and M12451 are provided for detailed analysis. The GRA Settlement Agreement's potential contravention is noted but not directly addressed.

NSPI Responses to BW Information Requests 1 Request IR-4: 2 3 Please refer to Exhibit N-3, page 10 lines 3 to 7. 4 5 (a) What was NSPI's role in developing or vetting PHP's referenced forecasted energy 6 requirements for 2026 and 2027? 7 8...

AI summary NSPI responds to BW Information Requests regarding PHP's load forecasts and the ELID Tariff. NSPI states it receives PHP's load forecasts but does not evaluate their validity. The ELID Tariff includes costs related to the FLG through the Base Cost of Fuel and Energy Charge provisions.

REDACTED 1 Request IR-7: 2 3 Please refer to Exhibit N-1. 4 5 (a) Does NSPI consider the ELID Tariff as offering PHP a discounted rate for power 6 relative to other customers? Please explain. 7 8 (b) Is NSPI aware of PHP's financial condit...

AI summary The document contains a series of information requests related to the ELID Tariff and its implications for PHP, including questions about rate structures, financial conditions, and potential impacts if the tariff is not accepted. NSPI is asked to provide detailed responses to these inquiries.

Response IR-7: (a) No, the ELID Tariff demand and energy elements are costed on an embedded cost basis like other above-the-line customers. The costing and pricing of the energy and demand components has been determined through the Company...

AI summary The response addresses the ELID Tariff, stating that it is costed on an embedded cost basis and references the 2026-2027 General Rate Application Settlement Agreement. It also notes that no review of PHP's financial condition has been undertaken and directs to another document for further details on LIIR Tariff rates.

9 The total smoothed revenues of the transmission-connected customers, billed under the 10 LIIR Tariff, are forecast to go down by 5.3 percent in 2027. It is important to note the 11 costing and pricing of the LIIR Tariff does not incorpor...

AI summary The forecasted total smoothed revenues for transmission-connected customers under the LIIR Tariff are expected to decrease by 5.3% in 2027. The LIIR Tariff does not include the load from PHP, and it is not expected that PHP's demand or energy under the LIIR Tariff would match that under the ELID Tariff.

REDACTED 1 • Exh 6.1 (lines 476 to 536) of the 2026 and 2027 COSS, included in Attachments 1 2 and 2 to CA IR-001 (M12451), for determination of energy- and demand-related 3 costs. 4 5 • Tabs "ELID Rate Design," "PHP," and "ELID Rate Table...

AI summary The text references exhibits and attachments from the 2026 and 2027 COSS related to energy and demand-related costs, as well as tabs from an application concerning the ELID Tariff. It also mentions NSPI's responses to BW information requests.

NON-CONFIDENTIAL (e) NS Power intends to continue reporting cause codes for deviation from optimal dispatch on a monthly basis. At the conclusion of the year, NS Power will calculate actual load shifting benefit as a comparison of actual r...

AI summary NS Power plans to monthly report dispatch deviation cause codes and annually calculate load shifting benefits by comparing actual PHP load profiles to theoretical CBL profiles using consistent pricing. It argues that CBL ignores exogenous power prices, potentially increasing costs under levelized pricing. DR credits will use actual load data with flat CBL profiles and randomized outages to ensure equal energy consumption comparisons.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 As noted in NSPI's Application: 4 5 The Tariff is based on the Large Industrial (LI) Tariff under which the 6 7 Company's large industrial customers are served. (N-1, page 3 of 19) 8 … 9 10 As noted in...

AI summary The document discusses the proposed interruptible credit for PHP under the Large Industrial Interruptible Rider (LIIR) Tariff, noting that it is significantly lower than the company's established practice. The response explains that this credit aligns with the 2026-2027 GRA Settlement Agreement.

PARTIALLY CONFIDENTIAL (Attachment Only) 1 Request IR-2: 2 3 (a) Please provide COSS and resulting tariff reflecting all parameters proposed by PHP 4 in its evidence, including: 5 6 (i) designing the capacity charge to reflect PHP's actual...

AI summary The document outlines a request for the provision of a COSS and resulting tariff that reflects specific parameters proposed by PHP, including adjustments to the capacity charge, interruptible credit, revenue-to-cost ratio, and updated forecast energy requirements for 2026 and 2027. The response refers to a partially confidential attachment containing the requested information.

PHP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR

AI summary The document contains a table with entries related to municipal unmetered allocation factors, possibly part of a cost-of-service study or rate application process.

ALLOCATION OF AVERAGE POLE INVESTMENT (1) TOTAL PLANT (2) PRIMARY DEMAND (3) PRIMARY CUSTOMER (4) SECONDARY DEMAND (5) SECONDARY CUSTOMER ( 1) DOMESTIC $338,328 $39,627 $175,796 $30,989 $91,915 ( 2) SMALL GENERAL 18,913 2,166 9,867 1,721 5...

AI summary The document presents a table detailing the allocation of average pole investment across various categories, including domestic, small general, general, and industrial customers, with specific amounts allocated to primary and secondary demand and customer segments. An allocation factor is also provided.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS BY FUNCTIONAL AREAS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : DOMESTIC RATE BASE (Source Exh. 3) Variable Fixed Costs COSTS (Source Exh 6) Unit Cost Demand ($/kW of Class monthl...

AI summary This document presents a detailed breakdown of Nova Scotia Power Inc.'s rate class disaggregation analysis by functional areas for the year ending December 31, 2026. It includes cost allocations across various categories such as generation, transmission/distribution, and retail, along with unit costs and total costs for different rate classes.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : LARGE GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold D...

AI summary This document provides a detailed rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2026, breaking down costs and revenues by generation, transmission/distribution, and retail categories.

(1) REVENUE ELECTRIC REVENUE (1) (2) FULLY ALLOCATED RATE CLASSES (ATL) (3) DOMESTIC (4) SMALL GENERAL (5) GENERAL (6) LARGE GENERAL (7) SMALL INDUSTRIAL (8) MEDIUM INDUSTRIAL (9) LARGE INDUSTRIAL (10) ELI 2P-RTP (11) MUNICIPAL (12) UNMETE...

AI summary The document presents a revenue breakdown by rate class and revenue type, including fully allocated and formula-based rate classes, non-electric revenue sources, and total operating expenses. It is part of a redacted tariff attachment from a regulatory proceeding.

DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL COMPANY (2) (3) SMALL DOMESTIC GENERAL GENERAL (4) (5) GENERAL LARGE (6) SMALL (7) MEDIUM INDUSTRIAL INDUSTRIAL INDUSTRIAL (8) LARGE (9) PHP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (...

AI summary This section outlines the development of allocation factors across various customer segments and load types, including percentages of responsibility for different categories such as demand, generation, and purchasing, along with associated exhibits and data tables.

DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (24) AVERAGE CUSTOMERS ADJ SEASONAL (25) % RESPONSIBILITY 527,767 100.00% 476,846 90.35% 27,443 5.20% 11...

AI summary The text discusses the development of allocation factors for different customer categories, including average customers, seasonal adjustments, and wiring inspection costs. It includes percentages of responsibility and various metrics such as number of bills, revenue, and costs.

EXHIBIT 8B PAGE 1 OF 3 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL (7) MEDIUM (8) LARGE (9) PHP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (41) TOT.RAT...

AI summary The exhibit presents a detailed breakdown of rate base allocations across various categories, including small, medium, and large companies, as well as municipal and industrial sectors. It includes percentages of responsibility and allocation factors for different line items, such as streetlight and generation-related costs.

EXHIBIT 8B PAGE 3 OF 3 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL ELI 2P-RTP MUNICIPAL UNMETERED (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION FACTOR (1) T...

AI summary The document presents a detailed breakdown of expenses and responsibilities across various categories, including total expenses, customer solutions, meter data services, and revenue. Each row includes percentages of responsibility allocated to different customer segments and associated matter numbers. The data reflects financial allocations and advocacy expenses related to regulatory proceedings.

FOR JULY 2026 (1) MWH SALES LOSSES (2) ENERGY LINE (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT D...

AI summary The text presents a detailed table with energy-related metrics, including sales losses, energy line losses, demand losses, and system factors for different customer classes and categories. It includes data for various sectors such as domestic, industrial, municipal, and others. The table also includes sub-totals and totals for different categories, as well as a note about redacted information.

NOVA SCOTIA POWER INC. CLASS MONTHLY DEMAND ADJUSTMENT FACTORS UNDER STANDBY TARIFF FOR THE YEAR ENDING DECEMBER 31, 2026 RATIOS OF AVERAGE OF 3 WINTER MONTH COINCIDENT PEAKS TO MONTHLY COINCIDENT PEAKS ( 1) JANUARY 0.96 0.97 0.96 0.93 0.9...

AI summary The document presents a table of monthly demand adjustment factors under the standby tariff for Nova Scotia Power Inc. for the year ending December 31, 2026. It includes ratios of average of 3 winter month coincident peaks to monthly coincident peaks and seasonal coincident peaks.

INSERT TABLE FOR STANDBY SERVICE TARIFF Classes Jan, Feb, Dec Mar, Apr May, June Jul, Aug, Sep Oct, Nov Domestic 1.00 1.34 2.13 2.26 1.65 Small General 1.00 1.24 1.62 1.59 1.35 General 1.00 1.21 1.47 1.36 1.20 Large General 1.00 0.99 0.93...

AI summary The text presents a table outlining standby service tariff rates for various customer classes in Nova Scotia, with different rates for different months. The table includes rates for Domestic, Small General, General, Large General, Small Industrial, Medium Industrial, Large Industrial Firm, and Unmetered classes.

REDACTED ELID Tariff CA IR-2 Attachment 1 Page 89 of 94 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Line # AVERAGE RATE BASE RATE BASE 2025 RATE BASE 2026 (360) SHORE POWER (361) GEN.REPL./LOAD FOLL. RETAIL PROD 4.97 (13.96) 43.80 4.972 (1...

AI summary The document presents a table with rate base information for various line items, including Shore Power, Generation Replacement, Load Follow, ELIADC, BUTU, and Spill, for the years 2025 and 2026. The table includes details on production, transmission, distribution, and retail for each line item.

NOVA SCOTIA POWER INC. 2027 COST OF SERVICE STUDY ANALYSIS R E F E R E N C E G U I D E EXHIBIT COMPARISON OF REVENUE TO EXPENSE RATIOS 1 FUNCTIONALIZATION OF AVERAGE RATE BASE 2 INITIAL CLASSIFICATION OF AVERAGE RATE BASE 2A FINAL CLASSIFI...

AI summary The document is a reference guide for the 2027 Cost of Service Study Analysis by Nova Scotia Power Inc., containing various exhibits related to revenue, expenses, rate base classification, and allocation factors. It outlines the structure and components of the study for regulatory review.

EXHIBIT 6 PAGE 5 OF 6 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (33) Retail 2% 3% 4% 1% 1% 1% 0% 1% 1% 4% (34) Total 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% (35) (36) AVERAGE CUSTOMER CO...

AI summary The table provides a detailed breakdown of customer-related costs, including distribution and retail credit adjustments, across various customer categories. It includes subtotals and percentages of total costs, as well as average monthly costs per customer for different segments.

RATE CLASS DISAGGREGATION ANALYSIS BY FUNCTIONAL AREAS CLASS : DOMESTIC RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Costs Demand ($/kW of Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Class monthly N...

AI summary The document presents a detailed breakdown of rate class disaggregation by functional areas, including generation, transmission/distribution, and retail. It includes cost allocations, unit costs, and financial figures related to energy sales, reliability, and customer services, with data sourced from various exhibits and cost files.

FOR APRIL 2027 (1) MWH SALES LOSSES (2) ENERGY LINE (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT...

AI summary The text presents a table with various metrics related to energy sales, losses, and demand factors across different customer classes and special programs in April 2027. It includes data on energy losses, demand factors, and system peak demand, but no explicit arguments or discussion of policy, regulation, or stakeholder positions are present.

NOVA SCOTIA POWER INC. SALES, GENERATION AND DEMAND ANALYSIS FOR MAY 2027 (1) MWH SALES LOSSES (2) ENERGY LINE (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMA...

AI summary The document presents a detailed breakdown of Nova Scotia Power Inc.'s sales, generation, and demand analysis for May 2027, including energy sales, losses, demand factors, and system performance metrics across various customer classes and programs.

FOR JUNE 2027 (1) MWH SALES LOSSES (2) ENERGY LINE (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT D...

AI summary The document presents a table with various energy metrics, including sales losses, energy line losses, demand line losses, and system factors, categorized by different customer classes and services. It includes totals and subtotals for different segments, such as domestic, industrial, and municipal, as well as special cases like Shore Power and ELIADC.

FOR THE YEAR ENDING DECEMBER 31, 2027 (1) (2) TOTAL (3) SMALL (4) (5) GENERAL (6) (7) SMALL MEDIUM LARGE (8) (9) (10) (11) (12) SHORE (13) (14) (15) (16) REAL TIME MONTH COMPANY DOMESTIC GENERAL GENERAL LARGE INDUST. INDUST. INDUST. ELI 2P...

AI summary This document presents a detailed table of demand data for various customer categories and months, including total demand, small, general, large, and shore categories, with specific values for each month from January to December 2027. It includes data for different types of demand, such as firm and interruptible rider demands.

SUMMARY OF SYSTEM DEMAND LINE LOSSES SYSTEM COINCIDENT DEMAND LINE LOSSES BY RATE CLASS FOR THE YEAR ENDING DECEMBER 31, 2027 NOVA SCOTIA POWER INC. (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL I...

AI summary The document presents a summary of system demand line losses by rate class for Nova Scotia Power Inc. for the year ending December 31, 2027. The table shows percentages of losses across various rate classes, including domestic, small general, general, large industrial, and others.

REVENUE TO EXPENSE COMPARISON (1) TOTAL (2) TOTAL (3) UNIT COST (4) TOTAL (5) (6) (7) VARIANCE CALC (70) DEFERRED CHARGES - Financing (71) DEFERRED CHARGES - Tax (72) DEFERRED CHARGES - Pension 20,546 22,739 184,035 113,102 21,099 23,925 1...

AI summary The document presents a revenue-to-expense comparison table, highlighting deferred charges and credits across various categories, including financing, tax, pension, steam assets, and other deferrals. The table includes variance calculations for different line items, such as adjustments and average asset retirement obligations (ARO).

Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (NSEB M12661) NSPI Responses to CA Information Requests

AI summary The document involves an application for the approval of an Above-the-Line Tariff for Port Hawkesbury Paper, along with NSPI's responses to information requests from the Commission. The content pertains to regulatory processes and tariff design.

Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (NSEB M12661) NSPI Responses to CA Information Requests

AI summary The document outlines an application for approval of an Above-the-Line Tariff for Port Hawkesbury Paper and includes NSPI's responses to information requests from the Commission for the Environment. The proceeding involves regulatory approval processes and tariff design.

Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (NSEB M12661) NSPI Responses to CA Information Requests

AI summary The document outlines an application for the approval of an Above-the-Line Tariff for Port Hawkesbury Paper, along with NSPI's responses to information requests from the Commission for the Environment.

PARTIALLY CONFIDENTIAL Request IR-9: In its evidence, PHP proposes the following modifications to the proposed ELID tariff: 1. designing the capacity charge to reflect PHP's actual 8 MW firm demand rather than the proposed 65 MW; 2. adjust...

AI summary PHP proposes modifications to the ELID tariff, including adjusting the capacity charge and interruptible credit, and applying a revenue-to-cost ratio of 1.0. NSPI is asked to explain if these changes are consistent with the 2026-2027 GRA settlement agreement, particularly regarding cost allocation and rate design based on updated load forecasts.

Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (NSEB M12661) NSPI Responses to CA Information Requests

AI summary The document outlines an application for the approval of an Above-the-Line Tariff for Port Hawkesbury Paper (NSEB M12661) and includes responses from NSPI to information requests from the Commission for the Environment (CA).

5 General, Large General, Small Industrial, Medium Industrial, Large Industrial, and Municipal classes. Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (NSEB M12661) NSPI Responses to CA Information...

AI summary The document references an application for approval of an Above-the-Line Tariff for Port Hawkesbury Paper and mentions NSPI responses to information requests from the Commission for the Environment. It also lists various customer classes.

PARTIALLY CONFIDENTIAL 1 The Company provides the following in response to parts (a) and (b) of this IR. 2 3 (a) Confirmed. The 2026-2027 GRA was prepared in accordance with the SA. Changes to this 4 to align with PHP's Evidence will resul...

AI summary NS Power confirms the 2026-2027 GRA aligns with the SA but notes PHP's evidence will cause cost reallocations and price increases. NS Power opposes PHP's proposal to include 8 MW peak demand in capacity cost allocation, citing inconsistency with the GRA settlement agreement. The Board's Decision M12451 avoids re-opening COSS and rate design matters.

NSPI Responses to Industrial Group Information Requests Request IR-5: Reference: N-1, ELID Application, Page 6. Consistent with the foregoing, it is proposed that the assumed costing/billing demand also be adopted and applied for billing p...

AI summary NSPI proposes a fixed charge for demand cost recovery using the PHP 3CP figure for the ELID Tariff class, citing unique service characteristics of a single customer with a large, dispatchable load. This approach diverges from standard practices but claims consistency with ratemaking principles due to challenges in applying conventional ATL cost-of-service methods during system peaks.

NON-CONFIDENTIAL 1 (c) The cited extract is intended to recognize that, for FAM-related matters, but potentially 2 other matters as well, customer demand can factor into the allocation of Rider costs and, 3 as a result, there could be a ci...

AI summary The text discusses the allocation of Rider costs based on customer demand and mentions that adjustments to the Demand Charge would be addressed through a GRA or BCF proceeding, not an AA/BA proceeding. It also references an external document (IG IR-5 part (c)).

REDACTED (Attachment Only) 1 Request IR-7: 2 3 Reference: N-1, ELID Application, page 7. 4 5 Preamble: NSPI indicates the cost-of-service information is contained in files associated 6 with M12451, General Rate Application, specifically SR...

AI summary The document requests cost-of-service information related to Nova Scotia Power Inc.'s (NSPI) General Rate Application (M12451), specifically referencing Exhibit N-1 and seeking details on PHP load scenarios for 2026-2027, including varying firm and interruptible load configurations and associated pricing proposals.

ALLOCATION OF OPERATING EXPENSES (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL (7) MEDIUM INDUSTRIAL INDUSTRIAL (8) LARGE INDUSTRIAL (9) PHP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (9...

AI summary The document presents a detailed breakdown of operating and maintenance expenses across various categories and customer segments, including steam, hydro, wind, biomass, and others. Allocation factors and specific line items are provided for each category, with some entries referring to additional allocation details or related proceedings.

NOVA SCOTIA POWER INC. (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (8) BUTU CAPACITY CREDIT (8) OPER. & MAINT STEAM $0 60,953 - 30,438 - 2,062 - 12,906 - 2,031 - 1,481 - 2,523 - 3,89...

AI summary The document presents a detailed breakdown of operational and maintenance costs for various energy generation and management activities by Nova Scotia Power Inc., including capacity credits, hydro, wind, biomass, and other generation sources, along with DSM and FCR deferral allocations. It references specific cost allocations and board orders.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026

AI summary This document outlines Nova Scotia Power Inc.'s Rate Class Disaggregation Analysis for the year ending December 31, 2026. It provides a detailed breakdown of rate classes, likely including financial and operational data relevant to regulatory proceedings.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026

AI summary This document outlines Nova Scotia Power Inc.'s Rate Class Disaggregation Analysis for the year ending December 31, 2026. It provides a detailed breakdown of rate classes, likely including financial and operational data relevant to regulatory proceedings.

FOR THE YEAR ENDING DECEMBER 31, 2026 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL ELI 2P-RTP MUNICIPAL UNMETER...

AI summary The document presents a detailed breakdown of expenses and responsibilities across different customer categories and sizes for the year ending December 31, 2026, with various percentages allocated to different sectors. It includes data on distribution and retail expenses, as well as customer solutions, with specific figures and percentages provided for each category.

NOVA SCOTIA POWER INC. CLASS MONTHLY DEMAND ADJUSTMENT FACTORS UNDER STANDBY TARIFF FOR THE YEAR ENDING DECEMBER 31, 2026 RATIOS OF AVERAGE OF 3 WINTER MONTH COINCIDENT PEAKS TO MONTHLY COINCIDENT PEAKS ( 1) JANUARY 0.96 0.97 0.96 0.93 0.9...

AI summary Nova Scotia Power Inc. provides a detailed table of class monthly demand adjustment factors under the standby tariff for the year ending December 31, 2026, including ratios of average winter month coincident peaks to monthly and seasonal coincident peaks for different customer classes.

NOVA SCOTIA POWER INC. 2027 COST OF SERVICE STUDY ANALYSIS R E F E R E N C E G U I D E EXHIBIT COMPARISON OF REVENUE TO EXPENSE RATIOS 1 FUNCTIONALIZATION OF AVERAGE RATE BASE 2 INITIAL CLASSIFICATION OF AVERAGE RATE BASE 2A FINAL CLASSIFI...

AI summary The document presents Nova Scotia Power Inc.'s 2027 Cost of Service Study reference guide, including exhibits analyzing revenue-to-expense ratios, rate base classifications, and operational cost allocations. Key data includes proposed revenue recovery ratios for customer classes in 2026 and 2027, with most classes showing stable or slightly increasing ratios.

ALLOCATION OF OPERATING EXPENSES TOTAL COMPANY DOMESTIC GENERAL SMALL GENERAL GENERAL SMALL MEDIUM LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL LARGE (11) ELI 2P-RTP MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (20) DEPRECIATION 55,951 36,022 1,90...

AI summary The document presents a detailed breakdown of operating expenses for a company, including depreciation, interest, taxes, and various revenue and adjustment items. It allocates these expenses across different customer classes and includes references to specific exhibits and orders.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2027

AI summary The document presents a rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2027, focusing on financial and regulatory aspects of utility operations.

FOR THE YEAR ENDING DECEMBER 31, 2027 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL ELI 2P-RTP MUNICIPAL UNMETERED (12) ALLOCATI...

AI summary The text presents a table with various rate base and responsibility percentages across different categories, including distribution and retail, for the year ending December 31, 2027. The data includes allocations and factors, such as P-18A, P-18B, and P-19, indicating specific line items or allocations.

NOVA SCOTIA POWER INC. CLASS MONTHLY DEMAND ADJUSTMENT FACTORS UNDER STANDBY TARIFF FOR THE YEAR ENDING DECEMBER 31, 2026 RATIOS OF AVERAGE OF 3 WINTER MONTH COINCIDENT PEAKS TO MONTHLY COINCIDENT PEAKS ( 1) JANUARY 0.96 0.97 0.96 0.92 0.9...

AI summary The document presents a table of monthly demand adjustment factors under a standby tariff for Nova Scotia Power Inc. for the year ending December 31, 2026. The table includes ratios of average winter month coincident peaks to monthly coincident peaks for each month, with some months highlighted for specific ratios.

INSERT TABLE FOR STANDBY SERVICE TARIFF Classes Jan, Feb, Dec Mar, Apr May, June Jul, Aug, Sep Oct, Nov Domestic 1.00 1.34 2.15 2.29 1.64 Small General 1.00 1.23 1.63 1.59 1.35 General 1.00 1.22 1.50 1.39 1.20 Large General 1.00 0.99 0.93...

AI summary The table presents standby service tariff rates for different customer classes across various months, showing seasonal variations and differing rates based on usage categories.

FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (1) TOTAL (2) TOTAL (3) UNIT COST (4) TOTAL (5) (6) (7) VARIANCE CALC (299) LIR Credit ($/kVA) (300) % Premium for Priority Interruptions -7.667 10.0% (301) OPERATING ALLOCATI...

AI summary The text presents a financial table outlining various cost allocations and percentages for the year ending December 31, 2027, including operating allocations, FCR deferrals, and customer solutions allocators across different sectors.

ALLOCATION FACTOR INFORMATION Calendar Month of System Peak 1 January February March April May June July August September October November December Total (87) DEMAND LINE LOSS ADJUSTMENT - MUNICIPAL (88) DEMAND LINE LOSS ADJUSTMENT - UNMET...

AI summary The document presents a table detailing demand line loss adjustments across various categories and months, including municipal, unmetered, shore power, general replacement, PHP, BUTU, and EBS/RTR, with specific values for each calendar month and a total column.

CLASSIFICATION OF AVERAGE RATE BASE (1) (2) (3) (4) (5) (6) (7) (8) (9) (20) MAT. & SUPPLIES - OTHER (21) DEF. CHG Financing 15,376 4,526 9,878 2,908 504 148 2,736 806 312 92 280 83 360 106 559 165 461 136 213 63 72 21 P-7 P-7 (22) DEF. CH...

AI summary The document presents a detailed breakdown of the classification of average rate base across various categories, including DEF. CHG financing, tax, pension, steam assets, fuel deferral, and ARO (Asset Retirement Obligation) for different energy sources such as steam, hydro, wind, and LM6000. The data is presented in a tabular format with multiple columns and rows indicating different financial figures and references.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS CLASS : LARGE GENERAL RATE BASE (Source Exh. 3) Variable Fixed COSTS (Source Exh 6) Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Genera...

AI summary Nova Scotia Power Inc. provides a detailed rate class disaggregation analysis, breaking down costs by generation, transmission/distribution, and retail. The analysis includes various cost components such as fuel, operating expenses, capital, and return on investment. Unit costs are calculated and presented for different categories, including energy and demand.

DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (6) SECONDARY CUSTOMER (7) WEIGHTED FACTOR (8) WEIGHTED TOTAL (9) RESPONSIBILITY 100.00% 529,710 488,926...

AI summary The text presents a table discussing the development of allocation factors, including weighted totals, responsibility percentages, and customer categories. It includes data on the number of bills and weighted factors for different customer segments, with a reference to 'C-2B' as an allocation factor.

FOR FEBRUARY 2026 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT ( 1) DOMESTIC ( 2) SMALL GENERAL ( 3) GENERAL ( 4) GENER...

AI summary The text presents a table with various energy usage metrics across different customer classes and system conditions for February 2026, including MWH, percentages, and other related data points. It includes subtotals and specific categories such as shore power and real-time pricing.

FOR SEPTEMBER 2026 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT ( 1) DOMESTIC ( 2) SMALL GENERAL ( 3) GENERAL ( 4) GENE...

AI summary The document presents a table detailing energy usage and related metrics across various categories for September 2026, including MWH, energy line percentages, demand line percentages, and system coincidence percentages for different customer classes and programs.

FOR THE YEAR ENDING DECEMBER 31, 2026 (IN THOUSANDS OF DOLLARS) (1) TOTAL (2) TOTAL (3) UNIT COST (4) TOTAL (5) (6) (7) VARIANCE CALC (267) RETAIL (268) NON-FUNCTIONALIZED 6,250.7 37,846.2 0.0 0.0 6,251 37,846 6,251 37,846 6,251 37,846 0 0...

AI summary The document presents a financial summary for the year ending December 31, 2026, with various line items including retail, depreciation, interest charges, corporate taxes, and other operating allocations. It outlines costs, revenues, and variances related to different operational and financial aspects of the organization.

ALLOCATION FACTOR INFORMATION Calendar Month of System Peak 1 January February March April May June July August September October November December Total (85) DEMAND LINE LOSS ADJUSTMENT - DOMESTIC (86) DEMAND LINE LOSS ADJUSTMENT - SMALL...

AI summary The table presents allocation factor information, including demand line loss adjustments categorized by domestic, small general, general, and small industrial sectors across different calendar months, with totals and figures for each category.

FUNCTIONALIZATION OF OPERATING EXPENSES (1) TOTAL EXPENSES (2) PROD. (3) TRANS. (4) DIST. (5) RETAIL EXPENSES EXPENSES EXPENSES EXPENSES EXPENSES (6) DIRECT (57) LM6000 7,372 7,100 0 0 0 272 (58) OTHER GAS TURBINE 3,239 3,119 0 0 0 120 (59...

AI summary The document presents a detailed breakdown of operating expenses categorized into production, transmission, distribution, retail expenses, and direct expenses, with specific line items such as generation batteries, distribution infrastructure, and depreciation. It also includes non-operating revenue and net income figures.

DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL (2) PROD. (3) TRANS. (4) DIST. (5) RETAIL (6) DIRECT (7) EXPENSES EXPENSES EXPENSES EXPENSES EXPENSES EXPENSES ALLOCATOR (12) SHORE POWER (13) GEN.REPL./LOAD FOLL. (14) ELIADC (15) BUTU (16) REAL...

AI summary The text presents a table outlining the development of allocation factors for various categories, including production, transmission, distribution, and retail expenses. The table includes figures and percentages related to different items such as Shore Power, GEN.REPL./LOAD FOLL., ELIADC, and EXPORT SALES, indicating a detailed breakdown of costs and allocations.

FOR MARCH 2027 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT SALES LOSSES REQUIREMENT DMD. (KW) FACTOR DMD. (KW) LOSSES...

AI summary The text presents a table with various energy-related metrics, including sales, losses, requirements, demand factors, and system coincident peak demand, organized under different categories for March 2027.

-1A (13) OPER. & MAINT OTHER CT's 0 0 0 0 0 0 0 0 0 0 0 E-1A (14) OPER. & MAINT GENERATION BATTERIES 0 0 0 0 0 0 0 0 0 0 0 E-1A (15) OPER. & MAINT RADIAL TO GENERATION TRANS. 1,549 774 52 328 52 38 64 99 114 18 11 E-1A (16) DSM 0 See DSM A...

AI summary The document presents financial data for Nova Scotia Power Inc., including operational and maintenance costs, depreciation, interest, taxes, and revenue from exports and other sources. It includes line items such as DSM allocation, fuel cost deferral, and grants in lieu, with some figures referenced to external files or exhibits.

EXHIBIT 6 PAGE 6 OF 6 (1) INTERR. RIDER DMD ADJ. (2) (5) (3) Peak Dmd. in KWs (at Generator) (4) Int Credit Amount 69,594 11,165 (7) (6) PHP DEMAND ADJUSTMENT CALCULATION (8) Demand Usage Annual Credit Amount Calculation Winter Month kW Po...

AI summary This exhibit presents a detailed table outlining demand adjustment calculations, including peak demand, power factor adjustments, and interruption credit amounts. It includes various metrics such as kW and kVA demands, premium percentages, and associated financial figures.

CLASS : TOTAL COMPANY RATE BASE COSTS (Source Exh 6) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $1,564,130 $747,232.643 $77,229 $112,465 $54,901 $...

AI summary The document presents a detailed breakdown of costs and revenue for a utility company, categorized into Generation, Transmission/Distribution, and Retail. It includes figures for variable and fixed costs, unit costs, and total costs across different segments of the company's operations.

DETAIL OF MONTHLY CLASS SYSTEM COINCIDENT KW DEMAND FOR THE YEAR ENDING DECEMBER 31, 2026 (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) TOTAL SMALL GENERAL SMALL MEDIUM LARGE SHORE REAL TIME MONTH COMPANY DOMESTIC...

AI summary The document presents monthly data on system coincident kilowatt demand for various customer classes in Nova Scotia for the year ending December 31, 2026. It includes detailed breakdowns of demand across different categories such as small general, medium large industrial, and others, with totals and interruptions listed at the end of the year.

NOVA SCOTIA FUNCTIONALIZATION OF FOR THE YEAR ENDING (IN THOUSANDS (1) REGULATORY AFFAIRS (2) Advocacy Expense 0.1 (0) 3 3 0 1 8 55 1 70 (3) Other Expenses 0.2 (1) 12 11 0 2 32 216 4 277 (4) Subtotal 0.3 (1) 15 14 0 3 40 271 6 347 (5) (6)...

AI summary The text presents a financial breakdown of various departments and groups within Nova Scotia's regulatory and enterprise services divisions, including expenses related to regulatory affairs, finance, enterprise services, human resources, and other expenses, for the year ending in thousands of dollars.

RATE CLASS DISAGGREGATION ANALYSIS BY FUNCTIONAL AREAS FOR THE YEAR ENDING DECEMBER 31, 2027

AI summary This document presents a rate class disaggregation analysis by functional areas for the year ending December 31, 2027. It outlines the breakdown of costs and revenues across different rate classes, likely to inform regulatory decisions and tariff design.

NOVA SCOTIA POWER INC. DEVELOPMENT OF ALLOCATION FACTORS FOR THE YEAR ENDING DECEMBER 31, 2027 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL ELI 2P-RTP MUNICIPAL U...

AI summary The document presents allocation factors for various categories of responsibility related to pole and wire infrastructure investments and customer responsibilities for the year ending December 31, 2027. It includes percentages and dollar amounts allocated across different customer segments and categories.

REVENUE TO EXPENSE COMPARISON (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (298) Power Factor Adjustment (299) LIR Credit ($/kVA) (3...

AI summary The text presents a revenue-to-expense comparison table, including categories such as Power Factor Adjustment, LIR Credit, and various customer solutions allocators. It outlines percentages and allocations for different types of customers and operations, with some variance calculations included.

FUNCTIONALIZATION OF AVERAGE RATE BASE (1) (2) (3) (4) (5) (6) (31) METERS 70,426 0 0 70,426 0 0 (33) (32) STREET LIGHTING 35,211 0 0 35,211 0 0 (34) TOTAL DIST. PLANT 1,550,189 0 0 1,550,189 0 0 (35) (36) SUB-TOTAL DIST. PLANT 4,480,567 2...

AI summary The text presents a detailed breakdown of various asset categories, including meters, street lighting, distribution plant, and general property plant, along with associated financial figures such as deferred charges and credits. It outlines the functionalization of the average rate base, providing data on the distribution and transmission infrastructure, as well as working capital and deferred charges related to fuel, tax, and pension.

EXHIBIT 3 PAGE 2 OF 5 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL (7) MEDIUM (8) LARGE (9) BUTU (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (18) CASH -...

AI summary This page of Exhibit 3 presents a detailed breakdown of various financial categories and allocations across different customer segments and classes. The table includes items such as cash, materials and supplies, deferred charges, and other financial factors, with corresponding figures and allocation factors for each segment.

NOVA SCOTIA POWER INC. ALLOCATION OF OPERATING EXPENSES FOR THE YEAR ENDING DECEMBER 31, 2026 (IN THOUSANDS OF DOLLARS) (1) INTERR. RIDER DMD ADJ. (3) Peak Dmd. in KWs (at Generator) 69,594 (4) Int Credit Amount 11,165 (5) (6) PHP DEMAND A...

AI summary The document presents Nova Scotia Power Inc.'s allocation of operating expenses for the year ending December 31, 2026, including tables and calculations related to demand adjustments and interruption credit amounts.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS CLASS : LARGE GENERAL RATE BASE (Source Exh. 3) Variable Fixed COSTS (Source Exh 6) Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Genera...

AI summary The document presents a detailed breakdown of Nova Scotia Power's rate class disaggregation analysis, including various cost components such as fuel, operating, capital, and return on investment, along with unit costs and total costs for different segments like generation, transmission/distribution, and retail.

RATE BASE COSTS (Source Exh 6) RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $98,311 $47,459 $4,747 $7...

AI summary The document presents a detailed breakdown of rate base costs and associated expenses, including generation, transmission/distribution, and retail costs, along with unit costs and total expenses. It includes various line items such as fuel, operating, and capital costs, as well as return on equity and total costs for different segments of the utility system.

FOR AUGUST 2026 (1) MWH SALES LOSSES (2) ENERGY LINE (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT...

AI summary The document presents a detailed table of sales, generation, and demand analysis for August 2026, including metrics like energy sales losses, energy line losses, demand losses, and system factors for various customer classes and programs. It also includes sub-totals and totals for different categories such as shore power, generation replacement, and real-time pricing.

(300) Total 100.00% (301) (302) METER DATA SERVICES ALLOCATORS (403) EBS (404) RTR 10,878.3 19,964.1 37,414.711 10,878.3 19,964.1 (405) SOLAR GARDEN RIDER (SGR) (406) TOTAL 191.6 37,606.344 - 37,414.711 50,075 -12,468.8371 0.000 0 (407) LA...

AI summary The text presents a table detailing various revenue and charge allocations, including late payment charges and connection charges, with data categorized by different customer types and historical averages. It includes figures related to EBS, RTR, and Solar Garden Rider (SGR), along with budget projections for the year 2026.

ALLOCATION OF AVERAGE RATE BASE FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRI...

AI summary The document presents the allocation of the average rate base for the year ending December 31, 2027, across various categories including tax, pension, steam assets, fuel deferral, and asset retirement obligations for different customer classes and company segments.

NOVA SCOTIA POWER INC. (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL (7) MEDIUM INDUSTRIAL INDUSTRIAL INDUSTRIAL (8) LARGE (9) ELI 2P-RTP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (8) B...

AI summary The document presents a detailed breakdown of operating and maintenance costs for various energy sources and categories under Nova Scotia Power Inc. It includes line items for steam, hydro, wind, biomass, and other generation types, as well as DSM and FCR deferral costs, with references to specific accounting entries and allocation factors.

CLASS : GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Generation (1) Usage (Energy) $324,420 $142,119 $16,169 $24,344 $11,26...

AI summary The document presents a detailed breakdown of costs and rates for energy generation, transmission, distribution, and retail services. It includes figures for fuel, operating, capital, and return costs, as well as unit costs and total expenses for various components of the energy system.

DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL (2) COMPANY DOMESTIC GENERAL GENERAL (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL (8) LARGE (9) PHP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (...

AI summary The document presents a table detailing the development of allocation factors, including various demand and generation metrics across different categories such as domestic, small, medium, and large industrial sectors, as well as municipal and PHP (Peak Hour Pricing) categories. Each row provides numerical data and percentages of responsibility for different allocation factors.

FOR FEBRUARY 2027 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT

AI summary The document presents a table with various energy and demand-related line items for February 2027, including categories such as MWH, Energy Line, Class Non-Coincident, System Coincident, and Demand Line. The table structure is detailed but lacks specific data or explanations.

FOR JUNE 2027 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT

AI summary The text presents a table with various columns related to energy and demand metrics for June 2027. It includes categories such as MWH, Energy Line, Class Non-Coincident, System Coincident, and Demand Line, indicating a focus on energy usage and system performance.

0 0 0 0 0 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL (7) MEDIUM (8) INDUSTRIAL LARGE (9) (10) (11) ELI 2P-RTP MUNICIPAL UNMETERED (12) ALLOCATION FACTOR

AI summary The document presents a table with various categories and allocation factors related to the distribution of an average rate base across different customer classes and business sizes. The table includes columns labeled with categories such as 'SMALL', 'MEDIUM', 'LARGE', 'INDUSTRIAL', and 'MUNICIPAL', indicating the allocation of the rate base among different sectors.

NOVA SCOTIA POWER INC. (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL (7) MEDIUM INDUSTRIAL INDUSTRIAL INDUSTRIAL (8) LARGE (9) ELI 2P-RTP (10) (11) MUNICIPAL UNMETERED (12) ALLOCATION FACTOR (8) B...

AI summary The document presents a detailed breakdown of various operational and maintenance costs across different categories and customer segments for Nova Scotia Power Inc., including specific line items such as capacity credit, hydro, wind/biomass, biomass, and other generation-related expenses, along with references to allocation factors and related documents.

CLASS MONTHLY DEMAND ADJUSTMENT FACTORS UNDER STANDBY TARIFF FOR THE YEAR ENDING DECEMBER 31, 2026 RATIOS OF AVERAGE OF 3 WINTER MONTH COINCIDENT PEAKS TO MONTHLY COINCIDENT PEAKS ( 1) JANUARY 0.96 0.97 0.96 0.93 0.97 0.99 0.85 1.00 1.00 0...

AI summary The document presents monthly demand adjustment factors under the standby tariff for the year ending December 31, 2026. It includes detailed tables with ratios of average winter month coincident peaks to monthly coincident peaks, as well as seasonal ratios and class-specific tariff adjustments.

FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (11) (12) (13) OPER. & MAINT BIOMASS OPER. & MAINT LM6000 OPER. & MAINT OTHER CT's 6,547 629 0 3,454 332 0 238 23 0 1,440 138 0 231 22 0 169 16 0 273 26 0 443 43 0 167 16 0 80...

AI summary The document presents a detailed financial table for the year ending December 31, 2027, outlining operating and maintenance costs across various energy generation and management categories, including biomass, LM6000, other combined cycle turbines, generation batteries, and radial transmission. It also includes entries related to Fuel Cost Recovery (FCR) deferral, regulatory affairs, and grants in lieu, with specific allocations noted for DSM.

(IN THOUSANDS OF DOLLARS) Depreciation 173,942 59,927 49,872 283,741 (1) (2) (3) (4) INTERR. RIDER DMD ADJ. Dmd. in KWs Int Credit Amount 69,857 11,207 (5) (6) (7) PHP DEMAND ADJUSTMENT CALCULATION (8) Demand Usage Annual Credit Amount Cal...

AI summary The text presents depreciation figures and a table related to demand adjustment calculations, including credit amounts and priority interruption adjustments. It includes numerical data and calculations associated with energy demand and credits.

DEVELOPMENT OF ALLOCATION FACTORS FOR THE YEAR ENDING DECEMBER 31, 2027 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (26) NUMBER OF BILLIS (27) % RESPONSIBILITY (28) REVENUE (29) % RE...

AI summary The document outlines the development of allocation factors for the year ending December 31, 2027, with detailed breakdowns of numbers, percentages of responsibility, revenue, and wiring inspection cost allocators across various categories such as small, general, medium, and large.

FOR SEPTEMBER 2027 (1) MWH SALES (2) ENERGY LINE LOSSES (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM COIN. PEAK DMD. (KW) (9) SYST...

AI summary The text presents a table with various metrics related to energy sales, losses, demand, and system factors for September 2027. It includes columns such as energy sales, energy losses, energy requirement, demand factors, and system peak demand. The table appears to be part of a regulatory proceeding related to energy billing and real-time pricing.

INSERT TABLE FOR STANDBY SERVICE TARIFF Classes Jan, Feb, Dec Mar, Apr May, June Jul, Aug, Sep Oct, Nov Domestic 1.00 1.34 2.15 2.29 1.64 Small General 1.00 1.23 1.63 1.59 1.35 General 1.00 1.22 1.50 1.39 1.20 Large General 1.00 0.99 0.93...

AI summary The text presents a table outlining standby service tariff rates for different customer classes in Nova Scotia, with varying rates across different months. This information is part of a regulatory proceeding document.

REDACTED ELID Tariff IG IR-7 Attachment 11 Page 92 of 97 (339) ELI 2P-RTP 1,824.69 1,106.00 (482) (483) CASH WORKING CAPITAL (484) CWC % DISTRIBUTION - DOMESTIC 73.8% (485) CWC % DISTRIBUTION - SMALL GENERAL 5.2% (486) CWC % DISTRIBUTION -...

AI summary The document presents a table with data on cash working capital distribution percentages across various customer categories and average customer numbers for different years. It includes distribution percentages for domestic, general, industrial, and municipal customers, as well as average customer counts for 2026 and 2027.

ALLOCATION OF OPERATING EXPENSES (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL INDUSTRIAL (7) MEDIUM INDUSTRIAL (8) LARGE INDUSTRIAL (9) PHP (10) MUNICIPAL (11) UNMETERED (12) ALLOCATION FACTOR (1...

AI summary This section presents a detailed breakdown of operating expenses allocated across various categories and customer segments, including grants, depreciation, interest, taxes, revenue, and adjustments related to demand and rider allocations.

NOVA SCOTIA POWER INC. ALLOCATION OF OPERATING EXPENSES (1) INTERR. RIDER DMD ADJ. (2) (3) Peak Dmd. in KWs (at Generator) 69,594 (4) Int Credit Amount 11,165 (5) (6) PHP DEMAND ADJUSTMENT CALCULATION (7) (8) Demand Usage Annual Credit Amo...

AI summary The document presents a detailed table and exhibit related to Nova Scotia Power Inc.'s allocation of operating expenses, particularly focusing on demand adjustment calculations and interruption credit amounts. The table includes metrics such as peak demand, power factor, and credit calculations, but most values are zero or not fully populated.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS BY FUNCTIONAL AREAS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : DOMESTIC

AI summary This document presents a rate class disaggregation analysis for the Domestic class by functional areas for Nova Scotia Power Inc. for the year ending December 31, 2026. It outlines the breakdown of costs and revenues associated with the Domestic rate class.

DETAIL OF MONTHLY CLASS SYSTEM COINCIDENT KW PEAK DEMAND MONTH (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL INDUST. (7) MEDIUM INDUST. (8) LARGE INDUST. (9) ELI 2P-RTP (10) MUNICIPAL UNMETERED (1...

AI summary The document presents a detailed breakdown of monthly system coincident kilowatt peak demand by class across various months in a year, including data for different customer segments such as domestic, general, industrial, and others, as well as specific charges like ELIADC and real-time pricing.

INSERT TABLE FOR STANDBY SERVICE TARIFF Classes Jan, Feb, Dec Mar, Apr May, June Jul, Aug, Sep Oct, Nov Domestic 1.00 1.34 2.13 2.26 1.65 Small General 1.00 1.24 1.62 1.59 1.35 General 1.00 1.21 1.47 1.36 1.20 Large General 1.00 0.99 0.93...

AI summary The document presents a table outlining standby service tariff rates for various customer classes across different months. The rates vary depending on the class, with differences in pricing observed throughout the year.

ALLOCATION FACTOR INFORMATION ALLOCATION FACTOR INFORMATION (162) Distribution BP Substation LIR (163) Distribution BP Substation - Municipal (164) Distribution Primary Voltage - LIR (165) Distribution Primary Voltage - Municipal (166) (15...

AI summary The document provides allocation factor information related to distribution substations, voltage levels, and loss factors under the ELIADC. It includes data on revenue-to-expense ratios and the functionalization and classification of average rate bases.

REVENUE TO EXPENSE COMPARISON (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (295) Normal Interruption Cost (296) Interr. Rider Coinci...

AI summary The document presents a revenue to expense comparison, focusing on various cost-related categories such as normal interruption costs, power factor adjustments, and customer solutions allocators, with percentages and figures indicating allocations and variances across different sectors and customer types.

(IN THOUSANDS OF DOLLARS) FOR THE YEAR ENDING DECEMBER 31, 2027 ALLOCATION FACTOR INFORMATION (152) Distribution Primary Voltage - LIR (153) Distribution Primary Voltage - Municipal (154) (143) (144) System Coincident 3CP DMD (145) EHV - L...

AI summary The document presents allocation factor information and various exhibits related to revenue to expense ratios and the functionalization of average rate base for the year ending December 31, 2027. It includes distribution voltage classifications, loss factors, and detailed breakdowns of rate base allocations.

(IN THOUSANDS OF DOLLARS) (401) REAL TIME PRICING (402) OATT (403) EBS 1,277.0 625.1 10,878.3 70,801,052.523 1,277.0 625.1 10,878.3 0.000 0.000 (404) RTR (405) SOLAR GARDEN RIDER (SGR) 19,964.1 191.6 70,831,894.967 - 19,964.1 70,831,894.96...

AI summary The document presents a detailed financial breakdown of various revenue streams and charges, including real-time pricing, late payment charges, and connection charges. It includes figures and percentages related to different customer categories and programs, such as the Solar Garden Rider and Electricity Billing System.

ALLOCATION OF AVERAGE RATE BASE (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL INDUSTRIAL (7) MEDIUM INDUSTRIAL (8) LARGE INDUSTRIAL (9) BUTU (10) MUNICIPAL (11) UNMETERED (12) ALLOCATION FACTOR (2...

AI summary The table presents the allocation of the average rate base across various customer classes and categories, including domestic, small and large general, industrial, municipal, and unmetered classes. The data includes total transaction function values for each category, as well as an allocation factor.

FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (14) (15) OPER. & MAINT GENERATION BATTERIES OPER. & MAINT RADIAL TO GENERATION TRANS 0 1,960 0 1,061 0 73 0 442 0 71 0 52 0 84 0 136 0 0 0 25 0 16 E-1A E-1A (16) (17) (18) (1...

AI summary The document presents financial data for the year ending December 31, 2027, including operational and maintenance costs for generation batteries, radial transmission, and other related expenses. It also includes details on demand-side management (DSM), deferred charges (FCR deferral), regulatory affairs, and grants in lieu.

NOVA SCOTIA POWER INC. SALES, GENERATION AND DEMAND ANALYSIS FOR JANUARY 2027 (1) MWH SALES (2) ENERGY LINE LOSSES (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7)...

AI summary The document presents a sales, generation, and demand analysis for Nova Scotia Power Inc. in January 2027, including metrics such as MWH sales, energy losses, demand factors, and system peak demand. It includes sub-totals and breakdowns for various categories like Shore Power, ELIADC, and Real Time Pricing.

REVENUE TO EXPENSE COMPARISON (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (215) POWER PRODUCTION - OTHER GAS TURBINE (216) POWER PR...

AI summary The document presents a revenue to expense comparison, detailing various categories such as power production, purchased power, and DSM expenses. It includes figures related to fuel procurement, capacity credit, and deferrals, highlighting the financial breakdown of operations and related costs.

1 Request IR-9: 2 3 NSPI states at page 7 that the ultimate energy charge is subject to change based on the - 4 outcome of the ongoing Court proceedings regarding FLG2 responsibility. Please provide - 5 an analysis quantifying the impact o...

AI summary NSPI requests an analysis of the impact on Large Industrial and Medium Industrial customers if PHP is not found responsible for FLG2 costs, with a reallocation of those costs. NS Power provides a forecast assessment including FLG2-related costs and references Table 1 for the impact analysis.

CONFIDENTIAL (Attachment Only) 1 Request IR-11: 2 3 Reference: N-1, ELID Application, Page 8 lines 19-26. 4 5 With respect to the SA priority interruptible service provisions, the 6 Company's initial analysis of the priority interruptible...

AI summary The document requests detailed information from NSPI regarding its analysis of priority interruptible service, including internal documentation, economic analysis, and modeling results. It also questions the rationale behind considering the discontinuation of this service premature, given the lack of current compensation.

PHP ATL Tariff Development – Priority Interruption - Development of the PHP ATL Tariff application requires an assessment of: - 1. The potential value to the NS Power system of PHP providing priority interruptible service for all load grea...

AI summary The development of the PHP ATL Tariff application involves assessing the potential value of PHP providing priority interruptible service for loads exceeding 8 MW and identifying customers who may benefit from this service.

Background – Evolution of Priority Interruptibility in NS Regulatory Context Since 1976, interruptible service has evolved from a single "Industrial Interruptible Rate" into a mix of above-the-line (ATL) and below-the-line (BTL) rates, inc...

AI summary This section outlines the evolution of interruptible service in Nova Scotia's regulatory context, tracing its development from a single 'Industrial Interruptible Rate' in 1976 to a combination of above-the-line and below-the-line rates.

ELIIR-2 (introduced in 2006) – M05550 - Board Decision stated priority interruptibility has value for: - o Historical value and system-wide benefits. - o System reliability ("keeping the lights on") - o Planning flexibility and avoided pea...

AI summary The Board Decision emphasizes the value of priority interruptibility under ELIIR-2, highlighting its contributions to system reliability, planning flexibility, and reduced interruption risk. A 15% premium for priority interruptibility is introduced, with the cost to be allocated to all other customers.

NSPI Responses to Industrial Group Information Requests 1 Request IR-12: 2 3 (a) Where PHP's load under ELIADC was optimized along with other supply resources 4 in the development of the day-ahead dispatch plan to provide the least cost di...

AI summary NSPI responds to questions about the optimization of PHP load under ELIADC and ELID DR, confirming that PHP load is economically dispatched and not counted as synchronized reserve if already part of other demand response programs. It also confirms that ELID DR provides full authority for dynamic dispatch of PHP.

Part B – Protocol Forecasting and Operation - (1) Annually, no later than the seventh business day of NovemberQuarterly, NS Power will forecast the Monthly Demand Schedule, Weekly Demand Schedule, and monthly and weekly limits based on PHP...

AI summary NS Power is required to provide regular forecasting and operational coordination with PHP, including monthly and weekly demand schedules, updates during the year, and advance notice of shutdowns for both parties. These processes ensure alignment in system planning and operational efficiency.

Part C – Conditions - (9) Subject only to reasons of health, safety, environmental, system reliability, equipment failures, and Force Majeure events, PHP must not deviate from the NS Power/NSPSO final demand schedule. NS Power/NSPSO must c...

AI summary Part C outlines conditions for PHP's operations, emphasizing compliance with demand schedules, communication during disruptions, tracking deviations, and collaboration between NS Power, NSPSO, and PHP. It includes procedures for maintaining 24/7 operations teams, handling outages, and ensuring dispatch decisions align with system needs and agreed schedules.

8 Year Tariff under which PHP, or Predecessor, Took Service and which included Priority Interruptibility Matter No. 2003 Extra Large Industrial Interruptible Rate (ELIIR) M05656 2006 ELIIR-2 – also referred as, Extra Large Industrial One-P...

AI summary The document outlines various tariff matters related to priority interruptibility and associated regulatory proceedings, including the ELIIR, ELI 1P-RTP, LRT, and ELIADC. It notes that only the ELI 1P-RTP Tariff applied an additional credit for priority interruptible service.

NSPI Responses to Industrial Group Information Requests 1 Request IR-15: 2 incur a penalty, while the IR interruption directives issued by NSPSO cannot be 3 disregarded, and if they are, would be subject to significant penalties. 4 5 The s...

AI summary NSPI outlines that interruptible load from industrial customers is not forecasted in day-ahead planning but serves as a tool for managing unforeseen real-time events. Priority Interruptibility requires further assessment and analysis, with references to other inquiries and reports for context.

NON-CONFIDENTIAL 1 (AGC) volumes will be included on PHP's bill as appropriate and PHP will be 2 billed at the above-the-line rate for the remaining energy volume. If PHP's demand 3 is such that it requires energy during these higher-varia...

AI summary The document discusses the billing mechanism for PHP, including the Fuel Adjustment Mechanism (FAM) and how DR credits and wind credits affect the net bill. It also includes a table with various cost scenarios and optimized rates.

NON-CONFIDENTIAL (ii) an interruptible credit for having its load interrupted under the Interruptible Rider —for the same reduction in load? If yes, please address how NSPI proposes to avoid double-counting. If no, please explain how these...

AI summary The response addresses the interaction between the Dispatchable Rider and the Interruptible Rider, clarifying that dispatch under the Dispatchable Rider does not count as a customer interruption. If PHP deviates from dispatch instructions and system security requires load reduction, the Interruptible Rider may apply. References to IG IR-10 and Synapse IR-14 are provided for further details.

NON-CONFIDENTIAL 1 (iii) The PHP proposal is accepted, and the ELID interruptibility credit is 2 established based on a higher benchmark avoided cost, but the LIIR credit is 3 retained to be based on a different factual assumption about th...

AI summary The document discusses the acceptance of the PHP proposal and the establishment of the ELID interruptibility credit based on a higher benchmark avoided cost, while retaining the LIIR credit based on a different assumption. NS Power explains that the LIIR credit is not outdated and will be reviewed in the next GRA. The response also mentions the deferral of revenue shortfall and its potential recovery from all above-the-line customers.

NSPI Responses to NSEB Information Requests 1 Request IR-1: 26 While PHP continued to provide PI service under both tariffs, under neither tariff was the value of 27 PI service examined and quantified or the cost of service treatment assoc...

AI summary NSPI responded to NSEB information requests, explaining that it has not conducted a detailed analysis of the value and cost of PI service since the last rate application. Instead, it proposed using a modeled PI valuation of 10 percent as a proxy for reliability benefits.

NON-CONFIDENTIAL The Company estimates the annual value to the system and PHP of NS Power dispatching the PHP load will be approximately $3.5 to 5.5 million. (b) On page 8 and page 9 of the Application is the following: The DR is premised...

AI summary The document discusses the economic implications of Nova Scotia Power Inc. (PHP) operating as an above-the-line (ATL) customer without the Dispatchable Rider (DR). It highlights that PHP's flat load profile could lead to increased costs for other ATL customers and proposes the DR to align PHP's interests with the system, ensuring savings are credited to PHP while protecting other customers from higher costs.

NSPI Responses to NSEB Information Requests 1 cost to serve the NS Power dispatched PHP load. (i.e. the credit for DR will equal the 2 benefit of DR, returning the FAM to the same result as if PHP had run flat without DR.) 3 4 (c) Per the...

AI summary NSPI responds to NSEB information requests regarding the cost of serving PHP load, the allocation of savings from demand response, and concerns about the proposed ATL tariff. NSPI explains that under the ELIADC Tariff, PHP would accrue full benefits from dispatching load, and highlights concerns about the ATL tariff's impact on PHP.

NON-CONFIDENTIAL It is important to keep in perspective the aspects of the Application with which PHP does not agree. The ELID Tariff is a comprehensive above-the-line (ATL) tariff construct that enables the transfer of the system's larges...

AI summary The document discusses disagreements between PHP and NS Power regarding the ELID Tariff, emphasizing that PHP's concerns are narrow and focused on costing/pricing matters in the Settlement Agreement. The Company argues that the ELID Tariff provides stability and cost recovery, while amending it would increase costs for other customers. The text references CA IR-2 and CA IR-9 for financial impact assessments.

NSPI Responses to Port Hawkesbury Paper Information Requests 1 Request IR-1: 2 3 Reference: Application, page 5, lines 15-17. 4 5 "In accordance with the Company's Cost of Service Study (COSS), demand 6 7 related costs are proposed to be a...

AI summary NSPI responds to information requests related to the allocation of demand-related costs to the ELID Tariff class based on PHP assigned demand at the time of three coincident peaks (3CP), and the unavailability of data on hourly Net Load breakdown by customer class due to a cyber incident.

NSPI Responses to SBA Information Requests 1 Request IR-1: 2 3 Refer to M12661, Exhibit N-1, the Application for Approval of an Above-the-Line Tariff 4 applicable to Port Hawkesbury Paper (the "Application"), Section 2.2 Demand Charge, 5 s...

AI summary NSPI is responding to SBA information requests regarding the Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper. The request includes questions about demand charge rationale, definitions, historical 3CP data, and billing practices.

2 (f) Yes, PHP's flexibility is incorporated into the Company's planning. However, as provided 3 in part (a) and described on page 6 of the Application, the 65 MW figure reflects the figure 4 used in prior forecasts for estimating the dema...

AI summary The document discusses PHP's demand forecasting and billing practices under different tariffs, noting that the 65 MW figure is based on historical data and that the Large Industrial Tariff uses metered demand, while the ELID Tariff uses cost of service assumptions for billing.

NON-CONFIDENTIAL 1 (LIIR) credit. This premium was proposed at 20 percent by Dr. Rosenburg (Board Counsel 2 consultant) and at 10 percent by Dr. Stutz (SEB consultant). In its September 28, 2006 3 Decision, the Board provided: 4 5 The Boar...

AI summary The document discusses the allocation of the priority interruptibility credit, with differing proposals from consultants and the Board's decision to set it at 15%. It also notes the Company's position on maintaining the service and compensation for PHP until further review in the next GRA.

NON-CONFIDENTIAL 1 Consistent with the above, in recognition that the ELID is an above-the-line, embedded 2 cost-based tariff and DR service is enabled by PHP's load flexibility the ELID Tariff 3 proposes that all benefits provided by DR a...

AI summary The text discusses the ELID Tariff and its distinction from the ELIADC Tariff, emphasizing that benefits from DR accrue solely to PHP and are not inclusive of embedded non-fuel costs. It also references limitations on interruption hours under the Interruptible Rider and cites several regulatory references.

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-1: 8 • provision of supplemental service by own or a third-party generation (GRLF, Shore 9 Power, RtR Energy Balancing and Standby Service Tariffs); 10 11 •...

AI summary The text discusses NSPI's responses to Synapse Energy Economics' information requests, including specific service requirements and tariff structures that affect the availability of Alternative Ancillary Rate (AAR) options for large customers. It also references the Board's decision on a Generic Rate Design Hearing and requests for NS Power's cost of service study related to PHP.

CONFIDENTIAL (Attachment Only) 1 (d) Does NS Power expect that PHP's load would have been different if it had been 2 enrolled in the Large Industrial Interruptible Rider for 2023 and 2024? 3 4 (i) If yes, please qualitatively describe how...

AI summary The document discusses whether PHP's load would have been different if enrolled in the Large Industrial Interruptible Rider (LIIR) for 2023 and 2024. It notes that the LIIR and ELIADC Tariff differ significantly in structure and pricing, and that under LIIR, PHP would likely operate at a high load factor to minimize costs.

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-7: 13 Please provide all calculations with all inputs and assumptions in Excel. 14 15 Response IR-8: 16 17 (a) Please refer to SBA IR-1 part (b). 18 19 (b)...

AI summary NSPI is responding to information requests from Synapse Energy Economics, Inc., addressing the use of the three coincident peaks (3CP) methodology for determining peak demand billing determinants, its adoption history, and its application across rate classes. Responses reference prior submissions and regulatory approvals.

Date Filed: April 10, 2026 NSPI (Synapse) IR-19 Page 2 of 2 1 Request IR-20: 2 3 Refer to the Application, Attachment 1 ELID Tariff, p. 5, Interruptible Rider to the ELID 4 Tariff. The proposed tariff states 5 6 7 "The billed interruptible...

AI summary The document outlines a request and response regarding the ELID Tariff, specifically addressing the billed interruptible demand, total firm demand, and billing demand. Nova Scotia Power proposes a billing demand of 65 MW and confirms the calculations related to the billed interruptible demand and associated credit. A second request pertains to the Threshold Penalty charge, defined as the appropriate firm billing for consumption in a billing period.

Account Number: Billing Determinants Monthly Bill (for the purposes of calculating the Threshold Penalty, to be added to the end-of-month weekly bill) kWh Total Actual Load 40,000,000 Net Load 40,000,000 Charges Monthly Charges Customer Ch...

AI summary This table outlines the monthly billing details for a customer, including charges such as customer charge, demand charge, energy charge, and various riders. The total amount after HST is listed as approximately 5,575,609.02.

PARTIALLY CONFIDENTIAL (Attachment Only) 1 Request IR-30: 2 3 Refer to the Direct Evidence of Fitzhenry and Gorman, p. 19. 4 5 (a) Please provide all confidential responses to Undertaking U-3 in NSEB M12451. 6 7 (b) Please also provide the...

AI summary The text references a request (IR-30) for confidential responses to an undertaking and the provision of a confidential version of the Cost of Service Study (COSS). It also mentions the 2026-2027 General Rate Application (M12451) and references the Board's recent decision in that matter.

EXHIBIT 3 PAGE 3 OF 5 (1) TOTAL COMPANY (2) DOMESTIC GENERAL (3) SMALL (4) GENERAL (5) GENERAL LARGE (6) SMALL INDUSTRIAL (7) MEDIUM INDUSTRIAL (8) INDUSTRIAL LARGE (9) ELI 2P-RTP (10) MUNICIPAL (11) UNMETERED (12) ALLOCATION FACTOR (25) D...

AI summary The exhibit presents a table with various deferred charges and credits across different customer categories, including domestic general, small, general large, small industrial, medium industrial, industrial large, municipal, and unmetered. The table includes allocation factors and references to specific codes such as E-1A and P-10.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : MUNICIPAL RATE BASE (Source Exh. 3) Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Cu...

AI summary Nova Scotia Power Inc. provides a detailed rate class disaggregation analysis for the municipal class, breaking down costs into generation, transmission/distribution, and retail components. The analysis includes variable and fixed costs, unit prices, and total expenditures for the year ending December 31, 2026.

DEVELOPMENT OF ALLOCATION FACTORS (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL PHP MUNICIPAL UNMETERED FACTOR (...

AI summary The document presents a detailed breakdown of allocation factors related to demand, generation, and purchase across various categories such as small, general, and industrial sectors. Percentages of responsibility are calculated for each category, with specific values and exhibits referenced for further details.

NOVA SCOTIA POWER INC. DEVELOPMENT OF ALLOCATION FACTORS FOR THE YEAR ENDING DECEMBER 31, 2026 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL (7) MEDIUM (8) LARGE (...

AI summary Nova Scotia Power Inc. is developing allocation factors for the year ending December 31, 2026. The document includes a detailed table outlining the total rate base demand for various categories, including percentages of responsibility, with allocation factors indicated in the last column.

FOR JUNE 2026 (1) MWH SALES LOSSES (2) ENERGY LINE (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT D...

AI summary This table presents data related to energy sales, losses, and demand factors across various customer classes for June 2026. It includes metrics such as MWH sales losses, energy line losses, demand losses, and system coincidence factors. The data is categorized by customer type, including domestic, industrial, and municipal classes, and includes subtotals and totals for different categories.

FOR OCTOBER 2026 (1) MWH SALES LOSSES (2) ENERGY LINE (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDEN...

AI summary The document presents a table with various metrics related to energy sales, losses, demand, and system factors across different customer classes in October 2026. The table includes figures for MWH sales losses, energy line losses, demand losses, system coincident demand factors, and other related metrics. The data is categorized by customer class, such as domestic, industrial, and municipal. The table also includes subtotals and totals for different categories, as well as a note about redacted information.

DETERMINATION OF CLASS NON-COINCIDENT KW DEMAND BY VOLTAGE LEVEL (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) TOTAL COMPANY DOMESTIC GENERAL GENERAL SMALL GENERAL LARGE SMALL MEDIUM LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL ELI 2P-RTP MUNICI...

AI summary The document presents a detailed breakdown of non-coincident kilowatt demand by voltage level, including losses and subtotals for various categories such as domestic, general, small, medium, large, and industrial classes. Loss percentages are also provided for different voltage levels and classes.

NOVA SCOTIA POWER INC. CLASS MONTHLY DEMAND ADJUSTMENT FACTORS UNDER STANDBY TARIFF FOR THE YEAR ENDING DECEMBER 31, 2026 RATIOS OF AVERAGE OF 3 WINTER MONTH COINCIDENT PEAKS TO MONTHLY COINCIDENT PEAKS ( 1) JANUARY 0.96 0.97 0.96 0.93 0.9...

AI summary The document presents tables with monthly demand adjustment factors under the standby tariff for Nova Scotia Power Inc. for the year ending December 31, 2026. It includes ratios of average winter month coincident peaks and seasonal coincident peaks, as well as class-specific adjustments for different customer categories.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 91 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Line # AVERAGE RATE BASE RATE BASE 2025 RATE BASE 2026 (84) DEFERRED CHARGES - Financing (85) DEFERRED CHARGES - Tax (86) DEFERRED CH...

AI summary The document presents a table with deferred charges and credits under the ELID Tariff Synapse IR-30, showing values for 2025 and 2026, including categories such as financing, tax, pension, steam assets, and regulated assets.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 96 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED)

AI summary The document is a redacted attachment from a Nova Scotia regulatory proceeding related to the ELID Tariff and Synapse IR-30. It is part of a 96-page submission, with confidential information removed. The content likely pertains to rate design, cost recovery, or tariff structures for industrial energy services.

ALLOCATION FACTOR INFORMATION Calendar Month of System Peak 1 January February March April May June July August September October November December Total (113) REQUIREMENTS - ELI 2P-RTP (114) REQUIREMENTS - MUNICIPAL 8,343 31,866 8,322 33,...

AI summary The document presents a table with allocation factor information, detailing requirements across different categories for various months. It includes data for ELI 2P-RTP, municipal requirements, unmetered, shore power, generation replacement, ELIADC, BUTU, RTP, and EBS/RTR. The table provides monthly data and totals for each category.

Monthly Energy Allocators Rate Class Jan-26 Feb-26 Mar-26 Apr-26 May-26 Jun-26 Jul-26 Aug-26 Sep-26 Oct-26 Nov-26 Dec-26 Total Municipal 1.44063% 1.37% 1.28% 1.11% 0.76% 0.77% 0.92% 0.89% 1.00% 1.10% 1.27% 1.28% 1.13% Unmetered BUTU Total...

AI summary The document presents monthly energy allocator percentages for different rate classes from January to December 2026, showing fluctuations in the 'Municipal' category with 'Total' consistently at 100%. The 'Unmetered' and 'BUTU' categories are listed but have no data provided.

r>0 4,103 4,655 (23) DEF. CHG Tax 9,693 0 0 -5,152 5,152 0 4,541 5,152 (24) DEF. CHG Pension 42,525 46,107 0 0 0 0 42,525 46,107 (25) DEF. CHG Steam Assets 0 0 0 0 0 0 0 0 (26) DEF. CHG Fuel Deferral 0 3,900 0 0 0 0 0 3,900 (27) DEF. CHG O...

AI summary The text presents a detailed breakdown of various financial entries, including deferred charges and credits related to taxes, pensions, steam assets, fuel deferral, and other categories. These entries are part of a classification of average rate base, indicating financial accounting and regulatory considerations.

(16) Sum of Monthly Demands in KVAs (at the Meter) 0 (17) Int Credit Amount - PHP 0 (2) (5) (7) (1) INTERR. RIDER DMD ADJ. (3) Dmd. in KWs (4) Int Credit Amount (6) PHP DEMAND ADJUSTMENT CALCULATION 69,857 11,207 (8) Demand Usage Annual Cr...

AI summary The document presents a table related to demand adjustment calculations, specifically focusing on the PHP (Port Hawkesbury Paper LP) demand adjustment, with values such as kW and kVA demands, power factor adjustments, and credit amounts. It includes references to the ELIADC tariff and Synapse Energy Economics, Inc.

EXHIBIT 8B PAGE 3 OF 3 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL COMPANY DOMESTIC GENERAL GENERAL LARGE INDUSTRIAL INDUSTRIAL INDUSTRIAL ELI 2P-RTP MUNICIPAL UNMETERED (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION FACTOR (1) T...

AI summary The document presents a table with various financial figures and percentages related to customer expenses, revenue, and responsibilities across different categories. It includes references to allocation factors and various matters (e.g., O-13, R-1, R-2).

NOVA SCOTIA POWER INC. CLASS MONTHLY DEMAND ADJUSTMENT FACTORS UNDER STANDBY TARIFF FOR THE YEAR ENDING DECEMBER 31, 2026 RATIOS OF AVERAGE OF 3 WINTER MONTH COINCIDENT PEAKS TO MONTHLY COINCIDENT PEAKS ( 1) JANUARY 0.96 0.97 0.96 0.92 0.9...

AI summary Nova Scotia Power Inc. is presenting class monthly demand adjustment factors under the standby tariff for the year ending December 31, 2026, using various ratios of average winter and seasonal coincident peaks. The data includes different classifications of users and their corresponding demand adjustment factors.

FOR THE YEAR ENDING DECEMBER 31, 2027 NOVA SCOTIA POWER INC. DISTRIBUTION SYSTEM DEMAND LINE LOSSES COINCIDENT WITH SYSTEM PEAK FOR THE YEAR ENDING DECEMBER 31, 2027 2.43% 4.22% (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL...

AI summary The document presents a table of distribution system demand line losses coincident with system peak for Nova Scotia Power Inc. for the year ending December 31, 2027. The data includes percentages for various customer categories and energy demand metrics.

NOVA SCOTIA POWER INC. DETAILED LISTING OF C.O.S.S. INPUT INFORMATION FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) Line # AVERAGE RATE BASE RATE BASE 2026 RATE BASE 2027 (70) DEFERRED CHARGES - Financing (71) DEFERRED CH...

AI summary The document presents a detailed listing of input information for Nova Scotia Power Inc.'s Cost of Service Study (COSS) for the year ending December 31, 2027. It includes deferred charges and credits related to financing, taxes, pensions, steam assets, and various other categories, along with adjustments and averages for specific accounts.

NOVA SCOTIA POWER INC. DETAILED LISTING OF C.O.S.S. INPUT INFORMATION FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (207) (403) EBS (404) EBS DIST RETAIL 1,537.3 124.4 1,537. 3 124.4 4,475. 2 0.000 0.000 (405) RTR (406) R...

AI summary This document presents a detailed listing of input information for Nova Scotia Power Inc.'s Cost of Service Study (COSS) for the year ending December 31, 2027, including various cost and revenue categories.

REDACTED ELID Tariff Synapse IR-30 Attachment 4 Page 2 of 15 # iuel Co st of Se ervice Al locatio n of Fue el Expen ses am ong Rate e Classes FOR THE YEAR ENDING I DECEMBER 31, 2027 COLUMN 0 P Q R s Т U V w x Y Z AA AB Fuel- related C o st...

AI summary This table presents the allocation of fuel expenses among rate classes for the year ending December 31, 2027, including breakdowns of fixed energy-related and demand-related costs, total fuel-related costs, and other associated expenses and revenues.

Rate Class FAM Rate Classes (ATL) Residential Small General General Demand Large General Small Industrial Medium Industrial Large Industrial PHP Municipal Unmetered Total Purchased Power Allocation Factors. Non-FAM Rate Classes BUTU GRLF 1...

AI summary The text provides a table with rate classes and allocation factors for different categories of power usage, including FAM and PAM rate classes. It includes details on various rate classes such as Residential, Small General, Large General, Industrial, and others, along with allocation factors for purchased power and exports.

1 Response IR-1: - (a) If the Board adopts an 8 MW demand allocator, the resulting rates will only reflect the costs of providing firm service. In this scenario, because PHP is not being charged for the system capacity required to serve it...

AI summary The response discusses the implications of adopting an 8 MW demand allocator on rates and interruptible credits for PHP, contrasting scenarios where the allocator exceeds 8 MW. It also rejects the proposed ELID tariff, citing inconsistencies with PHP's position on cost causation and credit pricing. The analysis centers on tariff design, demand-side management, and cost recovery mechanisms.

And further: NS Power estimates its marginal cost of adding production resource capacity during its 3-CP peak periods to be $13.107/KVA. Hence, to the extent the Board approves the use of a demand charge applicable to PHP's interruptible l...

AI summary NS Power estimates its marginal cost of adding production capacity during peak periods at $13.107/KVA, arguing that PHP's interruptible load credit should reflect this avoided cost. PHP questions whether setting the credit at this rate would make its coincident peak parameter in the COSS reasonable for both firm and interruptible demand.

1 2 fuel margins recovered in its energy rate and the remaining difference between the demand charge and the credit. Request IR-4: In its evidence, PHP states: PHP has the following specific areas of concern with respect to the proposed Ab...

AI summary PHP raises concerns about the proposed Above-the-Line Tariff, specifically regarding the use of a 57,000 kW winter month system coincident demand for its interruptible load and the value of the proposed Interruptible credit. PHP also questions the use of a Revenue-to-Cost ratio greater than 1.0 and the accuracy of forecast energy requirements used in calculating the tariff.

interruptible load is three-fold: - 1. It is based on PHP's historic contribution to winter month system coincident demand when PHP was operating on a different tariff that was subject to dispatch by NS Power and not intended nor anticipat...

AI summary PHP argues that using historic interruptible load data for capacity cost allocation is inappropriate, as it was based on a different tariff and could lead to over-allocation of costs. PHP proposes using 0 kW for winter month system coincident demand under the proposed ATL tariff, as interruptible load is subject to NS Power dispatch.

lication for the PHP successor tariff" and that "…the creation of the proposed deferral account, and the assumptions underlying it, do provide some certainty for the utility and the customer classes." (i) For the above noted reasons PHP's...

AI summary PHP argues that the proposed deferral account provides certainty for utilities and customers, aligning with the 2026-2027 GRA Settlement Agreement. It claims changes to COSS load parameters and rate design in its application would be managed prospectively by the deferral account, avoiding reopening prior matters determined in Matter M12451.

Response IR-7: (a) The additional ancillary service value noted by PHP should be considered as part of the overall determination of an appropriate cost-based rate applicable to PHP, and in support of the other cost-based approaches put for...

AI summary PHP requests the Board to mandate NSP to quantify ancillary value from ADC for rate-setting post-2027 and references an expedited process for determining an alternative BTL tariff by 2027, citing prior responses.

Preamble: NSPI's evidence states that optimal dispatch of PHP's load could yield system savings of $7–$11 million annually – which would accrue to PHP under the DR credit – but that realized savings may be approximately half that amount. (...

AI summary NSPI claims that optimal dispatch of PHP's load could result in system savings of $7–$11 million annually, but realized savings may be about half. The request asks PHP and BAI to assess the reasonableness of this range and identify key assumptions and constraints affecting the difference between optimal and realized savings.

Response IR-2: (a) Neither PHP nor BAI have conducted an independent production-cost modelling or analysis regarding the potential system savings achievable through dispatch of PHP's load. Such estimates are highly dependent on actual syst...

AI summary PHP and BAI argue they have not conducted independent production-cost modeling for dispatch savings, emphasizing the proposed methodology's reliance on actual system conditions. They note discrepancies between modeled and realized savings due to unpredictable events and lack access to NS Power's proprietary model. The ELIADC Tariff's past performance is cited as a reference.

1 Request IR-3: 2 3 Reference: N-2, Evidence of C. Fitzhenry and M. Gorman, page 3. 4 5 Preamble: PHP's consultant, Brubaker & Associates, Inc., states that the current ELID R/C 6 ratio is 1.04373 and recommends an R/C ratio of 1.0 "ensuri...

AI summary PHP argues that a new ATL tariff class should start with an R/C ratio of 1.0 to avoid cross-subsidies and ensure competitive neutrality, citing the Principle of Cost-Causality. It distinguishes this from past cases where gradualism was applied to protect existing classes.

Request IR-2: Considering the circumstance where the application is not approved, or considered not to be acceptable by PHP, and the ELIADC is not extended, and no new BTL rate exists on January 1, 2027, what is PHP's understanding of its...

AI summary Request IR-2 inquires about PHP's default rate for service if the application is unapproved, ELIADC not extended, and no new BTL rate exists by January 1, 2027, seeking clarity on the fallback rate structure under these conditions.

Response IR-2: Although PHP understands it would meet the availability requirements to take service under the Large Industrial Rate Interruptible Rider tariff, this tariff was not designed to accommodate the dispatch service proposed to be...

AI summary PHP argues the Large Industrial Rate Interruptible Rider tariff is unsuitable for its dispatch service and requires separate cost allocation. NS Power proposes treating PHP as a distinct rate class due to unique load characteristics. PHP suggests a below-the-line tariff if an above-the-line option is unavailable.

PHP INFORMATION REQUEST RESPONSES To: NS Power From: Port Hawkesbury Paper LP ("PHP") Copies: 1 electronic copy (PDF searchable) Contact Person: James MacDuff McInnes Cooper 1300 – 1969 Upper Water Street Purdy's Wharf, Tower II Halifax, N...

AI summary Port Hawkesbury Paper LP (PHP) disagrees with NS Power's proposed Above-the-Line Tariff for 2026-2027, citing concerns over demand parameters, interruptible credit value, revenue-to-cost ratio, and energy forecast assumptions. PHP requests clarification on the terms of the Settlement Agreement that underpin the tariff.

1 (iii) PHP energy will be based on PHP's forecast usage for the test years, net of 2 the amount forecast to be provided by the Goose Harbour Lake Wind Farm; 3 and 4 5 (iv) The dollar value of the Interruptible credit to be applicable to P...

AI summary The text outlines specific conditions and requests related to PHP's energy usage, interruptible load credits, revenue-to-cost ratios, transmission cost recovery, and rate structures. It includes questions about the application of the GRA Settlement Agreement, transmission cost savings, and the treatment of non-firm transmission service.

Response IR-1: (a) While the terms of the GRA Settlement Agreement establish the parameters for the modeling of the tariff to be included in the Application, the GRA Settlement Agreement is also clear that parties are free to take any posi...

AI summary The GRA Settlement Agreement allows parties to take positions in the Board process while requiring PHP to adopt a tariff with priority interruptibility by 2026. It also permits parties to challenge the alignment of the tariff with load characteristics in future regulatory processes.

e ability to serve PHP expected load according to its dispatch. PHP also notes the response to NSP IR-3 (b) which PHP has notified NS Power of its drop in maximum expected load from the previous year. Request IR-5: Reference: Direct Eviden...

AI summary PHP raises concerns about the ELID tariff, noting its drop in expected load and uncertainty about tariff differences. It requests clarification on ATL vs. BTL tariff distinctions, particularly regarding fuel and non-fuel components. PHP acknowledges the ELID tariff's fuel component but emphasizes BTL alternatives may include embedded non-fuel costs, though it cannot confirm this distinction definitively.

(b) Under the proposed ELID Tariff, PHP's understanding is that the Company proposes to credit PHP for the continued provision of Priority Interruptible service at a value of 10% of the Interruptible Credit, which is approximately $500,000...

AI summary The proposed ELID Tariff would credit PHP for providing Priority Interruptible service at 10% of the Interruptible Credit, approximately $500,000. NS Power argues that the ELID Energy Charge recovers both fuel and non-fuel costs of serving interruptible demand, and thus no additional interruptible credit is needed beyond PHP's firm demand of 8 MW.

Request: Please confirm, or explain otherwise, if it is BAI's understanding that in accordance with the Company's proposed cost-of-service methodology, as supported by PHP, and the proposed rate design, under the proposed ELID Tariff: (a)...

AI summary The request seeks confirmation from BAI regarding the proposed ELID Tariff's cost-of-service methodology, specifically whether non-fuel energy-related fixed costs are included in the Energy Charge and if demand-related costs are recovered solely through a demand charge.

Response IR-7: - (a) PHP cannot confirm that non-fuel energy charges consist strictly of energy-related fixed costs. Based on the System Load Factor ("SLF") methodology, generating resource costs are functionally allocated to both demand a...

AI summary PHP argues that non-fuel energy charges recover production capacity costs via the ELID energy charge, while NS Power clarifies that energy rates capture non-fuel expenses. The ELID Tariff's interruptible credit aligns with LIIR terms but differs from NS Power's standard practice. BAI questions if the ELID Tariff's demand charge and interruptible credit match their proposal, with NS Power noting discrepancies in capacity cost calculations.

ible and dispatchable, and, as result, should be adequately compensated for the operational benefits that PHP provides to the NS Power system through the ELID Tariff. (b) See response to subpart (a). Request IR-11: Reference: Evidence of C...

AI summary The text discusses the proposed ELID 2027 energy charge exceeding NS Power's LI tariff fuel costs, leading to non-fuel margin collection. It requests clarification on BAI's comparison intent between 2026 and 2027 BCF components and highlights differences in COSS metrics and service area utilization between rate classes.

1 2  Differences in the extent to which demand and energy charges applicable to 3 each of the classes are aligned with the costs of energy and demand services 4 in the COSS for these two classes. 5 6  The effect of fuel-related rate-smoo...

AI summary The text discusses differences in energy and demand charges between the LI and ELID rate classes, the effect of fuel-related rate-smoothing, and the potential for credits to PHP from dispatching its load under the ELID tariff. It also references the ELID's role in system power supply savings and its interruption limitations compared to the LIIR tariff.

he Performance Penalty which is based on the Customer's performance during the interruption event is calculated as per the formula below: Performance Penalty = ($15/kVA x A) + ($30/kVA x B) Where: - "A" is any residual customer demand (abo...

AI summary The text outlines a Performance Penalty formula for customer demand during interruptions, defines variables A and B, and discusses NS Power's policies on interruptible load. It argues that PHP's load should not be treated as firm service, and that capacity allocation charges may be excessive. BAI did not perform the requested calculation, while PHP lacks penalty examples.

(d) Please see the table below: Value Attribute Associated Credit / Component System Energy Savings Dispatchable Rider (DR) Credit Generation Capacity Interruptible Credit Transmission Capacity Interruptible Credit Priority Interruption Pr...

AI summary The document references a table outlining value attributes and associated credits, including Dispatchable Rider (DR) Credit and Interruptible Credit. It also references a request (IR-7) and directs to evidence provided by Colin T. Fitzhenry and Michael G. Gorman on behalf of PHP, regarding the utilization of the marginal cost of capacity at $13.107/kVa for the interruptible credit.

Response IR-1: - The Cost of Service GRA element in the Settlement Agreement is as follows: - a) The COS as set out in the Draft GRA will be included in the 2026-2027 GRA and put forward for approval, subject to the following: (a) use of t...

AI summary The Settlement Agreement outlines the Cost of Service (COS) GRA element for 2026-2027, subject to future proceedings on methodology and cost apportionment. NSP will disclose data on PHP's use of the High Voltage transmission system, with parties free to argue PHP's responsibility for associated costs. PHP is classified as an above-the-line customer in the 2026/2027 COS study, contingent on Board approval for a new tariff by 2026.

In respect of the DR (previously ADC), the Tariff (page 8 of Attachment 1 to N-1) indicates: "NS Power will be able to actively manage the Customer's load in accordance with the terms and conditions to be set out in an Operating Procedure"...

AI summary The document discusses Nova Scotia Power's (NSP) ability to manage customer load under the DR (Demand Response) program, specifically whether NSP can force consumption profiles or if PHP can ignore DR price signals. It also questions why an Interruptible Rider is needed if NSP already has dispatch authority.

Responses to IG Consultant (Bowman) Questions – 2 of 4 Question NS Power Response Please also refer to 2. The PHP related savings from optimizing load are indicated to be already included in the COS from the GRA. NSP indicates this means t...

AI summary The document discusses responses from NS Power to questions raised by an IG consultant regarding demand response (DR) savings and the Customer Baseline Load (CBL) calculation. It explains that if PHP does not optimize load, the costs would be absorbed by NS Power, and the CBL is based on a high-load factor annual profile to ensure optimal energy use.

Responses to IG Consultant (Bowman) Questions – 3 of 4 Question NS Power Response Please also refer to 4. NSPI(IG) IR-27(b) indicates: "Any attempt to more precisely quantify monthly benefits before the annual load is known and the PortOps...

AI summary NS Power explains that implementing the ELID rate partway through a year, such as mid-2026, would require settling the ELIADC Tariff first. The CBL would be based on PHP's actual energy consumption during the ELID service period, and outage days would be randomized for comparison on an equivalent-energy basis.

NON-CONFIDENTIAL 1 Request IR-20: 2 3 Reference: N-1, ELID Application, page 17. 4 5 6 In addition to [fixed cost recovery], the ELID tariff will affect fuel costs borne by other customer classes in two respects: 7 8 9 10 11 12 13 14 15 16...

AI summary The text discusses how the ELID tariff affects fuel costs for different customer classes, particularly focusing on the impact of DR service on PHP and ATL customers. It outlines scenarios where marginal costs are above or below average and explains how this affects cost distribution and the role of the FAM in addressing these effects.

ty provision for PHP reduces the potential of other customers to be interrupted, then the value of the interruptible credit to other interruptible customers should be revisited in a future proceeding. Furthermore, NSP explained that with r...

AI summary NSP and InterGroup discuss the value of Priority Interruptible (PI) service under the ELID Tariff, noting that its benefits require further evaluation. NSP proposes examining PI service value in the next GRA, while InterGroup suggests aligning the review with 2028 implementation. The Board recommends approving the service for 2026–2027 test years with a pre-2028 review.

AREAS OF EXPERIENCE: - Utility Regulation, including Revenue Requirement, Depreciation, Cost of Service and Rate Design - Economic/Financial Analysis, including Cost-Benefit Analysis and Business Valuation - Strategic Planning and Assessme...

AI summary The text outlines areas of expertise in utility regulation, economic analysis, and public policy advisory, highlighting qualifications such as Certified Depreciation Professional and advanced degrees in economics. It emphasizes experience with revenue requirement, depreciation, cost-of-service analysis, and rate design within regulatory contexts.

Utility Regulation For the Office of the Utilities Consumer Advocate of Alberta (UCA) (2019-Present): Expert support in the review and analysis, including drafting information requests and issues summary, submission of testimony in the For...

AI summary The text details professional experience in utility regulation, including expert support in Alberta and Northwest Territories proceedings involving rate design, revenue requirements, and General Tariff Applications (GTA). It outlines involvement in mediation, testimony, and analysis for multiple utilities and regulatory bodies.

Municipal Utility Rates Review For Town of Drumheller (AB) (2022): Developed a water and sewer utility rate model that allows systematic calculation of appropriate water and sewer utility rates to charge to ratepayers. Developed rate desig...

AI summary The document details various municipal utility rate reviews conducted between 2020 and 2025, focusing on developing fair rate structures, revenue requirements, and cost-of-service studies to ensure financial sustainability for water, sewer, and other utilities across multiple Canadian municipalities.

ation approach focused on a staged analysis, including a baseline financial forecast focusing on utility cash- flow and dividends, with reasonable estimates of future capital spending and rate levels. For Government of Northwest Territorie...

AI summary The text outlines economic/financial analyses for renewable energy projects in the Northwest Territories and Qulliq Energy Corporation's (QEC) initiatives. It includes evaluations of solar, wind, and LNG projects, transmission line extensions, and capacity planning for industrial customers. QEC's work on pricing strategies, IPP programs, and capital project planning is detailed.

Public Policy Advisory For Qulliq Energy Corporation (QEC) (2009-Present): Organize regulatory sessions for QEC's senior management to familiarize them with the regulatory process and policy requirements. Assisted QEC with developing a Net...

AI summary The text outlines regulatory and policy advisory work for Qulliq Energy Corporation (QEC), the Government of the Northwest Territories (GNWT), and the Northwest Territories Power Corporation (NTPC), including net metering program development, electricity regulation reviews, and energy action plans. It also details a study on diesel fuel costs for the Gwich'in Council International, focusing on alternative energy solutions.

Hayitboy Mahmudov - Utility Regulation Experience Utility Proceeding Work Performed Before Client Year Oral Testimony NTPC 2012/13 and 2013/14 Phase II General Rate Application Lead consultant on cost of service study and rate design; Assi...

AI summary Hayitboy Mahmudov has provided utility regulation consulting services to NTPC in multiple rate applications and technical workshops, including conducting cost of service studies, rate design, revenue requirement analysis, and preparing evidence for regulatory proceedings.

Utility Regulation For the Utilities Consumer Advocate of Alberta (2018-Present): Retained by the UCA as a technical expert on revenue requirement, cost of service and rate design matters for a number of proceedings including the 2025-2028...

AI summary The Utilities Consumer Advocate of Alberta (UCA) has served as a technical expert in multiple regulatory proceedings, focusing on revenue requirement, cost of service, and rate design. Key proceedings include rate applications by ENMAX, ATCO, FortisAlberta, and others, involving tariff structures and distribution system inquiries.

For the Ontario Energy Board (2024) Study director for a review of cost award processes, consultant and legal fee tariffs and options for improving regulatory efficiency. Reviewed practices in a number of Canadian and American jurisdiction...

AI summary The text outlines consulting roles in regulatory reviews, including cost award processes, tariff improvements, and efficiency reforms for the Ontario Energy Board and other jurisdictions. It highlights work on revenue requirements, rate design, and cost-of-service analyses for various utilities and governments.

Andrew McLaren Utility Regulation Experience Utility Proceeding Work Performed Before Client Year Oral Testimony Enmax Energy Corporation 2021 RRO Non-energy tariff Lead consultant to UCA, submitted expert written evidence AUC UCA 2020-202...

AI summary Andrew McLaren's utility regulation experience includes leading consultancy roles for the Office of the Utilities Consumer Advocate of Alberta (UCA) in various regulatory proceedings involving rate applications, tariff designs, and mediation processes before multiple regulatory bodies including the Alberta Utilities Commission (AUC) and the Northwest Territories Public Utilities Board (NWTPUB).

Q. What is the purpose of your evidence in this proceeding? - A. On December 29, 2025, Nova Scotia Power, Inc. ("NSPI") filed a letter with the Nova Scotia - Energy Board ("Board") seeking approval for the Extra Large Industrial Dispatchab...

AI summary Nova Scotia Power, Inc. (NSPI) seeks approval for the ELID Tariff, an above-the-line tariff for Port Hawkesbury Paper (PHP). Bates White Economic Consulting, as the Board's independent consultant, reviews the Energy Charge, Customer Charge, Goose Harbour Lake Wind Farm treatment, and the Dispatchable Rider Credit (DR Credit) in NSPI's application.

Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Confidential Version - Customer Charge ($/month) : Designed to recover the "costs associated with the provision of dispatch service to...

AI summary NSPI proposes an Above-the-Line Tariff for Port Hawkesbury Paper (PHP), including monthly customer charges, demand charges based on peak demand, energy charges tied to load and Goose Harbour output, and Above-the-Line Rider charges. PHP may earn Dispatchable Rider Credits to offset costs. The proposal is part of NSPI's 2026-2027 General Rate Application.

Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Confidential Version 1 Q. Do NSPI and/or PHP suggest that the ELID Tariff is proposed as a load retention tariff or 2 as including a d...

AI summary The document discusses whether the ELID Tariff is proposed as a load retention tariff or includes a discounted rate for power relative to other customers. NSPI denies this, confirming that the tariff is not structured as such.

- provision of dispatch service to PHP and to administer the Tariff." [35](#page-8-1) NSPI states that this includes (but is - not limited to) the following: (1) development, management, and refinement of ELID Tariff operating - procedures...

AI summary NSPI outlines the provision of dispatch service to PHP, including development of operating procedures, engagement with PHP on dispatch schedules, system operator interactions, regulatory reporting, and real-time optimization of PHP load for economic system dispatch.

- development."[40](#page-10-0) As such, "[t]he forecast cost of providing this function remains high level and, - as a result, the more conservative figure is proposed."[41](#page-10-1) NSPI did not, for example, develop its - estimates u...

AI summary NSPI explains that the Customer Charge for 2026 and 2027 will not be revised and that differences between collected charges and actual costs for administering the ELID Tariff will be reconciled through the PHP Deferral account, as outlined in the General Rate Application Settlement Agreement.

III. Assessment of the Energy Charge - Q. Please summarize the ELID Energy Charge proposed in NSPI's application. - A. NSPI proposes an Energy Charge of 9.977 ¢/kWh in 2026 and 11.240 ¢/kWh in 2027. 52 - Q. How were the Energy Charge rates...

AI summary NSPI proposes ELID Energy Charges of 9.977 ¢/kWh (2026) and 11.240 ¢/kWh (2027), calculated via a cost-of-service study (COSS) that treats PHP as an ATL customer. The rates incorporate fixed costs and net PHP load after subtracting Goose Harbour output (507 GWh), reducing PHP's modeled load to 304 GWh. This lowers PHP's total payments but increases per-kWh charges due to fixed cost allocation.

Q. Do you have concerns regarding the way the Energy Charge was determined? - A. Yes. Most significantly, we conclude that the net PHP load used in deriving the ELID Energy - Charge is too high, and the resulting Energy Charge rates are co...

AI summary The respondent raises concerns that NSPI's calculation of the ELID Energy Charge is flawed, citing an overestimated PHP load and an underestimated Goose Harbour capacity, leading to an incorrect net load figure and thus undervalued Energy Charge rates.

Q. What do you recommend with respect to the ELID Energy Charge? - A. We recommend that the Board does not approve the ELID Energy Charge as proposed. We - recommend that NSPI be required to update the COSS model to better reflect likely P...

AI summary The recommendation is to reject the ELID Energy Charge as proposed, emphasizing the need to update the COSS model with accurate PHP net load estimates, including Goose Harbour's 168 MW capacity output. Modifying other ELID tariff components without this update risks under-recovery of costs from PHP, increasing FAM customer risk.

- the value of the DR credit, NSPI will conduct an ex post production cost simulation model run to - determine the total system FAM costs using "actual system conditions that occurred throughout the year," - but assuming PHP would consume...

AI summary NSPI proposes a method to calculate the DR credit by comparing actual system costs with a scenario assuming high load factor consumption by PHP. The DR credit would be recovered from all above-the-line customers, but concerns are raised about the credit's accuracy as a proxy for marginal price signals.

1 V. Treatment of Goose Harbour Output 112 Goose Harbour PSA, page 7. 113 NSPI Application, page 13, lines 30-31. 2 Q. Please summarize how Goose Harbour generation is treated with respect to PHP and NPSI. 3 Goose Harbour is being develope...

AI summary The Goose Harbour output is treated under a Power Purchase Agreement (PPA) and a Power Sale Agreement (PSA) with NSPI. The PSA allows PHP to offset higher-cost energy with lower-cost Goose Harbour energy, potentially undermining PHP's status as an Above-the-Line (ATL) customer under the ELID. The output is deemed to serve PHP's load, and any excess is carried forward to future billing periods.

VI. Recommendations 2 Q. Please summarize your recommendations with respect to NSPI's Application. 3 A. We recommend that NSPI file additional evidentiary support for its proposed Customer Charge. 4 Absent this, we recommend NSPI set the C...

AI summary The recommendations include requiring NSPI to provide additional evidence for the Customer Charge, setting it at a midpoint if not supported, and ensuring reconciliation of ELID Tariff administration costs. The ELID Energy Charge and DR credit are not approved as proposed due to concerns over clarity, verifiability, and risk of mismatch.

1 National Association of Regulatory Utility Commissioners (NARUC) Subcommittee on 2 Rate Design at the 2021 Winter Policy Summit and the 2018 Annual Meeting. 3 I have sponsored testimony before the Newfoundland and Labrador Board of 4 Com...

AI summary The witness has provided evidence before multiple regulatory bodies and has previously testified before the Nova Scotia Energy Board in several matters. They are now providing evidence on behalf of the Board regarding Nova Scotia Power's proposed ELID tariff, focusing on the Interruptible Rider and demand charge.

Q. What is the difference between an above-the-line tariff and a below-the-line tariff? - A. An above-the-line (ATL) tariff is primarily designed to recover embedded costs as - determined through a cost of service study after accounting fo...

AI summary An above-the-line (ATL) tariff recovers embedded costs determined through a cost of service study, while a below-the-line (BTL) tariff is used to achieve specific objectives like reducing peak load and is recalculated annually with formulas including embedded, marginal, and avoided costs.

Application (GRA)? A. NS Power's 2026-2027 GRA was resolved through a settlement agreement[9](#page-6-5) that was 2026-2027 GRA SR-01, Attachment 1b, p. 2, lines 21-24. Response to Synapse IR-2(c), 2026-2027 GRA SR-01, Attachment 1b, p. 2,...

AI summary The 2026-2027 GRA Settlement Agreement was approved with modifications, outlining assumptions for PHP's load characteristics and the creation of a regulatory deferral account to address variances between the ELID tariff and GRA assumptions. The agreement allows flexibility in the ELID tariff filing.

NS Power ELID Application, page 14. 1 subject to future recovery from ATL customers, subject to Board approval. These 2 differences may include final approved tariff design, PHP's participation, or related cost 3 12 and load assumptions. 4...

AI summary The ELID tariff is based on NS Power's existing Large Industrial (LI) tariff, with an Interruptible Rider and a Dispatchable Rider. Key elements include monthly customer charges, demand and energy charges, and various riders such as the fuel adjustment mechanism and demand-side management cost recovery.

Q. Does PHP support NS Power's proposed ELID tariff? - A. No. While PHP is interested in moving to an above-the-line tariff to reduce its exposure to electricity price volatility, PHP opposes NS Power's proposed ELID tariff and is unlikely...

AI summary PHP opposes NS Power's proposed ELID tariff and is unlikely to accept service under it if approved as-proposed. PHP suggests an extension of the ELIADC tariff or collaboration to develop a below-the-line tariff as alternatives.

1 Q. What are PHP's primary concerns regarding the ELID tariff as proposed by NS 2 Power? 3 A. PHP states that it is concerned about the following components of the proposed tariff: 4 1) Interruptible load of 57 MW; 5 2) The value of the p...

AI summary PHP raises concerns about the ELID tariff proposed by NS Power, focusing on interruptible load, the value of the interruptible credit, the use of a revenue-to-cost ratio exceeding 1.0, and forecast energy requirements for 2026 and 2027. PHP suggests treating demand above 8 MW as non-firm and increasing the interruptible credit by over 50%.

3 In addition, PHP recommends that its revenue-to-cost ratio be reduced from 1.04 4 to 1.0 in the allocation of costs among customer classes, and that the ELID tariff be updated to incorporate revised 2026 and 2027 energy sales forecasts f...

AI summary PHP recommends reducing its revenue-to-cost ratio from 1.04 to 1.0 in the allocation of costs among customer classes and updating the ELID tariff to include revised energy sales forecasts for 2026 and 2027. These adjustments are summarized in Table 1.

IV. DEMAND CHARGE AND INTERRUPTIBLE CREDIT on PHP's firm load level of 8 MW, with no interruptible credit? A. No. PHP's consultants, Mr. Fitzhenry and Mr. Gorman of Brubaker and Associates (BAI), argue that NS Power's ability to curtail PH...

AI summary The discussion revolves around the appropriate basis for calculating PHP's demand charge and interruptible credit. PHP argues that its interruptible load does not contribute to NS Power's generation and transmission costs, but NS Power counters that transmission costs are driven by both interruptible and firm load, and that PHP's proposal would shift costs to other customers. NS Power also argues that compensating PHP at the full marginal cost would overstate its benefit to other customers.

PROFESSIONAL EXPERIENCE Synapse Energy Economics , Cambridge MA. Vice President, April 2023 – Present; Senior Principal, May 2022 – April 2023, Principal Associate, 2017 – May 2022 , Senior Associate, 2015 – 2017 , Associate , 2012 ‒ 2015...

AI summary The text details the professional experience of an individual working in energy economics, including roles at Synapse Energy Economics and the University of Wisconsin, with a focus on utility regulation, environmental economics, and energy efficiency. The individual has contributed to rate design, alternative regulation, and public utility commission proceedings.

PUBLICATIONS Havumaki, B., A. Fuzaylov, M. Whited. 2025. Optimizing Incentives for Effective PIMs: Coordinating PIMs with authorized ROE for Efficient and Effective Regulation. Synapse Energy Economics for Clean Virginia. Shenstone-Harris,...

AI summary The publications section lists several studies and reports conducted by Synapse Energy Economics and other organizations on topics such as electric vehicle adoption, building electrification, offshore wind benefits, and industrial electrification. These studies aim to inform regulatory and policy decisions related to energy efficiency and grid modernization.

TESTIMONY AND COMMENTS Indiana Utility Regulatory Commission (Cause No. 46120): Direct Testimony of Melissa Whited addressing the appropriate return on equity for Northern Indiana Public Service Company in light of its high rates and recen...

AI summary Testimony and comments from Melissa Whited and others in various regulatory proceedings across different states and provinces, discussing topics such as return on equity, electrification rates, cost of service studies, and infrastructure cost recovery mechanisms. These testimonies were presented on behalf of various organizations and commissions.

TESTIMONY ASSISTANCE Colorado Public Utilities Commission (Proceeding No. 16AL-0048E) : Answer testimony of Tim Woolf regarding Public Service Company of Colorado's rate design proposal. On behalf of Energy Outreach Colorado. June 6, 2016....

AI summary This section lists various testimonies provided by individuals and organizations in different regulatory proceedings across multiple states, including Colorado, Nevada, Missouri, Wisconsin, and Maine, regarding rate design proposals, net metering tariffs, and other energy-related matters.

PRESENTATIONS Whited, M. 2024. "Benefits of Offshore Wind in New England" Webinar presentation sponsored by Sierra Club, June 24, 2024. Whited, M. 2021. "Evolution of Net Metering in Hawaii." Presentation to the NARUC Winter Policy Summit....

AI summary The document lists a series of presentations by Michael Whited on various energy and utility-related topics, including offshore wind, net metering, rate design, demand charges, performance incentive mechanisms, and energy policy. These presentations were delivered at conferences, summits, and workshops across North America.

Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report (NSEB M12768) NSPI Responses to BW Information Requests

AI summary The document outlines the Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report and Nova Scotia Power Inc.'s (NSPI) responses to BW Information Requests, providing insights into the tariff's implementation and related inquiries.

NON-CONFIDENTIAL 1 Request IR-5: 2 3 Please refer to PDF page 3, "Load Variations." Did PHP's lower-than-forecasted demand 4 increase system costs, such as through retention of higher capacity, higher reserves, greater 5 unit commitment, o...

AI summary The response to Request IR-5 explains that PHP's lower-than-forecasted demand did not impact NS Power's long-term procurement decisions, such as gas and power RFPs, as PHP's load is not currently included in these decisions. Modeling from PortOps shows that PHP pays for all generation serving its demand.

Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report (NSEB M12768) NSPI Responses to BW Information Requests 1 Request IR-6: 2 3 Please refer to PDF page 4, "Off-Schedule Summary" and "Other Code Summary." 4 5 (a...

AI summary The document outlines NSPI's responses to information requests regarding the ELIADC Tariff 2025 Annual Report, focusing on the impact of a cyber event on cause codes, the dispatch process for PHP, and the tracking of cause codes post-cyber event.

Extra Large Industrial Active Demand Control (ELIADC) Tariff 2025 Annual Report (NSEB M12768) NSPI Responses to IG Information Requests 1 Request IR-1: 2 3 4 Reference: 2025 Annual Report, Exhibit N-1, p. 3/9, Table 1 5 (a) Please explain...

AI summary The document outlines a request and response related to the ELIADC Tariff 2025 Annual Report, focusing on the benefits reported for 2025 compared to initial forecasts and the factors influencing the ADC load shifting differential. The response references a 2019 tariff application and provides context on expected annual benefits.

Part B – Protocol Forecasting and Operation - (1) Annually, no later than the seventh business day of November, NS Power will forecast the Monthly Demand Schedule, Weekly Demand Schedule, and monthly and weekly limits based on PHP's demand...

AI summary NS Power is required to provide regular demand forecasts and schedules to PHP and NSPSO, including monthly, weekly, and daily demand schedules, as part of the system day-ahead planning process. These forecasts are used to optimize PHP's demand within the NS Power portfolio.

EXTRA LARGE INDUSTRIAL ACTIVE DEMAND CONTROL TARIFF Page 3 of 7 Schedule 1: Active Demand Control Energy Supply Protocol - (a) With respect to forecast PHP annual capital shutdowns, PHP will provide a minimum of one month's advance notice...

AI summary This section outlines the procedures for adjusting demand schedules and communication protocols under the Extra Large Industrial Active Demand Control Tariff, including advance notice requirements for shutdowns, intra-day schedule updates, and conditions for rate adjustments based on cost differences.

2025 ELIADC IG IR-3 Attachment 1 Page 5 of 7 REDACTED (CONFIDENTIAL INFORMATION REMOVED)

AI summary The document is a redacted attachment from a 2025 ELIADC IG IR-3 proceeding, indicating that confidential information has been removed. It likely contains details related to the Extra Large Industrial Active Demand Control program and its implications for Nova Scotia's energy sector.

Part D – Operating Mode Characteristics Schedule For the purpose of planning, dispatch and forecasting, PHP's loading levels will be separated into 9 distinctive operating modes. Only one mode will be able to operate at any given time. The...

AI summary PHP's load will be divided into nine operating modes for planning and dispatch purposes. The Operating Mode Characteristics Schedule outlines parameters such as ramp rates, outage planning, and energy requirements. NS Power and NSPSO must dispatch PHP's load according to this schedule, and it can be modified with agreement between PHP and NS Power.

2025 ELIADC IG IR-3 Attachment 1 Page 7 of 7 REDACTED (CONFIDENTIAL INFORMATION REMOVED)

AI summary The document is a redacted attachment from a 2025 ELIADC IG IR-3 proceeding, indicating that confidential information has been removed. It likely contains details related to the Extra Large Industrial Active Demand Control program and its implications for Nova Scotia Power Inc. and the Nova Scotia Energy Board.

REDACTED 1 incentive for PHP to follow dispatch and retain its 25 percent share of the ADC Load 2 Shifting Differential. In 2021-2024, the ADC Load Shifting Differential was negative, and 3 therefore no Off-Schedule Charges were applied. 4...

AI summary The text discusses the ADC Load Shifting Differential and Cause Code tracking issues in 2025, including the lack of Off-Schedule Charges due to a negative differential and the need for normalization of data during incomplete tracking periods. NSPI's assessment of ELIADC performance is also addressed.

1 Request IR-1: 22 in three bullets. Were these reasons referenced in previous years by PHP, in relation 23 to its reason for having deviated from the submitted schedule? If it has, what does 24 NS Power understand to be the specific impac...

AI summary The document outlines questions from a regulatory proceeding regarding deviations by PHP from its submitted schedule, the impact of global trade challenges in 2025, and the net balance owing to PHP. It also inquires about the ELIADC Tariff and its implications for PHP's load forecasts and ADC benefits.

PRE-FILED TESTIMONY OF PATRICK BOWMAN IN REGARD TO MATTER M12661 NOVA SCOTIA POWER EXTRA LARGE INDUSTRIAL DEMAND TARIFF Submitted to: The Nova Scotia Energy Board on behalf of Industrial Group Prepared by: Bowman Economic Consulting Inc. 1...

AI summary Pre-filed testimony submitted by Bowman Economic Consulting Inc. on behalf of the Industrial Group regarding Nova Scotia Power's Extra Large Industrial Demand Tariff in Matter M12661. The testimony is part of a regulatory proceeding before the Nova Scotia Energy Board.

1.1 Findings and Recommendations - The proposed ELID rate is complicated and unusual in utility rate regulation. No comparable rate could be - identified in Canada, particularly for a major customer on a regulated utility system. - Despite...

AI summary The proposed ELID rate is criticized for being complex and unfair, failing to reflect service costs or value. Recommendations include adjusting capacity values, limiting PHP's DR credits, rejecting interruptibility credits, and ensuring transparency in operating procedures. The ELID's predecessor, ELIADC, is acknowledged as beneficial but requires reforms to address inequities in cost allocation and dispatchability.

2.0 NSP ELID RATE PROPOSAL - PHP is NSP's largest customer, forecast in the most recent NSP GRA to use over 810 GW.h per year for - 2026, with the hourly on-site demand able to vary from 12 M[W](#page 1-7) 1 to 160 MW.[2](#page 1-8) PHP no...

AI summary NSP proposes a new ELID tariff for its largest customer, PHP, retaining the dispatch role under the 'Dispatchable Rider' (DR). The proposal uses 'above the line' Cost of Service techniques and a DR credit to allocate costs, claiming it is functionally similar to the existing ELIADC tariff but with updated rate-setting methods.

3.0 ISSUES WITH NSP'S PROPOSED ELID TARIFF - The proposed ELID tariff is fundamentally an attempt to cost and price the service that PHP is proposed to - receive. The ELID as proposed by NSP contains a number of assumptions and calculation...

AI summary The proposed ELID tariff by NSP faces four key issues: flawed cost-of-service (COS) calculations, improper DR credit application, IR credit concerns, and inadequate transparency. These flaws result in an unfair tariff framework for PHP and other ATL customers, failing to accurately price services.

3.1 Issues in the COS for establishing the ELID ATL Costing (Before Application of the DR) - In the first step of the rate development, PHP is included in the NSP COS study as an ATL customer. - The PHP usage in the COS is intended to refl...

AI summary The document addresses issues in the Cost of Service (COS) study for establishing the ELID ATL Costing for PHP prior to applying the Dispatchable Rider (DR). It emphasizes the need to base capacity inputs on a Constant Base Load (CBL) assumption, recommending a 120 MW capacity value for PHP to align with CBL principles and ensure accurate transmission and generation cost allocation.

3.2 Issues Associated With Application of the DR - The DR is a highly accommodating and beneficial aspect of the ELID rate to PHP. It also appears to be - unprecedented in Canada. - Not only does PHP secure the ability to access approximat...

AI summary The Dispatchable Rider (DR) under the ELID rate provides PHP with significant benefits, including compensation for load variation and access to NSP's embedded resources. The DR is unprecedented in Canada and allows PHP to shift load without obligation, though NSP retains dynamic dispatch rights. This arrangement is clarified in a 2026 Technical Conference.

sidential classes (104.4% revenue:cost). [39](#page 1-14) - 4) PHP also apparently suggests some form of ancillary services credit be applied, though no specifics have been proposed.[40](#page 1-17) In respect of #1 – the update to loads –...

AI summary PHP proposes updating load forecasts, resulting in a slight decline in average energy unit cost ($425,000 annual savings) but increased capacity costs ($233,000). The net impact is deemed de minimus (under $200,000 annually on $80M/year billed amounts), with no material effect on Cost of Service (COS) under current +/-5% reasonableness ranges.

BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...

AI summary Bowman Economic Consulting Inc. provides regulatory consulting services to industrial energy users in Manitoba and Newfoundland, focusing on rate design, revenue requirement reviews, cost of service, and demand-side management initiatives. They assist with General Rate Applications, cost-of-service analyses, and represent clients in regulatory proceedings.

Utility Regulation Conducted research and analysis for regulatory and rate reviews of electric, gas and water utilities in eight Canadian provinces and territories and international. Prepared evidence and expert testimony for regulatory he...

AI summary The text outlines a firm's extensive experience in utility regulation, including rate reviews, regulatory hearings, and analysis for various utilities across Canada and internationally. It highlights expertise in cost of service, revenue requirements, depreciation, and rate design, as well as involvement in regulatory processes and resource planning.

Utility Proceeding Work Performed Before Client Year Oral Testimony Newfoundland Hydro Rate Stabilization Plan (RSP) Finalization of Rates for Industrial Customers Analysis, Preparation of Intervenor Evidence NLPUB Newfoundland Industrial...

AI summary The table outlines various regulatory proceedings involving utility companies and their clients, detailing the work performed, the regulatory bodies involved, and the years of the proceedings. It includes examples of rate applications, depreciation methodology, and investigations into needs and alternatives.

Request IR-1: - Reference: Testimony, Section III, Page 15, Lines 2–13. Bates White states that the net PHP - load used in deriving the Extra Large Industrial Dispatchable (ELID) Energy Charge is too high - because it fails to incorporate...

AI summary Bates White argues that the net PHP load used in calculating the Extra Large Industrial Dispatchable (ELID) Energy Charge is too high, suggesting a more accurate figure of 121 GWh instead of 304 GWh. The question asks whether this revised net load would be used for both COS and rate design purposes.

Response IR-1: (a) The related discussion in the Bates White evidence addresses the effect of assumed PHP net load on determination of the ELID Energy Charge within NSPI's worksheets, and specifically that applying the more realistic net l...

AI summary The response discusses the inappropriateness of using PHP's net load definition for determining the ELID Energy Charge and actual cost to serve PHP load, citing Bates White evidence and suggesting a more realistic net load value would result in a higher Energy Charge rate.

Request IR-3: - Reference: Testimony, Section V, Page 33, Lines 11–18. Bates White outlines an extreme but - plausible scenario where PHP's annual net load subject to the tariff rate drops to zero, meaning - the mill would pay no Energy Ch...

AI summary The document references a scenario where PHP's net load could drop to zero, leading to no Energy Charge and failure to cover embedded fixed costs. It asks Bates White if customer classes using no energy from NSP due to a sleeving arrangement should be exempt from NSP's embedded fixed energy costs.

Request IR-1: - Refer to Section II of Bates White Evidence, where Bates White recommends that NS Power set - the Customer Charge at the midpoint of its estimated range, or $12,291.67/month.[1](#page-1-0) Bates - White further recommends t...

AI summary Bates White recommends setting the Customer Charge at $12,291.67/month with reconciliation to ELID Tariff administration costs. Questions seek clarification on whether this creates symmetric cost recovery, how under-recovery would be handled, and if full reconciliation would shift costs to PHP if NS Power's tracking methodology is validated.

30 Added peak demand to 120 MW: $9.4 million (may be less, pending NSP analysis) 1 multiple places, NSP indicates that effectively no PHP is load is typically 2 on the system at coincident peaks, as it will have already been curtailed 3 un...

AI summary The text discusses the impact of adjusting the peak demand and interruptible load valuation for PHP (Port Hawkesbury Paper) under NSP's (Nova Scotia Power) proposal. It highlights a potential overvaluation of PHP's interruptibility credit, with calculations showing varying monthly credits based on different demand levels, and recommends eliminating the priority interruptible credit due to its lack of system value.

1 2 wind, PHP will consume 305 GW.h, so that scenario does not appear relevant. 3 4 (b) If PHP operated at 120 MW all year, and consumed 1,051 GW.h of energy, then yes, the system costs would go up. 5 (c) Yes. 6 7 8 9 10 11 (d) No. The 3-C...

AI summary The text discusses the impact of PHP's energy consumption and demand scenarios on system costs and rate-setting. It outlines considerations for determining capacity value, load factors, and the use of different demand approaches, such as 3-CP, for establishing ATL rates, particularly for PHP.

Reference: Testimony, pages 12-13, lines 25-2. "The DR dollar value credit proposed to be allocated 100% to PHP risks over-crediting PHP for the value of DR, and harming other customers. This arises in part because the theoretical CBL agai...

AI summary The testimony raises concerns about the proposed DR credit allocation to PHP, suggesting it may over-credit PHP and harm other customers. It highlights the need for benefit sharing, similar to the current ELIADC tariff, and questions whether the DR calculation includes capacity cost savings and how these savings are passed on to PHP.

25 Response IR-4: 26 (a) The question poses an interesting hypothesis, as nowhere in the materials 27 did Mr. Bowman see a discussion of outcomes that could lead to the DR 28 being a net charge to PHP. Specifically, the ELID Tariff page 8...

AI summary The response discusses the DR mechanism and its implications for PHP, noting that there is no evidence supporting a net cost to PHP from DR. The DR is not intended to credit capacity cost savings to PHP, and the mechanism is recommended for review after the first year of operation.

26 Response IR-5: 27 (a) This is not clear. Mr. Bowman's understanding is that the interruptibility 28 values are based on $160/kW. In Exhibit N-2, Brubaker and Associates 29 indicate that this value is linked to a dated value of the avoid...

AI summary The response discusses the basis for interruptibility credits, particularly the $160/kW value linked to avoided generation costs. It questions the relevance of using a dated value and highlights that the actual contribution to system capacity avoidance depends on the customer's load during system peaks, not their maximum potential load.

1 Request IR-7: - 2 Reference: Testimony, page 15, lines 6-9. "The Board should not adopt the proposals - 3 from PHP to alter the rate as proposed by NSP. This includes adjusting the PHP peak load - 4 to 8 MW in the COS study, adjusting th...

AI summary The document includes a request (IR-7) asking for explanations regarding how PHP is compensated for ancillary services and operating reserves through the DR, and what the firm demand level for PHP would be under Mr. Bowman's proposals, which set its capacity value at 120 MW with limited credit for interruptibility.

1 Request IR-8: - 2 Reference: Testimony, page 18 lines 8-10. "Regarding PHP proposal #3, seeking - 3 changes to the proposed Revenue-to-Cost Ratios, there is no basis to exclude PHP from - 4 the overall GRA adoption of ratios above 100% f...

AI summary The text references testimony regarding PHP proposal #3 and its implications for revenue-to-cost ratios, referencing the NSP GRA negotiated settlement and Matter M12451 compliance filing. It asks for confirmation on whether the testimony contradicts the settlement, whether the ELID tariff was approved, and whether the PHP deferral account was approved in Matter M12451.

IG Request IR-1: Reference: N-19, Evidence of InterGroup, p. 5/pdf p. 7. Preamble: In s. 4.1, Inclusion of Interruptible Load in 3CP Calculation InterGroup stated: In InterGroup's experience this is a common problem with "interruptible" lo...

AI summary InterGroup is asked to identify alternative cost allocation methods for interruptible loads in the ELID Tariff, explain their operation, and assess their impact on demand cost allocation. It is also asked whether it agrees with using PHP's expected CBL operating load and if any method aligns better with the principle that ATL customers should pay their proper share of embedded system costs.

number of peak hours, without regard for whether such lowered capacity levels are consistent with sustainable business operations, are likely to result in an underallocation of costs to that customer. One set of options to address this as...

AI summary InterGroup discusses challenges in cost allocation for interruptible customers, proposing objective baseline verification methods like ERCOT's approaches. They agree the CBL baseline could be considered but note PHP's exclusion from capacity allocation risks cost shifting. Alberta's rate design recommendations are referenced as potential solutions.

CA Response IR-3: a) In InterGroup's view, the following factors need to be considered in assessing the quantum of DR savings proposed to be credited to PHP: - NSP cost-of-service study (COSS) already reflects interruptible service credit...

AI summary InterGroup argues that NSP's proposed DR credit to PHP may misalign with load seasonality, lacks alignment with existing cost allocations, and would shift costs to other customers via FAM. The response highlights issues with modeled baseline load assumptions, exclusion of VCC in the ELID Tariff, and reliance on theoretical data.

CA Response IR-4: a) Yes. - b) InterGroup believes that the proper mechanism should be aligned with key regulatory rate principles, in particular: - Simplicity and understandability; - Freedom from controversies as to proper interpretation...

AI summary InterGroup supports aligning the IR credit mechanism with regulatory rate principles, emphasizes the need to separate interruptible and DR service loads, and approves IR credit for 2026-2027 based on the GRA Settlement Agreement. However, they oppose future IR credit without a mechanism to prevent double-counting DR and IR service values.

PHP Request IR-2: Reference: Testimony, page 5: "InterGroup agrees with the concerns raised by NSP that including only the firm 8 MW of load would under-represent the degree to which PHP makes use of and benefits from the transmission syst...

AI summary InterGroup supports NSP's load parameters in the SA but notes that interruptible loads may underrepresent usage. They suggest this is a common issue and that alternative cost allocation methods could address it, though they find the current model reasonable.

PHP Request IR-3: Reference: Testimony, page 6. "The proposed cost-based demand charge is $12.872/kVA for 2026 and $14.310/kVA for 2027. At the rate of $13.107/kVA plus 10% PI premium, the interruptible credit would be $14.42/kVA, thus exc...

AI summary The text discusses the proposed cost-based demand charges for 2026 and 2027, comparing them to an interruptible credit calculation. It raises questions about the regulatory or economic rationale for ensuring that interruptible credits do not exceed embedded cost-of-service demand charges, as well as whether Intergroup agrees that capacity costs are functionalized as energy costs under NSP's COS.

CA Response IR-3: a) The rationale for why an interruptible credit based on a utility's avoided marginal cost of capacity cannot or should not exceed an embedded cost-of-service demand charge in the case of NSP's PHP ATL Tariff application...

AI summary The response discusses the rationale for limiting interruptible credits to avoid exceeding embedded cost-of-service demand charges in NSP's PHP ATL Tariff application, citing fairness and cost recovery principles. It also notes uncertainty about whether capacity costs are functionalized as energy costs under NSP's cost-of-service study.

CA Response IR-4: a) and b) Please see the response to NSPI (SBA) IR-1(h) (Exhibit N-9), where NSP states as follows: [M](#page-3-1)12451, Exhibit N-9, page 10 and 11 of 29. Under the Large Industrial Tariff, billing demand is based on met...

AI summary NSP proposes using the cost of service assumption for billing purposes under the ELID Tariff, while InterGroup argues that PHP's interruptible demand should be calculated based on load characteristics from the Settlement Agreement and historical peak loads for future years.

CA Response IR-5: a) No. InterGroup's evidence page 9 and 10 discusses NSP's response to NSEB-3 (Exhibit N-7), where NSP states: While on the ELIADC Tariff, 75 percent of the Active Demand Control (ADC) value was assigned to FAM. However,...

AI summary The response discusses the ELIADC and ELID tariff differences, focusing on how PHP's fixed cost contributions and DR credit impacts other customer classes. NSP explains that PHP can ignore DR price signals, but this results in increased costs for other customers. InterGroup raises concerns about fairness and cost causation.

And, at p. 12 line 24, and p. 13, lines 1-2: We do not agree that NSPI has made the "conservative" choice. Rather, NSPI has selected the value from its range that is most likely to under-collect the costs that the Customer Charge is intend...

AI summary The text presents questions challenging NSPI's Customer Charge estimation methodology, under-recovery implications, midpoint justification, and tracking mechanisms, involving Bates White and NSPI. It questions whether NSPI's approach under-covers costs and how adjustments would be handled.

Response IR-2: - (a) The Customer Charge cost estimate range put forth by NSPI has limited support. As we explain in our evidence, "NSPI's methodology for developing the [Customer Charge] estimate is not well explained in its Application,...

AI summary NSPI's proposed Customer Charge estimate lacks sufficient support, requiring additional evidence. If no evidence is filed, an alternative approach would increase the charge to $12,291.67/month with a reconciliation mechanism to recover ELID Tariff administration costs from PHP. Labor cost tracking for ELID Tariff administration is recommended for transparency.

And at p. 16, lines 10-13 and 15-16: Combining both the lower projected PHP gross load, and the higher expected output from Goose Harbour, the net PHP load incorporated in the COSS would more appropriately be 121 GWh rather than the 304 GW...

AI summary The text discusses a discrepancy in PHP's net load projections (121 GWh vs. 304 GWh) and its impact on NSPI's revenue, estimating a $21 million annual shortfall if Energy Charge rates are approved without correction. Questions are raised about Bates White's calculations, the accuracy of the Energy Charge rate, and funding sources for the shortfall.

Request IR-4: Reference : N-20, Bates White Evidence, pp. 16-17: Another issue that is notable, but likely of less significance than proper representation of the Goose Harbour facility capacity, is the fact that the generation of the facil...

AI summary The text discusses the use of P90 versus P50 generation levels in the cost-of-service study (COSS) for the Goose Harbour facility. Bates White argues that while P50 is more appropriate in principle, switching to it without operational data is premature. The questions raised focus on significance, cost impacts, risks, capacity factor calculations, and regulatory mechanisms for updating generation assumptions.

o set the Energy Charge rate, a lower amount of system fixed costs would be recovered from PHP, and a larger amount of system fixed costs would be borne by FAM customers. - (c) See response to IR-4(b)

AI summary The Energy Charge rate allocation would recover fewer system fixed costs from PHP customers while shifting a larger share to FAM customers. This approach is referenced in a prior response (IR-4(b)).

for changes to its load profile that would have been made regardless of the ELID Tariff and its components. - (a) Is Bates White saying that the ELID, or the DR credit specifically, should not pay PHP for load variations that are done for...

AI summary The text raises questions about whether Bates White believes the ELID Tariff, particularly the DR credit, should not reimburse FAM customers for load variations unrelated to NSPI's pricing signals. It also inquires about potential modifications to the ELID Tariff and whether similar issues exist under the ELIADC structure.

1 guardrails or reporting requirement? 2 (d) Under the current ELIADC tariff, load shifting savings are shared 75% to 3 other customers and 25% to PHP. Does Bates White agree that: 4 (i) The 75/25 benefit-sharing arrangement served as a 5...

AI summary The text raises questions about the ELIADC tariff's benefit-sharing arrangement, specifically whether the 75/25 split between other customers and PHP served as a buffer against overestimation of CBL and whether removing it would increase exposure for FAM customers. It also asks if Bates White objects to retaining a benefit-sharing approach in the ELID DR credit.

M12661 Date Filed: June 18, 2026 BW (IG) Page 21 of 28 1 (i) How could a true-up mechanism be designed to address 2 this scenario specifically? 3 (d) Does Bates White recommend that the true-up mechanism be scoped and 4 approved as part of...

AI summary The document discusses the design of a true-up mechanism to address cost recovery issues related to PHP under the ELID tariff. It highlights concerns about the PSA allowing PHP to 'bank' excess energy and avoid tariff charges, as well as issues with transmission losses not being properly accounted for.

And: We also recommend NSPI explain the methodology for tracking the costs of administering the ELID Tariff and how NSPI plans to ensure that 100% of the costs incurred above in administering the ELID Tariff are paid by PHP, including thos...

AI summary The text requests NSPI to explain the methodology for tracking the costs of administering the ELID Tariff and how PHP will cover these costs. It also seeks Bates White's opinion on quarterly reporting, the relationship between annual evaluation and true-up mechanisms, and the sequencing of these mechanisms in case of over-generation. Additionally, it asks whether the Board should impose specific reporting obligations.

Issued at Halifax, Nova Scotia, this 22nd day of June 2026. 1 Request IR-1: 16 • 2026-2027 GRA SR-01 – SR-04 17 18 Other Materials: 19 • Board Decision in NSUARB-NSPI-P-878 20 1 Request IR-2: 2 3 Reference: N-21 – Synapse Evidence, p.3/pdf...

AI summary The document discusses a proposed transition from a below-the-line tariff to an above-the-line framework for service to PHP by NS Power. The response outlines factors that make such a transition appropriate, including reasonable reflection of customer use, reduced complexity, and continuation or increase in net benefits to other customers.

evidence, setting the interruptible credit equal to the full marginal cost would allocate all of the benefits of avoided capacity to PHP, leaving other customers no better off than if an equivalent amount of generation capacity had been pr...

AI summary The text discusses the impact of setting interruptible credit equal to full marginal cost on PHP and other customers, and references FERC Orders 745 and 745-A regarding demand response compensation. It emphasizes the need for cost-effective alternatives to generation resources that provide net benefits to all ratepayers.

l ratepayers if the compensation rate is less than the full avoided cost, but sufficiently high enough to induce participation by those resources, while also accounting for changes in revenue impacts. (c) (i – iii) PHP would be charged for...

AI summary The text discusses compensation rates for PHP, suggesting they should be set below full avoided costs to induce participation while managing revenue impacts. It also proposes charging PHP based on embedded costs to maintain cost causation principles and reduce overall costs to ratepayers.

tribution) would reduce costs to all ratepayers relative to obtaining the capacity from the marginal generator. (d) It is appropriate to deviate from a credit at the level of the full avoided cost of

AI summary The text discusses the potential cost savings to all ratepayers if a certain approach is taken instead of relying on the marginal generator for capacity. It also mentions the appropriateness of deviating from a credit at the level of the full avoided cost.

- capacity in order to ensure that the credits provided to PHP provide net benefits to other customers. - (e) (i iv) "Induce participation" means a credit high enough that PHP is willing to take service on the tariff. The minimum compensat...

AI summary The text discusses the determination of interruptible credit levels for PHP, emphasizing the need to balance participation incentives with ratepayer benefits. It highlights that the minimum compensation required to induce participation is higher than $8.404/kVA but lower than PHP's proposed $13.107/kVA. The discussion also considers industry practices and the importance of maximizing net benefits to all ratepayers.

1 Request IR-4: 2 3 Reference: N-21 – Synapse Evidence, p.9/ pdf p.11, lines 16-17. 4 …[T]here is no above-the-line offering that would serve as a default rate for PHP. 5 (a) Please confirm Ms. Whited's understanding that PHP would meet th...

AI summary The document discusses a regulatory inquiry regarding PHP's eligibility for specific tariff rates and its potential uptake based on evidence provided. It confirms PHP's understanding of eligibility but notes that the proposed tariff has not been costed or priced with PHP's demand and energy forecast, nor would it enable the dispatch of PHP load.

M12661 Date Filed: June 22, 2026 Synapse (IG) Page 10 of 14 1 Request IR-5: 2 3 Reference: N-21 – Synapse Evidence, p. 13/ pdf 15, lines 7-10 and 14-19. 4 5 Q. If PHP's proposal to assess the demand charge on only 8 MW of its 6 demand is n...

AI summary The response to Request IR-5 discusses the theoretical net-avoided-cost figure as an upper bound for negotiated outcomes and confirms that the Board should pre-establish this cap as a condition of negotiation. The respondent also acknowledges the need for further calculation using NSPI's capacity cost data.

- (a) Please refer to the response to IG (Synapse) 3(f). - (b) Please refer to the response to IG (Synapse) 3(f). - (c) No. It is possible that PHP would require revisions to other aspects of the tariff as well before it would agree to tak...

AI summary The response outlines that PHP may require revisions to the ELID tariff before agreeing to take service, and clarifies that customer preference for lower rates is not, by itself, a basis for setting lower rates, though exceptions may exist for load retention.

Request IR-1: Reference: Testimony, page 12, line 20 to page 13, line 2: "Given that transmission costs are driven by both interruptible and firm load, it would not be appropriate to assign PHP a demand charge based solely on its 8 MW firm...

AI summary The text discusses concerns about how PHP's interruptible load may impact transmission costs and whether it should be held responsible for those costs. It requests analyses showing whether PHP's interruptible load has driven or is expected to drive incremental transmission investment or capacity expansion in Nova Scotia.

Request IR-2: Reference: Testimony, page 13, lines 10-19. "First, compensating PHP at the full marginal cost of generation capacity would overstate the value of its interruptible load from the perspective of other customers. While PHP's in...

AI summary The text discusses the compensation of PHP for its interruptible load, arguing that compensation should be capped at the avoided capacity cost net of its expected revenue contribution under firm service. It raises questions about the appropriate value to net from the avoided capacity cost and whether the expected revenue contribution should be limited to portions of PHP's COS for generation.

Response IR-2: (a) The referenced passage was intended to convey the need to compare two different scenarios: (1) a scenario in PHP is not interruptible and receives no interruptible credit, and in which NS Power procures 57 MW of addition...

AI summary The response discusses two scenarios involving interruptible credits and their impact on revenue and capacity costs. It highlights that interruptible credits should be set to ensure other ATL customers are not worse off and emphasizes the need for a rate and bill impact analysis in setting these credits.

Reply Evidence of Colin T. Fitzhenry and Michael P. Gorman 1 Q PLEASE STATE YOUR NAMES AND BUSINESS ADDRESS. 18 Industrial Dispatchable ("ELID") Tariff designed strictly around cost-causation 19 principles. The tariff must produce cost-bas...

AI summary PHP proposes a tariff design based on cost-causation principles, aiming to accurately reflect the specific costs it imposes and the benefits it provides to NS Power. It suggests separating its contribution to the 3-CP demand allocator into firm and interruptible demand components for rate design adjustments.

A No. PHP's current Tariff, the ELIADC Tariff, which will expire at the end of 2026, utilizes marginal energy cost rates. Marginal cost rates are generally applied to customers that are new to a system, charging them a premium energy rate...

AI summary PHP argues that its current ELIADC Tariff, which uses marginal energy cost rates, is unfair as it charges a premium to reflect incremental costs, despite PHP's long-standing contribution to the NS Power system. PHP requests a transition to a properly structured ELID Tariff on an ATL basis to ensure fair cost allocation and recognition of its operational flexibility.

Q HAVE INTERVENING PARTIES PROPOSED ALTERNATE RATES AND BILLING DETERMINANTS FOR THE ELID TARIFF THAT WOULD PRODUCE DISCRIMINATORY RATES FOR THE CLASS? A Yes, the IG's proposal to utilize PHP's average demand of 120 MW rather than the 3-CP...

AI summary Intervening parties have proposed alternate rates and billing determinants for the ELID tariff that may result in discriminatory rates for the class. The IG's proposal to use PHP's average demand instead of the standard 3-CP framework is criticized for unfairly increasing PHP's cost burden. Similarly, InterGroup's proposal to apply LIIR rates to the ELID class is deemed discriminatory as it uses billing determinants from a different class.

Q WHAT CAN YOU CONCLUDE ABOUT THE INTERVENOR EVIDENCE? A The alternative billing determinants and rate structures proposed by certain intervening parties violate fundamental principles of rate uniformity and cost causality, resulting in an...

AI summary The intervenor evidence shows that proposed alternative billing determinants and rate structures by some parties violate rate uniformity and cost causality principles, leading to an unjustly discriminatory framework aimed only at PHP.

Q CAN YOU BRIEFLY SUMMARIZE THE RECOMMENDATIONS OF MR. BOWMAN? A Yes. Mr. Bowman makes five recommendations: - 1) The capacity value used in the Cost of Service ("COS") for PHP should be representative of PHP's average demand, rather than...

AI summary Mr. Bowman recommends adjusting PHP's capacity value in the Cost of Service based on its average demand rather than peak demand, and revising the DR credit allocation to prevent over-crediting PHP. NS Power argues that using average demand ignores PHP's efforts to reduce system peak demand and the need for capacity investment.

Q PLEASE EXPLAIN WHY MR BOWMAN'S PROPOSAL TO USE PHP'S AVERAGE DEMAND IN DEVELOPING A DEMAND ALLOCATOR IS DISCRIMINATORY . A. As discussed previously, the proposal to inflate PHP's contribution to the system 3-CP demand by substituting its...

AI summary The response argues that using PHP's average demand instead of its actual peak demand in the demand allocator proposal is discriminatory. It inflates PHP's contribution to system capacity, leading to an overallocation of production and transmission resources, which is not cost-based and unfairly advantages PHP.

Q IS MR BOWMAN'S PROPOSAL CONSISTENT WITH THE BOARD DIRECTIVES THAT COST OF SERVICE AND RATE DESIGN BE BASED ON NON-DISCRIMINATORY RATEMAKING PRINCIPLES? A No. While we are not attorneys, our understating is that the Board operates under a...

AI summary The response argues that Mr. Bowman's proposal is inconsistent with the non-discriminatory rate-making principles mandated by the Nova Scotia Public Utilities Act. It also rejects his recommendation to allocate demand costs to PHP based on its average demand, citing unfair cost distribution. Additionally, the proposal to provide NS Power with practical control of PHP load during constrained conditions is deemed unreasonable, as it disregards PHP's operational constraints.

Q HOW DO YOU RESPOND TO MR. BOWMAN'S THIRD RECOMMENDATION THAT THE 100% ALLOCATION OF DR SAVINGS RISKS OVER-CREDITING PHP FOR THE VALUE OF THE DR? A Mr. Bowman's recommendation to strip PHP of 100% of the calculated DR savings ignores the...

AI summary The response argues that allocating 100% of DR savings to PHP is justified due to its unique load flexibility and the structural changes in the ELID tariff. It also defends the Interruptible Rider credit, emphasizing its role in cost avoidance and system planning.

Q DO YOU AGREE WITH MR. BOWMAN THAT BECAUSE PHP MAY HAVE ALREADY BEEN DISPATCHED DOWN TO REDUCE LOAD UNDER THE DR THAT THEY SHOULD NOT RECEIVE AN IR CREDIT? No. Mr. Bowman's argument ignores the completely distinct benefits of the DR and t...

AI summary The response rejects Mr. Bowman's argument that PHP should not receive an IR credit because it already reduced load under the DR. It emphasizes that DR and IR provide distinct benefits: DR avoids high-cost energy hours, while IR improves system reliability during constraints. The two mechanisms are not conflated despite overlapping timing.

Q PLEASE REPLY TO MR. BOWMAN'S FIFTH RECOMMENDATION TO ELIMINATE THE 10% PRIORITY INTERRUPTIBILITY CREDIT. A Mr. Bowman's recommendation is without merit. PHP is the first customer to be interrupted on the system and thus acts as a resourc...

AI summary The response argues against eliminating the 10% priority interruptibility credit for PHP, stating that PHP's role as the first customer to be interrupted provides value to the grid and other customers. It emphasizes that the tiered interruptibility structure reduces system reliability risk and protects other entities from operational disruptions, making the 10% premium fair and balanced.

Q CAN YOU BRIEFLY SUMMARIZE THE RECOMMENDATIONS OF THE CA WITNESSES? A Yes. InterGroup recommends that the Board rejects all four of PHP's proposed tariff modifications, noting that parameters like the 65 MW 3-CP Demand Allocation and the...

AI summary InterGroup recommends rejecting PHP's proposed tariff modifications, approving the Interruptible Service component for specific test years, mandating a review of the ELID Tariff, evaluating the retention of DR savings, and requiring formal Board approval of PHP's operating procedures to ensure transparency and prevent cost shifting.

Q DO YOU AGREE WITH INTERGROUP THAT THE R/C RATIO OF 1.04373 WAS AN "INTEGRAL CONSIDERATION" 17 OF THE SETTLEMENT AGREEMENT AND CANNOT BE ALTERED WITHOUT UNDERMINING THE AGREEMENT? A No. InterGroup's position attempts to lock PHP into an i...

AI summary The respondent disagrees with InterGroup's assertion that the R/C ratio of 1.04373 is an integral consideration of the settlement agreement. They argue that the agreement includes mechanisms allowing for challenges and adjustments, and that enforcing the 4.373% premium would create an inequitable subsidy to other customer classes. An R/C ratio of 1.0 is deemed fair under the Public Utilities Act.

Q DO YOU AGREE WITH INTERGROUP THAT ALLOWING PHP TO EARN AN IR CREDIT THAT EXCEEDS EMBEDDED DEMAND CHARGES WOULD CREATE A "NEGATIVE CONTRIBUTION" AND A DESIGN ERROR? A No. InterGroup's argument in PHP-IR-3(a) rests on the claim that becaus...

AI summary The response argues against the claim that allowing PHP to earn an IR credit exceeding embedded demand charges would create a negative contribution or design error. It explains that NS Power's tariff is based on embedded cost, not marginal cost, and that the COSS model does not fully classify generation capacity costs into demand charges. The response emphasizes that PHP's energy charge supports the system and that the IR credit should reflect the full avoided marginal cost of capacity.

Q DO YOU AGREE WITH INTERGROUP THAT THE IR CREDIT FOR PHP SHOULD BE SET TO THE SAME CREDIT AS THE LIIR CLASS? A No, as discussed previously, InterGroup's proposal to force the LIIR interruptible rate credit onto the ELID class is inherentl...

AI summary The respondent disagrees with InterGroup's proposal to apply the LIIR interruptible rate credit to the ELID class, arguing that it is discriminatory and inappropriate under cost-based rate-making principles.

Q CAN YOU BRIEFLY SUMMARIZE THE RECOMMENDATIONS OF MS. WHITED? A Synapse witness Melissa Whited recommends that the Board approve the proposed ELID tariff, but subject it to specific, targeted modifications to achieve a more equitable allo...

AI summary Melissa Whited recommends approving the ELID tariff with modifications to ensure fair allocation of capacity costs and system benefits. She opposes PHP's proposal to assess demand charges solely on its 8 MW firm load and rejecting pricing interruptible credit at full marginal cost. Instead, she suggests negotiating a revised credit value to balance PHP's participation and benefit other customers.

Q DO YOU AGREE WITH MS. WHITED'S RECOMMENDATION TO ADJUST THE PHP IR CREDIT TO ACCOUNT FOR PHP'S REVENUE CONTRIBUTION FOR NEW CAPACITY? A No. While I agree with this recommendation in principle, I do not recommend adjusting the methodology...

AI summary The respondent agrees with the principle of adjusting the PHP IR credit to account for revenue contribution from new capacity but does not recommend changing the methodology at this time, citing negligible impact and potential non-uniformity. PHP is willing to collaborate on revisiting the calculation in a future proceeding.

TO PHP? A No. As discussed in PHP's direct evidence, a minimal transmission cost allocation is entirely appropriate based on cost-causation principles and system planning realities. System reliability studies, such as Steady-State Power Fl...

AI summary PHP's demand should be allocated based on its 8 MW firm demand, as it does not require incremental transmission investments and its interruptible load does not necessitate capacity expansion. Charging PHP for unused assets would unfairly burden the ELID class.

V. RESPONSE TO BOARD STAFF WITNESS BATES WHITE Q CAN YOU BRIEFLY SUMMARIZE THE RECOMMENDATIONS OF BATES WHITE? A Bates White recommends that several key components of Nova Scotia Power's proposed ELID Tariff be rejected or substantially mo...

AI summary Bates White recommends rejecting or modifying several components of Nova Scotia Power's proposed ELID Tariff, including the ELID Energy Charge, DR credit framework, and mechanisms in the Power Sales Agreement, to prevent cost-shifting and under-recovery risks. They suggest recalculating the ELID Energy Charge using an updated COSS model and implementing an annual true-up mechanism for cost recovery.

Q DOES NS POWER AGREE WITH BATES WHITE THAT THE ELID ENERGY CHARGES IS NOT BASED ON PHP'S COST OF SERVICE? A. No. In Bates White IR-7(a), NS Power was asked if it considers the ELID Tariff as offering PHP a discounted rate for power relati...

AI summary NS Power disagrees with Bates White's assertion that the ELID Energy Charges are not based on PHP's Cost of Service. NS Power confirms that the energy and demand charges in the ELID Tariff are based on the Cost of Service Study, but the interruptible demand and priority interruption credits for PHP are not cost-based, leading to a $4.2 million annual impact.

Q WHAT IS YOUR UNDERSTANDING OF BATES WHITE'S RECOMMENDATION TO ADJUST THE ELID ENERGY CHARGE USING A NET LOAD THAT WOULD BE 121 GWH? A Bates White's recommendation to alter the COSS model inputs to force a higher per-unit Energy Charge ra...

AI summary Bates White's recommendation to adjust the ELID Energy Charge using a 121 GWh net load is rejected due to contradictory methodology. Bates White admits the net load framework is inappropriate for determining actual cost to serve PHP load, making the recommendation unreasonable.

Q DO YOU AGREE WITH BATES WHITE'S RECOMMENDATION TO CREATE A SYMMETRICAL TRUE-UP MECHANISM TO CORRECT FOR "SUBSTANTIAL DEVIATIONS" IN NET LOAD FACTOR EXPECTATIONS? A No. While Bates White confirms in its response to PHP-IR-4(b) that any pr...

AI summary The response rejects Bates White's recommendation for a symmetrical true-up mechanism, arguing that the parameters for 'substantial deviation' are arbitrary and that the requirement for hour-by-hour output from the wind facility violates the Power Sales Agreement, which allows PHP to track energy blocks on a monthly basis.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act – and – IN THE MATTER OF: An Application by Nova Scotia Power Incorporated for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable to Port...

AI summary Port Hawkesbury Paper LP disagrees with Bates White's assertion that PHP cannot levelize its load, arguing that industrial producers aim for efficient operations, continuous running of large motors reduces equipment wear, and improves reliability.

irements over the next three-year - 5 period." Our understanding is that no true-up mechanism is applied in these tariffs if those other - 6 industrial customers actual load deviates from forecast. 7 - 8 Furthermore, as noted by NS Power a...

AI summary The discussion revolves around the use of P90 in wind power projects and the treatment of demand cost recovery as a fixed charge. NS Power's approach to billing and the implications of the Power Sales Agreement (PSA) on the Goose Harbour facility are addressed, with a focus on system impact and cost recovery mechanisms.

tions on the system, at any given time, that will constrain PHPs ability to run, regardless of the price of energy on the system. PHP is not responding to price signals, and has no mechanism to do so. 9 See NSPI Application page 8, at foot...

AI summary PHP argues that it cannot respond to price signals under the ELID tariff and emphasizes the need for a cost-based interruptible credit to compensate for the risks of compliance. It highlights the self-policing mechanism of the ELID tariff and its willingness to take on risk in exchange for a financial benefit.

DATE FILED: July 8, 2026 Page 3 of 25 1 (2) Given that service to PHP under the proposed ELID Tariff has been costed and priced in 2 accordance with well-established ATL embedded cost-based practices, examined and 3 approved by the Board i...

AI summary The document discusses the proposed ELID Tariff and compensation for PHP's Priority Interruptible (PI) service. It argues that PHP should be compensated for PI service due to its reliability benefits and that the ELID Tariff aligns with established cost-based practices. The document also references the PHP Power Purchase and Sales Agreements and the Prescribed Generation Facilities and Energy-Storage Projects Regulations.

DATE FILED: July 8, 2026 Page 4 of 25 (1) For a new tariff with the unique characteristics and administrative requirements of the ELID Tariff, a Customer Charge is appropriate. In the absence of a concrete cost foundation for this tariff e...

AI summary The document proposes a Customer Charge for the ELID Tariff based on a high-level forecast due to the lack of concrete cost data. It argues that Board approval of DR Operating Procedures is not necessary for ELID Tariff administration, and that current annual reporting is sufficient for transparency and oversight.

2.1.2 Demand Assumptions The Company expressly recognized, in section 2.2. of the Application, the challenge with setting the initial demand assumption for a customer whose load is dispatched by the Company. To address this, NS Power propo...

AI summary The document discusses the challenge of setting initial demand assumptions for a customer with dispatchable load, noting that NS Power proposed revisiting this in future GRAs. The SA prescribes a 65 MW initial demand assumption, but both Bowman and PHP propose different figures based on their operational perspectives.

DATE FILED: July 8, 2026 Page 11 of 25 InterGroup Evidence (CA Consultant), page 6. - operational frameworks applicable to non-firm service for large industrial customers in Nova - Scotia have been in place for decades,[16](#page-11-0) the...

AI summary The text discusses operational frameworks for non-firm service for large industrial customers in Nova Scotia, highlighting the ELID Tariff and its distinction from other tariffs like the PHP Load Retention Tariff and ELIADC Tariff. It notes concerns about potential double-counting of credits if the Dispatchable Rider is paired with the Interruptible Credit. The Company argues that IR and DR services are distinct in their value to the system and how they are regulated.

ruptible service.[19](#page-11-3) This is the long-established process applicable to ATL interruptible service in Nova Scotia. DATE FILED: July 8, 2026 Page 12 of 25 As provided in NS Power's responses to Synapse IR-14 and SBA IR-2 part (c...

AI summary The document discusses the long-established process for ATL interruptible service in Nova Scotia, referencing historical approvals and methodologies for determining interruptible credit amounts. It also mentions system cost savings associated with interruptible service and how they are credited and assigned across rate classes.

time are assigned as costs to all rate classes, including those which provide the interruptible service, such that the net cost effect of these calculations on the total revenue requirement is zero."

AI summary The text explains that costs associated with time-based services are distributed across all rate classes, including those that provide interruptible service, ensuring that the overall revenue requirement remains unaffected.

• As with ADC under the ELIADC Tariff, DR is not mandatory. Under both the ELIADC Tariff and the proposed ELID Tariff it remains the customer's decision to comply with the dispatch direction necessary for the customer to achieve the associ...

AI summary The document discusses demand assumptions related to the ELID Tariff and DR (Dispatchable Rider) service, noting that DR is not mandatory and does not provide capacity-related compensation. It addresses concerns about the infrequency of interruptions and highlights the difference between system planning and operations. The ELID Tariff requires both DR and IR services, and there is a recommendation for stronger dispatch rights for NSP.

dispatched to minimal load under conditions likely to lead to calls for interruption than was the case under the ELIADC. [22](#page-13-0) It is true there is some interplay between these two service offerings. As PHP is dispatched down, wh...

AI summary The text discusses the interplay between Interruptible (IR) and Dispatchable (DR) services under the ELID Tariff, noting that while they interact operationally, they are distinct in compensation and purpose. It argues that IR allows for load interruption for reliability, while DR provides dispatch rights without overlapping compensation. The Bowman Evidence is referenced in this context.

e result is (absent the SA provision), the calculated ELID Tariff IR credit is much larger than the calculated LIIR IR credit. While Synapse recommends a larger IR credit should be provided to PHP than the SA prescribes, Synapse is of the...

AI summary The document discusses the calculation of ELID Tariff IR credits and LIIR IR credits, noting that the ELID Tariff IR credit is significantly larger than the LIIR IR credit. Synapse argues against providing the full calculated credit to PHP, citing concerns about over-allocation of benefits and shifting costs to other customers.

pan id="page-14-1"> InterGroup Evidence (CA Consultant), page 7. Refer to NS Power's responses to CA IR-1 and CA IR-9. Synapse Evidence (BCC), page 13, lines 16-18. allocate all of the benefits of avoided capacity to PHP, leaving other cus...

AI summary The text discusses NS Power's position on the allocation of benefits from avoided capacity, emphasizing that the ELID IR credit is established by the SA and that cost recovery practices are cost-neutral. It also mentions the proposed ELID Tariff and the distinction between interruptible service and DR service. The revenue-to-cost ratios for 2026 and 2027 are noted as an integral consideration in the SA.

Synapse Evidence (BCC), page 13, lines 20-21 and page 14, line 1. NSPI (Synapse) IR-10, as provided in footnote 20. InterGroup Evidence (CA Consultant), page 6. Refer to NSPI (CA) IR-9 which provided "[w]hile not expressly addressed in the...

AI summary The text discusses the transition of PHP from the ELIADC Tariff to the ELID Tariff, highlighting the shift from an incremental cost-based tariff to an embedded cost-based tariff. It mentions concerns about the allocation of DR benefits to PHP and the complexity of the ELID Tariff. NS Power argues that the new tariff aligns PHP's interests with other ATL customers and credits DR benefits fully to PHP.

and, as a result, it is proposed the benefits accrue fully to PHP (other than the portion recovered from PHP through the FAM).[36](#page-17-1) While the ELIADC Tariff has a sharing mechanism, this was appropriate because the cost foundatio...

AI summary The text discusses demand assumptions related to the ELID Tariff, highlighting the sharing mechanism and the fixed non-fuel cost component for PHP. It also addresses concerns about the DR credit as an imperfect proxy for marginal price signals and the reasonableness of assuming a high load factor premise for the ELID Tariff.

2.2.3 Concern with ELID Tariff Complexity - Bowman provides: "[t]he proposed ELID rate is complicated and unusual in utility rate regulation. - No comparable rate could be identified in Canada, particularly for a major customer on a regula...

AI summary The document discusses concerns about the complexity of the ELID Tariff, noting that while Bowman finds it complicated, the Company argues it is an evolution of the ELIADC Tariff and not a dramatic change. It also addresses the recommendation for Board approval of DR operating procedures, though no process is proposed for this approval.

Bowman Evidence (IG Consultant), page 15, lines 25-26 and lines 27-28. 1 The Company submits the Board's approval of the Operating Procedures will not limit or expand 2 the Board's oversight of tariff operation, while the process required...

AI summary The Company argues that the Board's approval of Operating Procedures will not enhance regulatory oversight and emphasizes the importance of analyzing the implications of eliminating Priority Interruptible (PI) service for all customers, given the size of PHP's load and the potential risks to the power system.

September 14, 2026 Nova Scotia Power is here before the Board in support of its Application for approval of the Extra Large Industrial Dispatchable, or ELID, Tariff applicable to Port Hawkesbury Paper. This Application was filed on Decembe...

AI summary Nova Scotia Power is seeking approval for the ELID Tariff for Port Hawkesbury Paper. The proposal was tested through written evidence, technical conferences, and stakeholder consultations. The ELID tariff is seen as a logical implementation of the framework established through the GRA process and the Cost of Service Study.

le PHP is generally in agreement with the form of the ELID Tariff applied for by NS Power, it has serious remaining concerns with various aspects of the proposed costing of the ELID Tariff as follows: - a) the use of a 57,000 kW winter mon...

AI summary PHP agrees with the form of the ELID Tariff but has concerns about its costing, including the use of outdated demand figures, the R/C ratio, and forecast energy assumptions. PHP seeks an embedded cost-based tariff and argues the current ELID Tariff overcharges them. These points are detailed in evidence from Brubaker & Associates and align with the 2026/27 GRA Settlement Agreement.

OPENING STATEMENT OF BRUBAKER & ASSOCIATES, INC. (BAI) ON BEHALF OF PORT HAWKESBURY PAPER LP NOVA SCOTIA ENERGY BOARD — MATTER NO. M12661 Good morning, Commissioners, Board Staff, and Counsel. My name is Colin Fitzhenry, and appearing with...

AI summary Brubaker & Associates, Inc. represents Port Hawkesbury Paper LP in a proceeding regarding Nova Scotia Power Inc.'s application to establish the ELID Tariff. While supporting the structural transition from the ELIADC Tariff, they argue that the proposed rate design and cost allocations deviate from cost-causation and non-discriminatory principles, leading to an over-allocation of costs to PHP.

on of costs to PHP. Our evidence focuses on several central cost-allocation and tariff-design elements required to ensure that the ELID Tariff produces just, reasonable, and non-discriminatory rates. First, regarding demand cost allocation...

AI summary Nova Scotia Power argues that the ELID Tariff's demand cost allocation should be based on PHP's 8 MW firm demand, not a 65 MW determinant, as the latter unfairly increases PHP's costs. The Industrial Group's proposal to use a 120 MW annual average load is criticized as discriminatory under the Public Utilities Act.

1 properly sequenced, and well-reasoned approach. Mr. Bowman's evidence proceeds in logical 2 order. First, a cost-of-service-based CBL reflecting PHP's expected high-load-factor demand 3 must be determined before any riders are considered...

AI summary The document outlines a method for determining the Cost-Based Load (CBL) for PHP, emphasizing the need to first establish a cost-of-service-based CBL before applying riders. It discusses the Dispatchable Rider and interruptible credit, highlighting the importance of aligning with the ELIADC approach and historical data. NSPI, PHP, and the Industrial Group present differing proposals for the CBL.

Mr. Bowman's approach is the only one of the three proposals that is analytically coherent 17 with the premise of an Above-the-Line rate and reflects the demand on which NSPI has built its 18 system. - 19 A further complicating factor is t...

AI summary Mr. Bowman's proposal is deemed analytically coherent with the Above-the-Line rate and NSPI's system demand. The Industrial Group raises concerns about the interaction between ELID and PHP's arrangements, dispatch rights under the Dispatchable Rider, benefit-sharing, and oversight of operational procedures.

Opening Statement of Patrick Bowman [1](#page-0-0) Nova Scotia Power Inc. ( NSP ) proposes a new tariff applicable to PHP, effective January 1, 2027. The proposed ELID is an "above-the-line" tariff, with Riders reflecting PHP's unique load...

AI summary Nova Scotia Power Inc. (NSP) proposes a new 'above-the-line' tariff for PHP, which allocates system costs to PHP based on load flexibility. The proposal includes Dispatchable and Interruptible Riders to credit PHP for load shaping. The speaker concludes that NSP's proposal requires adjustments to align with proper regulatory considerations for such a tariff.

2) DISPATCHABLE RIDER (DR): The DR credits PHP for shifting its load in response to marginal system costs. This is a substantial and unique benefit, particularly because it applies to approximately 800 GW.h of PHP consumption, even though...

AI summary The Dispatchable Rider (DR) provides PHP with credits for shifting load in response to system costs, including its own wind generation. While the benefit is acknowledged, concerns exist about insufficient control over PHP's dispatch and the potential for over-crediting. Recommendations include increasing system operator control and retaining benefit-sharing aspects of the ELIADC mechanism.

4) PRIORITY IR: NSP also proposes a further 10% IR credit for "Priority" interruptibility, meaning PHP would be interrupted before other customers. I do not find this appropriate for three reasons: - 1. PHP is rarely interruptible in pract...

AI summary NSP proposes a 10% IR credit for 'Priority' interruptibility, interrupting PHP before other customers. However, this is criticized for being inappropriate due to PHP's low interruptibility, non-priority status compared to some LIIR customers, and lack of new value or interruptible load.

Recommendation #5 is to eliminate the priority interruptible credit. PHP has rejected the NSP version of the ELID, and instead proposes an 8 MW peak load, a 100% Revenue-to-Cost ratio, and an added ancillary services related credit. These...

AI summary Recommendation #5 suggests eliminating the priority interruptible credit. PHP has rejected NSP's ELID proposal, offering an 8 MW peak load, a 100% Revenue-to-Cost ratio, and an ancillary services credit, which are deemed inappropriate and should be rejected.

Recommendation #7 is to reject the PHP proposals. I also note issues raised by Synaps[e](#page-2-8)7 suggesting that some of the above ratemaking principles should be abandoned simply to arrive at a rate PHP will accept. That would be inco...

AI summary The text discusses concerns with the PHP proposals, highlighting issues with ratemaking principles, complexity of the DR mechanism, and potential discriminatory practices. It also references cost implications and differences in how demand is calculated for PHP compared to other customer classes.

2 M12661, Letter from the Industrial Group, July 16, 2026. - 1 the Board as well and concurred with the Industrial Group that an oral hearing was appropriate - 2 given all the circumstances3 and the Board set a timetable for this hearing....

AI summary The document discusses the complexity of the ELIADC Tariff application, referencing its differences from the previous ELIADC Tariff and the impact of a prior Settlement Agreement. It highlights concerns about the equity of the proposed tariff and the need for a thorough discussion of these issues before approval.

- (DR-26) - Re: COSS - From Appendix 12A, Section 5.10 PHP as an above-the-line rate class, - (a) If PHP were to become an above-the-line rate class for the 2027 test year, please provide an estimate on the impact to NSPI's proposed rate i...

AI summary The response discusses NS Power and PHP's ongoing efforts to develop a potential above-the-line rate class successor to the ELIADC Tariff, focusing on cost of service treatment and rate design. The information provided is considered indicative and will be fully examined in a future regulatory proceeding.

REDACTED Crystal Henwood Regulatory AffairsOfficer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: Extra Large Industrial Active Demand Control (ELIADC) Tariff –...

AI summary Nova Scotia Power Incorporated submitted the 2022 Annual Report for the ELIADC Tariff, which resulted in a $3.83 million benefit to other customers. The report was required under the Board's approval of the ELIADC Tariff, which mandated annual reporting on system savings achieved through Active Demand Control.

CBL Energy Charge $ 54,298,884 956,809 ELIADC Report CBL Energy Charge ($) CBL Adder ($) ADC Load # of Hours # of Hours # of Hours # of Hours # of Hours Fuel & Purchased Variable Operating & Fixed Cost Total Delivered Target Energy Fixed C...

AI summary The document presents a detailed breakdown of the CBL Energy Charge and related financial figures for each month in 2022, including fuel and purchased power charges, variable operating and maintenance charges, fixed cost recovery, and ADC load shifting. The data shows fluctuations in energy charges and shifting benefits, with specific cause codes for load shifting events.

Cause Code 2 - NDN - NSP Energy System Operator initiated ramp Down Cause Code 3 - PFL - PHP Failure to Load due to equipment or process constraints Cause Code 4 - PNA - PHP and NSP Agreement to new dispatch Cause Code 5 - PDN - PHP Decisi...

AI summary The text discusses ADC and VOM adjustments related to energy management and financial provisions. It outlines how differences between provisional and actual values are accounted for in 2023, including the ADC Load Shifting Differential and VOM adjustments tied to ELIADC revenue and load serving.

Nova Scotia Power Inc. Annual FAM Reporting ELIADC Benefit Breakdown For the Year Ended December 31, 2022 Month Generation Cost Purchase Cost Sale Revenue Start Cost PHP Load CBL Energy Charge Cost to Serve (1) ADC Differential $/MWh ADC D...

AI summary The document presents Nova Scotia Power Inc.'s Annual FAM Reporting for the ELIADC Benefit Breakdown for the year ended December 31, 2022, including detailed monthly data on generation cost, purchase cost, sale revenue, and ADC differential.

rategy and approach to natural gas procurement and hedging by - Northwestern Energy Public Service Corporation d/b/a NorthWestern Energy (Nebraska Public Service Commission, Application No. NG-115.1) - On behalf of the Mississippi Public S...

AI summary The text outlines various testimonies and recommendations provided by entities on behalf of different regulatory bodies concerning energy procurement, hedging strategies, fuel adjustment mechanisms, and rate applications. These include matters related to natural gas procurement, fuel adjustment audits, and general rate applications.

ver's Report Regarding Hawaiian Electric Companies' Request for Proposals for Renewable Dispatchable Generation and Energy Storage on O'ahu. For the Hawaii Public Utilities Commission (November 2025). - Post-bid Report of the Procurement M...

AI summary The text lists various regulatory filings and reports related to energy procurement and tariff applications in multiple jurisdictions, including Hawaii, Illinois, and Nova Scotia. These include post-bid reports, comments, and submissions regarding renewable energy, demand control tariffs, and procurement events.

Selected experience - Evaluated PJM price formation, demand responsiveness, and demand response compensation proposals for comments submitted on FERC's ANOPR on "Wholesale Competition in Regions with Organized Electric Markets" (Docket Nos...

AI summary The text outlines the expert's experience in evaluating energy market regulations, providing testimony, and participating in FERC proceedings. Key areas include PJM price formation, demand response compensation, VPPA settlements, modifications to the minimum offer price rule, and rate design proposals for large loads.

Response Undertaking U-18: PHP is not aware of any communications in which PHP expressed dissatisfaction with the modelled costing determinants that are embedded in the Cost-of-Service Study for GRA settlement purposes. PHP understood that...

AI summary PHP has no record of expressing dissatisfaction with the modelled costing determinants in the Cost-of-Service Study for GRA settlement purposes. PHP acknowledges that the Settlement Agreement allows parties to take positions in the Tariff and ADC processes and that a deferral account will be established for revenue variances.

PARTIALLY CONFIDENTIAL (Attachment Only) ELID LIIR (with PHP) Variance % Var Subtotal $/kVA 5.801 0.552 (5.249) -90% Energy Charge (Firm) Base cost of fuel ¢/kWh 8.762 8.216 (0.546) -6% Non-fuel ¢/kWh 2.374 2.519 0.145 6% Subtotal ¢/kWh 11...

AI summary The document presents a comparison of energy charges and costs between ELID and LIIR (with PHP) in Nova Scotia, showing significant variances in both subtotal and energy charge categories. The data highlights differences in base cost of fuel and non-fuel costs, with percentages indicating the degree of variation between the two categories.

2 The annual revenue from the remaining LIIR customers would change very little in 2026; however, 3 in 2027 it would increase by $4.1 million (5.6 percent). NS Power has not analyzed the effect of 4 these rate changes on individual LIIR cu...

AI summary The text discusses the financial implications of changes to the LIIR rate class, noting that annual revenue from LIIR customers would increase in 2027 due to the inclusion of PHP's lower load factor. This affects cost distribution across the LI class. The analysis also highlights the sensitivity of results to different assumptions, such as demand figures.

REDACTED ELID Tariff U-1 Attachment 2 Page 27 of 94 REDACTED (CONFIDENTIAL INFORMATION REMOVED) (1) (2) (3) (4) (5) (6) (7) (8) (9) TOTAL PROD. TRANS. DIST. RETAIL PROD. TRANS. DIST. RETAIL EXPENSES EXPENSES EXPENSES EXPENSES EXPENSES WEIG...

AI summary The document presents a detailed breakdown of operating expenses for Nova Scotia Power Inc. for the year ending December 31, 2026. It includes various categories such as fuel, purchased power, thermal operations, solar, combustion turbine, and corporate expenses. The table outlines costs and weights associated with different operational segments, providing a comprehensive view of financial allocations.

FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : DOMESTIC RATE BASE (Source Exh. 3) Variable Fixed Costs COSTS (Source Exh 6) Unit Cost Demand ($/kW of Class monthly Energy Customer Fuel Operating Capital Return Total Total Cost Units Sold NC...

AI summary The document presents a detailed breakdown of financial and operational costs for the year ending December 31, 2026, including generation, transmission, distribution, and retail costs. It provides figures for fuel, operating, capital, and return costs, as well as unit costs and customer charges.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2026 CLASS : GENERAL RATE BASE COSTS (Source Exh 6) (Source Exh. 3) Variable Fuel Operating Capital Fixed Return Total Total Cost Units Sold Demand...

AI summary This document presents a detailed rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2026, including breakdowns of rate base, costs, and unit costs across various categories such as generation, transmission, distribution, and retail.

EXHIBIT 8B PAGE 2 OF 3 (1) TOTAL COMPANY (2) DOMESTIC (3) SMALL GENERAL (4) GENERAL (5) GENERAL LARGE (6) SMALL (7) MEDIUM INDUSTRIAL INDUSTRIAL INDUSTRIAL (8) LARGE (9) ELI 2P-RTP (10) MUNICIPAL (11) UNMETERED (12) ALLOCATION FACTOR (32)...

AI summary The document presents a table with various categories and percentages of responsibility for different types of expenses across multiple segments, including domestic, small general, general, and large industrial. Each row provides the total expense demand and the percentage of responsibility for each category, along with an allocation factor and reference numbers.

2018-2020 Regulatory Affairs Advocate Costs.xlsx 2022-2024 BTL Revenue.xlsx FOR-1-IS RB-2-16.xlsx 2022-2024 Proof of Revenue RD1.xlsx FOR-1-IS RB-2-16.xlsx 2019 Non-coincident peaks by Voltage category.xlsx 20210924 2022 Revenue model TVP....

AI summary The document contains a table with data on revenue ratios, number of bills, and revenue distribution across different customer categories from 2023 to 2026. It also includes factors related to wiring inspections, NRIS, ERIS, and biomass demand and energy splits, as well as a bad debt direct cost allocator for domestic customers.

ANALYSIS OF AVERAGE UNDERGROUND WIRE INVESTMENT (1) TOTAL PLANT (2) PRIMARY DEMAND (3) PRIMARY CUSTOMER (4) SECONDARY DEMAND (5) SECONDARY CUSTOMER (1) FACTORS 1.000 0.061 0.006 0.189 0.744 (2) TOTAL NET WIRE COST $61,657 $3,784 $347 $11,6...

AI summary The text presents an analysis of average underground wire investment, including factors and adjustments related to total plant, demand, and customer categories. It includes figures for total net wire cost and adjustments before and after a zero cap restriction.

CLASSIFICATION OF OPERATING EXPENSES (1) INTERMEDIATE CLASSIFICATION (2) (3) THERMAL O&M $112,085 (4) HYDRO O&M 4,410 (5) WIND O&M 15,704 (6) BIOMASS O&M 12,580 (7) LM6000 O&M 1,209 (8) OTHER CT's O&M 3,182 GENERATION BATTERIES RADIAL TO G...

AI summary The document presents a detailed classification of operating expenses for various energy generation sources, including thermal, hydro, wind, biomass, and others. It also includes allocations for demand, energy, and customer costs, as well as distribution and transmission expenses.

NOVA SCOTIA POWER INC. RATE CLASS DISAGGREGATION ANALYSIS FOR THE YEAR ENDING DECEMBER 31, 2027 CLASS : TOTAL COMPANY RATE BASE Variable Fixed Unit Cost Fuel Operating Capital Return Total Total Cost Units Sold Demand Energy Customer Gener...

AI summary The document presents a detailed rate class disaggregation analysis for Nova Scotia Power Inc. for the year ending December 31, 2027, breaking down costs into categories such as generation, transmission/distribution, and retail, with a focus on variable and fixed costs, unit costs, and total costs.

FOR FEBRUARY 2027 (1) MWH SALES (2) ENERGY LINE LOSSES (3) ENERGY REQUIREMENT (4) CLASS NON- COINCIDENT DMD. (KW) (5) SYSTEM COINCIDENT FACTOR (6) SYSTEM COINCIDENT DMD. (KW) (7) DEMAND LINE LOSSES (8) SYSTEM COIN. PEAK DMD. (KW) (9) SYSTE...

AI summary The document presents a detailed table with data on energy sales, losses, and demand across various customer classes for February 2027. It includes metrics such as energy line losses, demand factors, and system peak demand. The table is part of a redacted attachment related to the ELID Tariff U-1.

REDACTED ELID Tariff U-1 Attachment 3 Page 95 of 98 REDACTED (CONFIDENTIAL INFORMATION REMOVED) (IN THOUSANDS OF DOLLARS) 2022-2024 Subfunctionalization of Customer Service Costs.xlsx 2018-2020 Regulatory Affairs Advocate Costs.xlsx FOR-1-...

AI summary The document presents customer weighting factors and revenue to COSS ratios for different customer classes, along with the number of bills and revenue projections for 2024 and 2027. It includes data on residential, general, industrial, and municipal customers.

REDACTED ELID Tariff U-1 Attachment 5 Page 10 of 10 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Category Jan-26 Feb-26 Mar-26 Apr-26 May-26 Jun-26 Jul-26 Aug-26 Sep-26 Oct-26 Nov-26 Plant Fuel Costs $67,441,935 $54,358,722 $49,574,650 $30,...

AI summary The document provides a detailed breakdown of fuel costs and energy purchases over several months, including specific figures for plant fuel costs, Maritime Link block allocations, biomass purchases, and wind generation. These data points are relevant to cost recovery and rate design considerations.

5 6 10 Cost Allocation Factors Purchased Power other than 3 CP Demands Energy Requirement Purchased Power- Biomass Maritime Link Wind Relative Shares of Relative Shares of Imports (allocated on Basic and Supplemental Blocks Embedded Cost E...

AI summary The text presents a detailed table outlining cost allocation factors across various rate classes, including residential, small general, general demand, and large general. The table includes metrics such as R/C ratios, energy requirements, purchased power costs, and fixed energy and demand-related allocations.

ELID Tariff U-1 Attachment 9 Page 2 of 3 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Nova Scotia Power Determination of Revenue Responsibilities by Rate Class May 2025 1 Apportionment of the revenue requirement; exclusive of the FAM, DSM a...

AI summary This document outlines how Nova Scotia Power determines revenue responsibilities by rate class, excluding certain riders, using a Cost of Service Study (COSS). It describes the apportionment of revenue requirements among Above-the-Line (ATL), Below-the-Line (BTL), and Miscellaneous revenue classes, and highlights the methodology for calculating revenue increases for ATL classes.

NON-CONFIDENTIAL 1 Undertaking U-3: 2 3 To provide the periodic confirmations completed by NSPI that 65 MW is the reasonable 4 quantity for PHP demand load. 5 6 Response U-3: 7 8 NS Power tracks system coincident demand for PHP on an annua...

AI summary NS Power provides confirmation that 65 MW is a reasonable estimate for PHP's coincident demand load based on historical data and a moving average adjusted for losses. This is supported by data from the Company's responses to SBA IR-1 and IG IR-30.

4 The results of the analysis show the benefit of ADC in 2025 to be $8.98 million. This result is 5 consistent with NS Power's expectations based on previous forward-looking modeling and 6 stochastic analysis. 7 8 Please note that this com...

AI summary The analysis indicates that ADC in 2025 provided a benefit of $8.98 million, consistent with NS Power's expectations. The methodology used is agnostic to the outcome and could show incremental costs if load shifting was not optimal.

Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (NSEB M12661) NSPI Responses to NSEB Undertakings

AI summary The document outlines an application for the approval of an Above-the-Line Tariff for Port Hawkesbury Paper, along with NSPI's responses to NSEB Undertakings. This proceeding involves regulatory considerations related to tariff design and the approval process.

NON-CONFIDENTIAL 1 Undertaking U-13: 2 3 To reconcile how you get from the fully allocated demand and energy costs for 2027 in 4 Exhibit N-6, Attachment 3, Exhibit 10 ($26.1 million (energy) and $12.0 million (demand)) 5 to the demand and...

AI summary The document addresses the reconciliation of demand and energy costs for 2027 from Exhibit N-6 with the corresponding revenues in the ELID Rate Design tab of Exhibit N-1(i). The discrepancy is attributed to the inclusion of demand-related fuel costs in the Energy Charge and the use of a revenue-to-cost ratio in the ELID rate design.

Undertaking U-16: To indicate when PHP understood that there was a disagreement with the utility's position about the 3-CP demand to be used. From Transcript, September 28, pages 32, 35: "To provide the date the modelling results changed P...

AI summary This section of the proceeding discusses PHP's awareness and response to a disagreement regarding the 3-CP demand parameter used by the utility. It references transcript pages that outline when PHP changed its view based on modelling results and when it would have communicated this to Nova Scotia Power.

Refer to M12661, Exhibit N-1, the Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (the "Application"), Section 2.2 Demand Charge, starting at page 5 of 19, and please answer the following: - a) Desc...

AI summary The text requests detailed explanations regarding the demand charge structure in the ELIADC Tariff for Port Hawkesbury Paper, including the rationale for specific MW values, definitions of terms like 'judgment', and comparisons with other tariff structures. It also asks about the consistency of billing demand definitions and cost implications.

Request IR-5: - a) Please confirm, should PHP decide not to choose to move to the ELID tariff, what rate would PHP be on beginning January 1, 2027. - b) If it was determined that a new tariff would be required for PHP, how long would it ta...

AI summary This request seeks clarification on the rate structure for PHP if it does not transition to the ELID tariff by January 1, 2027, and the timeline for developing and approving a new tariff if necessary.

Request IR-7: Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Attachment 3, page 1 of 1, please answer the following: - a) Please provide the supporting workpapers with intact formulas for the calculation of the cost e...

AI summary Request IR-7 asks NS Power to provide supporting workpapers for cost estimates, confirm the inclusion of incremental costs in the Customer Charge, clarify the separation of customer-related costs, confirm if costs will be adjusted annually, and whether customer costs will be included in annual reports to the Board.

the Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (the “Application”), Section 2.2 Demand Charge, starting at page 5 of 19, and please answer the following: 1. Describe the rationale for the use o...

AI summary The text presents a set of questions related to the Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper. The questions focus on demand charges, definitions, cost recovery, and tariff comparisons, particularly concerning the ELIADC Tariff and the 3CP (coincident peak) figures used for billing purposes.

ations of the Customer’s major scheduled maintenance periods and other factors as may be appropriate to calculate a representative CBL. please explain what ‘other factors’ may be included in the CBL. 1. Provide the analyses demonstrating t...

AI summary The text outlines several requests for clarification and supporting documentation related to the calculation of the Customer Base Load (CBL), demand response (DR) credits, and tariff structures. Questions focus on savings analyses, DR credit composition, tariff alignment, and potential new tariff development timelines.

Request IR-3: Refer to M12661, Exhibit N-3, the PHP Evidence. Regarding PHP's desire to move to an above the line ("ATL") tariff, please answer the following: - a) Does PHP believe that the ATL ELID tariff should be designed as an embedded...

AI summary The document requests PHP to clarify its stance on the design of the ATL ELID tariff, specifically whether it should be embedded, marginal based, or a combination, and how this aligns with PHP's objective of price stability.

Request IR-4: - If PHP did not take service under the new ELID tariff: - a) When does PHP understand the development of a new tariff would occur? c) Would PHP require interim service if the alternative tariff was not developed prior to Jan...

AI summary The document includes a request (IR-4) asking PHP about the timeline for developing a new ELID tariff and whether interim service would be required before January 1, 2027, and under what rate.

Request IR-2: Regarding interruptible service, on page 8, NS Power stated: …the relatively low cost of acquiring priority interruptible service (approximately $500,000 annually as modeled in the GRA COSS), the Company considers this to be...

AI summary NS Power mentions a $500,000 annual cost for priority interruptible service and suggests further review before discontinuation. The request seeks clarification on the derivation of the cost and the nature of the additional review.

Request IR-2: - Considering the circumstance where the application is not approved, or considered not to be - acceptable by PHP, and the ELIADC is not extended, and no new BTL rate exists on January 1, - 2027, what is PHP's understanding o...

AI summary The document poses a question regarding PHP's default rate for service in 2027 if the application is not approved and no new BTL rate exists, highlighting concerns about rate structures and regulatory decisions.

lain whether PHP contemplated any potential BTL tariffs as potential options if an acceptable version of the ATL tariff is not approved. Were any such discussions held with NS Power? Please elaborate. Considering the circumstance where the...

AI summary The text inquires whether PHP considered BTL tariffs as alternatives if the ATL tariff is not approved, and whether discussions with NS Power occurred. It also asks about PHP's default rate if the ELIADC is not extended and no new BTL rate exists by January 1, 2027.

9 Request IR-4: 10 As noted in NPSI's Application: 11 12 In accordance with this provision, PHP will be billed at the applicable ATL tariff rates for 13 electricity consumed at the PHP facility in excess of the PHPW PPA aggregate amount of...

AI summary The document discusses the billing mechanism for PHP based on ATL tariff rates and the netting off of energy produced by the Goose Harbour Lake wind facility against energy consumed by the mill. It also requests clarification on NSPI's line losses and their impact on this netting process.

19 Request IR-8: 20 How would the ATL cost allocations be determined in a scenario where PHP does not subscribe 21 to the ELID Tariff beyond 2026? 22

AI summary The question asks how ATL cost allocations would be determined if PHP does not subscribe to the ELID Tariff beyond 2026, highlighting a regulatory consideration regarding cost allocation mechanisms.

23 Request IR-9: 24 In its evidence, PHP proposes the following modifications to the proposed ELID tariff: 25 - 26 1. designing the capacity charge to reflect PHP's actual 8 MW firm demand rather than the 27 proposed 65 MW; - 28 2. adjusti...

AI summary PHP proposes modifications to the ELID tariff, including adjusting capacity charges, interruptible credit, revenue-to-cost ratios, and load forecasts. The request asks NSPI to assess whether these changes are consistent with the 2026-2027 GRA settlement agreement and whether they require re-opening of related matters.

ions be determined in a scenario where PHP does not subscribe to the ELID Tariff beyond 2026? Request IR-9: In its evidence, PHP proposes the following modifications to the proposed ELID tariff: 1. designing the capacity charge to reflect...

AI summary PHP proposes modifications to the ELID tariff, including adjusting capacity charge, interruptible credit, revenue-to-cost ratio, and energy forecast assumptions. NSPI is asked whether these proposals are inconsistent with the 2026-2027 GRA settlement agreement.

1 Request IR-1: 2 In their evidence, Brubaker & Associates state: 3 4 The interruption demand service will not impose resource capacity cost on NS Power 5 because this demand will be served only on an as-available basis. Hence, NS Power ca...

AI summary Brubaker & Associates argue that interruptible demand will not require a capacity charge as it is served on an as-available basis, and that NS Power can recover costs through the ELID energy charge. PHP's firm demand contributes 8 MW to NS Power's peak demand, and any demand above this will be covered by the ELID energy rate without an interruptible credit.

30 Request IR-2: 31 In their evidence, Brubaker & Associates state: 32 33 If the ELID capacity charge is designed to include the cost of firm demand service for a 65 34 MW tariff capacity, then the interruptible credit should be applied to...

AI summary Brubaker & Associates argue that the ELID capacity charge should account for interruptible demand, allowing NS Power to avoid additional resource costs. The interruptible credit should be priced at NS Power's estimated marginal cost of capacity and updated in the next GRA filing. PHP is asked to confirm if the proposed ELID tariff aligns with this position.

18 And further: 19 20 NS Power estimates its marginal cost of adding production resource capacity during its 3- 21 CP peak periods to be $13.107/KVA. Hence, to the extent the Board approves the use of a 22 demand charge applicable to PHP's...

AI summary NS Power estimates the marginal cost of adding production resource capacity during peak periods to be $13.107/KVA. It argues that if the Board approves a demand charge for PHP's interruptible load, the ELID interruptible credit should be based on this avoided cost, ensuring fair compensation for PHP's system benefits.

17 Request IR-6: 18 In its evidence, PHP proposes the following modifications to the proposed ELID tariff: 19 - 20 1. designing the capacity charge to reflect PHP's actual 8 MW firm demand rather than the 21 proposed 65 MW; - 22 2. adjusti...

AI summary PHP proposes modifications to the ELID tariff, including adjusting the capacity charge, interruptible credit, revenue-to-cost ratio, and updating load forecasts. The request asks whether these changes are consistent with the 2026-2027 GRA settlement agreement and whether they require reopening previous agreements.

M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , R.S.N.S. 1989, c. 380 as amended -and- IN THE MATTER OF: AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable A...

AI summary The Consumer Advocate has requested information regarding the ELID tariff for Port Hawkesbury Paper, including claims by Brubaker & Associates that interruptible demand will not require capacity charges and will be recovered through the ELID energy charge.

be inconsistent with any terms of the 2026-2027 GRA settlement agreement and why. In answering this question, and without limiting the generality of the foregoing, please also address the following: 1. Please confirm PHP’s understanding th...

AI summary The document asks PHP to explain whether its proposed changes to load forecasts and capacity cost allocations are consistent with the 2026-2027 GRA settlement agreement. It also requests clarification on whether these changes would require re-opening of existing matters. PHP’s evidence highlights its role in system reliability and the need to recognize additional ancillary service value in the approval of a new ATL tariff.

PARTIALLY CONFIDENTIAL 1 (ii) PHP's firm, plus interruptible load, at a forecast of 65 MW based on prior 2 actual PHP metered load at the time of NS Power's 3 coincident peaks (3-CP); 3 4 (iii) PHP energy will be based on PHP's forecast us...

AI summary The document outlines details regarding PHP's load forecasts, interruptible load credits, and revenue-to-cost ratios. It requests confirmation on the revenue-to-cost ratio applied to PHP, the recovery of transmission cost savings, and the transmission costs for Large Industrial Interruptible Rider customers. The ratios provided are 1.04373 and 1.04713 for 2026.

M12661 – NS Power Application for Approval of the ELID Tariff NSPI Information Requests to PHP 1 2 3 site, that includes approximately 4MW that are needed to maintain the shared services required for the NS Power Port Hawkesbury Biomass Pl...

AI summary The document discusses NS Power's application for approval of the ELID Tariff and includes information requests to PHP regarding interruptible service and compensation. It references the ELIADC tariff and its mechanisms for peak avoidance, including the ADC and Priority Interruptible mechanisms.

INFORMATION REQUESTS To: Port Hawkesbury Paper James MacDuff 1300 – 1969 Upper Water Street Purdy's Wharf, Tower II P.O. Box 730 Halifax, NS B3J 2V1 By email: [[email protected]](mailto:[email protected]) Tel: 9...

AI summary The document is an information request from Synapse Energy Economics, Inc. to Port Hawkesbury Paper, seeking clarifications and supporting references related to cost of service, PHP treatment, and tariff-related matters. The request includes specific page and line references from submitted documents and testimony.

___________________________________ Crystal Henwood, Clerk of the Board 1 Request IR-1: Refer to NS Power's Application, p. 3, lines 8-10 regarding the expiration of the 2 ELIADC tariff by the end of 2026 and an "alternative course of acti...

AI summary The document outlines several requests related to the ELIADC tariff expiration, alternative course of action for Port Hawkesbury Paper LP, and the distinction between above-the-line and below-the-line tariffs in Nova Scotia Power's cost-of-service study.

- a. Please provide NS Power's most recently filed cost of service study in Excel with working formulas. - b. Please provide the allocators associated with each cost category in NS Power's most recent cost of service study along with a bri...

AI summary The document requests detailed information from NS Power regarding their cost of service study, including allocators, derivation of allocators, stakeholder input, and modifications to cost allocation methods. It also asks for an explanation of the LIIR credit amounts for 2026 and 2027, along with associated workpapers.

- b. Please provide the workpapers calculating each rate element of the Large Industrial tariff. 1 c. Please explain why the LIIR credit is lower than that which would have been 22 were not interrupted? If so, how frequently did this occur...

AI summary The text contains a series of questions related to the Large Industrial tariff, LIIR credit, curtailments, and the ELID tariff. It requests workpapers, explanations of curtailment frequency, and bill calculations under different tariff scenarios.

- i. Demand Charge - 1. Monthly billed per kilovolt ampere (kVA) demand - 2. Demand employed in the costing and pricing of the tariff - ii. Monthly minimum charge

AI summary The document outlines two components of a tariff: demand charge, which is billed monthly per kilovolt ampere (kVA) and used in tariff costing and pricing, and a monthly minimum charge.

- ii. Can PHP be dispatched for load reduction prior to the first tier of interruptible load being interrupted, that being Generation Replacement and Load 1 Following Tariff. Please provide historical examples of PHP being dispatched 2 pri...

AI summary The text raises questions about the dispatch priority of PHP (a load type) relative to Generation Replacement and Load Following (GR and LF) tariffs, whether PHP load can be split into dispatchable and interruptible portions, and the implications of holding PHP load as Operating Reserve. It also asks for historical examples and workpapers related to these matters.

c. Please describe if the load reduction should have been instituted as a real time 1 b. Please provide the date and time of interruptions and direct control actions for PHP for 2 each of 2022, 2023, 2024, and 2025. Please provide an estim...

AI summary The text includes a request for details on load reduction during specific peak periods, including the dates and times of interruptions and direct control actions for PHP in 2022–2025, and the associated capacity reductions. It also asks about the impact of not reducing load during certain peak hours and the associated costs or benefits.

1. Refer to NS Power’s Application, p. 3, lines 8-10 regarding the expiration of the ELIADC tariff by the end of 2026 and an “alternative course of action” if Port Hawkesbury Paper LP (PHP) will not subscribe to the Extra Large Industrial...

AI summary The text outlines questions regarding the ELIADC tariff expiration, alternative tariffs for Port Hawkesbury Paper LP, and the distinction between above-the-line and below-the-line tariffs. It also requests information on cost allocation in NS Power’s cost of service study.

been enrolled in the Large Industrial Interruptible Rider for 2023 and 2024. 7. Refer to the Application, p. 3, lines 13-15. Are there any differences between the “Dispatchable Rider” under the ELID tariff and the “Active Demand Control” u...

AI summary The text outlines a series of questions directed at an applicant regarding the Large Industrial Interruptible Rider (LIIR), the Dispatchable Rider under the ELID tariff, and the Active Demand Control under the ELIADC tariff. It also requests clarification on the derivation of firm and interruptible load calculations, the use of three coincident peaks (3CP) for billing determinants, and differences in how NS Power manages firm and interruptible load.

from PHP during the winter peak, as well as the PHP firm load amount that the asset was designed to serve. 7. What firm load from PHP was the Port Hawkesbury Biomass plant designed to accommodate? 1. Refer to the Application, p. 8, lines 3...

AI summary The document includes questions about the Port Hawkesbury Biomass plant's capacity to serve PHP firm load, the derivation of a 10% credit for priority interruptible service, and the rationale for matching winter month system coincident demand with negotiated firm plus interruptible demand. It also asks for NS Power’s forecast for avoided costs and the comparison of dispatch service to interruptible service for LIIR customers.

Reference: Application, page 5, line 21 to page 6, line 2. "As proposed, rather than relying solely on PHP metered data at the time of the 3CPs, the setting of the PHP coincident peaks for costing and pricing purposes will require judgment...

AI summary The document discusses the proposed method for setting PHP coincident peaks for costing and pricing purposes, emphasizing the need for judgment in determining representative demand levels. It highlights the variability of PHP demand based on system load conditions and the Dispatchable Rider, suggesting that the PHP demand determinant should be reviewed and set during the GRA process or related proceedings like the Fuel Adjustment Mechanism (FAM).

Questions: (a) How does NS Power propose that "judgment as to the level of demand which is representative of PHP system usage" be used to determine the PHP coincident peaks? (b) Does NS Power use "judgment" in determining the coincident pe...

AI summary The document outlines questions regarding NS Power's methodology for determining PHP coincident peaks, specifically how judgment is used, whether it applies to other rate classes, and the frequency of adjustments. It also references proposed energy charges for 2026 and 2027.

1 2 IR-6 3 4 Reference: Application, Attachment 4, page 11 of 21: "The dollar value of the 5 Interruptible credit to be applicable to PHP's interruptible load shall be the same 6 as the credit for Large Industrial Interruptible customers."...

AI summary The text references an application and requests information on the reduction in allocated demand costs to the Large Industrial Interruptible customer class due to the application of the interruptible credit for 2026 and 2027.

12-13, Figures 4 and 5. Question: Please provide a breakdown of the hourly Net Load as shown in each of Figures 4 and 5 of the Cold Weather Event Report by Customer Class, including PHP. IR-2 Reference: Application, page 5, line 21 to page...

AI summary The document discusses NS Power's proposal for determining PHP coincident peaks using judgment to represent system usage, and outlines proposed energy charges for 2026 and 2027. It raises questions about the methodology, use of judgment in other rate classes, and frequency of peak adjustments.

Request IR-7: Please refer to Exhibit N-1. - a) Does NSPI consider the ELID Tariff as offering PHP a discounted rate for power relative to other customers? Please explain. - b) Is NSPI aware of PHP's financial condition? If so, please expl...

AI summary The document contains a series of regulatory requests directed at NSPI, focusing on the ELID Tariff, PHP's financial condition, and cost of service estimates for 2026 and 2027. The requests include inquiries about rates, assumptions, and forecasts related to PHP's power services.

1. Please refer to Exhibit N-1, section 2.1 and Attachment 3. 2. Why did NSPI select the “low range” of costs as the basis for calculating the Customer Charge? 3. If the actual costs to administer the tariff exceed the “low range,” who wil...

AI summary The text contains a series of questions directed to NSPI regarding cost assumptions, tariff administration, and the potential impact of PHP's requests to update energy and generation forecasts on other FAM customers. It also asks whether these requests violate the GRA Settlement Agreement.

25. Please provide PHP’s annual energy demand forecast for 2020, 2021, 2022, 2023, 2024, and 2025. For clarity, this request refers to forecasts developed by PHP and provided to NSPI. 26. Please provide PHP’s actual annual energy demand fo...

AI summary The text contains a series of questions directed at Nova Scotia Power Inc. (NSPI) and Prince Heritage Power (PHP) regarding energy demand forecasts, financial assumptions, and the impact of various scenarios on the FAM balance, as well as inquiries about the ELID Tariff and PHP’s financial condition.

21 Request IR-3: 22 Reference: N-1, ELID Application, page 5. As proposed, rather than relying solely on PHP metered data at the time of the 3CPs, the setting of the PHP coincident peaks for costing and pricing purposes will require judgme...

AI summary The document requests an explanation of the methodology used to determine the 65 MW figure as the PHP 3CP billing determinant, including data, calculations, assumptions, and judgments made in the process.

Consistent with the foregoing, it is proposed that the assumed costing/billing demand also be adopted and applied for billing purposes throughout the year (i.e. the PHP 3CP figure employed for Tariff costing and pricing would also be appli...

AI summary The text proposes adopting a fixed demand charge based on the PHP 3CP figure for billing purposes, similar to how it is used in tariff costing. It raises questions about other customer classes billed on fixed demand charges, the appropriateness of this approach, and requests a framework for setting or resetting the PHP 3CP demand determinant.

- 3 Preamble: NSPI indicates the cost-of-service information is contained in files - 4 associated with M12451, General Rate Application, specifically SR-01 and associated - 5 Attachments. - 6 Please provide either a copy of the Cost-of-Ser...

AI summary The document requests the provision of cost-of-service information related to M12451, specifically regarding different load scenarios for PHP, including firm and interruptible loads, and associated pricing proposals from NSPI and PHP.

- 26 (ii) Using a PHP firm load of 8 MW for 3 CP, and 57 MW of 27 interruptible load priced at the PHP proposed rate from Ex. 28 N-2 (e.g., $13.107/kVA in 2027). 1 (iii) Using a PHP firm load of 8 MW for 3 CP, and no interruptible 2 load i...

AI summary The document discusses the use of PHP's firm and interruptible load in the context of a cost-of-service study, requesting clarification on load levels and the application of the ELID tariff. It also raises concerns about potential adverse economic consumption patterns under the ELID supply.

16 Request IR-10: 17 Reference: N-1, ELID Application, Page 8, lines 11-17. As noted in the SA, for 2026 and 2027, the proposed interruptible credit applicable to PHP is the same as proposed for the LIIR: $7.638 per kVA and $7.667 per kVA...

AI summary The document discusses the proposed interruptible credit for PHP under the ELID application, noting that the current proposed rate is significantly lower than the company's established practice. The request asks for confirmation of the credit using the established approach and the anticipated cost variance for 2026 and 2027.

1 2 (d) Please provide historical and forecasted hours in which NSPI expects priority interruptibility will be: 3 (i) Operationally necessary; 4 (ii) Materially different from DR dispatch; and 5 (iii) Not substitutable with DR load reducti...

AI summary The document includes a request for historical and forecasted hours in which NSPI expects priority interruptibility to occur, and a detailed request (IR-16) concerning the Dispatchable Rider mechanism, FAM accounting, and the review process for FAM supply cost modelling.

1 Request IR-18: 2 Reference: N-1, ELID Application, page 10, lines 9-12. 3 within or outside the control of NSPI. 4 Request IR-19: 5 Reference: N-1, ELID Application, page 11. 6 7 8 9 10 11 12 13 Consistent with the ELIADC Tariff, PHP ope...

AI summary This document discusses the ELID Application and the ELIADC Tariff, focusing on the governance of PHP operations under DR and the Operating Procedures. It raises questions about the assurance of holding ATL customers harmless, the impact of dispatch decisions on DR credits, and the need for Board approval of Operating Procedures.

20 Request IR-24:

AI summary The document outlines Request IR-24, which includes various topics related to energy efficiency, demand response, and regulatory processes. It discusses the need for updated programs and the evaluation of existing initiatives.

4 Request IR-25: - 5 (a) Where GRLF is interruptible in advance of ELID, why should ELID be 6 afforded a priority credit above GRLF? - 7 (b) Were other LII customers offered the opportunity to obtain additional credit 8 for priority interr...

AI summary The text presents three questions regarding priority credit for ELID over GRLF, opportunities for other LII customers to obtain credit for priority interruptibility, and the value of PHP compared to other telemetry customers, all in the context of NSPI and DR load shifting.

1 Request IR-27: 2 Reference: N-1, ELID Application, Attachment 1, ELID Tariff, page 8 of 8. - 3 Annually, NS Power shall report to the Board to confirm the dollar value of 4 system savings that have been achieved through the dispatch of t...

AI summary NS Power is required to annually report system savings achieved through the dispatch of the Customer's load under the Operating Procedure to the Board. The Customer is entitled to a credit based on the cost differential between actual and calculated system costs if served under the high load factor scenario.

and 24 LIIR interruptibilty credits are revised upward as part of the 25 resolution of M12661. If so, please indicate how other 26 customer rates may need to be adjusted to implement this 27 outcome. 1 (iii) The PHP proposal is accepted, a...

AI summary The text discusses adjustments to interruptibility credits for LIIR and ELID as part of the resolution of M12661, and requests an analysis of how customer rates may need to be adjusted. It also asks for a discussion on regulatory principles of fairness between classes if the PHP proposal is accepted and the ELID interruptibility credit is based on a higher avoided cost benchmark.

Preamble: The transition or effective date for PHP to take service under the ELID rate has not been determined, but may occur part of the way through 2026, and no later than January 1, 2027. The GRA models assume ELID service starting Janu...

AI summary The document discusses the proposed ELID rate for PHP if it begins service as an ATL customer mid-2026, including considerations for COSS and 3CP allocation, as well as the rationale for setting the Customer Charge at the lower end of estimated costs. It also references specific pages from the ELID Application.

estimated costs. 2. Are the estimated costs based on prior actuals? If so, from what years? Please provide records supporting the basis for the costs. Reference: N-1, ELID Application, page 5. As proposed, rather than relying solely on PHP...

AI summary The document requests clarification on the methodology used to determine the 65 MW figure for PHP 3CP billing and its impact on class rates. It also references the need to review the PHP demand determinant through the GRA process or Fuel Adjustment Mechanism (FAM).

r machine running, there is approximately 12MW of demand on site, that includes approximately 4MW that is needed to maintain the shared services required for the NSPI Port Hawkesbury Biomass Plant”. 1. Please provide all relevant informati...

AI summary The text discusses NSPI's proposal to use the 8 MW 3CP demand determinant for billing purposes, referencing a 12 MW connected load with 4 MW allocated to shared services. It requests evidence for the 8 MW figure and a breakdown of connected loads, as well as past load interruption events.

purposes throughout the year (i.e. the PHP 3CP figure employed for Tariff costing and pricing would also be applied for billing purposes essentially making the demand cost recovery a fixed charge). 1. Are there any other ATL customer class...

AI summary The text discusses the billing practices for demand charges, specifically the use of the PHP 3CP figure for fixed demand charges and the procedures for revising such charges through regulatory processes. It also references a Rider proceeding and a FAM proceeding, and asks for clarification on these terms and their application.

load levels NSPI considers reasonable for each year. 3. For 2026 and 2027, please provide a version based on PHP BTL, using the updated PHP estimates. Reference: N-1, ELID Application, page 7. Preamble: The Application indicates that the E...

AI summary The text requests clarification on the ELID tariff application, COSS modelling assumptions, and potential economic risks associated with ELID energy consumption patterns. It also asks for confirmation of expected load factors for ELID by 2027.

1. Please provide all data or internal documentation making up NSPI’s “initial analysis” of the priority interruptible service, including details on the interruptions determined to be avoided. 2. Please provide a copy of NSPI’s internal in...

AI summary The document contains a series of questions directed at NSPI regarding its priority interruptible service, including data on interruptions, internal protocols, economic analyses, and the operation of ELID under the ELIADC. It also references a regulatory application and requests clarification on dispatch procedures and compliance with reserve requirements.

under which PHP (or its predecessor owners of the mill) has taken service and specify the applicable tariff in each case. Reference: N-1, ELID Application, page 9 – Priority Interruptible Credit. 1. Please provide all workpapers, calculati...

AI summary The document requests detailed explanations and supporting calculations regarding the priority interruptible credit values, the derivation of the 10% premium, and the distinction between priority interruptibility and DR dispatch. It also seeks clarification on the conditions under which priority interruptibility might be called upon separately from DR dispatch.

load after DR load shifting as Operating Reserve, please explain how PHP offers any value over and above any other telemetry customer? Reference: N-1, ELID Application, Attachment 1, page 8 of 8. Customers taking service under the ELID Tar...

AI summary The document discusses the ELID Tariff and Dispatchable Rider (DR) under which NS Power manages customer load, including the distinction between load reductions under the Interruptible Rider and the Operating Procedure. It also outlines the requirement for NS Power to report annually on system savings and provide credits based on cost differentials.

tomer will be entitled to a credit equal to the cost differential between the actual annual system cost and the calculated system cost if the Customer was served under the high load factor scenario. 1. Please compare the reporting provided...

AI summary The text discusses the ELIADC and ELID tariff structures, focusing on reporting requirements, fixed cost revenues for PHP, and the need to update tariffs based on revised energy sales forecasts. It also raises questions about transparency, audit mechanisms, and cost recovery.

avoided peaker cost used in determining the proposed $7.661/kVA monthly credit for both Large Industrial Interruptible and for ELID is out of date and undervalues the benefit of interruptible load. 1. Please indicate whether NSPI considers...

AI summary The document raises concerns about the outdated nature of the $7.661/kVA monthly credit for Large Industrial Interruptible and ELID customers, suggesting it undervalues interruptible load benefits. It requests NSPI's position on the matter and explores potential scenarios for updating the rate, considering fairness and practicality.

14 Request IR-3: - 15 Reference: N-2, Evidence of C. Fitzhenry and M. Gorman, page 3. - 16 Preamble: PHP's consultant, Brubaker & Associates, Inc., states that the current ELID 17 R/C ratio is 1.04373 and recommends an R/C ratio of 1.0 " e...

AI summary The text outlines several requests from a regulatory proceeding, including inquiries about the R/C ratio, interruptible credit calculations, and the impact of reducing PHP's demand determinant on revenue requirements and customer classes. These requests are aimed at ensuring transparency and proper cost allocation.

1 Request IR-6: - 2 (a) Set out in a single consolidated table BAI's recommended rate for each 3 ELID tariff component for 2026 and 2027, compared to NSPI's proposed 4 rate for the same component. - 5 (b) For each component where BAI recom...

AI summary The document requests a consolidated table comparing BAI's recommended rate for each ELID tariff component in 2026 and 2027 with NSPI's proposed rate. It also asks for the impact of any changes on PHP's annual bill and revenue requirements for other customer classes.

sociates, Inc., states that the current ELID R/C ratio is 1.04373 and recommends an R/C ratio of 1.0 " ensuring PHP pays its cost to serve without subsidizing or being subsidized by other classes. " 1. Please confirm that PHP agreed to an...

AI summary The text discusses the ELID R/C ratio, interruptible credit calculations, and revenue implications of reducing PHP's demand determinant. It includes questions posed regarding regulatory principles, supporting decisions, and financial impacts on various tariff classes.

enry and M. Gorman, page 16, lines 9-11. Amidst this event, PHP’s demand was dispatched down to approximately 9 MW, its lowest recorded level during any coincident peak in that two-year window. 1. Why does PHP conclude this was not a real...

AI summary PHP's demand was reduced to 9 MW during a coincident peak, raising questions about dispatch practices and the accuracy of the ELID tariff. PHP argues that its load flexibility and the benefits from the Maritime Link event should be considered in the demand allocator and as an additional ancillary service value.

27 1 2 (b) What factors does Ms. Whited believe make a transition appropriate or not appropriate? 15 16 17 18 19 (h) What analysis or criteria should the Board apply to assess whether a proposed negotiated credit value satisfies both recom...

AI summary The text contains a series of questions and references related to a regulatory proceeding. It includes inquiries about Ms. Whited's understanding of PHP's eligibility for specific tariff rates and references to Synapse Evidence. The questions focus on credit value assessments, tariff qualifications, and historical service arrangements.

29 that calculation? 1 Request IR-6: - 2 Reference: N-21 Synapse Evidence, p.14/ pdf p.16, lines 7-15. - 3 Preamble: You state that the interruptible credit should likely exceed the current - 4 proposed level of approximately $8.40/kVa for...

AI summary The text presents a regulatory inquiry regarding the interruptible credit for the ELID tariff, questioning whether PHP's reluctance to take service is a valid basis for adjusting the credit, and whether increasing it would induce PHP to take service. It also asks whether customer dissatisfaction with a just and reasonable rate should affect the rate determination.

33 that PHP was already contributing to some fixed cost recovery via the VCC 1 in the context of the ELID Tariff; and (ii) whether it would produce a demand 2 cost allocation to PHP that is higher or lower than the 65 MW approach 3 adopted...

AI summary The text discusses the cost allocation to PHP under the ELID Tariff, referencing the Variable Capital Charge (VCC) in the ELIADC Tariff and its role in fixed cost recovery. It also questions whether alternative methods of cost allocation, based on PHP's expected load, are consistent with principles of proper cost allocation for ATL customers.

ence of InterGroup, p. 13/pdf p. 15. NSP further confirmed that LIIR customers who are not held as Operating Reserve could be physically interrupted ahead of PHP despite PHP's priority status…. NSP states that it remains to be determined w...

AI summary NSP acknowledges that Priority Interruptible (PI) service may provide system value but is uncertain about its benefits and cost recovery. NSP proposes to evaluate the value of PI service in the next General Rate Application (GRA).

34 (a) Given that LIIR customers who are not on Telemetry and Control ("T&C") 1 can be, and in practice are physically interrupted ahead of PHP in the 2 dispatch stacking sequence, does InterGroup agree that PHP's designation 3 as a "prior...

AI summary The text raises questions about the practical implications of the Priority Interruptible (PI) designation for PHP customers, given that they are often already dispatched down during system constraints. It also asks for justification for the 10% PI credit in the 2026 and 2027 test years. The Board is recommended to approve the ELID Tariff's Interruptible Service component with a review prior to 2028.

- 3 Preamble: Throughout this section, Bates White assesses the Customer Charge - 4 Methodology and the Risk of Under-Recovery. At p. 12, lines 10-22, the evidence states: NSPI did not use a bottom-up methodology (using assumed labour hour...

AI summary Bates White evaluates the methodology used by NSPI in estimating the Customer Charge, noting that NSPI did not use a bottom-up approach or historical data. The analysis suggests that NSPI's choice may lead to under-recovery of costs intended to be collected through the Customer Charge.

NSPI has made the "conservative" choice. Rather, NSPI 11 has selected the value from its range that is most likely to under-collect the 12 costs that the Customer Charge is intended to recover. - 13 (a) Does Bates White agree that, without...

AI summary NSPI has selected a conservative estimate for the Customer Charge, potentially under-recovering costs. Bates White is questioned on the validity of NSPI's methodology, the implications of under-recovery, the reasoning behind their midpoint recommendation, and whether their proposed credit mechanism is reciprocal for over-recovery.

12 And Reference: N-4, NSPI (BW) RIR-4 (a-c), lines 20-23: NS Power cannot comment on the amount of generation required to meet PHP's energy demand as PHP's load forecasting is a PHP internal process. This is similar for PHP's wind forecas...

AI summary The text discusses NS Power's inability to comment on the generation required to meet PHP's energy demand, citing internal forecasting processes. It raises questions about the significance of the issue, the cost impact of using P90 forecasts, risks of conservative output levels, and the calculation behind a 44% capacity factor, as well as the interpretation of P90 forecasts.

- 31 (f) What annual capacity factor does Bates White believe is more reasonable 32 than the noted 44% annual capacity factor? Please provide the studies or 33 comparables relied upon in answering. 1 (g) In principle, is it appropriate to...

AI summary The document includes questions regarding the annual capacity factor, use of P90 or P50 estimates, and concerns about the predictability of PHP's load and forecast errors. Bates White raises issues about the reliability of assumptions used in setting the ELID Energy Charge and the challenges in forecasting PHP's load due to various operational and external factors.

29 (a) Does Bates White agree that its finding that PHP would have higher 30 demand in winter and summer months is inconsistent with PHP's evidence 31 on this proceeding? If not, please explain. 1 2 (b) If confirmed, are there any conseque...

AI summary The text raises questions about Bates White's findings regarding PHP's demand patterns and their consistency with PHP's evidence. It also questions whether a levelized high load factor CBL overstates savings and whether FAM customers should pay PHP for load variations unrelated to NSPI's pricing signals.

million. This means NSPI's discretionary adjustments would reduce the DR credit by $3.5 to $5.5 million. The adjustments NSPI made in its analysis included "system conditions, customer production constraints/ requirements, etc.," which are...

AI summary The text discusses NSPI's discretionary adjustments to the DR credit, which are subjective and difficult to verify due to a cyber incident. Bates White is asked to explain if there is a basis for assessing these adjustments, what the gap between the optimized and realistic DR credit represents, and what verification mechanisms are needed.

20 Request IR-9: - 21 Reference: N-20, Bates White Evidence, p.26, line 18- p. 27, line 2 describes its fifth - 22 concern relating to the use of forward replacement fuel pricing: However, NSPI has specifically veered away from using forwa...

AI summary The text raises a concern about NSPI's use of forward replacement fuel pricing methodology for calculating DR credits for PHP under the ELIADC Tariff, despite prior concerns about its reliability due to volatility in commodity prices. Bates White is asked to clarify whether the same methodology is being used.

Request IR-10: Reference: N-20, Bates White Evidence, p. 27, lines 4-9. Our sixth concern is that the DR credit represents a zero-sum mechanism that, if incorrectly calculated, could harm other FAM customers. Any load "smoothing" exercise...

AI summary The text raises concerns about the DR credit mechanism, suggesting it could be a zero-sum game that may overestimate benefits if not calculated correctly, potentially harming FAM customers by misattributing load variations to PHP rather than system conditions.

And at p. 28, lines 14-21: We do not recommend that the Board approve the DR credit as proposed. To be reasonable, at least two things must be true: (1) any payments to PHP from FAM customers under the DR credit must demonstrably tied to P...

AI summary The text critiques the proposed DR credit mechanism, arguing it is too vague and unverifiable. Bates White outlines concerns and suggests revisions for approval. Questions are raised about the necessity of resolving all six concerns, the impact of benefit-sharing arrangements, and potential tariff amendments to address overestimation risks.

30 reflective of the paper market order book) or retain a benefit-sharing 31 arrangement. Does Bates White have any objection in principle to a form 1 2 3 of benefit-sharing approach as is currently in place under the ELIADC (75/25 in favo...

AI summary The text inquires whether Bates White objects to retaining a benefit-sharing arrangement currently in place under the ELIADC and applying it to the ELID DR credit. It also references recommendations for a true-up mechanism to address deviations in PHP's net load from expectations, including scenarios where PHP's annual net load could be zero.

2 Reference: N-20, Bates White Evidence, p. 35, lines 15-17 and p. 36, lines 1-3, 3 Recommendations: Given the potential for variable Goose Harbour generation to have significant effects on cost recovery — to the potential disadvantage of...

AI summary The text recommends that NSPI evaluate cost recovery under the ELID tariff annually and explain the methodology for tracking and ensuring that all administration costs of the ELID Tariff are paid by PHP. This is due to the potential impact of variable Goose Harbour generation on cost recovery for PHP and FAM customers.

inistering the ELID Tariff and how NSPI plans to ensure that 100% of the costs incurred above in administering the ELID Tariff are paid by PHP, including those above the Customer Charge collections. - 13 (a) Would Bates White agree that qu...

AI summary The text discusses the administration of the ELID Tariff and the responsibility of NSPI to ensure that PHP covers all costs incurred above the Customer Charge collections. It also includes questions about reporting requirements, true-up mechanisms, and evaluation processes related to Goose Harbour output and DR credit accruals.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and IN THE MATTER OF: An Application by Nova Scotia Power Inc. ("NS Power") for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable to Port...

AI summary Nova Scotia Power Inc. has applied for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. Bates White has raised concerns about the net load calculation, suggesting it should be 121 GWh instead of the 304 GWh used by NSPI, based on updated gross load estimates and the full capacity of the Goose Harbour Wind Farm.

PHP Information Requests to Bates White IR-4 Reference: Testimony, Section VI, page 35, lines 23-25. "… we recommend that a true-up mechanism be created to address substantial deviations of PHP net load from expectations…"

AI summary The document references a recommendation from Testimony, Section VI, page 35, lines 23-25, suggesting the creation of a true-up mechanism to address significant deviations of PHP net load from expectations.

interruptible load above its 8 MW firm base demand has directly driven, or is forecasted to drive, incremental transmission investment or physical transmission capacity expansion in Nova Scotia. IR-2 Reference: Testimony, page 13, lines 10...

AI summary The document discusses the compensation of PHP for its interruptible load, emphasizing that compensation should be capped at the avoided capacity cost net of its expected revenue contribution under firm service. It raises questions about the calculation and basis of this expected revenue contribution.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and IN THE MATTER OF: An Application by Nova Scotia Power Inc. ("NS Power") for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable to Port...

AI summary The Nova Scotia Energy Board is considering an application by Nova Scotia Power Inc. for an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Consumer Advocate (InterGroup Consultants) has been asked to respond to several questions regarding settlement agreements, load modeling, and the calculation of interruptible credits and demand charges.

- (a) For each recommendation, quantify the specific impact on NSP's proposed ELID tariff charges and credits and the additional costs that would be allocated to PHP under Mr. Bowman's proposed approach. Provide all workpapers in excel for...

AI summary The text requests quantification of the impact of recommendations on NSP's ELID tariff charges and credits, as well as revised tariffs if all seven recommendations are adopted. It also asks for detailed Excel workpapers.

Application by NS Power for Approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff Applicable to Port Hawkesbury Paper (NSUARB M12661) PHP Information Requests to the IG (Bowman) IR-8 Reference: Testimony, page 18 lines 8...

AI summary NS Power is seeking approval for an ELID tariff for PHP. The testimony by Mr. Bowman raises questions about the alignment of PHP's proposed changes to revenue-to-cost ratios with the NSP GRA negotiated settlement, and whether the ELID tariff was approved in Matter M12451. It also asks about the approval of a deferral account for PHP in that matter.

Re: M12661 – NSPI - ELID Above-the-Line Tariff Application available to PHP When the Board issued its timetable, it included a deadline by which parties could request the current written process be converted to an oral hearing. The Industr...

AI summary The Industrial Group requests the conversion of the tariff proceeding to an oral hearing, citing the lack of a consensus proposal, credibility disputes, complex issues requiring clarification, and the significant impact on ratepayers.

terns relied upon by NSPI are representative of what PHP's demand will be during the tariff period, or whether Bowman's average demand methodology can instead be used for this unique tariff structure. A second example of contested issues t...

AI summary The document discusses disputes over the credibility of evidence and factual issues that cannot be resolved solely on the written record. Key issues include the methodology for calculating demand patterns and the Customer Baseline Load (CBL) for load-shifting activities, with concerns raised about potential overvaluation of dispatchable load contributions.

3. The Complexity and Novelty of the Proposed Tariff Require an Oral Hearing Bowman's evidence notes that the proposed ELID rate is "complicated and unusual in utility rate regulation" and that "[n]o comparable rate could be identified in...

AI summary The proposed ELID rate is described as complex and unusual in utility regulation, with no comparable rate in Canada. It combines multiple mechanisms, including an above-the-line cost-of-service framework and production cost simulation, raising concerns about cost recovery and potential financial consequences for ratepayers. The Industrial Group argues for an oral hearing due to the novelty and complexity of the tariff.

a round of IRs on intervenor and Board Counsel consultants' evidence, and reply evidence from both NS Power and PHP. The process established by the Board has now been underway for nearly seven months. Importantly, this process is in additi...

AI summary A round of intervenor and Board Counsel consultants' evidence, along with reply evidence from NS Power and PHP, is being reviewed. This process is separate from the 2026-2027 General Rate Application (GRA), which involved extensive consultation and led to the ELID Tariff. The IG's request revisits issues already discussed during the GRA process.

derlying the proposed ATL tariff. The rationale outlined in the IG's request largely revisits issues that were extensively detailed and explored during the GRA process and throughout this proceeding. First, the IG points to the existence o...

AI summary The IG's request for an oral hearing is based on differing expert opinions and unresolved issues such as the demand determinant, IR credit, DR design, and PI compensation. However, the Company argues that these issues were already thoroughly addressed during the GRA process and that an oral hearing is not necessary. The Company also confirms its agreement with the GRA Settlement Agreement's ELID tariff parameters.

tariff to be filed and in place by January 1, 2027,"[1](#page-1-0) the Company agrees, which is precisely why its application adopts the ELID Tariff parameters prescribed in the Settlement Agreement. Second, the IG suggests there are signi...

AI summary The Company agrees to file a tariff by January 1, 2027, based on the ELID Tariff parameters from the Settlement Agreement. The IG raises concerns about factual disputes and the complexity of the proposed tariff, but the Company argues that these are differences in expert judgment and not credibility issues. The tariff design has been established through the GRA process and builds on existing frameworks.

work. Whether, in a party's view, a tariff is considered "complex" does not make an oral hearing necessary, particularly where the issues have been fully explored through this, and the GRA, processes. Importantly, despite the differing vie...

AI summary The document discusses the regulatory proceeding regarding a tariff application by Nova Scotia Power Inc. (NSPOWER), noting that no party has provided evidence that the application incorrectly implemented parameters from the Settlement Agreement. Disagreements are limited to specific rate design issues, which have already been thoroughly examined in the written record.

matters for which a thorough examination has already been completed through this regulatory proceeding on the written record, and which do not require oral examination to be understood or adjudicated. Finally, the IG also points to discuss...

AI summary The document discusses the regulatory proceeding involving NS Power, noting that some matters have already been thoroughly examined and do not require oral examination. The Industrial Group (IG) mentions a methodology for quantifying load shifting, but it does not alter the tariff proposal. NS Power emphasizes the importance of avoiding unnecessary oral proceedings due to their cost and complexity.

asing the length of the proceeding. It is this outcome that NS Power has sought to avoid by providing a complete and clear application in this matter and comprehensive IR responses and Reply Evidence. Consistent with this, the Company also...

AI summary NS Power argues that converting the proceeding to an oral hearing would introduce unnecessary delays in establishing a successor tariff effective by January 1, 2027, and proposes a structured settlement process to address outstanding issues. The Company emphasizes the extensive record already developed and prior successful collaboration between parties.

at the proposed tariff is complicated and unusual, and the record before the Board did not currently provide it with adequate tools needed to resolve the outstanding issues with confidence or clarity. NS Power submitted there is already an...

AI summary NS Power argues that the extensive record and prior review process provide sufficient information for the Board to approve the proposed above-the-line tariff. It notes that key parameters were accepted in a prior settlement agreement and that differing expert opinions are common and do not require oral examination.

MATTER #: M12661 (PHP) (PHP) DATE: UND# DESCRIPTION REQUESTED OF BY DATE DUE September 21, 2026 U-1 To provide, using appropriate assumptions, the rate that would apply to Port Hawkesbury Paper, if Port Hawkesbury Paper applied to go on th...

AI summary This regulatory proceeding, Matter M12661, involves several requests related to rate structures and power factor corrections for Port Hawkesbury Paper (PHP). The requests include determining the rate for PHP if it were to switch to a large industrial interruptible rate, providing historical studies, confirming demand load assumptions, and evaluating the impact of power factor corrections on charges and embedded costs.

I N D E X O F P R O C E E D I N G S September 21, 2026 PAGE NO. 3 applied to establish a new above-the-line tariff for Port 4 Hawkesbury Paper, the Extra-Large Industrial Dispatchable 5 Tariff, the ELID. 6 The ELID is the long-awaited succ...

AI summary The document discusses the establishment of a new above-the-line tariff called the Extra-Large Industrial Dispatchable (ELID) Tariff for Port Hawkesbury Paper (PHP). It replaces the previous Extra-Large Industrial Active Demand Control Tariff and includes unique features such as Dispatchable and Interruptible Riders, and an accounting mechanism for wind farm output from a sister company.

OPENING STATEMENT 17 INDUSTRIAL GROUP 1 interruptibility. 17 through the Cost-of-Service Study and the 2026/'27 General 18 Rate Application process. The treatment of Port 19 Hawkesbury Paper as an above-the-line customer, the INTERNATIONAL...

AI summary The Industrial Group discusses the transition from the ELIADC Tariff to an above-the-line structure, emphasizing benefits such as cost certainty and predictability. This change is framed as a continuation of the regulatory path established through the GRA process, involving multiple stakeholders including Nova Scotia Power, Port Hawkesbury Paper, and others.

1 BY MR. MacDOUGALL: 2 And here at line 22 you state in Q. 3 your reply: 4 5 6 Specifically the GRA SA [that's the Settlement Agreement] provides: 7 8 9 10 11 12 13 In the PHP ADC and tariff processes that will be brought forward for appro...

AI summary The discussion revolves around the interpretation of a Settlement Agreement (GRA SA) and its implications for the PHP ADC and tariff filings. The parties are debating whether the agreement allows for any position on ELID tariff issues or restricts them to the 'basic tariff structure' outlined in the agreement. Nova Scotia Power's position is that the parameters for the ELID tariff were established in the Settlement Agreement.

NOVA SCOTIA POWER PANEL 63 Cr-ex, (MacDougall) 1 perspective and position with respect to the 2 interpretation and application of the Settlement 3 Agreement. 4 Q. Okay. Thank you very much, Mr. 5 Ferguson. 6 Gentlemen, I'm now going to mov...

AI summary The discussion centers on the interpretation and application of a Settlement Agreement, particularly regarding the establishment of a deferral account for PHP (Port Hawkesbury Paper) to track revenue variances between assumptions in the GRA cost-of-service study and the eventual ELID tariff approved by the Board.

meant to do that, to set a rate form that can be relied on as an above-the-line rate going forward, as opposed to saying, "We're going to set a rate today, but one of the key factors, the billing determinant for the 3CP, may be revised and...

AI summary The discussion centers on setting an above-the-line rate for Port Hawkesbury Paper, acknowledging the challenges in designing a tariff due to the variability of its load during system peaks. The conversation highlights the need for further study and the use of historical data for cost allocation purposes.

NOVA SCOTIA POWER PANEL 83 Cr-ex, (MacDougall) 1 Yeah, but would you agree that if Q. 2 the Board determined that Port Hawkesbury Paper was 3 correct, that it should be 8 megawatts firm, we wouldn't 4 have that issue? 5 (Ferguson) I'd real...

AI summary The discussion focuses on the methodology for demand cost recovery, specifically the proposal to apply a fixed charge based on the PHP 3CP figure for billing purposes. This is tied to the ELID Tariff and the implications of the Board's determination on Port Hawkesbury Paper's 8 megawatts firm capacity.

NOVA SCOTIA POWER PANEL 115 Cr-ex, (MacDougall) 1 correct? 22 certainly areas we differ among parties who are parties to 1 this proceeding, yes. 2 Q. Including PHP. 3 A. (Ferguson) Yes. 4 Q. And what's your explanation for 5 the failure to...

AI summary The text discusses a regulatory proceeding involving Nova Scotia Power and Port Hawkesbury Paper (PHP), focusing on disagreements over the implementation of a written tariff and priority interruptibility provisions. There is a lack of consensus between parties regarding the interpretation and application of the Settlement Agreement.

- Scotia Power, takes the position it does on the effect of - this paragraph. - A. (Ferguson) Yeah. I recall that I - said we've put our position forward in response to CA 9 as - clearly as possible. - Q. Right. - A. (Ferguson) And why we...

AI summary Nova Scotia Power argues that Port Hawkesbury Paper's position on the costing and pricing parameters of the tariff does not align with the parameters outlined in the Settlement Agreement, including the 65 megawatts of total coincident peak load, 8 megawatts of firm load, and the 104% revenue cost ratio for Port Hawkesbury Paper.

1 subparagraph (g), again, there are a number of different 2 scenarios in (a) that essentially inject a conditionality 3 into the outcomes of this process. The last one being if 4 PHP determines that PHP, ADC, and tariff processes outcome...

AI summary The discussion revolves around the potential outcomes if the PHP, ADC, and tariff processes are deemed unsatisfactory. If this occurs, alternatives to the ELID tariff, such as a below-the-line tariff like the ELIADC, may need to be considered, requiring a reevaluation of its parameters.

NOVA SCOTIA POWER PANEL 145 Cr-ex, (Powell) 1 is we are going to end up on PDF page 1373, starting 9 analysis hasn't been done aside from the description that 10 you've provided this morning, in terms of the 11 considerations that you took...

AI summary The document discusses the analysis of interruptibility and its impact on generation capacity requirements and demand-related costs. It includes a clarification that interruptibility may reduce generation capacity requirements and a discussion of how demand-related costs are allocated based on total forecast demand.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 interruptible part. Is that right? So it's not a 2 proportionality? 3 A. (Ferguson) Correct, yeah. The time 4 horizon is different. For the DR, that's the system 5 savings created ac...

AI summary The discussion addresses the difference between demand response (DR) and interruptible service (IR) in Nova Scotia Power's operations. DR involves system savings over the year through load adjustments, while IR is a tool used to require certain customers to reduce load within 10 minutes, potentially multiple times a year. The discrepancy in compensation for interruptible service and the frequency of interruptions is highlighted.

NOVA SCOTIA POWER PANEL 165 Cr-ex, (Powell) 1 THE CHAIR: Sorry; if I could if I could 3 A. (Ferguson) Yes. 4 I'm just seeing if some of my Q. 5 questions have already been answered, so just a moment. 6 (SHORT PAUSE) 7 BY MS. POWELL: 8 I'd...

AI summary The panel discussion involves a review of Nova Scotia Power's reliance on historical peak contributions from the Public Utilities Board (PHP) as presented in Patrick Bowman's Opening Statement. The discussion focuses on customer base line (CBL) considerations.

NOVA SCOTIA POWER PANEL 171 Cr-ex, (Powell) - were going to develop an above-the-line alternative. - Q. If I could just ask a question of - clarification on the tariff that is before the Board, so - back to the Application, if I may. Thank...

AI summary The discussion revolves around Nova Scotia Power's (NSP) capacity planning, specifically how the 57 megawatts of load, if firm, would impact NSP's need for additional capacity investment. The witness explains that generating capacity is based on firm requirements and reserve margins, and the 57 would not be included in that calculation.

NOVA SCOTIA POWER PANEL 183 Cr-ex, (Rudderham) - class like ELID class single customer with highly variable load. - Q. And so when, in this passage, you're referring to the need for formal analysis and expert evidence on the record, am I c...

AI summary The discussion centers on the need for expert evidence regarding demand assumptions and embedded-cost basis for setting demand. The panel questions the difficulty in determining historical load at peak times due to dispatchable impacts, and whether the load should be based on consistent demand levels.

NOVA SCOTIA POWER PANEL 185 Cr-ex, (Rudderham) excuse me; generation and transmission-related costs? The company's view is no, that's too light in light of their consistent their consistent usage of the generation and transmission systems...

AI summary The discussion revolves around the allocation of generation and transmission costs, particularly focusing on the Public Utilities Board's (PHP) load and its impact on rate-making decisions. The company argues that PHP's usage of the transmission system is significant, and fair allocation of demand-related costs is a key consideration.

customers would carry the cost of that, other above-the- line customers would carry the cost of that. And if it's too high, then PHP would be paying too much of the their share of the costs on the system? A. (Ferguson) Yes. Q. Okay. And ju...

AI summary The discussion addresses the transition of PHP from a below-the-line to an above-the-line rate structure, focusing on the implications for cost allocation and the use of historical load data for PHP at 3CP, including considerations of embedded cost principles and system availability.

NOVA SCOTIA POWER PANEL 195 Cr-ex, (Rudderham) 1 (Ferguson) I do. A. 2 And that there had been periodically Q. 3 confirmed to remained reasonable quantities. Recall 4 reading that? 5 (Ferguson) Yes. Q. 6 Okay. So first this 2012 study, has...

AI summary The panel is discussing the 2012 Stern Paper Mill Study and its inclusion in the proceeding record. There is a question about whether the study was previously produced and if it can be provided again, considering potential challenges from a cybersecurity incident. The study's value of 65 megawatts has been carried forward in load forecasts and is considered reasonable despite volatility, based on evidence from Brubaker and Associates.

NOVA SCOTIA POWER PANEL 221 Cr-ex, (Rudderham) there where it says power factor 90 to 100, 80 to 90, 75 to 80, 70 to 75; correct? A. (Stanford) Yes, that's correct. Q. Okay. Now, power factor corrections, they also apply to other large ind...

AI summary The discussion focuses on power factor corrections within Nova Scotia Power's tariff structure, specifically how they apply to demand charges under large industrial rates. The witness confirms the general structure of power factor tiers but acknowledges the need to verify specifics regarding the application of corrections to demand charges.

NOVA SCOTIA POWER PANEL 225 Cr-ex, (Rudderham) the system due to the poor power factor of the customer. If it was energy related, then there would have to be additional energy produced to supply that load. Q. So does that mean, and includi...

AI summary The discussion centers on the rationale for tying the Power Factor Correction to the energy charge rather than the demand charge under the ELID Tariff. Questions are raised about the impact of a fixed demand charge on embedded costs and whether alternative mechanisms were considered for the Power Factor Correction.

NOVA SCOTIA POWER PANEL 241 Cr-ex, (Rudderham) 1 the system? 2 (Mowatt) As my colleague Mr. Stanford A. 3 noted, that there is some inherent reliability associated 4 with Active Demand Control or dispatchability of PHP, and 5 the fact that...

AI summary The discussion revolves around the reliability benefits of Active Demand Control (ADC) and the justification for retaining a premium associated with priority interruptibility. The panel questions whether compensation for priority interruptibility is currently in place and confirms that a premium is being added to the tariff based on previous Board decisions.

NOVA SCOTIA POWER PANEL 263 Cr-ex, (Rudderham) 1 those three scenarios occur where we have to actually 2 operate that operating reserve, then PHP is targeted first 3 as a priority interruptible service. 4 And is that what occurred on Janua...

AI summary The testimony discusses the prioritization of interruptible service during operating reserve shortages, specifically mentioning PHP (Public Utilities Board) being targeted first. It also references a $500,000 annual value for a 10 percent figure related to the priority interruptible credit, confirmed by Mr. Ferguson.

NOVA SCOTIA POWER PANEL 269 Cr-ex, (Rudderham) implications, if any, of discontinuing it. But moreover, there's also been a recognition that ADC comes with reliabilities that benefits that are not being compensated. So the company's positi...

AI summary The discussion centers on the implications of discontinuing ADC, with the company advocating for maintaining the priority interruptible service and its compensation. The conversation also references a 10-year system outlook report from the IESO and a specific exhibit in matter M12916.

Q. Yeah. And I guess what I am trying to get at with my questions about the interruptible priority credit, assuming and knowing that Nova Scotia Power cannot act discriminately before or sorry; discriminatively before or to customers, if a...

AI summary The discussion revolves around the interruptible priority credit and whether Nova Scotia Power can offer it without discriminatory practices. Concerns are raised about the potential financial burden on other above-the-line customers who may be funding this credit. The response references legislation against undue discrimination and the need for Board approval of the tariff.

NOVA SCOTIA POWER PANEL 277 Cr-ex, (Rudderham) 1 (Ferguson) Sorry; can you just hold on A. 2 one second? 3 (SHORT PAUSE) 4 MR. FERGUSON: Was your question about 5 five-years notice to move to firm service or to non 6 priority interruptible...

AI summary The discussion revolves around the notice periods for switching between service types and the impact of PHP potentially becoming an above-the-line customer on NSPI's hedging plans for 2027. The parties are exploring the implications of these changes on forecasting and service planning.

NOVA SCOTIA POWER PANEL 281 Cr-ex, (Rudderham) 1 (Mowatt) Implement the hedges right A. INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 that's in the reply evidence. And perhaps it'd be easier 2 to bring it up. N-38, Exhibit N-38,...

AI summary Nova Scotia Power is developing a new methodology to quantify the value of load shifting under the ELID Tariff, which will be subject to FAM Small Working Group review and Board approval. The methodology aims to more accurately calculate the value of shifting load, isolated from price fluctuations.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 MS. RUDDERHAM: I am cognizant of the time. 2 It says it's 4:30. I do still have a number of questions. 3 I hope I won't be too long, but if I'm able to continue or 4 if...? 5 THE CHA...

AI summary The discussion involves the operating procedures for ELID and whether they require Board approval. The witness confirms that NSPI does not require Board approval for these procedures. The speaker references Exhibit N-6, specifically IR-12 and Attachment 1, in relation to Nova Scotia Power's responses to the Industrial Group.

NOVA SCOTIA POWER PANEL 297 Cr-ex, (Rudderham) main cause codes, as they would be the ultimate decision. Q. Okay. I'm going to switch gears here, and I'm going to follow up on some questions that were asked by counsel for the Small Busines...

AI summary The panel discussion focuses on the customer charge and the tasks required to support the tariff, with NSPI providing a list of items that may not be exhaustive. The discussion involves the administration of the tariff and associated costs.

NOVA SCOTIA POWER PANEL 301 Cr-ex, (Rudderham) which is the lower end of the range, and any variance would be tracked in the deferral account. Am I correct with that? A. (Ferguson) Yes. Q. And NSPI agrees that the scope of the deferral acc...

AI summary The discussion focuses on the deferral account for the Affordable Multifamily Housing and Non-Profit Organizations (AMF) program, including how costs and revenues are tracked, whether costs are classified as operating expenses, and how refunds would be handled if actual costs are lower than expected. NSPI confirms that the scope of the deferral account is governed by the Board's GRA decision.

NOVA SCOTIA POWER PANEL 305 Cr-ex, (Rudderham) understanding that there's variances that will arise over time. I understand your point. We'll have to take that into consideration. Q. Are you able to provide as an undertaking the costs asso...

AI summary The discussion revolves around the administration costs of the ADC mechanism within the 2027 revenue requirement and concerns about potential double counting. Nova Scotia Power acknowledges the need to ensure accurate tracking and verification to avoid overlapping costs.

NOVA SCOTIA POWER PANEL 307 Cr-ex, (Rudderham) 1 MS. RUDDERHAM: And I am cognizant that 2 it's 4:57; it's my last area of questions. I'm happy to 3 continue, but I can see you nodding your head yes? 4 Okay. Bear with me. 5 BY MS. RUDDERHAM...

AI summary The discussion focuses on the complexity introduced by wind output from Goose Harbour and the prescribed power agreement, with PHP being billed based on energy consumed above the contracted amount. The energy charge calculation is tied to forecasted consumption, with higher anticipated load leading to lower energy charges and vice versa.

assumptions for the wind potentially having an impact on that. And so that would need to be examined as part of the potential deferral mechanism that was approved in the GRA. Q. But the deferral mechanism is only recovered from other above...

AI summary The discussion revolves around the deferral mechanism approved in the GRA, its impact on above-the-line customers, and the ELID structure. It clarifies that variances in the deferral mechanism would not result in true-ups for PHP and that the Goose Harbour treatment is calculated annually rather than hourly.

NO. PAGE NO. September 22, 2026 U-11 To explain the difference between the RECs purchased by Nova Scotia Power as referred to in the FAM Audit and RECs referred to from the Goose Harbour PPA; to provide confirmation that the Goose Harbour...

AI summary The document outlines several issues for review, including the compliance of RECs from Nova Scotia Power and Goose Harbour, the comparison of the ELIADC Tariff with a proposed tariff regarding equipment failure, the reconciliation of demand and energy costs to revenues, and the submission of recent forecasts. It also asks whether NSPI has commented on the renewable attribute loss rate.

NOVA SCOTIA POWER PANEL 21 Cr-ex, (Mahody) 1 We're not pricing out the entire cost 14 benefit is that the depending on the load level that 15 PHP is at may not be as high as the levelized load for 16 that hour, at which point the levelized...

AI summary The discussion revolves around the cost implications of pricing mechanisms, specifically how the levelized costing may differ from actual hourly costs depending on load levels and dispatching practices.

NOVA SCOTIA POWER PANEL 39 Cr-ex, (Mahody) 1 And can we begin by just getting an 18 equipment failure is not specified as a reason to not 19 dispatch according to instruction, is it? 1 (Mowatt) I'm sorry, Mr. Mahody, I A. 2 don't know that...

AI summary The proceeding discusses a request to review and compare the ELIADC Tariff with a proposed tariff, focusing on equipment failure as a reason for deviation. It also addresses the reconciliation process for DR credits, highlighting concerns about time lags in end-of-year calculations versus real-time adjustments.

Mr. Mahody. Q. All right. Thank you, Mr. Stanford. So now I think I'm back to you, Mr. Ferguson. The company the tariff proposes the cost of service proposes using the same 65-megawatt demand determinant for allocating both generation and...

AI summary The discussion centers on the methodology used by Nova Scotia Power for allocating generation and transmission costs based on a 65-megawatt demand determinant. The approach is consistent with how costs are assigned to other classes, particularly large industrial classes, and relies on the company's expertise in system operations.

NOVA SCOTIA POWER PANEL 65 Cr-ex, (Mahody) 1 Q. But none of those customers are 1 system cost with an estimate of system cost assuming PHP 2 had operated without dispatch at the prescribed high-load 3 factor profile. Is that correct? 4 A....

AI summary The discussion revolves around the methodology used by Nova Scotia Power to estimate system costs assuming PHP operated without dispatch. The approach involves a replacement cost methodology and a functional formula to determine a levelized load, acknowledging that the assumed flat customer profile may be imperfect and subject to external factors.

NOVA SCOTIA POWER PANEL 85 Cr-ex, (Mahody) 1 details, but I can't think of anything right now that 2 would impede that. 3 Okay. Thank you, Mr. Willett. Q. 4 Mr. Mowatt, my final question just 5 returns to the implementation of discretion b...

AI summary The discussion revolves around the calculation of savings created by Nova Scotia Power's dispatch of customer load, specifically the use of the Customer Baseline Load (CBL) in determining demand response (DR) credits. The question focuses on whether discretion is involved in calculating the CBL, with the witness explaining that the process is a straightforward mathematical calculation.

completed using a random seed generator in Excel, so that can be spread out so such that every month has a similar number of outage days, and within each month those outages are randomized. That wouldn't be towards Nova Scotia Power's disc...

AI summary The discussion revolves around the methodology used to distribute outage days across months using a random seed generator in Excel, ensuring an even distribution. The witness clarifies that while the process is mathematical and formulaic, there may be future considerations that could influence the approach.

Power, if we make all or any of the adjustments some are you know, you can't do one two at the same time, but if you make some of these adjustments that are requested, because of the deferral account, would Nova Scotia Power be kept whole...

AI summary The discussion revolves around deferral accounts and their impact on Nova Scotia Power, particularly regarding whether the company would be kept whole with the deferral mechanism and concerns about the number and flexibility implications of deferrals. The conversation also touches on the Settlement Agreement and its potential influence on the Board's decision-making.

NOVA SCOTIA POWER PANEL 97 Questions, (Melanson) 1 class with one customer on it, where the variability can 14 credit, that you did not support the corresponding change 15 to the premium. Am I correct about that? 16 A. (Ferguson) Yes. 17 O...

AI summary The discussion revolves around the modeling of a 10 percent premium and the complexity of determining the true value of priority interruptible service. The entity acknowledges reliability benefits from ADC service and suggests that discontinuing the current approach would be premature without completing a full analysis.

NOVA SCOTIA POWER PANEL 101 Questions, (Melanson) 1 Agreement and it was agreed by the parties that they would 8 THE CHAIR: First, if we could pull 9 up, Mr. Norwood, Exhibit N-1(i), please? It's an Excel 10 spreadsheet. And if we could go...

AI summary The text discusses a regulatory proceeding involving Nova Scotia Power and the ELID rate design tab in an Excel spreadsheet. The discussion centers on revenue anticipated from the proposed ELID Tariff, specifically referencing cell L-21 for 2026 and L-44 for 2027 energy charges.

NOVA SCOTIA POWER PANEL 113 Questions, (Chair) 1 And in Column 5, as I understand Q. 2 it, that's the actual allocated cost, as opposed to the 3 revenue that is expected to be derived from the rate as 4 designed, producing that 104.71 reve...

AI summary The discussion centers on the allocation of demand and energy-related costs to different classes under the cost-of-service model. The witness explains that some demand costs are recovered through the energy charge, and the numbers in Exhibit 10 represent fully allocated costs based on energy and demand for the class.

1 megawatts and what's established over time. But just 2 going forward, as that load at time of system peak varies, 3 we're of the view that it's it will need to look beyond 4 what the actual 3CP number is to make sure that it 5 produces a...

AI summary The discussion focuses on the challenges of determining fair demand allocation under a specific rate design, particularly as load varies during system peak times. The speaker acknowledges the subjective nature of the debate and anticipates that future General Rate Applications may involve a more long-term and refined process.

d with the 17 benefit of this proceeding and experience with the tariff, 18 my hunch is that what's established the next time around 19 will be a much more longer-term process that will be more definitive going forward and likely won't hav...

AI summary The discussion suggests that future GRA proceedings will involve a more definitive and long-term process for determining demand numbers, relying on information gathered through this proceeding and analysis in subsequent ones, ensuring reliability over time.

NOVA SCOTIA POWER PANEL 135 Questions, (Chair) 1 A. (Willett) Mr. Chair, I believe 15 aspect of a General Rate Application and say, "Well, this 16 one component of things has changed, so let's make some 17 modifications on that single comp...

AI summary The discussion revolves around the challenges of isolating specific components within a General Rate Application, particularly in updating demand forecasts and energy rates without affecting other aspects of the application.

NOVA SCOTIA POWER PANEL 145 Cr-ex, (Rubin) 1 (Ferguson) Yes. A. 2 Okay. Including an industrial Q. 3 expansion rate? 4 (Ferguson) I think it is A. 5 described as the industrial expansion rate at one time, 6 yes. 7 Q. Okay. And then followi...

AI summary The discussion revolves around the demand charge structure for Nova Scotia Power, distinguishing between fixed charges for PHP and variable charges based on actual demand for large industrial customers. The proposed fixed charge for PHP is based on assumed demand contributions, while large industrial customers are billed based on actual meter readings or winter peak ratchet values.

1 and their use of the system on the most, you know, 2 demanding days of the year. Is that your understanding as 3 well? 4 A. (Fitzhenry) Yes, I would largely 5 agree with that characterization. 6 Q. Okay. And isn't the purpose of 7 it to...

AI summary The discussion centers on the use of the CP3 demand allocator as a method to estimate customer class contributions to production capacity and transmission costs. The method is described as a rough tool that provides a snapshot rather than an exact depiction of customer demand.

PHP EXPERT PANEL 197 Cr-ex, (Murphy) - figure that may artificially depress or increase an impression of somebody's demand? - A. (Fitzhenry) I would say that the 3CP demand is an estimation of customer usage at times of peak demand. - Q. B...

AI summary The discussion focuses on the estimation of peak demand using the 3CP (Three-Class Power) methodology, contrasting it with single customer peak demand. It addresses how customer behavior can influence demand estimates and the role of NS Power in managing PHP (Power Hosting Provider) through price signals and potential interruptions.

PHP EXPERT PANEL 223 Cr-ex, (Powell) 1 eventually achieving a 1.0 R/C ratio, but in this 2 instance, we will deviate from that 1.0 ratio in order to 3 ensure that a specific class doesn't have an undue 4 financial burden and is not experie...

AI summary The discussion revolves around the application of a 1.0 R/C ratio in tariff proceedings and the potential financial burden on specific customer classes. The expert explains that a new tariff is not a full rate case and therefore does not involve the same considerations as a comprehensive rate adjustment. The concept of a 'double hit' is introduced, referring to the inequity of transitioning a customer to a full-cost tariff while also applying an R/C ratio above 1.0.

PHP EXPERT PANEL 225 Cr-ex, (Powell) INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS MS. POWELL: So we're going back to page 3, which is PDF page 5 in Exhibit N-2, Mr. Norwood. BY MS. POWELL: Q. We're still talking about R/C ratios....

AI summary The discussion centers on the application of R/C ratios to mitigate cost shifting among existing customer classes during rate changes. The expert explains that adjustments to R/C ratios are typically applied to existing customer classes and not to new tariffs, which would represent new customer classes.

PHP EXPERT PANEL 233 Cr-ex, (Rubin) 1 Again, I'll restate my previous Q. 6 benefits to the system which are captured in the credit. 7 Q. Sorry; and this is with the 8 interruptible credit? 9 A. (Gorman) Yes. 10 Q. Okay. And so I asked is t...

AI summary The discussion revolves around the evaluation of interruptible credits and the proposed design of the Electric Load Index Demand (ELID). The panel is examining whether the ELID design is cost-based, with references to a proposed cap on priority interruptibility at $500,000. There is an emphasis on the capacity value of interruptible credits and their impact on transmission service costs.

PHP EXPERT PANEL 255 Cr-ex, (Rubin) 1 time. 4 BY MS. RUBIN: 5 Was this disagreement with the Q. 6 costing determinants, or dissatisfaction, communicated in 7 writing to other signatories to the Settlement Agreement? 8 A. (Fitzhenry) I'm th...

AI summary The discussion revolves around PHP's eligibility to continue using the ELIADC tariff past its expiration in 2026. The response indicates that PHP cannot continue under the current tariff as it uses marginal energy cost rates, which are typically applied to new customers, not existing ones like PHP.

PHP EXPERT PANEL 261 Cr-ex, (Rubin) 1 know, discussions. 6 Retention Tariff either; you can't say one way or another? 7 (Fitzhenry) I'm not familiar with A. 8 that rate. 9 Would you acknowledge that there Q. 10 are numerous tariffs in addi...

AI summary The discussion revolves around the use of marginal cost pricing in Nova Scotia, specifically referencing PHP's long-term use of such a rate. The conversation questions whether this justifies a transition in tariff structures, with a mention of the ELIADC and other tariffs.

PHP EXPERT PANEL 275 Cr-ex, (Rubin) 1 A. (Fitzhenry) Oh, excuse me. 2 You're right. From because of the ratchet. It was 3 based on their individual billing demands; correct? 4 Q. Right. 5 A. (Fitzhenry) Okay. 6 Q. And under this proposal,...

AI summary The discussion centers on the impact of a fixed demand charge on PHP's operational incentives, contrasting it with other customer classes. It highlights that PHP may not be incentivized to adjust demand during peak times, but also notes that PHP will still operate efficiently due to factors like dispatchable rider benefits and regulatory review processes.

PHP EXPERT PANEL 289 Cr-ex, (Mahody) 1 (Gorman) It was based on A. 2 representations that we understand from PHP and their 3 expected operations over the next few years. 4 Q. Understood. So no review of the 5 model itself? 6 A. (Gorman) No...

AI summary The expert panel is discussing the ELID Tariff and its impact on PHP, including potential production delays and increased operating costs. The panel members base their opinions on conversations with PHP personnel rather than detailed documentation. They acknowledge that forecasts improve as they approach the start date.

R/C ratio is going to be, and you establish in the GRA what the forecast numbers are, individual customers can't come in individual rate classes can't come in and adjust that because they think it's unfair a year later. There could be an e...

AI summary The discussion centers on the R/C ratio and the use of a deferral account to address adjustments for individual rate classes. Concerns are raised about fairness and the implications of adjusting rates for a single class, with a response indicating that the deferral account provides flexibility for NS Power.

PHP PANEL 1 25 Cr-ex, (Murphy) 1 consistent with prior applications for the ELIADC as well, 2 right? That those were filed by Nova Scotia Power before 3 the Board? 4 A. (Lock) Honestly, I can't remember 5 if it was a joint tariff in the EL...

AI summary The discussion revolves around the ELIADC tariff application process, with Nova Scotia Power and PHP jointly presenting and supporting the application, including stakeholder conferences and testimony from the System Operator. The conversation also touches on the process of filing a tariff for an above-the-line rate.

PHP PANEL 1 27 Cr-ex, (Murphy) 1 (Lock) A similar process to the A. 2 extension? Sorry. 3 Q. Yes. 4 (Lock) Yeah, okay. Yeah, we A. 5 this these tariffs both work very closely with the 6 utility, and like has been mentioned a few times here...

AI summary The discussion revolves around the development of a tariff agreement between PHP and Nova Scotia Power, with specific concerns about the terms of the Port Hawkesbury application and the process followed to finalize the tariff. There is mention of collaboration since 2023 and the need to align actual performance with forecasts.

asked about the process you follow to reflect the foregoing in a written tariff, that it was through, that through subsequent modelling I'm not trying to put words in your mouth, but through subsequent modelling that you realize that you w...

AI summary The discussion revolves around the process of updating a written tariff based on subsequent modelling, which revealed discrepancies between initial assumptions and actual data related to 3CP demand during specific periods. The timeline of this realization is unclear but linked to an IR and a review by BA or BAI.

1 can certainly look that up, if you'd like. 2 Okay. And that'd be helpful if A. 3 you could provide an undertaking on that. 4 (Lock) Yes, we can. A. 5 THE CHAIR: Just for clarity on the 6 record, Mr. Murphy, the undertaking is for a date...

AI summary The discussion revolves around PHP's undertaking to provide the date when their modelling results changed their view on load parameters, in response to questions from the BAI. The timeline of events, including the GRA filing and the Settlement Agreement, is also explored, though specific dates remain unclear.

under the tariff on the terms that were set out here, why bother going through with the process of having NSP create a deferral account? A. (Lock) Sorry; can you reframe the question? Q. Sure. So the deferral account, as I understand it, w...

AI summary The discussion revolves around the creation of a deferral account under the tariff and whether the cost differences between the Settlement Agreement and PHP's proposed changes are material. The witness emphasizes that without a final approved tariff, it is not possible to comment on the materiality of the cost differences.

is see subject to a satisfactory conclusion of, and resolution of, this process. Q. Right. So PHP commits to taking service and PHP's commitment is subject to satisfactory conclusion of the resolution of the PHP ADC and tariff processes. T...

AI summary PHP's commitment to take service is conditional on the satisfactory conclusion of the PHP ADC and tariff processes. The discussion suggests that PHP's baseline load is 65 megawatts, and there is a focus on the terms and conditions of the new rate form, with an emphasis on consensus and fairness.

1 level of load relief they get when they ask for that. 2 So that's what it's that it's not 3 like, "Please dial back or ramp down to something," you 4 know, 10 percent or 5 percent less. It's that it's in 5 those same chunks, which is com...

AI summary The discussion focuses on the Dispatchable Tariff operating procedure and the limits of changes that can be requested for dispatch schedule changes. It differentiates between load relief mechanisms and interruptibility responsibilities, highlighting that the latter remains unchanged regardless of dispatch adjustments.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS forecast demand for PHP is which is Column 4, is shown as 199,370 megawatts. You see that? A. (Lock) I do see the number, yeah. Q. And so my question is how do you reconcile that to th...

AI summary The text discusses a question regarding the discrepancy between forecasted demand for Port Hawkesbury Paper (PHP) at 199,370 megawatts and previously discussed operating modes (OMs) of 160 megawatts. The witness indicates uncertainty and suggests the question should be directed to Nova Scotia Power. An undertaking (U-20) is requested to confirm the reported load for PHP on January 19, 2024, during the peak hour.

PHP PANEL 1 237 Cr-ex, (Mahody) 1 interruptibility, not dispatchability? 2 A. (Lock) Sorry; just wanting to 3 review for clarity because it is a confusing 4 differentiation. 5 Q. Yeah. 6 A. (Lock) I have to believe that 7 this is referring...

AI summary The discussion centers on the distinction between interruptibility and dispatchability in the context of a rate structure. The witness clarifies that dispatchability involves PHP having some discretion in following schedules, while interruptibility allows Nova Scotia Power to control load placement unilaterally.

PHP PANEL 1 263 Questions, (Melanson) 1 differentiator. In all but, you know, 2 or 3 percent of 2 the time we have complied, but it's not 100 percent, which 3 the interruption call makes it absolute 100 percent. 4 Q. And when you're in a s...

AI summary The testimony discusses the importance of accurate forecasting in ratemaking, referencing a Settlement Agreement anticipating a tariff effective January 1st, 2026, and the challenges in achieving timely implementation of all rates.

PHP PANEL 1 265 Questions, (Melanson) 1 ordinarily you don't get I know there are mechanisms 2 like the FAM, those various specialized situations. But 3 ordinarily you don't get to true-up your forecasts after 4 the rate application is con...

AI summary The discussion centers on the Fuel Adjustment Mechanism (FAM) and whether ratepayers can adjust forecasts after a rate application is concluded. Nova Scotia Power (NSP) argues that using the most up-to-date forecasts is necessary, especially given trade concerns, while others question the fairness of allowing only certain ratepayers to adjust forecasts.

PHP PANEL 1 1 THE CHAIR: Anything I'm just going 6 So just a moment ago, the Consumer 7 Advocate went over your experiences and qualifications. 8 And I won't repeat it, but I want to confirm; you're not a 9 lawyer, neither of you, and have...

AI summary The discussion centers on the Settlement Agreement (SA) and its implications for the ELID Tariff, with a focus on whether the SA dictates the structure of the tariff and its alignment with load characteristics. The panel is examining the interpretation of contractual terms and the application of the SA in the context of a tariff filing.

CONSUMER ADVOCATE PANEL 293 Cr-ex, (Rudderham) 1 that any element of it were, you know, unjustly 2 discriminatory or unduly preferential or otherwise not in 3 the public interest, then, yes, the Board can and should 4 make changes. But I a...

AI summary The Consumer Advocate Panel discusses the Board's discretion in reviewing a Settlement Agreement, emphasizing deference to negotiated terms unless they are unjust, discriminatory, or not in the public interest. There is also discussion about the merits of PHP's position and the reasonableness of load assumptions, particularly regarding the 57 megawatts agreed upon in the Settlement Agreement.

CONSUMER ADVOCATE PANEL 299 Cr-ex, (Rudderham) 1 that's N-16 and it was previously labelled as confidential 16 it for that 100 percent is that, you know, PHP under the 17 proposed ELID tariff will be now contributing towards the 18 fixed c...

AI summary The discussion revolves around the proposed ELID tariff and its impact on the PHP program, including changes to how fixed costs are allocated and the discontinuation of a variable capital charge. There is a focus on the potential savings and how they should be distributed to customers.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 appropriate rate if applied using the general practice. 2 A. (Mahmudov) Yes. Maybe if you 3 allow me to call up Nova Scotia Power's rebuttal, it's 4 Exhibit N-38. Maybe I can take yo...

AI summary The discussion revolves around the fairness of interruptible credit compared to demand costs, referencing Nova Scotia Power's rebuttal evidence. The witness argues that assigning demand costs to customers receiving interruptible credit should not exceed the value of the credit, as it would be unreasonable.

idence that 23 if the if the amount of the credit exceeded the demand 24 cost, that would be unreasonable. But as we've already 25 indicated and that you gentlemen agreed to earlier, not all of the demand cost is in the demand charge. Nova...

AI summary The discussion centers on the allocation of demand costs in Nova Scotia Power's cost of service, noting that a portion of demand costs are recovered through energy charges rather than just demand charges. This practice is also followed by other utilities, and the credit formula is questioned in relation to these costs.

1 related demand cost is being recovered by energy and this 2 percent of transmission demand related costs are being 3 recovered by energy. That's the first concern. 4 And second concern is in particular 5 with respect to PHP is this offse...

AI summary The text discusses concerns about the recovery of demand costs by PHP, particularly in a scenario where PHP's net energy purchase is zero. It highlights a proposed interruptible demand credit that may be higher than PHP's demand charge, raising questions about cost allocation and fairness.

REPORTING INC. CERTIFIED COURT REPORTERS A. (Mahmudov) I heard that, yes, but I think I also heard that there is already, you know, the adjustments are being proposed which reduced the net energy 1 versus what was in the settlement agreeme...

AI summary The discussion revolves around the adjustment of net energy and its impact on fixed costs recovery from PHP. The speaker explains that reductions in net energy may lead to less recovery of fixed costs, and the billing method for energy is tied to the cost per megawatt hour or kilowatt hour.

y, you know, it's 16 fixed. We'll just divide it by, you know, 12 and collect 17 it monthly. 18 They're not able to do the same for 19 the energy, so if the energy is lower, net energy is lower than what's built into the cost of service an...

AI summary The discussion centers on the cost recovery mechanism for NSP, specifically the inability to recover fixed costs when energy usage is lower than expected. The conversation also touches on the position regarding Port Hawkesbury Paper and its potential credit for interruptibility if on the DR.

ptibility so that 17 you can avoid the cost of future generation. It's 18 completely distinct product which the customer is providing 19 to the utility than the DR, which is a product that runs 1 every 8,760 hours of the year and reduces a...

AI summary The discussion revolves around the differences between demand response (DR) and a distinct product related to avoiding future generation costs. It also addresses the interruptibility of PHP under the current ELIADC rate and the lack of interruptible credit, highlighting the value exchange between fixed costs and interruptibility.

1 looking at, the $13.107, is becoming too high. And I think 2 they said that they want to review it. 3 So it may be that this interruptible 4 credit amount, whatever it is, will also be reduced because 5 at the moment, if you just look at...

AI summary The discussion focuses on the potential reduction of an interruptible credit amount, highlighting concerns over the $9.5 million credit to PHP compared to revenue from fixed charges. There is a suggestion to use a lower estimate of $6 million instead, considering operational and commercial risks associated with demand response (DR) programs.

1 Would you advise someone to say, well, 2 take the IR with no interruptible value? 3 A. (Mahmudov) If it's only a monetary 4 if it's only a monetary factor, like if you're only 5 looking at the dollars, probably, you know, doesn't make 6...

AI summary The discussion revolves around the considerations of interruptible load (IR) versus demand response (DR), with a focus on monetary factors and risks associated with DR. The witness, Mahmudov, notes a lack of information on non-monetary considerations and risks related to DR. The Chair also references a statement from InterGroup regarding the underrepresentation of PHP's use of the transmission system when only firm load is considered.

bit of 16 difficulty, in my view, in segregating what is what 17 really should be called firm and what should be more 18 correctly called interruptible. 19 Q. Okay. And that kind of bleeds 1 into the next piece of elaboration I was going t...

AI summary The discussion focuses on the difficulty of distinguishing between firm and interruptible loads in electricity demand, the use of the 3 CP methodology by Nova Scotia Power, and concerns about cost shifting. Alternative cost allocation methods are mentioned as potential solutions, though no specific recommendations are provided.

ght the settlement - agreement as we understood it was reasonable for the time - being. But in the future, there may be a need to explore - other methods and some of what we see in other places are - expanding the number of coincident peak...

AI summary The discussion centers on the current methodology used by Nova Scotia Power for cost allocation and the potential need to explore alternative methods, such as expanding the number of coincident peak hours considered in the calculation.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 instead of the 65 proposed in the application. 2 If NSP has more detailed and reliable 3 peak demand data supporting a more accurate CBL, I agree it 4 should be used. Based on the ev...

AI summary The text discusses the setting of a capacity-based load (CBL) at 120 megawatts for PHP based on current evidence, and the benefits of a dispatchable rider that credits PHP for load shifting in response to system costs, despite most of PHP's energy coming from its own wind generation.

s such that 17 its load is already off the system, NSP need not compensate 18 the customer for that reduction through the IR. The IR 19 should only apply to additional interruptions the utility INTERNATIONAL REPORTING INC. CERTIFIED COURT...

AI summary The text discusses the application of interruption credits (IR) to PHP, noting that if PHP's load is already off the system during interruptions, no IR credit should be awarded. Historical ELIADC data shows PHP was dispatched down during interruptions, suggesting little to no IR credit. The recommendation is that there is little to no credit due under the IR.

1 interruptible compared to some IR customers who do not 2 participate in the telemetry and control option. Note this 3 is contrary to Brubaker's rebuttal evidence claiming that 4 PHP is the first customer to be interrupted on the system....

AI summary The text discusses the rejection of PHP's proposals related to interruptible load and rate adjustments, emphasizing that labeling PHP as priority interruptible does not add value to the system. It also highlights the cost implications of adopting certain ratemaking principles and compares PHP's load and energy usage to the LI class.

ings from 16 shaping their own wind. And so you apply that to the to 17 the shape of their load second, and for which they will 18 receive a credit. 19 The third piece, which is has some 1 experience and practice in this jurisdiction for c...

AI summary The text discusses mechanisms related to load shaping, interruptibility, and credits based on load at peak times, particularly referencing 3 CP and LIIR customers. It also touches on the process for determining priority interruptibility.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 businesses or for residences. It doesn't necessarily work 2 well for large industries. 3 So when you come to the large 4 industrial customers, they use a mix of sort of past 5 experi...

AI summary The discussion focuses on how large industrial customers use a combination of past experience, customer surveys, and adjustments to determine their energy usage, rather than relying solely on past data. This approach accounts for interruptions and credits them through different mechanisms, avoiding double-counting in the cost-of-service analysis.

awatts, but 17 now we know the 28 probably includes a misreference in it 18 and it's probably something more like 13 megawatts. And 19 then we heard that that includes the load of the biomass so 1 the the peak's actually more like nine if...

AI summary The text discusses concerns about the accuracy of load estimates and their impact on rate stability. It highlights that applying peak load estimates without considering rider credits may lead to unstable rates and that transmission planning should not be based on interruptibility. Large industrial customers do not receive credits for transmission costs, only for generation costs.

BY MR. MURPHY: - Q. And just to pick up on that point, - as I understand your evidence, it's the problem with using - there only the historical data is that that already - takes into account interruptibility and the dispatchable - nature o...

AI summary Mr. Murphy questions the use of historical data in accounting for interruptibility and dispatchable nature of the ELIADC, suggesting that the NSP proposal splits the issue and may not be coherent. He supports applying a DR rider to credit industrial customers for load shaping but questions the actual level of interruptibility achieved.

1 know, 105 at times, their loads might be 80. Like their 2 billing determinants lead to 115 or something on average. 3 They're only credited for 60 or 70 or approximately 70 4 because that's all that's expected to be on the system at 5 pe...

AI summary The text discusses interruptible load management, where customers are credited for a portion of their load based on system expectations during peak times. It also mentions considerations around rate structures and system planning, including potential alternatives like the large industrial interruptible rate for PHP.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 principles, but not mixed in with the other large 2 industrial customers who don't have that type of, you know, 3 own non-firm generation behind the meter, for example. 4 Q. From tha...

AI summary The discussion revolves around classifying PHP customers differently from other LIIR customers based on their unique characteristics and system impacts, similar to how rural and urban residential customers are classified separately.

1 under if you increase control, they wouldn't have the 2 ability to reject or refuse? Is that what you're 3 suggesting with the increasing control? 4 A. Or it may just be that the cost 5 consequences are somewhat increased compared to jus...

AI summary The discussion centers on the control mechanisms NSP may use to influence PHP's behavior during high-cost hours, potentially increasing cost consequences. The speaker mentions that NSP might issue operating modes to balance the grid, with some having greater practical control implications.

gh the different mechanisms, suggested that there's concern that calculating that DR benefit to the to the penny will be difficult and it's possible that the results will be skewed in the direction 1 of overestimating the benefit rather th...

AI summary The discussion raises concerns about the difficulty in accurately calculating demand response (DR) benefits to the penny, with a risk of overestimation. It suggests that while PHP should receive cost benefits from DR dispatch, there should be some degree of benefit sharing to address the risk of overestimation.

1 determination that this is the best. It's not I'm not 2 sure I can fully support that the 3 CP is the best, but it 3 is the current method and it's been approved for use in 4 this jurisdiction. 5 So I accept all of that. 6 Q. Yeah. 7 A....

AI summary The speaker acknowledges the current use of the 3 CP method, which has been approved for the jurisdiction, but expresses uncertainty about its effectiveness. The discussion shifts to Exhibit N-28, page 11, focusing on the IG's response to PHP IRs, specifically section 5(g).

1 around 38.1 million, possibly lower, but against your 2 ultimate number of 48.5 million. 3 A. Yes. 4 Q. Okay. And now if we simply divide 5 the cost by the load, the 38.5 million divided by the 305 6 GWH, would you accept subject to chec...

AI summary The discussion revolves around calculating energy rates by dividing costs by load for different customer classes. The calculations show higher rates for low load factor customers and lower rates for high load factor customers, with the latter resulting in a rate of approximately $104.90 per megawatt hour.

1 services, though. The value proposition of the DR is to 2 reduce energy costs and get a credit for that, but you 3 don't have any demand credit provided under the DR; 4 correct? 5 A. That is correct. There is no 6 mathematical demand cre...

AI summary The discussion centers on the Demand Response (DR) program and its credit mechanism. It highlights that NSP does not provide a mathematical demand credit under the DR but adjusts the load in the cost of service instead. The DR is intended to reduce energy costs and provide credits, but the current approach is seen as a compromise rather than a full implementation of the intended credits.

e 14 numbers. 15 A. Okay. 16 Q. So your view is the typical 17 operating load would be 120. 18 A. The typical operating load would 19 be in that OM 5 to 6 but for the DR. And that would be in INTERNATIONAL REPORTING INC. CERTIFIED COURT RE...

AI summary The discussion centers on the calculation of operating load for a customer, with a focus on the impact of demand response (DR) on capacity and load factors. The witness argues that DR provides an energy benefit but not a capacity benefit, and questions the basis for using a load of 120 in calculations.

's what we keep 16 hearing. They're a high load factor customer. That keeps 17 being repeated. 18 Q. No, I don't know that we keep 19 hearing that. What we hear is that to do the CBL, NSPI has 1 assumed that Port Hawkesbury Paper would be...

AI summary The discussion revolves around Port Hawkesbury Paper's load factor and the impact of Demand Response (DR) on their operations. The witness explains that without DR, the customer would maintain a high load factor due to operational constraints and thermal stresses, running machinery as much as possible.

you're not 16 proposing that they be absent the DR. You're proposing 17 that there be a DR. 18 That's what I'm saying. You propose 19 you propose a DR, and then you propose that the credit be INTERNATIONAL REPORTING INC. CERTIFIED COURT RE...

AI summary The discussion centers on the implementation of a Demand Response (DR) program and its impact on the calculation of 3 CP (Cost of Service) values. The concern is that using an average load of 120 megawatts may not be accurate when DR is in place, as it could lead to incorrect assumptions about load profiles.

1 offline for a third of the month. The nine, nine and nine. 2 Q. Yeah, but earlier when we talked 3 about the Interruptibility, the interruptibility only 4 allows a customer to be taken off down to 30 percent of the 5 month; correct? 6 Th...

AI summary The discussion revolves around the limitations of interruptibility and demand response (DR) programs, particularly focusing on how customers under an interruptibility (IR) program can only be interrupted for 30% of the hours in a month. The conversation also touches on the conditions required for interruptibility and how DR differs from IR in this context.

1 is actually going to happen, it injects significant 2 complications into how cost to serve PHP is actually 3 determined and how costs are recovered under the energy 4 chart and the other rates. 5 I would say you know, for example 6 there...

AI summary The text highlights complications in determining the cost to serve the PHP (Preliminary Hearing Panel) due to transmission limitations, energy losses, and misalignment between generation and load periods. These issues create challenges in cost recovery under the energy chart and other rates, with benefits from the PSA not being fully reflected in cost calculations.

1 that if the energy charge does not reflect the accurate 2 load and there's no separate mechanism to address 3 shortfalls for fixed costs, those costs would fall on FAM 4 customers? 5 A. (Cain) That's correct. 6 Q. Okay. So this same thre...

AI summary The discussion addresses concerns about fixed costs being passed on to FAM customers if energy charges do not accurately reflect load, and whether a deferral account can recover costs from load forecasting errors. Bates White's evidence is referenced, and the role of the PHP deferral account under the GRA is questioned.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 that deferral account. 2 A. (Cain) So, you know, we're not 3 advancing ourselves as attorneys and we also recognize the, 4 you know, sort of packaged element of the settlement 5 agre...

AI summary The discussion revolves around the interpretation of a deferral account in a settlement agreement, with concerns raised about its scope and whether it addresses load variance impacts or only deviations from rate settings. The speaker references evidence from NSP and Bates White, and raises questions about cost recovery from other FAM customers.

sts would fall on other 16 FAM customers. How would that be recovered from other FAM 17 customers? 18 A. (Cain) If there are amounts that INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS are, you know, essentially unrecovered for the...

AI summary The discussion revolves around the recovery of unrecovered costs from FAM customers, with the utility needing a deferral mechanism to recover such costs. It also notes that NSPI cannot recover OM&G costs after the fact, except in cases of storms.

ect? 15 A. (Cain) Yes. 16 Q. Okay. And currently, NSPI can't 17 recover after the fact of variance in, let's say, OM&G 18 costs except for storm; correct? 19 A. (Cain) I believe that's correct. INTERNATIONAL REPORTING INC. CERTIFIED COURT...

AI summary The discussion revolves around cost recovery mechanisms for NSPI, specifically how variances in OM&G and fuel costs are handled, and the role of the Board in interpreting deferral accounts. It also touches on concerns regarding load forecasting variability and its impact on DR credits.

1 A. (Musco) That's that's my 2 general understanding. Yes. 3 Q. Okay. Now, in relation to the DR 4 credit, Bates White has identified several concerns with 5 the credit, I think it's numbered one 1 to 6. And the one 6 I wanted to, to kind...

AI summary The discussion centers on concerns raised by Bates White regarding the level of discretion Nova Scotia Power (NSP) has in calculating the Demand Response (DR) credit. NSPI initially suggested a formulaic approach with little discretion, but further questioning revealed some discretion, particularly around the term 'other factors' in the ELID tariff language and operating protocols.

that change or alleviate 16 any of the concerns that Bates White has raised in relation 17 to the level of discretion or verifiability of the DR 18 credit? 19 A. (Musco) Unfortunately, on the 1 on the discretion, no. Term "other factors" r...

AI summary The discussion centers on the discretion and verifiability of the DR credit mechanism. Concerns are raised about the broad interpretation of 'other factors' and the subjectivity it introduces. Nova Scotia Power acknowledges the need for verifiability and suggests that the process can be reviewed post facto.

done, if 17 there were any discretionary adjustments where those were 18 and how they impact the calculation. So I think that was 19 fairly positive to hear because it allows for the potential INTERNATIONAL REPORTING INC. CERTIFIED COURT R...

AI summary The discussion centers on the verification and credibility of discretionary adjustments in the calculation of end-of-year tariff and DR credit determinations, with a focus on the documentation required for audit purposes, such as production cost simulation runs.

to adjust the model was it was a product of Port 17 Hawkesbury Paper, then that's something we would have to be 18 able to understand and dig into. 19 But again, if the intent of the tariff 1 is to allow for transparency and a review of th...

AI summary The discussion centers on the DR credit mechanism and its implications for FAM customers. There is uncertainty about how FAM customers would ultimately pay for the DR credit, with the understanding that it may be charged to other customers who benefit from the dispatchability of the DR service.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 the current mechanism. 2 But I take your answer to be could be, 3 could not be. You're not 100 percent sure. 4 A. (Musco) Correct. 5 Q. Okay. Now NSPI's reply evidence 6 has stated t...

AI summary The discussion revolves around NSPI's new methodology for quantifying the value of the ADC, which was developed in response to feedback from Bates White and presented to the FAM Small Working Group for review. The witness confirms attendance at these groups but clarifies that NSPI did not develop the methodology themselves.

Bates White 17 recommendation, an audit recommendation and they reasonably 18 will will provide us a sort of access to what they're 19 working on. And then and can sometimes follow up INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS...

AI summary The discussion involves Bates White's potential involvement in reviewing a new methodology proposed by Nova Scotia Power, which would be subject to SWG review, Board approval through the ELID tariff application, and future audits. No formal opinion has been provided yet.

s not. 16 Q. Okay. That was my understanding 17 as well, but I just wanted to clarify that. 18 Based on your understanding of this new 19 methodology for calculating the DR credit, does that new 1 methodology address any of the concerns th...

AI summary The discussion addresses concerns raised by Bates White regarding the new methodology for calculating DR credits, particularly the use of forward replacement pricing. The response explains that the methodology aims to maintain consistent pricing for system dispatch and DR credit calculations, which has helped alleviate some concerns, though one remains.

so 16 be used in the after the fact calculation of the DR credit. 17 That has made some not some analytical sense. That 18 makes analytical sense. 19 I think the one concern that remains is INTERNATIONAL REPORTING INC. CERTIFIED COURT REPO...

AI summary The discussion focuses on concerns regarding the methodology for calculating DR credits and its potential to distort impacts from volatile fuel prices. Reference is made to Nova Scotia Power's past adjustments to their EDLIADC tariff in response to volatility in 2022. The new methodology using forward replacement costs is noted as a positive step, but concerns remain in limited circumstances.

are you what are you referring to? 15 A. (Musco) I would be referring to 16 FAM Audits. 17 Q. Okay. 18 A. (Musco) And potentially any 19 submissions we've made in response to annual ELIADC INTERNATIONAL REPORTING INC. CERTIFIED COURT REPOR...

AI summary The discussion revolves around the use of forward replacement costs in calculating the Decarbonization Deferral Account (ADC) and concerns about potential distortions caused by volatile fuel pricing. The speaker references FAM Audits and submissions related to the ELIADC, suggesting that the proposed ELID may still carry similar risks.

PHP is - depends on what PHP's load is doing relative to the - calculated levelized the CBL. - Q. Okay. And can you explain this - for me? Where the ELIADC under the last six years, it's - not reached benefits of load shifting in the range...

AI summary The discussion revolves around the ELIADC and ELID, with a focus on differences in load shifting benefits between the past six years and projections for 2027. The witness explains that differences in tariffs and lack of evidence on Nova Scotia Power's calculations contribute to discrepancies in the results.

1 shared and, if it should be shared, what that percentage 2 would be? 3 A. (Musco) So we did not suggest a 4 sharing mechanism. We did in a response, I believe, to the 5 Industrial Group respond confirm that a sharing 6 mechanism can have...

AI summary The discussion centers on the allocation of demand response (DR) benefits to PHP, with concerns raised about the accuracy of the DR credit calculation. The witness suggests that if the calculation is accurate, PHP should receive 100% of the benefit, but if there are concerns about accuracy, a sharing mechanism may be considered.

n, we've raised 17 concerns with the calculation of the DR excuse me, DR 18 credit and in our evidence and we did not propose a 19 sharing mechanism. Our focus has been to assist the Board 1 with an understanding of our view of the DR cred...

AI summary The discussion focuses on concerns raised regarding the calculation of the DR credit in the tariff proposal. The recommendation is to not approve the DR credit as currently proposed, and the options for the Board to address these concerns are being explored.

chanism will 17 recognize the value of any dispatchability provided without 18 resulting in payment for credit for the incidental load 19 changes changes in load that have nothing to do with 1 dispatchability. And you know, there is quite...

AI summary The discussion focuses on the dispatchability mechanism and the need for verification of DR credit results through post-facto reviews. The speaker acknowledges the uncertainty in DR credit and emphasizes the need for thorough review and potential revision if adjustments are not justified.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 question? I'm not sure I follow. 2 Q. First, NSPI's position is that the 3 operating procedures don't need to be reviewed or approved 4 by the Board; correct? 5 A. (Musco) That's my...

AI summary The discussion centers on whether the operating procedures related to demand response (DR) and capacity-based load (CBL) calculations should be reviewed and approved by the Board. The witness suggests that without an after-the-fact review, the risk of unreasonable results increases, and the DR mechanism's impact on payments to other FAM customers is significant.

dence was? 16 A. (Musco) Reasonably. Yes. 17 Q. Okay. And to have that 18 confidence, I assume that's what ties back to those cause 19 codes. In order to have confidence that the reason for the 1 dispatch load would relate to what those ca...

AI summary The discussion centers on establishing confidence in the accuracy of dispatch load calculations and the role of cause code tracking in this process. The witness suggests that while cause codes are relevant, they are not the sole factor in ensuring confidence, and understanding how Nova Scotia Power calculates final DR credits is also important.

1 had their rates set on there being a flat load, but an 2 adjustment is made to put them back into the same place as 3 if NSP as if PHP didn't shift its load. 4 A. (Musco) You're describing how it's 5 how the tariff's been proposed and fu...

AI summary The discussion revolves around a proposed tariff adjustment to ensure that other customers are not subsidizing the load shift benefits received by PHP. The adjustment aims to hold other customers harmless from paying for PHP's credit, though the cost will still be accounted for in some manner.

m PHP, which is 16 great. I think it would be it would fill out the record 17 helpfully. 18 I guess I was a little surprised that 19 the P90 value for the 168 megawatts wasn't higher, but I INTERNATIONAL REPORTING INC. CERTIFIED COURT REPO...

AI summary The discussion centers on the P90 value for a 168 megawatt facility and its implications for debt service and rate setting. The speaker acknowledges the engineering estimates and the importance of the P50 value as a best estimate for facility output and capacity.

below in the course of a 17 given year. And it does seem to me that it in the 18 context of setting the right rate, that that symmetry is 19 helpful. It cuts you know, it gives you equal 1 probability of being over or under and it mitigate...

AI summary The discussion revolves around the accuracy of wind generation potential estimates in Nova Scotia, with a concern that a 44% capacity factor seems high based on the speaker's experience, leading to a cautious approach in rate setting.

I N D E X O F P R O C E E D I N G S September 21, 2026 PAGE NO. 3 applied to establish a new above-the-line tariff for Port 4 Hawkesbury Paper, the Extra-Large Industrial Dispatchable 5 Tariff, the ELID. 6 The ELID is the long-awaited succ...

AI summary The document discusses the establishment of a new above-the-line tariff, the Extra-Large Industrial Dispatchable (ELID) Tariff, for Port Hawkesbury Paper (PHP). The ELID replaces the existing Extra-Large Industrial Active Demand Control Tariff and includes unique features such as Dispatchable and Interruptible Riders, as well as an accounting mechanism for output from the Goose Harbour Lake Wind Farm.

OPENING STATEMENT 17 INDUSTRIAL GROUP 1 interruptibility. 17 through the Cost-of-Service Study and the 2026/'27 General 18 Rate Application process. The treatment of Port 19 Hawkesbury Paper as an above-the-line customer, the INTERNATIONAL...

AI summary The Industrial Group discusses the transition from the ELIADC Tariff to an above-the-line structure, emphasizing benefits such as enhanced cost certainty and predictability for customers like Port Hawkesbury Paper. The change is framed as a logical implementation of the regulatory path established through the GRA process.

OPENING STATEMENT 39 NOVA SCOTIA POWER 1 oversight processes already used elsewhere within Nova 12 13 14 15 16 17 18 19 20 As noted in the [Settlement Agreement], for 2026 and 2027, the proposed interruptible credit applicable to PHP is th...

AI summary Nova Scotia Power is proposing an interruptible credit for PHP at a significantly lower rate than its established practice, which would have been $13.107 per kVA demand. The application notes that the proposed credit for 2026 and 2027 is 7.638 and 7.67 per kVA, respectively, and anticipates the ELID interruptible credit will be revisited in the next GRA.

General Rate Application for the test years '26/'27 and applicable to the development of the ELID Tariff for '26/'27 on the understanding that rates that are set through General Rate Application do carry forward until the next General Rate...

AI summary The discussion revolves around the General Rate Application for the test years '26/'27 and the ELID Tariff, with a focus on how rates set through General Rate Applications carry forward until the next application. The conversation also references Nova Scotia Power's reply evidence and an exhibit.

NOVA SCOTIA POWER PANEL 63 Cr-ex, (MacDougall) 1 perspective and position with respect to the 2 interpretation and application of the Settlement 3 Agreement. 4 Q. Okay. Thank you very much, Mr. 5 Ferguson. 6 Gentlemen, I'm now going to mov...

AI summary The proceeding discusses Nova Scotia Power's request for a deferral account related to the PHP (Port Hawkesbury Paper) and the ELID (Extra-Large Industrial Dispatchable) tariff. The deferral account was part of the Settlement Agreement and was intended to address revenue variances between the GRA cost-of-service study assumptions and the final ELID tariff approved by the Board.

meant to do that, to set a rate form that can be relied on as an above-the-line rate going forward, as opposed to saying, "We're going to set a rate today, but one of the key factors, the billing determinant for the 3CP, may be revised and...

AI summary The discussion centers on designing an above-the-line rate for Port Hawkesbury Paper, acknowledging the variability in its load at system peak and the challenge of selecting an appropriate number for cost allocation. Historical data is noted as significantly different from recent data, raising questions about fairness in apportioning generation demand-related costs.

NOVA SCOTIA POWER PANEL 83 Cr-ex, (MacDougall) 1 Yeah, but would you agree that if Q. 2 the Board determined that Port Hawkesbury Paper was 3 correct, that it should be 8 megawatts firm, we wouldn't 4 have that issue? 5 (Ferguson) I'd real...

AI summary The discussion revolves around the Board's determination regarding Port Hawkesbury Paper's demand and the implications of applying a fixed charge model for demand cost recovery. The conversation also touches on the ELID Tariff and moves into a discussion on renewable energy credit valuation.

NOVA SCOTIA POWER PANEL 115 Cr-ex, (MacDougall) 1 correct? 22 certainly areas we differ among parties who are parties to 1 this proceeding, yes. 2 Q. Including PHP. 3 A. (Ferguson) Yes. 4 Q. And what's your explanation for 5 the failure to...

AI summary The text discusses a regulatory proceeding involving Nova Scotia Power and PHP, focusing on disagreements over the implementation of a written tariff and priority interruptibility provisions. The conversation highlights differences in interpretation of a Settlement Agreement and the responsibility of the company to make an application for the tariff.

1 subparagraph (g), again, there are a number of different 2 scenarios in (a) that essentially inject a conditionality 3 into the outcomes of this process. The last one being if 4 PHP determines that PHP, ADC, and tariff processes outcome...

AI summary The discussion explores scenarios under subparagraph (g), focusing on the potential outcomes if the PHP, ADC, and tariff processes are deemed unsatisfactory. The witness, Ferguson, explains that alternatives such as the ELIADC tariff may need to be considered, requiring a reevaluation of its parameters.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 interruptible part. Is that right? So it's not a 2 proportionality? 3 A. (Ferguson) Correct, yeah. The time 4 horizon is different. For the DR, that's the system 5 savings created ac...

AI summary The discussion highlights the difference between demand response (DR) and interruptible service (IR), noting that DR involves system savings across the year, while IR is a tool used by Nova Scotia Power to require load reductions from certain customers within 10 minutes. Concerns are raised about the compensation for interruptible service due to the low frequency of interruptions.

NOVA SCOTIA POWER PANEL 165 Cr-ex, (Powell) 1 THE CHAIR: Sorry; if I could if I could 3 A. (Ferguson) Yes. 4 I'm just seeing if some of my Q. 5 questions have already been answered, so just a moment. 6 (SHORT PAUSE) 7 BY MS. POWELL: 8 I'd...

AI summary The panel is reviewing Exhibit 44, which contains the Opening Statement of Patrick Bowman, focusing on the historical contribution of the PHP at coincident peaks and the customer base line (CBL) discussion. The Chair is confirming if earlier evidence on this topic has already been presented.

NOVA SCOTIA POWER PANEL 169 Cr-ex, (Powell) have a historical base. It's kind of in the middle of what Port Hawkesbury Paper and Mr. Bowman are recommending. It may be more representative of where they'll land, but we'll have a better sens...

AI summary The discussion revolves around the determination of appropriate cost mechanisms for PHP under different tariff scenarios, referencing a Settlement Agreement and the need for regulatory input. The speaker suggests that the current approach is reasonable but acknowledges uncertainty in the final outcome.

NOVA SCOTIA POWER PANEL 183 Cr-ex, (Rudderham) - class like ELID class single customer with highly variable load. - Q. And so when, in this passage, you're referring to the need for formal analysis and expert evidence on the record, am I c...

AI summary The discussion revolves around the need for formal analysis and expert evidence regarding demand assumptions for the Peak Load Program (PHP) and the challenges in determining historical load due to dispatchable impacts. The company has not undertaken this work and emphasizes the necessity of expert input for accurate demand-related cost determination.

customers would carry the cost of that, other above-the- line customers would carry the cost of that. And if it's too high, then PHP would be paying too much of the their share of the costs on the system? A. (Ferguson) Yes. Q. Okay. And ju...

AI summary The discussion centers on the transition of PHP from a below-the-line to an above-the-line rate structure, with implications for cost allocation and the use of historical load data for PHP at 3CP, including considerations of wind generation and telemetry control.

figures that I believe it was Mr. Stanford had answered. That's where you're getting that above the 100? A. (Mowatt) Yes, that's correct. Q. Okay. And for rates that are above- the-line, and they're based on embedded costs, I'm correct in...

AI summary The discussion centers on the methodology for setting rates based on embedded costs and the appropriate load value for demand assumptions. The parties agree that embedded costs should be considered, but there is debate on whether dispatch-down events should influence the load value. A proposed starting point of 65 megawatts is suggested as a reasonable midpoint.

NOVA SCOTIA POWER PANEL 203 Cr-ex, (Rudderham) 1 A. (Willett) I wouldn't necessarily INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 MS. POWER: Do you mind if I just make the 2 point that we're happy to have Ms. Rudderham proceed...

AI summary The proceeding discusses data requests and responses between stakeholders and Nova Scotia Power in 2025, with PHP being modeled as an above-the-line customer in the Cost-of Service Study using the 2026/2027 revenue requirement. The dialogue outlines the context of the application and the settlement process.

PHP being moved to above-the-line. It's a fair summary of what the question is rather than reading them all in? A. (Willett) Yes. Q. Okay. MS. RUDDERHAM: And Mr. Norwood, if you don't mind scrolling down. I'm looking at the, yeah, that ans...

AI summary The discussion centers on the ongoing work by Nova Scotia Power and PHP on a potential above-the-line successor to the ELIADC tariff, focusing on cost-of-service modelling and rate design. The information provided is described as indicative and not final, as it has not yet been fully tested.

NOVA SCOTIA POWER PANEL 221 Cr-ex, (Rudderham) there where it says power factor 90 to 100, 80 to 90, 75 to 80, 70 to 75; correct? A. (Stanford) Yes, that's correct. Q. Okay. Now, power factor corrections, they also apply to other large ind...

AI summary The discussion focuses on power factor corrections within Nova Scotia Power's tariffs, specifically for large industrial rates. The witness confirms that power factor corrections apply to demand charges but notes the need to verify the exact application from the tariff document.

NOVA SCOTIA POWER PANEL 225 Cr-ex, (Rudderham) the system due to the poor power factor of the customer. If it was energy related, then there would have to be additional energy produced to supply that load. Q. So does that mean, and includi...

AI summary The discussion focuses on the rationale behind tying the Power Factor Correction to the energy charge rather than the demand charge under the PHP tariff. Questions are raised about the impact on embedded costs, the fixed nature of the demand charge, and whether an alternative mechanism was considered.

NOVA SCOTIA POWER PANEL 241 Cr-ex, (Rudderham) 1 the system? 2 (Mowatt) As my colleague Mr. Stanford A. 3 noted, that there is some inherent reliability associated 4 with Active Demand Control or dispatchability of PHP, and 5 the fact that...

AI summary The discussion centers on the reliability benefit of Active Demand Control (ADC) and its role in justifying the retention of a priority interruptibility premium in Nova Scotia Power's tariff. While there is no explicit compensation for the reliability benefit, the premium has historical approval from previous Board decisions.

NOVA SCOTIA POWER PANEL 263 Cr-ex, (Rudderham) 1 those three scenarios occur where we have to actually 2 operate that operating reserve, then PHP is targeted first 3 as a priority interruptible service. 4 And is that what occurred on Janua...

AI summary The discussion focuses on the operation of the Peak Load Program (PHP) and its prioritization during power shortages, with reference to the ELID Tariff and the priority interruptible credit. The frequency of such interruptions is noted as rare, with only one occurrence in the last six years. The value of the 10 percent priority interruptible credit is estimated at approximately $500,000 annually.

Q. Yeah. And I guess what I am trying to get at with my questions about the interruptible priority credit, assuming and knowing that Nova Scotia Power cannot act discriminately before or sorry; discriminatively before or to customers, if a...

AI summary The discussion revolves around the interruptible priority credit and its implications for Nova Scotia Power's treatment of customers. Concerns are raised about potential discriminatory practices and the financial burden on other customers who may be funding this credit. The response highlights the need for legislative guidance and the role of the Board's approval of the tariff.

NOVA SCOTIA POWER PANEL 277 Cr-ex, (Rudderham) 1 (Ferguson) Sorry; can you just hold on A. 2 one second? 3 (SHORT PAUSE) 4 MR. FERGUSON: Was your question about 5 five-years notice to move to firm service or to non 6 priority interruptible...

AI summary The discussion revolves around notice periods for service changes and the impact of PHP's potential switch to an above-the-line tariff on NSPI's hedging plans for 2027. The witness explains that if PHP moves to an above-the-line tariff, NSPI will adjust its forecasts and hedging accordingly.

NOVA SCOTIA POWER PANEL 281 Cr-ex, (Rudderham) 1 (Mowatt) Implement the hedges right A. INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 that's in the reply evidence. And perhaps it'd be easier 2 to bring it up. N-38, Exhibit N-38,...

AI summary Nova Scotia Power is discussing a new methodology to quantify the value of load shifting under the ELID Tariff, developed in accordance with a 2022-2023 FAM audit recommendation. The methodology requires Board approval and will be subject to FAM audits. The approach aims to isolate the value of load shifting from price fluctuations.

INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS 1 MS. RUDDERHAM: I am cognizant of the time. 2 It says it's 4:30. I do still have a number of questions. 3 I hope I won't be too long, but if I'm able to continue or 4 if...? 5 THE CHA...

AI summary The discussion focuses on the operating procedures for the Electric Load Incremental Demand (ELID) and whether they require Board approval. The witness confirms that Nova Scotia Power Inc. (NSPI) does not believe approval is needed.

NOVA SCOTIA POWER PANEL 305 Cr-ex, (Rudderham) understanding that there's variances that will arise over time. I understand your point. We'll have to take that into consideration. Q. Are you able to provide as an undertaking the costs asso...

AI summary The discussion centers on the administration costs of the ADC mechanism within the 2027 revenue requirement, with concerns about potential double-counting of costs. The parties acknowledge the need for a thorough analysis of incremental costs to ensure accuracy and avoid duplication.

NOVA SCOTIA POWER PANEL 307 Cr-ex, (Rudderham) 1 MS. RUDDERHAM: And I am cognizant that 2 it's 4:57; it's my last area of questions. I'm happy to 3 continue, but I can see you nodding your head yes? 4 Okay. Bear with me. 5 BY MS. RUDDERHAM...

AI summary The discussion centers on the complexity introduced by wind output from Goose Harbour and the prescribed power agreement, with clarification that PHP is billed based on energy consumed above the contracted amount. The energy charge calculation uses a forecasted net amount, and higher anticipated load leads to lower energy charges, and vice versa.

assumptions for the wind potentially having an impact on that. And so that would need to be examined as part of the potential deferral mechanism that was approved in the GRA. Q. But the deferral mechanism is only recovered from other above...

AI summary The discussion revolves around the deferral mechanism approved in the GRA and its impact on PHP, with clarification that variances would not lead to a true-up on the non-fuel component for PHP. The ELID structure is also discussed, noting that the Goose Harbour treatment is calculated annually rather than matching generation with PHP load hour by hour.