Topic:"Rate Design" in M13007

by energy consumption (MWh) provided to IESO Nova Scotia by the LSEs. The Proposed Mechanism uses a combination of a fixed charge and energy consumption as billing determinants. It applies a fixed charge to LSEs, but the fixed charge is al...

AI summary The Proposed Mechanism introduces a fixed charge for energy consumption based on proportional energy served by utilities, aiming to ensure revenue predictability and stability for the ISO, as costs incurred are generally fixed and evenly distributed throughout the year.

3.5. Collection and True Up True-Up Mechanism this information. Most ISO tariff frameworks include true-up mechanisms to reconcile over- or under-recovery in varies, this solution is less administratively burdensome for the LSEs who will h...

AI summary The section discusses the true-up mechanism within ISO tariff frameworks, which reconciles over- or under-recovery of costs between forecasted and actual expenses, reducing administrative burdens for Load Serving Entities (LSEs).

Revenue stability - Ability to adjust charges to ease volatility in cash flows - Allows for quicker reaction to changes in billing determinants (demand/usage), in internal costs, or exogenous factors (inflation, interest rates, regulations...

AI summary The text discusses revenue stability strategies, including the ability to adjust charges to manage cash flow volatility and the application of cost causation principles. It emphasizes minimizing distortion and administrative complexity, with a focus on selecting a fee recovery mechanism that is flexible and suitable for IESO Nova Scotia's early-stage operations.

13 11 In discussions with LSEs it is recognized that not all LSEs would have a detailed forward looking FY load forecast, and so based on the relatively stable load growth seen in the province that historic actuals from the most recent cal...

AI summary The document discusses the need for a Revenue Requirement Deferral and Variance Mechanism (DVM) to ensure IESO Nova Scotia can recover actual costs incurred, given its not-for-profit status. This mechanism would allow for truing up revenue requirements based on actual loads and account for fiscal year variances, as outlined in the 2026/27 Revenue Requirement application and referenced in FTI's Jurisdictional Report.

e requirement that remain to be collected have been calculated. The Fee - 21 Calculation Model determined the remaining fees proposed to be collected from LSEs based on - 22 the following assumptions: - NSEB approval of IESO Nova Scotia's...

AI summary The document outlines the calculation of remaining revenue requirement fees for LSEs based on assumptions including NSEB approval of IESO Nova Scotia's revenue requirement, interim payments from NSPI, and future true-up options for variances. It references a fee calculation model and provides sample charges for specific entities.

DATE FILED: July 31, 2026 Page 46 of 48 1 7. CONCLUSION IESO Nova Scotia respectfully submits that the Proposed Mechanism is fair, reasonable, and appropriate for approval. It provides a practical and necessary means of recovering IESO Nov...

AI summary IESO Nova Scotia submits that the Proposed Mechanism is fair, reasonable, and appropriate for approval. It provides a means of recovering revenue from market participants, consistent with its statutory mandate and not-for-profit status. The mechanism includes a fixed monthly direct charge to LSEs, with adjustments based on annual load served and true-up processes.

Step 2: Allocation of revenue requirement The revenue requirement is then allocated across the relevant services to determine the MPs that bear these costs. As we discuss in more detail below, these are typically LSEs and large loads conne...

AI summary The revenue requirement is allocated across services, typically borne by LSEs and large loads connected to the transmission network, generation, and intertie traders, which are passed on to end-users. In GB, NESO levies BSUoS on LSEs, who recover these costs from ratepayers. ISOs, except NESO, are non-profit, and specific costs can be charged directly to relevant users.

For LSEs there is a final step consisting of how they recover the ISO costs that they are charged. Each LSE will have its own unique ratemaking process, to determine how its share of the ISO's revenue requirement is recovered from end user...

AI summary The text discusses how Load Serving Entities (LSEs) recover ISO costs from end users through their ratemaking processes, highlighting that some ISO charges, like capacity-based ones, cannot be directly passed through due to non-simultaneity of peak usage. Examples from New England and California are referenced to illustrate this.

Billing determinants Billing determinants are the specific units of service consumption, such as megawatt-hours ("MWh"), megawatts ("MW"), or number of customers, used to calculate charges and determine how a revenue requirement is collect...

AI summary Billing determinants are units of service consumption used to calculate charges and revenue requirements. They can be based on usage (MW or MWh) or fixed charges. Cost reflectivity is a key principle for regulated activities, as export charges can distort efficient trading patterns and shift revenue recovery.

Steps 3 and 4: Set ISO fees and collection and true-up Once step 1, determining the revenue requirement (and associated ISO Core Costs), as well as step 2 to allocate between direct costs and inseparable costs are complete, step 3 will set...

AI summary Steps 3 and 4 involve setting ISO fees for recovering inseparable Core Costs and defining collection and true-up mechanisms. ISOs charge MPs directly for specific services, and true-up mechanisms are necessary due to variations between forecasted and actual Core Costs and billing determinants.

cost driver, such as inseparable ISO Core Costs. However, given the degrees of freedom in choosing the billing determinants and process under this option, we propose a hybrid billing determinant that 28 Load diversity refers to the extent...

AI summary The text discusses a hybrid billing determinant model that combines a fixed charge with energy consumption-based allocation. A monthly fixed charge is proposed, proportional to each Market Participant's annual forecast share of consumption. This approach aims to ensure revenue predictability and stability for the IESO, regardless of seasonal or usage fluctuations.

Ranking Ranking of each of the four options based on the five criteria indicates that a custom Direct Charge to MPs would most effectively recover IESO fees from users of the system, as shown in [Figure 11.](#page-21-0) Figure 11: Ranking...

AI summary The text evaluates four options for recovering IESO fees, concluding that a custom Direct Charge to MPs is most effective. It considers criteria like set-up costs, administrative simplicity, flexibility, revenue stability, and economic principles. A fixed charge offers revenue stability and minimizes behavioral distortions.

Appendix 1: Detailed example of Direct Charge to each MP (Option 2.a.) To provide more detail and explanation on how the monthly charges for a Direct Charge to MPs would work, the figures below provide additional illustration of the recomm...

AI summary This appendix details the structure of monthly charges for Market Participants (MPs) under a Direct Charge mechanism. The charge consists of a base allocation, an allocation adjustment based on forecast vs. actual load share, and a true-up based on forecast vs. actual IESO revenue requirement. The total revenue collected by the IESO is derived from base allocations and true-up amounts, while allocation adjustments net to zero.

Allocation adjustment design The allocation adjustment will resolve any over/under-forecast of MP load share. This provides a similar allocation to a usage-based charge, but without the risk of the IESO over/under-recovering due to unexpec...

AI summary The allocation adjustment design aims to correct over or under-forecasting of MP load share. It adjusts charges based on actual energy consumption relative to forecasts, ensuring fair distribution without the risk of over or under-recovery by the IESO.

Actual load above forecast (undercharged) [Figure 17](#page-28-0) [below](#page-28-0) illustrates an example Year 3 charge for MP1. MP1 was undercharged in Year 2 because its forecast load share was lower than its actual load, so its month...

AI summary The text explains how an MP (Market Participant) was undercharged in Year 2 due to a discrepancy between forecast and actual load share, resulting in a higher monthly bill in Year 3. The base allocation, year 2 adjustment, and year 1 true-up are calculated to determine the final charge.

Option 1: Energy Allocator Options Summ ary ¢/kWh To l B i l l ta $ $ 2 1 2 0. 4 7, 7 2 4 9 2. 0 1 7, 1. 4 % Be low he L ine t 1 0. 1 8 4 0. 0 9 0. 0 0 1 0. 1 2 2 0. 0 1 2 0. 1 8 9 La In du tr ia l rg e s To ta l ( Av ) era g e 9 0. 1 8 9...

AI summary The document presents a detailed breakdown of energy charges and billing calculations under the Domestic Service Tariff (Standard Offer) for 2026 and 2027. It includes customer charges, base fuel costs, non-fuel costs, and various adjustment mechanisms like DSM PCR and FAM BA. The data shows a slight decrease in base fuel costs and an increase in non-fuel costs.

NON-CONFIDENTIAL 19 note there are illustrative true-up and load allocation adjustment calculations in 20 Appendix 3.

AI summary The text notes the presence of illustrative true-up and load allocation adjustment calculations in Appendix 3 of the document.

vig ; Byers, Conleigh ; John Esaiw Subject: [External]RE: Jurisdictional Scan Workshop \ \ \ Exercise Caution - This is an external email - Beware of links or attachments from external sources. If you are unsure, click 'Report Phishing/Rep...

AI summary The email contains six questions posed to FTI Consulting regarding the jurisdictional scan, covering topics such as cost recovery, rate design, stakeholder engagement, and the treatment of core costs by the IESO-NS. The questions focus on prudence, cost allocation, and regulatory processes.

Response IR - 9 a)-c) Please refer to NSEB IR-8. It is too early to speculate on the details of a potential OATT and/or peak-load based fee recovery mechanism. IESO Nova Scotia will complete a fulsome evaluation of the suitability of an OA...

AI summary The response discusses the timing of evaluating an Open Access Transmission Tariff (OATT) and peak-load based fee recovery mechanism, noting that it is premature to speculate on details. It also mentions that IRP and long-term planning costs are included in Transmission O&M costs and that OATT rates are set on a $/MW-month basis.

e) IESO Nova Scotia has not developed a specific load verification procedure, but is amenable to doing so in conversation with the LSEs. Otherwise, IESO Nova Scotia notes that NS Power's load forecast is provided to the NSEB on an annual b...

AI summary IESO Nova Scotia does not have a specific load verification procedure but suggests that the existing process of submitting load forecasts to the NSEB and the corresponding hearing proceedings are sufficient for verifying load data used in the Base Allocation.

2.50 Energy Charges $ 2,823,782.06 $ 2,823,782.06 $ 4,9872.50 Energy Charges $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782.06 $ 2,823,782....

AI summary The text presents a detailed breakdown of energy charges and associated costs for various customer categories, including small general, large general, industrial, and extra large industrial customers. The data includes demand charges, energy charges, and illustrative IESO fees, with percentages indicating changes or variations in costs.

Option 5: SLF for Gen , Demand for Tx Options Summary ¢/kWh DSM PCR ¢/kWh 0.657 0.657 0.000 0.0% 887 kWh 5.83 5.83 5.83 DSM BA ¢/kWh -0.024 -0.024 0.000 0.0% kWh - 0.21 - 0.21 - 0.21 Subtotal 0.633 0.633 0.000 0.0% 5.62 5.62 5.62 SCRR ¢/kW...

AI summary The document outlines a detailed cost breakdown for Option 5, including DSM PCR, SCRR, IESO RR, and fuel and non-fuel related costs, with percentages and kilowatt-hour values. It also includes customer charges and energy charges for the Small General Tariff (Standard Offer).

I recommends that this re-evaluation, including recovery through OATT schedules, form part of its first revenue requirement application after the Phase 2 transition, rather than a separate proceeding. - v. True-up application options, i.e....

AI summary LEI recommends integrating re-evaluation and recovery through OATT schedules into the first revenue requirement application post-Phase 2 transition. It also prefers a two-year lag via annual revenue requirement application for regulatory efficiency and finds the fee calculation methodology reasonable, aligning with cost allocation and rate design principles.

LEI assessment Principles applied Key observations Interim mechanism (Sections 5.2-5.4) Accept the flat monthly fee, allocated Administrative simplicity and transparency Fixed monthly charges recover IESO Nova Scotia's largely fixed costs...

AI summary The document discusses the interim mechanism for cost recovery, including a flat monthly fee allocated to LSEs, granular cost allocation for Phase 2, billing determinants based on MW/MWh, and the recovery mechanism through OATT schedules. It also addresses true-up and fee calculation methodology.

3 Underlying principles for cost allocation and rate design Cost allocation and rate design determine allocation and collection of the revenue requirement among various customer groups. Three broad steps are key to the process: (i) functio...

AI summary This section outlines the principles for cost allocation and rate design, emphasizing financial sustainability, cost allocation between customer groups, and minimizing cross-subsidies. It references the Bonbright framework and various Canadian and US regulatory bodies that have adopted these principles.

4.3 Potential evolution under Phase 2 The MAEA fixes no date for proclaiming the Phase 2 provisions, which come into force only upon proclamation by the Governor in Council. It does, however, require that any ministerial orders transferrin...

AI summary Phase 2 of the More Access to Energy Act (MAEA) will transfer NS Power's operations to IESO Nova Scotia by May 1, 2028, impacting fee recovery and licensing requirements. IESO Nova Scotia will manage the OATT and seek new tariffs from the NSEB, while expanding market participation. The fee recovery mechanism will be re-evaluated once Phase 2 is fully implemented.

5 Reasonableness review for proposed recovery of IESO Nova Scotia's revenue requirement This section assesses the reasonableness of IESO Nova Scotia's fee recovery proposal. Specifically, it presents the results of LEI's review of the foll...

AI summary This section evaluates the reasonableness of IESO Nova Scotia's proposed fee recovery, focusing on components of the revenue requirement, allocation methods, fee structures, recovery mechanisms, true-up application options, and calculation methodologies.

5.1 Revenue requirement components Per the fee recovery application, IESO Nova Scotia is currently responsible for system planning, energy resource procurement, and interconnection functions, but does not yet have operational control of th...

AI summary The document discusses the revenue requirement components for IESO Nova Scotia, highlighting that most costs are fixed and primarily include employee, transition, and IT hardware costs. These costs do not vary significantly with energy throughput, and IESO Nova Scotia's costs are expected to remain fixed even as it assumes additional responsibilities under the MAEA.

5.2 Appropriateness of proposed cost allocation based on load Cost causation is a key underlying principle to be considered when allocating revenue requirement. As discussed earlier in Section [3,](#page-7-0) cost causation holds that the...

AI summary The section discusses the appropriateness of allocating costs based on load, emphasizing cost causation as a key principle. It notes that while MWh load is a reasonable method, the application lacks a detailed cost allocation exercise, unlike other North American ISOs.

In each case, costs are allocated directly to the function or customer class that causes them wherever practicable, with indirect and shared/overhead costs typically allocated based on the resulting direct-cost proportions. This approach a...

AI summary The text discusses cost allocation practices, emphasizing direct allocation to functions or customer classes that cause costs, and notes that IESO Nova Scotia's current limited mandate justifies a less granular approach, but a more detailed allocation may be needed as its responsibilities expand under the MAEA.

Illustrative granular cost allocation methodology Utilizing a granular cost allocation approach, the illustrative steps would be as follows: - Allocate all direct costs to each function, i.e., system planning, energy resource procurement,...

AI summary The text discusses a granular cost allocation methodology, emphasizing the allocation of direct and indirect costs to functions like system planning and energy procurement. It highlights the potential for increased electricity exports in Nova Scotia, such as through the Wind West initiative, and suggests that a granular cost allocation approach should be implemented as soon as IESO Nova Scotia reaches Phase 2 steady state.

(after factoring in Ontario Electricity Rebate) for residential customers. Source: IESO. [Usage Fees](https://www.ieso.ca/corporate-ieso/regulatory-accountability/usage-fees) . Accessed October 2026. 37 IESO Nova Scotia notes that a Renewa...

AI summary The text discusses the implementation of a Renewable to Retail (RtR) Load Serving Entity (LRS) in Nova Scotia, expected to begin operations in December 2026 and reduce NS Power's market share. It also addresses usage-based fees and how they could treat similarly situated customers more equitably compared to current methods. Sources include IESO Nova Scotia and NS Power.

e passed through to the LSEs and their ratepayers. As the OATT already exists, the resulting charges would sit alongside the other transmission-related charges that transmission customers already pay. LEI has also considered the consolidat...

AI summary The document evaluates the appropriateness of the proposed direct invoicing mechanism for recovering transmission costs. It considers alternatives, such as the consolidated direct charge option, but finds that the proposed mechanism is reasonable and administratively simple, despite some stakeholder opposition.

red balance, net of $9.5 million), 0.8% to the Town of Antigonish, 0.4% to Berwick Electric Commission, 0.1% to the Town of Mahone Bay, and 0.1% to Riverport Electric Light Commission.[54](#page-22-1) The recovery timeline at the bottom of...

AI summary The document discusses the fee calculation methodology for recovering revenue requirements, detailing the distribution of fees among various entities and the timeline for interim and final fee recovery. LEI deems the methodology reasonable, citing traceable inputs and proportional allocation of monthly fees among LSEs. NS Power's volumes are aligned with IESO Nova Scotia's fiscal year.

6 Concluding remarks LEI has assessed IESO Nova Scotia's fee recovery mechanism application against the rate design principles set out in Section [3,](#page-7-0) and in light of IESO Nova Scotia's current Phase 1 mandate described in Secti...

AI summary LEI evaluates IESO Nova Scotia's fee recovery mechanism and finds it reasonable as an interim measure. It recommends a granular cost allocation and a billing determinant based on MW or MWh once IESO Nova Scotia's Phase 2 mandate is implemented. LEI also suggests incorporating variances into the revenue requirement application and recommends Option 1 for true-up due to regulatory efficiency.

I. Identification & Qualifications - 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 educatio...

AI summary John D. Wilson, Vice President of Grid Strategies LLC, provides his background, including education and experience in energy and environmental policy, regulatory work with utilities, and expertise in cost-effectiveness, prudency review, and ratemaking.

II. Introduction and Summary - Q: Please summarize the scope of your evidence. - A: My evidence reviews the IESO Nova Scotia proposal for a fee recovery mechanism for costs - related to system planning, energy resource procurement, and int...

AI summary The evidence reviewed evaluates the IESO Nova Scotia fee recovery mechanism for system planning, energy resource procurement, and interconnection functions. It finds the mechanism reasonable except for the true-up process, which is recommended to be revised to align with budget cycles and prudency reviews. A unified proceeding is suggested to ensure timely and equitable cost recovery.

Q: Will a fixed monthly direct charge lead to revenue stability? A: Yes. As discussed by FTI, a fixed monthly direct charge based on the annual revenue requirement would fully recover IESO NS's forecast revenue requirement, regardless of v...

AI summary A fixed monthly direct charge based on the annual revenue requirement would ensure revenue stability for IESO NS, regardless of system usage fluctuations. Monthly adjustments could lead to frequent over- or under-recovery, increasing administrative complexity. Seasonal variations in usage-based fees would require an operating reserve, potentially increasing costs for customers.

Q: Did the IESO NS filings discuss any other options? A: Yes. FTI also discusses allocating all IESO NS costs direct to NS Power, similar to the Efficiency One DSM charge. While even simpler than the LSE charge, it outsources the allocatio...

AI summary The IESO NS filings discussed an option of allocating all IESO NS costs directly to NS Power, similar to the Efficiency One DSM charge. This approach would outsource cost allocation to NS Power's process, adding complexity to its rate case.

Q: What is your recommendation to the Board on the use of a fixed monthly direct charge? - A: I support the IESO NS proposal to use a fixed monthly direct charge to LSEs as the structure for the fee recovery mechanism. - I agree that reven...

AI summary The respondent supports the IESO NS proposal to use a fixed monthly direct charge to LSEs for fee recovery, citing revenue stability and administrative simplicity as key reasons. The recommendation is based on the assumption that IESO NS costs will not vary significantly with load or energy use.

Q: What is the IESO NS proposal for allocation of its revenue requirement to LSEs? - A: IESO NS proposes that the fixed monthly direct charge be allocated to LSEs, who are the only market participants,[8](#page-6-2) based on annual load se...

AI summary The IESO NS proposes allocating a fixed monthly direct charge to LSEs based on annual load served, with a true-up mechanism. This proposal is not based on cost-causation, as economic principles offer limited guidance on selecting a billing determinant.

A. Per-MW Allocation Should Not Be Used - Q: Do you agree with IESO NS and FTI that a demand-based, or per-MW allocation, should not be used? - A: Yes. FTI provides sound reasons against (a) allocating the charge on a per-MW basis and (b)...

AI summary The response agrees with IESO NS and FTI that a per-MW allocation should not be used due to revenue variability and equity concerns. The OATT mechanism is criticized for potential over- or under-recovery of costs, especially in Nova Scotia’s smaller system with less load diversity. Alternative recovery methods, such as direct LSE invoicing, are suggested.

Q: How does IESO NS reach its recommendation in favor of a per-MWh allocation? A: IESO NS explains its recommendation to allocate on the basis of LSE volumetric load served (MWh) as follows: FTI also considered two other key factors when p...

AI summary IESO NS recommends allocating based on LSE volumetric load served (MWh) due to its common usage among benchmarking groups and its stability compared to peak usage (MW), which is important for forecasting in the proposed methodology.

Q: Why does IESO NS require a true-up mechanism? A: The proposed true-up mechanism, or Deferral and Variance Mechanism (DVM), is necessary to ensure accurate revenue recovery. IESO NS's proposed base allocation is straightforward – allocat...

AI summary The IESO NS proposes a true-up mechanism, or Deferral and Variance Mechanism (DVM), to ensure accurate revenue recovery. The mechanism is necessary due to a disconnect between costs and rates, especially during the first half of the fiscal year when fees are not yet approved. True-ups may be needed in years with significant changes in responsibilities, costs, or market shifts.

Q: What is your recommendation for a true-up mechanism? - A: I recommend that the IESO NS recovery fee be updated annually on January 1. This has three advantages: - Assuming IESO NS does, in fact, have "well known" actual costs by mid-Jul...

AI summary The recommendation is to update the IESO NS recovery fee annually on January 1, allowing time for prudence challenges and aligning with retail rate adjustments. This approach avoids further true-up of FY1 costs and facilitates a more convenient schedule for rate changes.

Q: Why is a timely prudency review important? A: The IESO NS proposal to base its fees on the basis of a budget-based test year rather than a historical test year creates the need for a distinctive process for prudency review. Furthermore,...

AI summary A timely prudency review is important because the IESO NS proposal to use a budget-based test year requires a distinctive process. Disallowing cost recovery could create a deficit, necessitating alternative funding sources. A management directive from the Board is an alternative consequence for imprudent actions and must be implemented promptly to prevent repetition of imprudent behavior.

Q: Why might a calendar year fee change be more convenient for retail rate adjustments? A: While I have not conducted a survey of actual practices by all of Nova Scotia's retail electric utilities, it is my general experience that retail r...

AI summary A calendar year fee change is convenient for retail rate adjustments as it aligns with the common practice of implementing rate changes on January 1, simplifying the process of updating IESO NS fee allocations. The Board may also order provisional fees in complex prudence challenges, allowing proceedings to extend beyond December.

t Practices for All-Source Electric Generation Procurement," with Mike O'Boyle, Ron Lehr, and Mark Detsky, Energy Innovation Policy & Technology LLC and Southern Alliance for Clean Energy, April 2020. - "Municipal Coal in Ohio: Implication...

AI summary The text lists various reports and studies related to energy policy, procurement practices, and regulatory matters across different regions and organizations, including Nova Scotia Power, PG&E, and others.

SELECTED PRESENTATIONS - "Clean Energy Solutions for Western North Carolina," presentation to Progress Energy Carolinas WNC Community Energy Advisory Council, February 7, 2008. - "Energy Efficiency: Regulating Cost-Effectiveness," Florida...

AI summary The text lists various presentations and testimonies related to energy efficiency, renewable energy, and utility regulation, primarily in the southeastern United States. These include discussions on cost-effectiveness, integrated resource planning, and energy policy in Florida and the Tennessee Valley Authority region.

lity-installed chargers advance California goal for electric vehicles. Budget controls. Reporting requirements. Evaluation, monitoring and verification processes. Outreach to small business customers. California PUC Docket A.19-08-013, dir...

AI summary The text outlines various regulatory proceedings and expert testimonies across multiple jurisdictions, including California PUC, Georgia PSC, and Nova Scotia UARB, focusing on topics such as rate cases, fuel adjustment mechanisms, avoided cost reviews, and reliability measures for electric service.

Request IR-12: - Reference: 4.2. The Proposed Fee Recovery Mechanism - On pg. 27, IESO Nova Scotia notes that its revenue requirement in a fiscal year will be allocated - to load serving entities based on their proportional forecast load....

AI summary The document raises questions about the Proposed Fee Recovery Mechanism, specifically regarding the level of detail required for load forecasts, the use of historic actuals as a proxy, and methods to minimize adjustments due to load variances.

Request IR-19: - Reference: Appendix 1 ISO Cost Recovery Mechanism Jurisdictional Scan - On pg. 17, FTI states: - Even for LSEs that are levied a usage-based charge (per MWh, which could theoretically be linearly passed through to customer...

AI summary The text discusses the challenges of passing through ISO fees to customers via load serving entities (LSEs), noting that differing customer classes may contribute unevenly to ISO costs. It raises questions about whether any jurisdiction passes ISO Core Costs as a linear usage-based charge and references Ontario's 2026 Interim Usage Fees approved by the Ontario Energy Board.

Request IR-20: - Reference: Appendix 2 IESO Enduring Fee Cost Recovery Recommendation Report - On pdf pg. 5, FTI Consulting lays out four potential fee recovery mechanisms, the first of which is - a new schedule in the Open Access Transmis...

AI summary The text raises a question about whether Nova Scotia Power would pay the full amount of an enduring fee to the IESO and then use its approved Cost of Service methodology to allocate the costs between OATT customers and all other customers, if a new schedule in the Open Access Transmission Tariff were utilized.

1 Request IR-2: 2 Reference: Application, Section 3.2, p. 12, lines 13-15. In future years, IESO Nova Scotia proposes to apply for approval of its fees as part of its revenue requirement applications using the Proposed Mechanism – in that...

AI summary IESO Nova Scotia proposes to combine Step 1 of the fee-setting process with revenue requirement applications. The Board is asked to explain how the fee recovery mechanism would operate if the revenue requirement application is not fully approved and returned with recommendations, including the anticipated timeline for any iterative review and approval process.

1 Request IR-8: - 2 Reference: Application, Section 3.4, p.18, lines 1-7 and Section 4.2, p.27, lines 21-23. - 3 Preamble: The Proposed Mechanism allocates the fixed monthly charge among LSEs - 4 based on each LSE's proportionate share of...

AI summary Request IR-8 seeks analysis on the allocation of fixed monthly charges among LSEs based on annual energy consumption (MWh) rather than peak demand. It asks whether this approach produces different results, confirms the rationale for revenue predictability, and discusses the implications of a fixed charge versus volumetric approaches for LSEs and customers.

21 Request IR-5: 22 23 Regarding both options, please comment on whether carrying costs on over- or under-recovered 24 amounts from FY1 (see p. 31 of the Application) that are incurred in FY2 or FY3 would be (i) 25 fully recovered through...

AI summary The text requests comments on whether carrying costs from FY1 over- or under-recovered amounts, incurred in FY2 or FY3, would be fully recovered through a true-up adjustment or recovered as costs in the respective year through approved fees or true-up adjustments.