Topic:"Rate Rider" in M03632

11 II. Introduction - 12 Q: On whose behalf are you testifying? - 13 A: My testimony is sponsored by the Nova Scotia Consumer Advocate. - 14 Q: What is the purpose of your testimony? - 15 A: I review the basis for the draft tariffs for Com...

AI summary The testimony, sponsored by the Nova Scotia Consumer Advocate, reviews the draft tariffs for Community Feed-In Tariffs (COMFITs) developed by Synapse Energy Economics. It questions how the concept of 'community' was incorporated into cost estimates and compares COMFIT wind project costs with market-based wind projects. The testimony also computes the rate effects of the proposed tariffs under different levels of COMFIT development.

n MP system; historical, current, and projected. Review of MP planning prudence prior to and during excess; efforts to sell capacity. Cost of excess capacity. Recommendations for ratemaking treatment. 63. Massachusetts Division of Insuranc...

AI summary The text outlines various regulatory proceedings involving insurance rates, power sales contracts, and utility ratemaking treatments. It discusses underwriting profit margins, risk assessments, cost recovery for conservation programs, and the evaluation of power sales agreements. These proceedings involve entities such as the Massachusetts Division of Insurance and MDPU, with a focus on financial and regulatory considerations.

CanWEA Submission to Nova Scotia UARB Recommendations on COMFIT Program CanWEA is pleased to have this opportunity to submit written comments to the UARB in response to Synapse's recommended FIT rates for Community wind projects. CanWEA wi...

AI summary CanWEA supports the COMFIT program and recommends expanding eligibility to individual residents and adding a third FIT tranche for mid-sized wind turbines. They argue current restrictions hinder project uptake and limit community choice.

Comments on proposed small wind (<50 kW) COMFIT of 459.90$/MWh CanWEA supports Synapse's proposed small wind FIT rate of 459.90$/MWh as we feel such a rate is within range of providing a 13% IRR for a 50 kW turbine. This rate would allow s...

AI summary CanWEA supports the proposed small wind COMFIT rate of 459.90$/MWh, noting it provides a 13% IRR for 50 kW turbines but expresses concern about the decrease from the previously proposed rate. They request clarification on interconnection fees and note that Synapse's 23% capacity factor assumption is higher than CanWEA's recommended 20%.

Introduction The Alliance of Nova Scotia Sawmillers (ANSS) is a group of forest industry companies that have unified to pursue the common goal of ensuring that there is a COMFIT available for biomass CHP and that the rate set for the COMFI...

AI summary The Alliance of Nova Scotia Sawmillers (ANSS) supports the NSUARB and Synapse's transparent process for determining COMFIT rates for biomass CHP. ANSS seeks to contribute to ensuring fair rates that reflect accurate generation costs and provide a fair return to project proponents.

4. Revenues 4.1. Generation assumption is adequate at 2,628 hours. & lt;sup>1 As of February 5 th , 2011 & lt;sup>2 Please check public reference of Nutbby 45 MW Wind Project cost (2.7million CAD/MW) at http://www.nspower.ca/site-nsp/media...

AI summary The document discusses revenue considerations, including a generation assumption of 2,628 hours and a recommendation for a 25% tariff increase due to inflation, citing examples from Ontario and Spain. A link to a public reference for the Nutbby 45 MW Wind Project is also provided.

revisions, rather than introducing revisions based on the attainment of capacity targets, as the former increases stability and predictability in the market, both for investors and for the Government. - 8. The following paragraphs turn to...

AI summary The text highlights a disparity between <50kW and >50kW tariffs, suggesting it could lead to regulatory arbitrage by encouraging smaller projects to exploit higher rates. This may result in less renewable electricity and higher costs, referencing a similar issue in Spain. The COMFIT wind market is at risk of clustering around the 50kW size, reducing efficiency.

b) remove the system-wide subscription limit of 20 MW as well as the Class 1 limit of 5 MW and the Class 2 limit of 15 MW. - [48] In addition, the Board accepts NSPI's requested day implementation delay in order to provide sufficient time...

AI summary The Board accepts a delay in implementing a decision to remove subscription limits on net metering and requires NSPI to submit annual reports and revised regulations by specific deadlines.

these considerations into account, we selected factors for wind and the other COMFIT's that we believe convert required revenues to rates in a way that will reasonably facilitate project development. The second issue raised was the treatme...

AI summary The document discusses the treatment of year-to-year changes in COMFIT rates, particularly for CHP, and the rationale behind setting fuel payments based on inflation and diesel costs. It also mentions stakeholder input and confidence in the proposed rates.

adjust, the COMFIT program in 2012, to ensure that we learn from our experience and ensure that the objective of supplying 100 MW through community/ small-scale renewable electricity projects is met. Government is proceeding in this manner...

AI summary The COMFIT program in Nova Scotia aims to supply 100 MW through community and small-scale renewable projects. It is designed to ensure that projects are community-rooted and that investment returns stay local. The program addresses challenges with the distribution system by limiting access to eligible community-based participants and setting rates that reflect cost-recovery.

Utility and Review Board (UARB) The UARB already has responsibility for approving cost recovery for renewable energy projects through the setting of electricity rates. Under the Renewable Electricity Plan, it will take on responsibility fo...

AI summary The UARB is responsible for approving cost recovery for renewable energy projects through electricity rates and will also set and periodically review FIT rates under the Renewable Electricity Plan based on government-established criteria.

Opening Statement from E3 Analytics, on behalf of the EAC and NovaSEA. Good afternoon Mr. Chairman, members ofthe panel, and participants in attendance. I have submitted comments to the Board, which you should now have before you. I will m...

AI summary E3 Analytics highlights that the proposed tariffs for renewable energy projects are generally financially viable, but notes challenges for community-based projects in securing initial capital. They also point out a significant disparity between tariffs for projects under and over 50kW, which could lead to regulatory arbitrage and clustering around the 50kW threshold, resulting in inefficiencies and increased land use.

3.0 RENEWABLE ELECTRICITY REGULATIONS [14] Under s. 2 of the Regulations, the "feed-in tariff program" is defined as: "feed-in tariff program" means the program established by Section 4A of the Act under which a public utility permits a ge...

AI summary The document defines the feed-in tariff program under the Renewable Electricity Regulations, specifying that it applies to renewable low-impact electricity generation facilities. The Board is required to set separate tariffs for different classes of generation, including large and small wind, biomass CHP, and run-of-the-river hydroelectricity.

4.2 Findings [34] Based on the Board's review, and the model's universal acceptance by the parties in this proceeding, the Board accepts the adoption of the FIT model to determine COMFIT tariffs in Nova Scotia. [35] A number of intervenors...

AI summary The Board accepts the FIT model to determine COMFIT tariffs in Nova Scotia, based on universal acceptance by the parties. Intervenors provided comments on Synapse's proposed tariffs, but many inputs were accepted without material challenge and incorporated into the model.

5.4 Whether all potential projects should be economically feasible [57] The Board refers again to the general approach adopted by Synapse in developing COMFIT tariffs for the respective classes of electricity generation facilities. Synapse...

AI summary The Board acknowledges Synapse's approach to setting COMFIT tariffs, which balances cost-based rates with fostering project development. It emphasizes that not all projects will be economically feasible under the approved tariffs, as setting higher rates to ensure feasibility would contradict legislative goals of just and reasonable rates and reasonable development activity.

5.5 Consideration of tariffs in other jurisdictions - [61] In assessing whether the proposed COMFIT tariffs are reasonable, Synapse, in addition to considering stakeholder feedback, compared the proposed tariffs "...to FIT prices adopted i...

AI summary The document discusses the comparison of Nova Scotia's proposed COMFIT tariffs with those in other jurisdictions such as Vermont and Ontario. Key differences include eligibility for tax credits, ownership requirements, and project size, which influence tariff levels. The Province supports benchmarking as a necessary approach, despite uncertainties in project cost estimates.

6.2.1 Submissions [71] In developing proposed tariff rates under the COMFIT models, Synapse did not make any specific assumptions about the project ownership. As noted earlier in this Decision, the approach that was adopted was to determin...

AI summary Synapse developed COMFIT tariff rates using a 'typical cost' approach to ensure low tariffs while encouraging development. They considered the impact of ownership structures, particularly cost of capital and income tax treatment, but found the net impact on most resource classes to be small. For certain projects, rates were averaged between taxable and non-taxable assumptions.

[86] This was explored by Keith Tawse, who in his reply argument stated: ...However, in cross-examination, (transcript of Hearings April 7th, 2011, pages 946-947), the Consumer Advocate was unable to provide any evidence as to the existenc...

AI summary Keith Tawse argues that without mechanisms to provide capital for large wind projects at less than market rates, Synapse's proposed rates should be accepted. Toby Couture suggests a return on equity of 13% is reasonable and that current tariffs are sufficient to attract investors.

7.1 Submissions - [92] Synapse proposes a tariff of $139 per MWh for wind projects greater than 50 kW. - [93] This proposed tariff is based on a single turbine 1.5 MW in size. Synapse assumed total project costs of $3.8 Million or $2,520 p...

AI summary Synapse proposes a $139 per MWh tariff for wind projects over 50 kW, based on a 1.5 MW turbine and total project costs of $3.8 million. The proposed tariff assumes a capacity factor of 31%, with contested evidence regarding appropriate capacity factors. Synapse also considered financing assumptions and benchmarked against Vermont and Ontario.

8.2 Findings [130] With respect to the capacity factor, Synapse proposed a rate of 23%. The Board considers Seaforth's comments to be reasonable in terms of supporting the 23% recommendation. Based on its review of the evidence, the Board...

AI summary The Board accepts Seaforth's support for a 23% capacity factor for small wind projects. It adjusts Synapse's interconnection cost from $13,300 to $21,550 based on evidence from Scotian WindFields. The Board also increases Routine O&M costs from $1,642 to $4,500 annually, citing evidence from small wind operators. These changes are to be addressed in the Compliance Filing.

that bests suits their community's context. In order to achieve this, a tariff structure that is more reflective of real economies of scale should be introduced. [E3 Analytics, Exhibit B-14, pp. 6-7] - [137] To remedy this potential proble...

AI summary The document discusses the issue of tariff overlap between small and large wind projects, suggesting that an interpolated rate based on a linear scale between the two would better reflect economies of scale. However, the Province argues that the regulations require setting only one tariff per class of generation facility, not by size.

9.3.1 Findings on Capital Costs [170] The opinion of Mr. Hayes, together with the analysis of costs per MW to construct a full CHP, is indicative that the capital costs for equipment and installation used by Synapse might be too low. Synap...

AI summary The Board questions the accuracy of Synapse's capital cost estimates for a biomass CHP project, noting that Mr. Hayes' analysis suggests they may be too low. While Synapse made adjustments based on intervenor input, the Board prefers a conservative approach to avoid overburdening ratepayers and accepts Synapse's base cost for the tariff calculation.

10.2 Findings [243] While the Board is concerned about the high tidal tariff, it recognizes that this is both an experimental technology and is likely to be a small component of the overall COMFIT program. The Board notes that the Province...

AI summary The Board acknowledges the high tidal tariff but recognizes the experimental nature of the technology and its small role in the COMFIT program. It notes that the Province will review the Regulations in 2012 and plans to review all tariffs in three years. The Board accepts Synapse's capital structure and return recommendation and approves the submitted tariff.

11.1 Submissions [245] For run-of-the-river hydroelectricity Synapse proposed a tariff of $140 per megawatt hour. They based this tariff on a one megawatt project of either penstock or in-river type. At a penstock plant, water is diverted...

AI summary Synapse proposed a $140 per MWh tariff for run-of-the-river hydroelectricity, based on a 1 MW project and considering residual value and O&M costs. They compared it to Vermont and Ontario FIT rates. Mr. Chernick recommended a lower rate of $114 per MWh, adjusting for debt, equity, and tax relief, while noting varying rates in other jurisdictions.

14.0 SUMMARY [277] The Board held a hearing to determine Renewable Energy Community Based Feed-in Tariffs ("COMFIT"), pursuant to recent changes to the Electricity Act and the Renewable Electricity Regulations. [278] While there is no over...

AI summary The Nova Scotia Utility and Review Board held a hearing to determine COMFIT tariffs under the Electricity Act and Renewable Electricity Regulations. The Province expects about 100 MW of distribution grid capacity from COMFIT projects. The Board used a consultative process with Synapse to develop tariffs based on input cost assumptions and a discounted cash flow model.

AVAILABILITY The tariffis available to electricity generating facilities that: - (1) have been approved by the Nova Scotia Department ofEnergy as eligible for this tariff; - (2) are interconnected at distribution voltage level (i.e., less...

AI summary The COMFIT tariff is available to electricity generating facilities that meet specific criteria, including approval by the Nova Scotia Department of Energy, interconnection at distribution voltage, signing a PPA with the utility, and not exceeding the substation transformer's capacity. Real-time data costs are the proponent's responsibility.

Interconnection Costs Included in the Tariff Modeling ($2012) W in d 5 0 k W ≤ W in d 5 0 k W > B io C H P m as s Hy dr o T i da l S d ie tu s $ 0 $ 7, 6 0 0 $ 7, 6 0 0 $ 7, 6 0 0 $ 7, 6 0 0 N S P I Eq ip u $ 1 0, 2 0 0 $ 8 4, 1 0 0 $ 8 4,...

AI summary The document presents a table detailing interconnection costs for various generation types (wind, biomass CHP, hydro, tidal) under the $2012 tariff modeling. It includes costs for different components such as studies, equipment, line extensions, and totals for each category.

• Significant Issues and Ouestion There have been significant changes from the initial draft tariffs circulated by Synapse with respect to Biomass CHP and the final tariff. ANSS and other Intervenors had the opportunity to ask IRs on the i...

AI summary The text discusses concerns raised by ANSS regarding the final biomass CHP tariff, including reliance on outdated data and lack of current evidence supporting financial assumptions. ANSS plans to provide expert evidence on capital costs and financing, while noting insufficient time for review and discussion of Synapse's final model.

s in a very comprehensive and exhaustive manner, considering the difficult task of trying to arrive at average Tariffs that could satisfy a variety of sizes, technologies and applications. - 8 Synapse presented its report to the Board, con...

AI summary The document discusses the UARB's process of determining fair tariffs, noting the difficulty in satisfying all stakeholders. Synapse's proposed tariffs are deemed fair and effective, and the submitter urges the UARB to adopt them without delay.

2. Community-Based Feed-In Tariff ... This plan introduces a Community-Based Feed-In Tariff (COMFIT) to encourage the development of local renewable energy projects by municipalities, First Nations, co-operatives, and non-profit groups.......

AI summary Nova Scotia introduces a Community-Based Feed-In Tariff (COMFIT) to support local renewable energy projects by municipalities, First Nations, co-operatives, and non-profits. Projects will be connected at the distribution level, with eligibility limited to ensure community-rooted investments. The program will be reviewed in 2012 to ensure it meets its goal of supporting 100 MW of community-scale renewable energy.

he steps, to the results of similar ratemaking exercises in other jurisdictions and to other concerns such as interest coverage, using the spreadsheet model and inputs to it discussed in our evidence. Each of the three steps introduces sub...

AI summary The project team acknowledges the uncertainty in balancing costs and policy objectives, referencing similar ratemaking exercises and the need for the Panel to consider this. The COMFIT program is noted for requiring review due to uncertainty in project types and costs. Synapse's approach involved judgment in setting tariffs based on government guidance and a range of possible developer scenarios.

llocating the boiler costs that way that's how we're trying to make sure that electricity sold on the COMFIT Tariff is truly combined heat and power electricity. (Transcript, April 4, 2011, pp.180-82) - 29. The final aspect of the proposed...

AI summary The NSDOE supports adjusting the biomass tariff rate to account for fluctuating fuel costs but opposes the specific fuel adjustment mechanism proposed by the Alliance, citing administrative difficulties and lack of jurisdiction over COMFIT generators.

THE ADVANTAGES OF COMMUNITY ORGANIZATIONS The Consumer Advocate acknowledges that depending on the identity of the potential owner, community organizations may have disadvantages or greater challenges than commercial developers. They may,...

AI summary The Consumer Advocate notes that while community organizations may face challenges such as lack of experience and difficulty in securing financing, they also have advantages like not needing debt financing, as seen with St. Francis Xavier University and potentially municipalities. The Board should consider these factors when setting tariffs.

the community doesn't get behind it, it doesn't seem to me to be a community project and eligible under – at least with the spirit of the community feed-in tariff. [Transcript, p. 815] MR. CHERNICK: One of the big issues in this case which...

AI summary The discussion centers on the definition of a 'community project' under the Community Feed-in Tariff (COMFIT) and its implications for return on investment. Mr. Chernick argues that community projects should have lower returns than market rates if they genuinely benefit the community, while Synapse takes a different view. Mr. Merrick questions whether investors might accept lower returns for community projects.

[Transcript, pp. 926-927] Synapse assumes that community tidal projects would be financed entirely by tidal-technology developer equity, and that those developers should be allowed to earn a very high 15% return, due to the immaturity of t...

AI summary Synapse assumes tidal-technology developers can earn a 15% return on equity, but this is criticized as inconsistent with market realities. Mr. Chernick proposes a $381/MWh rate, which would be the highest globally, and suggests a 3.5 MW cap on tidal capacity under COMFIT to moderate rate impacts.

[Transcript, p. 948] This is a particularly relevant consideration in the difficult circumstances in which the Board has to carry out its instructions. Because of the wide range of potential tariffs, the wide range of requirements of power...

AI summary The Board is advised to take a conservative approach when setting initial COMFIT tariffs due to uncertainties in the market and potential risks of incorrect tariff levels. If initial rates are too low, adjustments can be made later, but overly high rates could lead to long-term consumer harm from excessive costs.

RECOMMENDATIONS It is the submission of the Consumer Advocate that in evaluating the recommended tariffs the Board adopt the lower of any potential tariff levels. The Consumer Advocate further recommends that the tariffs include the follow...

AI summary The Consumer Advocate recommends that the Board adopt the lower of any potential tariff levels and include specific provisions in the tariffs, such as approval from the Energy Minister and compliance with renewable electricity regulations. The Board also set a limit on tidal power under the COMFIT rate to align rate impacts with small wind limitations.

Re: Renewable Energy Community Feed-In Tariffs - BRD-E-R-10/Matter No: M03632 - 1. This is the submission of the Alliance of Nova Scotia Sawmillers ("ANSS"). It focuses on the Tariff to be established by the Nova Scotia Utility and Review...

AI summary The Alliance of Nova Scotia Sawmillers submits that the Tariff for a biomass CHP Facility should be based on cost-based rates rather than least-cost principles, emphasizing the need to consider capital costs, operating costs, debt-equity ratio, internal rate of return, and fuel cost reset mechanisms.

- 66. Synapse appears to assert in its evidence that COMFIT projects are likelier to be riskier than NSPI whose allowed rate of return is at 9.35% (within a range of +/- 25 points) thereby justifying its recommended 13%. These four reasons...

AI summary Synapse argues that COMFIT projects are riskier than NSPI, justifying a higher rate of return. It bases its recommendation on market data and comparisons with other jurisdictions. ANSS challenges Vermont as a weak comparator due to differing incentive structures in the U.S.

Introduction The Ecology Action Centre has acted on behalf of the Nova Scotian environment and population on a wide range of issues for over 40 years. Brennan Vogel (Bachelors Environmental Studies, University of Waterloo; Masters of Arts...

AI summary The Ecology Action Centre (EAC) supports the Community Feed-In Tariff (COMFIT) program but expresses concerns about its potential underperformance and risks. EAC argues that FITs are a better pathway for renewable electricity development and recommends policy clarification. The submission highlights issues with COMFIT and suggests considerations for the Board when setting rates.

Recommendations: - 1. EAC strongly recommends that it is within the scope of the Board and the amended Electricity Regulations to approve the linear interpolation wind tariff model, based on the reasons given through the testimony and evid...

AI summary The EAC recommends that the Board approve a linear interpolation wind tariff model, citing Toby Couture's testimony. They also suggest including multiple baseline points for flexibility in COMFIT wind projects and urge immediate development of the model to make Nova Scotia the first in North America to implement it.

ANSSSTEAM-ONLYARGUMENT In its submission at paragraphs 47 - 52, ANSS disputes Synapse's inclusion in the biomass rate of only the additional costs of a cogeneration system, above the cost of a steam-only system to meet the sawmill's heat r...

AI summary ANSS disputes Synapse's biomass rate model, arguing that it incorrectly allocates steam generation costs. ANSS claims that Synapse only allocates 55% of steam costs to the steam host, not 100% as misrepresented. ANSS also argues that the proposed biomass COMFIT rate is based on an inconsistent hypothetical scenario that violates COMFIT regulations.

No Jurisdiction to Cap Biomass Generation 12. The Consumer Advocate further suggests that if the Board approves a rate of $320/MWh as recommended by the ANSS, the Board should set a cap of no more than 8MW. 1 Decision, NSUARB-P-128.10, 201...

AI summary The Consumer Advocate suggests capping biomass generation at 8MW if the Board approves a $320/MWh rate. However, the Board argues it lacks jurisdiction to impose such a cap, as the Electricity Act and Renewable Electricity Regulations do not grant this power. The COMFIT program is inherently self-limiting, and the Department of Energy has reduced the biomass cap to 350,000 dry tonnes per year.

3.0 RENEWABLE ELECTRICITY REGULATIONS [14] Under s. 2 of the Regulations, the "feed-in tariff program" is defined as: "feed-in tariff program" means the program established by Section 4A of the Act under which a public utility permits a ge...

AI summary The section defines the feed-in tariff program under the Regulations, outlines the types of renewable electricity generation facilities for which the Board must set tariffs, and includes specific classifications such as large wind, small wind, and Biomass CHP. The Board is required to establish separate tariffs for different classes of generation facilities.

bt financing (i.e., universities), or the likelihood that some members of the community may be satisfied with a lower return on equity in return for the provision of renewable energy in the community. [48] In developing proposed tariffs un...

AI summary The document discusses the development of COMFIT tariffs for different resource classes, emphasizing the need for reasonable rates to encourage development activity. Synapse's approach involves creating one tariff per class based on typical project costs and discounted cash flow models, ensuring alignment with the Electricity Act and Public Utilities Act.

5.4 Whether all potential projects should be economically feasible [57] The Board refers again to the general approach adopted by Synapse in developing COMFIT tariffs for the respective classes of electricity generation facilities. Synapse...

AI summary The Board adopts Synapse's approach to setting COMFIT tariffs, balancing cost-based rates with fostering project development. It acknowledges that not all projects will be economically feasible under the proposed tariffs, as setting rates high enough to ensure feasibility would lead to higher rates for ratepayers, conflicting with legislative goals.

5.5 Consideration of tariffs in other jurisdictions - [61] In assessing whether the proposed COMFIT tariffs are reasonable, Synapse, in addition to considering stakeholder feedback, compared the proposed tariffs "...to FIT prices adopted i...

AI summary The document discusses the evaluation of the proposed COMFIT tariffs in Nova Scotia by comparing them to FIT rates in other jurisdictions like Vermont and Ontario. Key differences include tax credits in the U.S., ownership requirements in Vermont, and project size eligibility. The Province supports Synapse's benchmarking approach, emphasizing the importance of considering these differences when assessing tariff reasonableness.

6.2.1 Submissions [71] In developing proposed tariff rates under the COMFIT models, Synapse did not make any specific assumptions about the project ownership. As noted earlier in this Decision, the approach that was adopted was to determin...

AI summary Synapse developed COMFIT tariff rates using a 'typical cost' approach, assuming no specific project ownership. The Board approved this method, but Synapse also considered the impact of different ownership structures on cost of capital and income tax treatment. Taxable and non-taxable project statuses significantly affect COMFIT rates, with larger impacts observed for tidal projects.

the wind developers suggestion and the data assumption used by Hatch. [Synapse Report, Exhibit B-1, p. 23] [97] In terms of benchmarking its proposed tariff, Synapse considered Vermont and Ontario: We have proposed a flat rate of $139 per...

AI summary The document discusses proposed tariff rates for COMFIT projects, comparing them to rates in Vermont and Ontario. Synapse proposes a flat rate of $139 per MWh, citing Ontario's FIT rate of $135 per MWh. The Consumer Advocate recommends a lower rate of $102 per MWh, based on different assumptions including a lower capacity factor.

ration facility. - 47. Indeed, the only distinction based on size set out in the regulations is in s.18(3), which directs the board to set "separate tariffs for wind power with a capacity greater than 50kW and wind power with a capacity of...

AI summary The text discusses the distinction in wind power tariffs based on size, specifically 50kW, as outlined in section 18(3) of the regulations. It emphasizes that this size-based differentiation is intentional and suggests that variable rates based on size are not implied by the broader language in section 18(2).

9.3.1 Findings on Capital Costs [170] The opinion of Mr. Hayes, together with the analysis of costs per MW to construct a full CHP, is indicative that the capital costs for equipment and installation used by Synapse might be too low. Synap...

AI summary The Board found that Synapse's capital cost estimates for a biomass CHP project may be too low, but accepted Synapse's base cost for setting a COMFIT tariff. The Board emphasized the need for more detailed cost comparisons and opted for a conservative approach to avoid burdening ratepayers.

9.7.1 Findings on Fuel Escalator [232] The Board accepts the evidence of ANSS and Mr. Couture that there needs to be a periodic review of the biomass fuel cost. It appears it would be difficult, if not impossible, to finance these projects...

AI summary The Board accepts the need for periodic review of biomass fuel costs and adopts Synapse's index as the escalator. Reviews will occur every second year, using the formula from Undertaking U-11, with adjustments not being automatic. Parties must agree to disclose biomass fuel costs, and no retroactive adjustments will be made.

10.1 Submissions [235] Synapse proposed a tariff of $652 per megawatt hour for in-stream tidal projects. They based this tariff on a 500 kilowatt installation employing one or more instream tidal generators. Synapse assumed total project c...

AI summary Synapse proposed a $652/MWh tariff for in-stream tidal projects, citing high costs and technology immaturity. The Consumer Advocate suggested a lower rate of $398/MWh. Mr. Couture supported the higher rate but raised concerns about uncertainties in tidal power. The Province suggested tariff degression and deferred detailed consideration to future reviews.

10.2 Findings [243] While the Board is concerned about the high tidal tariff, it recognizes that this is both an experimental technology and is likely to be a small component of the overall COMFIT program. The Board notes that the Province...

AI summary The Board acknowledges the high tidal tariff but accepts it due to the experimental nature of the technology and its small role in the COMFIT program. It notes that a review of the Regulations will occur in 2012 and that all tariffs will be reviewed in three years. The Board approves the tariff as submitted by Synapse.

11.1 Submissions [245] For run-of-the-river hydroelectricity Synapse proposed a tariff of $140 per megawatt hour. They based this tariff on a one megawatt project of either penstock or in-river type. At a penstock plant, water is diverted...

AI summary Synapse proposed a $140 per MWh tariff for run-of-the-river hydroelectricity, based on a one-megawatt project. They compared this to Vermont and Ontario FIT rates, noting that Ontario's community-based rate in 2012 was $140 per MWh. Mr. Chernick recommended a lower rate of $114 per MWh, adjusting for debt, equity, and land donation factors.

12.3 Terms and Conditions of COMFIT tariffs - [261] In determining the terms and conditions for the various COMFIT tariffs, the Board considers s. 4A(3) and (4) of the Act to be instructive: - 4A(3) In setting a tariff pursuant to this Sec...

AI summary This section outlines the terms and conditions for COMFIT tariffs, referencing section 4A(3) and (4) of the Act. It specifies that the Board must consider regulations, determine qualifying generation classes, adjustment mechanisms, effective dates, duration, and payment terms for generators.

[262] In its Closing Submission, the CA stated: The Consumer Advocate further recommends that the tariffs include the following express provisions that are to be met by the project. - Approval from the Energy Minister. - The requirements o...

AI summary The Consumer Advocate recommends that tariffs include provisions such as approval from the Energy Minister and compliance with Renewable Electricity Regulations. The Board also set a limit on tidal power allowed on the COMFIT rate to manage rate impacts similarly to the small wind limitation.

14.0 SUMMARY [277] The Board held a hearing to determine Renewable Energy Community Based Feed-in Tariffs ("COMFIT"), pursuant to recent changes to the Electricity Act and the Renewable Electricity Regulations. [278] While there is no over...

AI summary The Board conducted a hearing to determine COMFIT tariffs under the Electricity Act and Renewable Electricity Regulations. The Province expects COMFIT projects to use about 100 MW of grid capacity. Synapse used a FIT model to calculate tariffs that provide a reasonable return on equity for project owners, and the methodology was generally well-received by intervenors.

AVAILABILITY The tariff is available to electricity generating facilities that: - (1) have been approved by the Nova Scotia Department ofEnergy as eligible for this tariff; - (2) are interconnected at distribution voltage level (i.e., less...

AI summary The tariff is available to electricity generating facilities that meet specific criteria, including approval by the Nova Scotia Department of Energy, interconnection at distribution voltage level, signing a PPA with the utility, and not exceeding the minimum load on the substations serving the feeder.

AVAILABILITY The tariff is available to electricity generating facilities that: - (1) have been approved by the Nova Scotia Department ofEnergy as eligible for this tariff; - (2) are interconnected at distribution voltage level (i.e., less...

AI summary The tariff is available to electricity generating facilities that meet specific criteria, including approval by the Nova Scotia Department of Energy, interconnection at distribution voltage level, signing a PPA with the utility, and not exceeding the minimum load on the substations serving the feeder.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS fact to inquire about? When size of the project is a risk 1 NSUARB-BRD-E-R.10 Page 201 factor, would you not inquire about the size of the 18 adjustments in the rates or in other things in or...

AI summary The discussion revolves around adjusting rates, specifically the COMFIT rate, to ensure the project meets its 100 megawatts target. It also explores the possibility of a reopener mechanism to address fuel price risks, similar to the NSPI NewPage project, to mitigate financial uncertainties.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS So if someone has a field of four 12 1 NSUARB-BRD-E-R.10 Page 449 and a half kilowatts is that or let's say a field of 1 this, but I'm not going to get you back, so I was going to 2 ask you t...

AI summary The discussion revolves around rate-setting for different technologies, considering the implications of full tariff differentiation and linear interpolation, which could lead to a large number of specific rates. The participants also address the interpretation of regulations and potential policy solutions to limit arbitrage after the rate-setting process.

money into these projects. We need a few. 1 of the questions that went to you know, this particular 21 at in after a period of time to see how they've 22 operated. DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS NSUARB-BRD-E-R.10 Page 475 1...

AI summary The discussion revolves around the need to periodically review and adjust rates, particularly for technologies like tidal energy, to ensure they remain effective and aligned with program goals such as investor security. There is a suggestion that all rates should be reviewed after a certain period of time.

- administrative burden. Page 486 NSUARB-BRD-E-R.10 1 MR. DEVEAU: Okay. Now, going back to 2 (b) for a minute: 3 "whether a tariff is to be 4 adjusted periodically and where 5 it is to be adjusted, the basis 6 for the adjustment." 7 We've...

AI summary The discussion revolves around periodic tariff adjustments, including potential triggers such as reviews or automatic adjustments based on schedules, time intervals, capacity thresholds, or technology experience curves. The example of Germany's feed-in tariff for solar is cited as a reference.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS set by the Board; is that possible the way you see it? 1 NSUARB-BRD-E-R.10 Page 549 MR. TRAVIS: Well, no. I mean, we 9 has suggested. So by that it would be a and like a 10 reopener, as an ex...

AI summary The discussion revolves around the Community Feed-in Tariff (COMFIT) and the suggestion to adjust rates based on market conditions, such as changes in the price of wood fibre and biomass, during reopener events every two years.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS businesses are here and employ people here and are 1 resident of Nova Scotia. I'm sorry, in that way I was 9 We see this often in our business 10 where people approach us and say, "We've got...

AI summary The text discusses a rate proposal with a FIT tariff of $320, which is significantly higher than the average generation cost. It also references a PPA and challenges related to capital costs and project feasibility.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS pressure and steam loads and those kind of things. If the 1 NSUARB-BRD-E-R.10 Page 759 Board would like, we have someone in the room who can 18 if it requires a 13 percent or 15 percent or do...

AI summary The testimony discusses the calculation of a required tariff level to achieve a 13% rate of return on investment, based on assumptions provided by Synapse and an analysis from CBCL. The discussion includes the capital costs and the necessary rate per kilowatt hour.

- approach of doing that sort of thing, but I doubt that the - efficiencies are so great that it's going to run away with - the system. - And again, if some CEDIF or - municipality or other eligible party applies for a large - number of th...

AI summary The discussion addresses concerns about the efficiency of a system and the potential for government intervention if certain parties apply for limited slots. It also touches on the tidal tariff and the suggested changes by E3 Analytics to shorten its duration for prudency, with a response indicating concern about higher rates if the project life is assumed to be shorter.

- DICTUM DIGITAL INC. CERTIFIED COURT REPORTERS MR. COUTURE: My understanding is that 1 NSUARB-BRD-E-R.10 Page 1195 as it's currently structured the policy will be reviewed 2 every 18 months. 3 THE CHAIR: No, but how often the 4 adjustment...

AI summary The discussion revolves around the frequency of reviewing a policy, with suggestions of quarterly or annual reviews. Environmental concerns regarding excessive extraction of forest biomass for electricity generation are also raised, suggesting potential adjustments to the policy to prevent inefficient allocation of resources.