Topic:"Rate Design" in M12696

3.0 NS BLOCK DELIVERIES FOLLOWING LIL COMMISSIONING 2 1 345678 9 1112 10 With the LIL's strong performance since its commissioning in April 2023 and the continuing strong availability of the Maritime Link, customers are receiving the full...

AI summary With the LIL's strong performance since commissioning in April 2023, NSPML proposes ending the Holdback as of May 1, 2024, and transitioning oversight to traditional regulatory tools like the Fuel Adjustment Mechanism (FAM) audit and cost assessment processes. Customers have received strong deliveries of the Base NS Block, with a consistent decline in the Deferred Energy balance.

Date Filed: February 3 , 2026 Page 30 of 37 1 8.0 REQUEST FOR RELIEF 26 In setting out the conditions for terminating the Holdback, the Board stated: 27 The Board concludes that the recent short-term NS Block and Make 28 29 up Energy deliv...

AI summary The Board has outlined conditions for terminating the Holdback mechanism, requiring consistent energy delivery performance over 12 consecutive months and a reduction in under-deliveries to reasonable levels. Since the commissioning of the LIL in April 2023, NSPML has been delivering promised benefits, and performance has improved significantly.

1 I. INTRODUCTION - 2 Q1. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. - 3 A1. My name is Danielle S. Powers. My business address is 293 Boston Post Road West, Suite - 4 500, Marlborough, Massachusetts 01752. - 5 Q2. BY WHOM ARE YOU EMPLOY...

AI summary Danielle Powers, CEO of Concentric Energy Advisors, Inc., describes her firm's services in regulatory, economic, and market analysis for energy and utility clients. Concentric provides consulting on wholesale electric market design, generation/transmission planning, and resource planning, with expertise in utility ratemaking and regulatory policy.

5 Q19. WAS THE HOLDBACK MECHANISM DESIGNED AS A HOLD HARMLESS 6 PROVISION? 7 A19. No, that is not my understanding. The Board never referred to the holdback mechanism as 8 a hold harmless provision. In its Decision in M10206 in February of...

AI summary The answer states that the holdback mechanism was not designed as a hold harmless provision. The Board's decision in M10206 mentioned it might ameliorate customer concerns regarding the Maritime Link's benefits.

12 Q20. WAS THE HOLDBACK MECHANISM DESIGNED AS A PENALTY? 13 A20. No, that is not my understanding. The Board never framed the holdback mechanism as a 14 penalty. Rather, the revised holdback mechanism was implemented during a period of ti...

AI summary The holdback mechanism was not designed as a penalty but to address intergenerational equity and incentivize NSPML to collaborate with Nalcor. Extending it beyond underperformance is seen as unreasonably punitive, with no customer harm since LIL commissioning. Emera's investment in Maritime Link considers long-term benefits and risks, with continued holdback adding unexpected risk.

Chart 3: Thermal DAFOR - 1 For the current period, the weighted DAFOR for all thermal units of 26.86% is above the 20.00% near- - 2 term and resource planning analysis values. The individual unit DAFOR outcome for the current period - 3 of...

AI summary Chart 3 presents the weighted DAFOR for all thermal units at 26.86%, which is above the 20.00% near-term and resource planning analysis values. Unit 2 at the Holyrood TGS has a DAFOR of 10.70%, below the 20.00% analysis value, while Units 1 and 3 are discussed in Sections 6.1 and 6.2.

NSPML Responses to Industrial Group Information Requests 1 Request IR-01: 2 3 Reference: N-01 Application, pages 3 and 13 of 37; Appendix D (Concentric Expert 4 Evidence of Danielle S. Powers); 2023 NSUARB 175, para. 95; Decision M11009 (2...

AI summary The document discusses NSPML's response to an information request regarding the definition of 'Good Utility Practice' as outlined in the Board's October 2023 Decision. It references the Joint Operations Agreement (JOA) and Concentric's interpretation, and notes that the Board intentionally left the scope of 'good utility practice or exceptional circumstances' undefined, to be addressed in evidence or argument.

15 The table above shows that in 2023 and 2024 customers received more energy (NS Block Energy 16 plus Make-up Energy) than the Contract amount. This higher energy represents the Deferred 17 Energy that was not redelivered in 2021 and 2022...

AI summary The text discusses the Deferred Energy not redelivered in 2021 and 2022, which was received by customers in 2023 and 2024. By March 2024, the Deferred Energy represented 9% of the annual contracted NS Block, meeting a condition for terminating the holdback mechanism. By June 2024, the balance of undelivered energy was less than 10% of the NS Block annual contracted amount.

NSPML Responses to Small Business Advocate Information Requests 1 Request IR-01: commissioning performance, NSPML does not envision a circumstance or rationale that would support a holdback disallowance as it would not be reflective of any...

AI summary NSPML responds to information requests regarding holdback disallowance, unplanned outages, and financial figures for 2025. It argues that holdback disallowance is not justified unless due to imprudence by NSPML, and outlines the planned distribution of holdback amounts post-May 1, 2024.

11 - 13 Q. For the four months in which deliveries were below threshold, did NSPML claim - 14 that the deficiencies were explained by "good utility practice" and/or "exceptional - 15 circumstances?" 48 NSPML Application, page 10 lines 12 t...

AI summary NSPML claims that deficiencies in NS Block volumes during four months were due to 'good utility practice' and 'exceptional circumstances,' specifically citing a planned LIL outage in July 2023 and other factors related to the LIL's performance, not Muskrat Falls or the Maritime Link.

- Q: Mr. Wilson, please state your name, occupation, and business address. - A: I am John D. Wilson. I am the Vice President of Grid Strategies LLC, Bethesda, MD. - Q: Summarize your professional education and experience. - A: I received a...

AI summary John D. Wilson, Vice President of Grid Strategies LLC, has extensive experience in utility regulation, including testimony in over seventy-five proceedings and work with the Consumer Advocate. He has expertise in cost-effectiveness, prudency reviews, and rate design.

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

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

rid Nova Scotia Project on behalf of the Nova Scotia Consumer Advocate. Cost classification, decommissioning costs, justification for software vendor selection, and suggested changes to project scope. Nova Scotia UARB Matter No. M09499, di...

AI summary Paul Chernick testified in multiple Nova Scotia and California regulatory matters, focusing on cost classification, decommissioning hydroelectric systems, software vendor selection, and project scope changes. Testimonies addressed capital expenditures, dam safety remediation, load forecasting impacts, and EV charging program compliance with state goals.

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

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

ths NSPML has met the requirements in provision (2) and provide a workbook with the data included in the graph shown in Exhibit N-1, p. 14. Request IR-3: With respect to Exhibit N-1, Appendix B, 1. Please explain the reason(s) for under de...

AI summary The document includes a request for NSPML to explain under delivery reasons, provide detailed calculations for holdback amounts, and clarify the causes of LIL outages. It also requests WACC calculations in a workbook format.

le switching” 3. July – October 2024 4. January 2025 5. April 2025 6. September 2025 6. Please provide the WACC calculations in a workbook, with formulas intact. Request IR-4: On p. 6 of Exhibit N-1, NSPML requests that in addition to dist...

AI summary The document requests clarification on NSPML's request for an additional $1.1 million in 'updated WACC consideration' and seeks justification for the delay in applying for a review of the holdback mechanism. It also asks for NSPML’s view on whether this accumulation affects intergenerational equity concerns.

1 2025 M12696 2 3 NOVA SCOTIA ENERGY BOARD 4 5 IN THE MATTER OF: The Public Utilities Act and the Maritime Link Act and the Maritime Link Cost Recovery Process Regulations 6 7 8 IN THE MATTER OF: An Application by NSP Maritime Link Inc. to...

AI summary The document outlines an application by NSP Maritime Link Inc. to end the holdback mechanism as per the Nova Scotia Utility and Review Board's parameters. The Board's October 2023 decision set conditions for termination, including the possibility of relief if 'good utility practice or exceptional circumstances' caused failure to meet the consecutive 12-month requirement.

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

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

29 was essentially eliminated in June 2024. 1 2 highlight any planned or unplanned outages from May 2023 to present that would not meet that definition. 23 from the comparison cost of the Maritime Link. If so, please provide a 24 detailed...

AI summary The text references a reduction in the Deferred Energy balance and requests detailed information on costs related to the Maritime Link, including workpapers and models. It also mentions a penalty and holdback-related disallowances, referencing specific application pages and requests for clarification.

NSPML Application to Review the Holdback Mechanism

AI summary NSPML seeks to review the holdback mechanism, a regulatory process component affecting cost recovery and rate design. The application highlights concerns over its effectiveness and alignment with current energy efficiency and affordability goals.

Undelivered Energy In its Application, NSPML provided a chart showing the Compliance Period NS Block Delivery Levels, which shows the Make-up Balance dropping to 9% in March 2024 7 , and stated: The net balance of Deferred Energy dropped b...

AI summary NSPML provided evidence that the balance of undelivered energy dropped below 10% by March 2024 and was nearly eliminated by June 2024, meeting the Board's threshold for ending the Holdback mechanism. The Small Business Advocate does not challenge this assertion.

LEGISLATIVE FRAMEWORK The Maritime Link Act , SNS 2012, c 9 (the " ML Act "), and the Maritime Link Cost Recovery Process Regulations , NS Reg 189/2012 (the " ML Regulations "), establish an approval mechanism by which NSPML recovers its c...

AI summary The legislative framework outlines the Maritime Link Act and ML Regulations , establishing how NSPML recovers costs from NSPI and ratepayers. The Board has broad jurisdiction and imposed conditions on cost recovery to ensure fairness and consistency, including the Holdback as a customer-protection measure.

y attributable to ML underperformance, to also be required to compensate NSPML with interest on Holdback funds that accumulated because of NSPML's self-inflicted inaction in bringing this Application. It is further worth noting that NSPML...

AI summary The document discusses NSPML's failure to act promptly on the Holdback application, resulting in the accumulation of Holdback funds. It notes that NSPML retained legal counsel in 2024, but the delay was attributed to other priorities. The Board previously allowed WACC on released Holdback funds, but this applies to regulatory delays, not those caused by the party's own inaction.