Topic:"Rate Rider" in M12588

1 Request IR-1: 40 4 Set Up Provincial HST Rebate The bulk vendor (supplier of electricity) will be have the responsibility to provide the provincial rebate to their customers (the LRS in the case of RtR). NSP will not include the HST reba...

AI summary The text discusses the setup of the Provincial HST rebate, where the bulk vendor is responsible for providing the rebate to customers, and the applicability of the Storm Rider described in the 2023 UARB GRA decision to the Distribution Tariff, with charges beginning in 2025.

Active Submissions Total A - Technical Evaluation A-1 - Adherence to RFP requirements A-2 - Ongoing support availability and service levels A-3 - Speed and efficiency of implementation (or project) plan, availability, and delivery the indu...

AI summary The text outlines the structure of an evaluation matrix for submissions, focusing on technical evaluation criteria such as adherence to RFP requirements, ongoing support, implementation speed, and industry expertise. It also includes sections related to corporate risk, including cybersecurity, insurance, and third-party attestation.

1 Request IR-3: 2 and effective date) and confirm what RtR implementation cost data will be included 3 in that initial filing. 4 5 (f) Please confirm whether the 2026 AAR filing will set the initial RtR tariffs based on 6 the amount approv...

AI summary The response to Request IR-3 discusses uncertainty regarding the cost recovery mechanism for the Renewable to Retail (RtR) Implementation Project, particularly in light of the ongoing development of the Independent Energy System Operator Nova Scotia (IESO-NS). Two scenarios are outlined: NS Power recovering costs through RtR Tariffs or transferring the asset to IESO-NS with compensation from Licensed Retail Suppliers (LRS).

Date Filed: March 3, 2026 NSPI (REI) IR-13 Page 3 of 3 1 Request IR-14: D.27 Business Process & Procedure Development Team has finalized process and procedure documentation from a Role Based perspective. Business Leads have all signed off...

AI summary The document outlines several tasks related to the final stages of a project, including the completion of business process documentation, technical development, and testing. These tasks are currently at various stages of completion, with some already finalized and others not yet started.

1.1.1 Customer Transaction Requests To initiate Customer transfers, obtain or provide Customer information, the LRS must complete and submit to NS Power an application form (RtR Customer Transaction Request Application) signed by both the...

AI summary This section outlines the process for LRS to initiate customer transfers and obtain or provide customer information by completing and submitting the RtR Customer Transaction Request Application to NS Power, which is required for various customer transaction types.

2.1 Business Priorities & Objectives - 1. Staff Impact To facilitate the completion of these Customer Information Requests with as small an impact as possible on the Customer Care group and other NSP teams required to fulfill the requests....

AI summary This section outlines key business priorities and objectives related to handling Customer Information Requests, emphasizing minimizing staff impact, controlling development costs, adhering to implementation guidelines, meeting terms and conditions, ensuring privacy compliance, and managing analytics and reporting for RCTRA submissions.

2.3 Options Review Outcome Based on the options available and reviewed by the business stakeholders, it was agreed that a Salesforce web form solution was the most viable approach to collecting RCTRA data from the LRS with the least develo...

AI summary The review of options concluded that a Salesforce web form solution is the most viable approach for collecting RCTRA data from LRS, offering auditability, minimal development, and future reporting opportunities. This method ensures customer consent for data sharing.

3.2.5 Scalability and Future Market Costs [81] Renewall expressed concern that the project included costs for potential future requirements if the renewable to retail market expands, rather than being limited to the immediate market develo...

AI summary Renewall raised concerns about NS Power including scalability costs for future renewable to retail market expansion in its project, arguing that no specific evidence was provided to support these claims. Renewall requested a 'Scalability Costing Protocol' to ensure it is not held responsible for future market entrant costs. NS Power countered that its work was limited to initial operations and did not expand system capacity.

3.3.2 Annual Certification [98] As the (currently) sole licensed retail supplier and party responsible for the payment of costs arising from the approval of the proposed capital project, Renewall submitted that NS Power should be required...

AI summary Renewall proposed that NS Power must file annual certifications to ensure renewable to retail project assets are used appropriately and prevent cost misallocation. NS Power countered that such processes are unnecessary as project costs are tracked separately and subject to Board review in the Annually Adjusted Rates process.

3.4 Cost Recovery [101] The Small Business Advocate also expressed concern about a level of uncertainty around the recovery of these costs from the renewable to retail market. This concern was shared by the Consumer Advocate who noted that...

AI summary The Small Business Advocate and Consumer Advocate raised concerns about the uncertainty of cost recovery from the renewable to retail market, with the latter attributing cost variances to Renewall. Renewall argued that costs should not be tied to a 10-year depreciation life but to actual market use. NS Power plans to propose a cost recovery methodology in its 2027 Annually Adjusted Rates application.

3.4.1 Findings [104] The issues relating to cost recovery are matters for a future Board proceeding. As NS Power noted in this matter, the Nova Scotia Utility and Review Board initially contemplated these issues would be addressed in Annua...

AI summary The Board notes that cost recovery for the renewable to retail market should be addressed in a future proceeding. While the Annually Adjusted Rates process was initially considered, the Board is concerned about its appropriateness due to the complexity of the issues involved. If new mechanisms or tariff language are needed, a separate process may be required.

Request IR-3: Refer to M12588, Exhibit N-1, Page 1 of 6, regarding the recovery of RtR costs over time, please answer the following questions: a) Will the recovery period align with the 10-year depreciation life? If not, please explain why...

AI summary The document requests responses regarding the recovery of RtR costs, alignment with depreciation life, cost structure for future LRSs, and risk mitigation for customer termination before capital recovery.

Request IR-5: Please identify all aspects of the proposed updates and enhancements to existing software solutions, the development of new and enhanced business processes and procedures, and enhancements to technology solutions such as the...

AI summary The document requests the identification of aspects related to software updates, new business processes, and technology enhancements, such as the CIS and MDMS, that could benefit NS Power's customers. It highlights considerations like decarbonization, electrification, and innovative rate designs, referencing the recent general rate application (M12451).

Request IR-7: - NS Power explained that changes to existing software are necessary for customer billing, metering, interval data collection and aggregation, tariff maintenance, etc. Please explain how these software capabilities are differ...

AI summary NS Power is asked to explain the necessity of software changes for customer billing, metering, and tariff maintenance, particularly for the Renewable to Retail (RtR) market, and to detail the updates and their implementation timeline.

Request IR-9: - Please explain how the systems are made scalable and the associated costs of that scalability. - a) Please explain why a scalable system is required. - b) Does NS Power intend to fully recoup the cost of the scalable system...

AI summary The request seeks clarification on the scalability of systems, the rationale for scalability, and whether NS Power intends to recover associated costs from a single LRS or spread them across multiple LRS as the market expands.

Request IR-12: - Please explain why the current reporting tools are insufficient or ineffective to accommodate - customers leaving NS Power's service and moving to RtR?

AI summary The request seeks an explanation for why current reporting tools are inadequate for tracking customers who leave NS Power's service and move to Renewable to Retail (RtR).

30 (a) Please confirm whether NSPI intends to recover all the RtR Implementation 31 Project costs incurred under capital application C0053699 through the AAR 1 process. 2 3 (b) If any portion of the costs will not be recovered through the...

AI summary The text requests confirmation on whether NSPI intends to recover all costs from the RtR Implementation 31 Project through the AAR, and if not, how these costs will be recovered. It also asks for details on the cost recovery framework, legacy costs, and the timing of the first AAR filing.

project cost might be avoided or reduced if NSPI had a modern, cloud-native CIS platform, and if so, please provide that analysis. Reference: M11874, N-4, NSPI (NSUARB) IR 1 Attachment 1, page 4; And Reference: N-1, C0053699 Renewable to R...

AI summary The text raises questions about the increase in AFUDC for NSPI and the methodology used, as well as the scope and processes for change requests in the Renewable to Retail Implementation Project. It also references a Board Order requiring NS Power to engage with interested parties and file an application for new tariffs by April 1, 2026.

5 Request IR-2: 6 7 Please confirm under the Board's decision in M11874, if the RtR market fails, NS Power would 8 expect to recover the outstanding balance of costs associated with this project from its ratepayers. 9 10 (a) Has the licens...

AI summary The request seeks clarification on cost recovery for a project under the Board's decision in M11874, including financial security, recovery forecasts, potential shortfalls, and customer class breakdowns. It also asks how project assets would meet the 'used and useful' test if the RtR market fails.

Submissions In conclusion, the SBA respectfully submits that the Board should consider the remaining gaps in cost transparency and undefined elements of the cost recovery approach. Ensuring that project cost variance are measured, time-rel...

AI summary The SBA submits that the Board should address gaps in cost transparency and undefined elements of the cost recovery approach. It emphasizes the need to measure project cost variances, document time-related impacts, and establish resource mechanisms to protect ratepayers in the RtR framework.

Submissions The Consumer Advocate has reviewed the Application, as well as NS Power's responses to all Information Requests. The Consumer Advocate has also reviewed the Small Business Advocate's submissions, which were filed with the Board...

AI summary The Consumer Advocate reviewed NS Power's Application and the Small Business Advocate's submissions, agreeing with concerns about cost recovery. The variance of $581,816 is attributed to increased administrative overheads and project timeline adjustments due to the LRS' revised COD dates. The Consumer Advocate is concerned about potential cost recovery issues if the LRS is unsuccessful in bearing these costs.

a) Reporting and Business Intelligence Development Costs NSPI states that its reporting tools are not, in themselves, insufficient, but that "the current reporting catalog needs to be enhanced to accommodate the anticipated transactional r...

AI summary NSPI argues that its current reporting tools are insufficient for new tariffs and settlement processes, requiring enhancements. REI acknowledges the need but criticizes the lack of defined outputs and cost alternatives. NSPI plans to deliver encrypted files monthly via SFTP. REI recommends deferring non-essential reporting costs.

3) Cost Recovery Methodology Section 22(2) (previously 3G(2)) of the Electricity Act is the statutory foundation for cost recovery in the RtR program. In responding to IRs, NSPI was unable to provide any clarity on any of: - The cost recov...

AI summary The document discusses the cost recovery methodology for the RtR program under the Electricity Act, highlighting NSPI's inability to clarify key aspects such as cost recovery mechanisms and allocation methodologies. REI argues against tying recovery to a fixed depreciation schedule and emphasizes the need for a methodology based on actual market use. NSPI outlines two scenarios for asset ownership and cost recovery, but uncertainty remains regarding future market developments and their impact on REI's customers.

a) Conditions Precedent to Recovery Approval should be conditioned on data-readiness milestones being satisfied — including AMI restoration, MDMS aggregation capability, and file delivery test completion —before market golive and first inv...

AI summary Approval of the project should be conditioned on NSPI meeting specific data-readiness milestones, such as restoring smart meter readings and achieving interval data aggregation capabilities, before market go-live and first invoice issuance to REI. These milestones should be formalized as conditions of approval, not just projections.

b) Cost Allocation Safeguards and Protection for REI and Non-RtR Ratepayers As the sole LRS and direct payer of the costs approved under this proceeding, REI requires regulatory safeguards ensuring that amounts charged to it are prudent, i...

AI summary REI requests regulatory safeguards to ensure costs allocated to it are prudent and exclusive to RtR implementation, protecting non-RtR ratepayers. Proposed conditions include annual certification, a true-up mechanism, a scalability costing protocol, and a ring-fence for CIS Replacement costs.

Cost Recovery The CA notes that the Application identifies a cost variance of $581,816, which NS Power attributes primarily to the need to ramp up project resources a second time as a result of changes to the Licensed Retail Supplier's (LR...

AI summary The CA notes a cost variance of $581,816 attributed to actions by the LRS, including changes to COD and increased costs. The CA is concerned about the risk of incomplete cost recovery if the LRS fails. The Board's decision in M11874 supports recovery through RtR tariffs, with NS Power planning to implement this in the 2027 AAR filing.

Cost Transparency The SBA notes that, in response to IRs seeking additional detail on project cost changes, NS Power advised that a detailed variance analysis by cost driver could not be provided due to the impacts of the 2025 cyber incide...

AI summary The SBA highlights concerns regarding NS Power's inability to provide a detailed variance analysis due to the 2025 cyber incident and the lack of detailed original ACE Plan estimates. The SBA suggests greater transparency in indirect costs and standardized reporting for schedule changes. NS Power explains that cost increases were primarily due to delayed COD and implemented mitigation measures, but acknowledges the lack of detailed original estimates. NS Power argues that existing processes already provide sufficient reporting on cost and schedule impacts.

Cost Recovery Approach The SBA notes that certain elements of the RtR recovery approach, including the recovery period and recovery mechanism, have not yet been determined and are expected to be addressed in a future filing once market par...

AI summary The SBA requests more clarity on the RtR recovery approach, particularly regarding scenarios where an LRS exits the program and the role of IESONS. NS Power plans to propose recovery mechanisms in the 2027 AAR filing and expects any remaining balance to be handled through general rate applications if needed. NS Power also acknowledges the evolving role of IESO-NS in managing the RtR market and expects cost recovery to remain with market participants.

RESPONSE TO THE SUBMISSONS BY RENEWALL ENERGY INC. The RtR implementation is a complex and non-standard undertaking, involving the development of new systems, processes, and integrations to support an emerging market and a retail supplier...

AI summary The response to Renewall Energy Inc.'s submissions highlights the complexity of implementing the Retail Tariff, noting that delays and cost impacts are harder to isolate due to the project's developmental nature and the evolving business model of the retail supplier.

Reporting and Business Intelligence Development Costs With respect to the reporting and business intelligence workstream, REI acknowledges the need for enhanced reporting to support the RtR market but submits that the scope and cost of the...

AI summary REI argues that the scope and cost of reporting and BI development for the RtR market should be deferred or funded outside this capital item, as it has not been tied to defined minimum functional requirements or assessed against lower-cost alternatives. NS Power disagrees, stating that the workstream is essential for meeting operational requirements and ensuring accuracy in RtR implementation.

MDMS Scalability and Cost Allocation REI notes NS Power's evidence that scalability costs under this project are immaterial and not included to support future LRSs and that any future scalability requirements would be addressed and allocat...

AI summary REI argues that NS Power's claims about MDMS scalability costs being immaterial lack supporting evidence and recommends disallowing certain costs unless NS Power provides documentation. NS Power counters that the project's scope was appropriately scaled to support RtR operations without unnecessary cost exposure and that any future scalability needs would be addressed in a regulatory proceeding.

Cost Recovery Methodology for RtR Implementation REI submits that NS Power has not yet provided clarity on the RtR cost recovery approach, including the recovery mechanism, allocation to future LRSs, which implementation costs would appear...

AI summary REI argues that NS Power has not provided sufficient clarity on the cost recovery approach for the RtR implementation, including how costs will be allocated to future LRSs and recovered through future AAR filings. REI also highlights the need to avoid redundant or stranded costs due to potential market structure changes. NS Power acknowledges uncertainty but asserts that the final recovery mechanism will be determined in the 2027 AAR proceedings.

Proposed Reporting and Approval Conditions REI submits that approval should be conditioned on data readiness milestones, AMI restoration, MDMS aggregation capability, and successful file delivery testing, being met before market go-live an...

AI summary REI proposes conditions for approval of a project, including data readiness milestones, AMI restoration, and testing requirements before market go-live. It also suggests safeguards to ensure charges are prudent and RtR-specific, such as annual certification, true-up mechanisms, and cost allocation protocols.

rements (Phase 2) to meet [Renewall's] expected commercial operation date of November 2024, their expected customer volume, and the potential for additional [licensed retail suppliers] in the market." [34] In response to CA IR-4 [Exhibit N...

AI summary NS Power engaged with Renewall to meet project requirements, including addressing scope changes related to the Large Industrial Interruptible Rider Pilot, Fuel Adjustment Mechanism balance reconciliations, and licensed retail supplier activities. A Board decision in November 2025 addressed some of these changes, and NS Power plans to incorporate any new costs into the project through a change request process.

3.2.6 Customer Information System Replacement Project [88] Renewall noted that NS Power plans to replace its Customer Information System and expressed concern about the potential for rework associated with any of the development undertaken...

AI summary Renewall expressed concern about potential rework in NS Power's Customer Information System replacement project, urging the Board to require an attestation that no renewable to retail functionality is rebuilt or remapped. NS Power stated that core functionality, including renewable to retail features, is typically included in future upgrades and does not anticipate incremental rebuilding.

3.3.2 Annual Certification [98] As the (currently) sole licensed retail supplier and party responsible for the payment of costs arising from the approval of the proposed capital project, Renewall submitted that NS Power should be required...

AI summary Renewall requests that NS Power file an annual certification to ensure project assets are used solely for renewable to retail purposes and that no costs are misallocated. NS Power argues such processes are unnecessary as costs are tracked separately and subject to Board review.

3.4 Cost Recovery [101] The Small Business Advocate also expressed concern about a level of uncertainty around the recovery of these costs from the renewable to retail market. This concern was shared by the Consumer Advocate who noted that...

AI summary The Small Business Advocate and Consumer Advocate raised concerns about cost recovery from the renewable to retail market, attributing variances to Renewall. Renewall argued that costs should not be tied to a 10-year depreciation life but to actual market use. NS Power plans to propose its cost recovery methodology in its 2027 Annually Adjusted Rates application.

3.4.1 Findings [104] The issues relating to cost recovery are matters for a future Board proceeding. As NS Power noted in this matter, the Nova Scotia Utility and Review Board initially contemplated these issues would be addressed in Annua...

AI summary The Board notes that cost recovery issues for renewable to retail market implementation costs should be addressed in future proceedings. While initially planned for Annually Adjusted Rates proceedings, concerns about the appropriateness of this forum have been raised due to the complexity of the issues involved.