Topic:"Rate Rider" in M12661

Nova Scotia Energy Board IN THE MATTER OF The Public Utilities Act, R.S.N.S. 1989, c.380, as amended Nova Scotia Power Application for Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper December 29, 2025 NON-CONFIDENT...

AI summary Nova Scotia Power is seeking approval for an Above-the-Line Tariff for Port Hawkesbury Paper under the Public Utilities Act. The proceeding involves regulatory review of the proposed tariff structure.

1.0 INTRODUCTION - Nova Scotia Power Inc. (NS Power, Company) is applying to the Nova Scotia Energy Board - (NSEB, Board) for approval of the Extra Large Industrial Dispatchable (ELID) Tariff, an above- - the-line (ATL) tariff available to...

AI summary Nova Scotia Power Inc. (NS Power) seeks approval for the Extra Large Industrial Dispatchable (ELID) Tariff to serve Port Hawkesbury Paper LP (PHP), replacing the expiring ELIADC Tariff. The ELID Tariff includes a Dispatchable Rider (DR) to manage PHP's load flexibility, with a Customer Charge for cost recovery. The application references the 2026-2027 General Rate Application (M12451) and its Settlement Agreement.

2.0 TARIFF COMPONENTS Key elements of the ELID Tariff, provided as Attachment 1 to this Application, include the following: • Customer Charge • Demand Charge • Energy Charge • Interruptible Service • Dispatchable Rider • Other Applicable R...

AI summary The ELID Tariff's Customer Charge recovers costs for dispatch services and tariff administration, including tasks like operating procedure development, PHP engagement, and real-time load optimization. The proposed $10,000 monthly charge for 2026-2027 is based on staff and software costs, with future GRA proceedings determining the final rate.

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

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

2.3 Energy Charge - The Energy Charge under the ELID Tariff will apply to all energy supplied to PHP in excess of - the Subject Energy Amount1F 2 deemed to be provided pursuant to the Power Sales Agreement issued - under Section 4AA (now S...

AI summary The Energy Charge under the ELID Tariff applies to PHP's energy consumption beyond the Subject Energy Amount, with proposed rates of 9.977 cents/kWh (2026) and 11.240 cents/kWh (2027). These rates consider embedded costs, energy displacement from the Goose Harbour Lake Wind Farm, and are subject to ongoing court proceedings regarding PHP's liability for the Maritime Link FLG2.

2.4 Interruptible Service The ELID Tariff interruptible service provisions, for the most part, adopt the LI Interruptible Rider (LIIR) terms with minor text updates drawn from the ELIADC Tariff interruptible service provisions. With respec...

AI summary The ELID Tariff's interruptible service provisions largely adopt the LIIR terms with minor updates from the ELIADC Tariff. The SA sets the interruptible credit for PHP at significantly lower rates than the Company's standard practice. Priority interruptible service is valued for reducing interruption risks and system reliability benefits, and NS Power proposes maintaining it until the next GRA.

2.5 Dispatchable Rider - The Dispatchable Rider (DR) will allow PHP to operate in a manner which reduces PHP's - individual cost of service, enables NS Power to manage PHP's load in response to system - conditions, reducing overall system...

AI summary The Dispatchable Rider (DR) enables PHP Wind Ltd to reduce its operational costs while allowing NS Power to manage PHP's load for system efficiency. It compensates PHP for load flexibility and shields ATL customers from PHP's potential cost impacts. The DR incentivizes non-levelized load profiles for optimal system performance.

2.10 PHP Deferral The GRA Settlement Agreement provides: NS Power may seek Board approval for a deferral account to account for any NS Power revenue variances that may arise in 2026 or 2027 from the following scenarios, which costs would b...

AI summary The GRA Settlement Agreement allows NS Power to request Board approval for a deferral account to address revenue variances in 2026-2027 arising from PHP tariff decisions, unavailability of the tariff, or unsatisfactory ADC/tariff outcomes. The deferral accounts for fixed cost recovery assumptions and potential variances in service costs, billing models, and Board-approved riders.

5.0 RELIEF SOUGHT - The Company requests Board Approval of the Extra Large Industrial Dispatchable Tariff as - provided in Attachment 1. Considering the development of this Tariff uses well-established costing - and pricing processes appli...

AI summary NS Power requests Board approval for the Extra Large Industrial Dispatchable Tariff, citing established processes and prior interruptibility provisions. They seek a paper process for the application, emphasizing alignment with existing Large Industrial class costing methods.

Extra Large Industrial Dispatchable Tariff Application – Attachment 1

AI summary This document outlines an application for an Extra Large Industrial Dispatchable (ELID) Tariff, potentially involving cost recovery mechanisms, regulatory approval processes, and related programs. It may address rate design, energy efficiency initiatives, and compliance with Nova Scotia energy regulations.

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

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

Recognizing that the Customer demand will be determined by the Company and the Customer working collaboratively to actively manage the Customer's demand in response to system load conditions, particularly during peak periods, and to reduce...

AI summary The text outlines how customer demand will be collaboratively managed with the company to reduce costs during peak periods. The monthly demand charge is set through regulatory proceedings and remains constant until revised by the Board.

DSM COST RECOVERY RIDER The Demand Side Management Cost Recovery charge (in cents per kilowatt-hour) applicable to the Tariff for the current rate year, shown in the Demand Side Management Cost Recovery Rider, shall apply, in addition to t...

AI summary The Demand Side Management Cost Recovery Rider imposes a charge (in cents per kilowatt-hour) on the Tariff for the current rate year, in addition to the Energy Charge. This charge is part of the regulatory framework for recovering DSM-related costs.

STORM COST RECOVERY RIDER Storm Cost Recovery charges or credits (in cents per kilowatt-hour) applicable to the Tariff for the current rate year, shown in the Storm Cost Recovery Rider, shall apply, in addition to the Energy Charge. (25,00...

AI summary The Storm Cost Recovery Rider introduces additional charges or credits (in cents per kilowatt-hour) applied to the Energy Charge in the Tariff for the current rate year. Rate Code X is specified for customers with 25,000 kVA and over, indicating a tiered structure for storm-related cost recovery.

PAYMENT FREQUENCY NS Power shall invoice PHP weekly, and PHP shall pay the billed amount net 7 days.

AI summary NS Power is required to invoice PHP weekly, with PHP paying the billed amount net 7 days. This establishes a specific payment schedule between the parties involved.

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

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

ELID Interruptible Rider Credit Reduction per kilovolt ampere reduction in demand charge Effective January 1, 2026 $7.638 Effective January 1, 2027 $7.667 Availability

AI summary The document outlines the ELID Interruptible Rider Credit, providing the reduction per kilovolt-ampere reduction in demand charge for the years 2026 and 2027. It also mentions the availability of this rider.

Where: - "A" is any residual customer demand (above that required by the interruption notice) remaining in the third interval directly following two complete 5-minute intervals after the interruption call is initiated and sent by NS Power....

AI summary The text defines terms for a service rider, including residual customer demand ('A'), average demand ('B'), and penalty limits. It outlines procedures for converting between interruptible and firm service, requiring 5-year advance notice for firm service and allowing early conversion. Interruption is capped at 16 hours/day, 5 days/week, with annual limits.

Special Conditions (1) The Company reserves the right to have a separate service agreement if in the opinion of the Company, issues not specifically set out herein must be addressed for the ongoing benefit of the Company and its customers....

AI summary The Company reserves the right to impose separate service agreements if necessary for system integrity. The Customer must ensure their load does not harm the power supply system through design or operation, with specific requirements outlined in a written agreement. Factors like reliability, harmonic levels, and voltage flicker are considered when assessing potential system integrity risks.

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

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

2026-2027 General Rate Application Settlement Agreement Extra Large Industrial Dispatchable Tariff Application – Attachment 4 Page 2 of 21 - 1. The Parties have reached agreement on the outcomes that will result from the 2026- 2027 GRA as...

AI summary The Parties agree on the 2026-2027 GRA outcomes outlined in Schedule A, with NS Power to file the GRA with NSEB consistent with the Settlement Agreement. Customer Representatives may request information if the GRA deviates from the agreement. A Pre-GRA Letter detailing the collaborative process will be filed prior to GRA submission.

Terms of Settlement It is acknowledged that, subject to Board approvals, rate increases other than those identified herein may occur prior to the effective date of the next general rate application in the form of Board-approved riders. Rec...

AI summary The document outlines terms of a settlement where NS Power acknowledges that rate increases, other than those specified, may occur before the next general rate application. NS Power will support efforts to smooth or mitigate the impact of rate changes for the 2026-2027 test period, particularly regarding the 2026 FAM AA/BA for large and medium industrial classes.

2026-2027 General Rate Application Settlement Agreement Extra Large Industrial Dispatchable Tariff Application – Attachment 4 Page 10 of 21 GRA Element Settlement Terms Storm Cost Recovery Rider a) The Storm Cost Recovery Rider will be imp...

AI summary The Storm Cost Recovery Rider will be implemented on a pilot basis for 2026 and 2027, with costs during these years eligible for the rider. It will not be implemented permanently as initially proposed, and there is a threshold for making an application to return an amount.

APPLICABILITY This schedule applies to all electric rate classes with the exception of the Wholesale Market Non-Dispatchable Supplier Spill Tariff, the Load Retention Tariff, and the Extra Large Industrial Active Demand Control Tariff. For...

AI summary This schedule applies to all electric rate classes except specific tariffs. Cost recovery for electricity efficiency and conservation activities, as defined in Section 79A of the Public Utilities Act, is direct billed to customers in Wholesale or Renewable to Retail markets, mimicking NS Power's bundled service offerings.

RESPONSIBILITIES OF FRANCHISE HOLDER It is the responsibility of the holder of the electric efficiency and conservation franchise granted under Section 79C of the Public Utilities Act (Franchise Holder) to apply to the Nova Scotia Utility...

AI summary The Franchise Holder must apply to NSUAREB for approval of all DSM activities, plans, and programs, including itemizing related costs. NS Power is required to seek annual approval for DSM Cost Recovery Rider amounts by October 1 and remit monthly payments to fund approved DSM costs.

DEMAND SIDE MANAGEMENT COST RECOVERY RIDER (DCRR) The monthly amount computed under each of the rate schedules to which this DSM Cost Recovery Rider is applicable shall be increased or decreased by the DCRR at a class-specific rate per kil...

AI summary The Demand Side Management Cost Recovery Rider (DCRR) adjusts monthly charges under applicable rate schedules using a class-specific rate formula (DCRR = PCR + BA), reflecting cost recovery mechanisms for demand-side management initiatives.

DEMAND SIDE MANAGEMENT COST RECOVERY RIDER (DCRR) Page 3 of 5 Applicable Tariff PCR (cents per kWh) BA (cents per kWh) DCRR (cents per kWh) Domestic Service, Domestic Service Time-of-Day, Domestic Service Time-of-Use, Domestic Service Crit...

AI summary The document outlines the Demand Side Management Cost Recovery Rider (DCRR) with various applicable tariffs and associated rates, including Program Cost Recovery (PCR) and Balance Adjustment (BA) for different service categories. The table provides specific monetary values per kWh for each category.

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

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

The ELID Energy Charge will apply to all delivered energy to PHP in excess of the subject Energy Amount deemed to have been provided, pursuant to the Power Sales Agreement issued under section 4 AA of the Electricity Act. 7 Energy credit w...

AI summary The ELID Energy Charge applies to excess energy delivered to PHP beyond a specified amount, with energy credits estimated annually. The ELID Demand Charge is based on a 'PHP demand determinant' set during the GRA process or other proceedings, with a stated demand price of $14.31/KVA-month in 2027. NS Power designates this as a 'fixed charge,' distinguishing it from other demand charges. The ELID Interruptible Service and Credit terms are similar to LIIR but with a 10% premium for PHP due to priority interruption.

15 Q HOW WILL NS POWER PROPOSE TO PASS ON THE BENEFITS OF THE DR AND 16 INTERRUPTIBLE SERVICE TO PHP? 17 A There will be two credits made to PHP cost of service. First, NS Power will provide a 18 billing determinant demand charge credit eq...

AI summary NS Power proposes passing benefits of DR and interruptible service to PHP via two credits: a demand charge credit (matching LIIR interruptible rates plus a 10% premium) and a power supply credit based on modeled savings from dispatching PHP load during high-cost periods. This reduces NS Power's supply costs, benefiting PHP while maintaining costs for ATL customers.

8 Q DO YOU AGREE WITH NS POWER THAT THE ELID IS STRUCTURED TO CREDIT 9 TO PHP ALL COST SAVINGS CREATED BY NS POWER'S ABILITY TO DISPATCH 10 PHP'S FLEXIBLE LOAD? 11 A No. We do not dispute the lower power supply benefits that can be realize...

AI summary The Board disagrees with NS Power's assertion that the ELID tariff fully credits PHP for all cost savings from dispatching PHP's flexible load. It argues the ELID design unfairly allocates non-fuel interruptible benefits and that PHP incurs production delays and increased operating costs due to the dispatching terms.

9 Q IS NS POWER'S PROPOSED ELID TARIFF RATE REASONABLE? 10 A. No. NS Power's proposed ELID capacity charge and interruptible credit are 11 imbalanced and overcharge PHP for its cost of providing service to PHP. The ELID 12 Tariff pricing s...

AI summary The answer states NS Power's proposed ELID tariff rate is unreasonable due to imbalanced capacity charges and interruptible credits that overcharge PHP. The ELID Tariff pricing requires modification to address these issues.

13 Q WHAT ARE THE RATE IMPLICATIONS FOR PHP IF THE BOARD ACCEPTS YOUR 14 PROPOSED WINTER MONTH SYSTEM COINCIDENT DEMAND FOR PHP? 15 A NS Power provided an updated COSS for 2026 and 2027 based on a reduction in 16 PHP's total demand coincid...

AI summary If the Board accepts PHP's proposed winter demand reduction from 65 MW to 8 MW, PHP's rates would decrease by $6.5M in 2026 and $9.4M in 2027. This aligns with cost causation principles, which NS Power's Application 2 fails to address adequately.

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

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

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

AI summary Nova Scotia Power Incorporated has applied for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper LP under the Public Utilities Act. The proceeding involves direct evidence submitted by Port Hawkesbury Paper LP.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 Please refer to Exhibit N-1, section 2.1 and Attachment 3. 4 5 (a) Why did NSPI select the "low range" of costs as the basis for calculating the Customer 6 Charge? 7 8 (b) If the actual costs to adminis...

AI summary NSPI explains its use of a conservative 'low range' cost estimate for the ELID Tariff Customer Charge, citing high-level forecasts and pending Board approval. The charge will be set via General Rate Applications (GRA), not adjusted to actual results, with future refinements dependent on Board approval and data availability.

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

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

NSPI Responses to BW Information Requests 1 Request IR-9: 2 3 Please refer to Exhibit N-1, page 10 lines 5-7 and section 2.5. 4 5 (a) Please identify "the cost of providing DR service" that "is borne by PHP." Is this a 6 reference to the C...

AI summary NSPI responds to BW's information requests regarding the ELID Tariff, addressing dispatch instructions, cost allocation, enforcement mechanisms, and exogenous factors affecting PHP's consumption. Questions focus on cost recovery, dispatchability, and tariff compliance.

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

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

NON-CONFIDENTIAL 1 c) The dollar value of the Interruptible credit to be applicable to 2 PHP's interruptible load shall be the same as the credit for Large 3 Industrial Interruptible customers , plus the value of priority 4 interruption se...

AI summary The document outlines the calculation of the Interruptible credit for Port Hawkesbury Paper (PHP), aligning it with the Large Industrial Interruptible Rider (LIIR) credit plus an additional 10% for priority interruption service. It explains that the LIIR credit is based on forecasted demand and billing practices, differing from the company's established pricing method, with reference to M12451 2026-2027 GRA SR-01 Attachment 4.

REDACTED ELID Tariff CA IR-2 Attachment 1 Page 9 of 94 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 2B PAGE 3 of 3 NOVA SCOTIA POWER INC.

AI summary This document is an exhibit from a Nova Scotia regulatory proceeding related to NSPI's ELID Tariff CA IR-2. It is part of a larger submission (Page 9 of 94) with confidential information redacted.

EXHIBIT 6 PAGE 6 OF 6 (1) INTERR. RIDER DMD ADJ. (2) (3) Peak Dmd. in KWs (at Generator) 69,594 (4) Int Credit Amount 11,165 (5) (6) PHP DEMAND ADJUSTMENT CALCULATION (7) (8) Demand Usage Annual Credit Amount Calculation (9) Winter Month k...

AI summary The text presents a table related to demand adjustment calculations, including peak demand, credit amounts, and priority interruption adjustments, as part of a tariff attachment. The table includes values for demand usage, power factor adjustments, and credit calculations, though many values are zero or redacted.

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

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

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

AI summary This document details monthly coincident kW demand across various customer classes in Nova Scotia for 2026, including breakdowns for small, medium, large industrial, and municipal sectors. It highlights demand patterns, interruptions, and firm large industrial demands, relevant to regulatory proceedings on energy management and tariff structures.

REDACTED ELID Tariff CA IR-2 Attachment 2 Page 29 of 94 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 4 - Detail A PAGE 5 OF 6 NOVA SCOTIA PO FUNCTIONALIZATION OF OP FOR THE YEAR ENDING D (IN THOUSANDS OF

AI summary Redacted exhibit from a Nova Scotia Power Inc. (NSPI) tariff proceeding, detailing functionalization of operations for the year ending D. The document is part of a regulatory process involving cost and operational considerations.

EXHIBIT 6 PAGE 1 OF 6 (1) TOTAL (2) (3) SMALL (4) (5) GENERAL (6) SMALL (7) MEDIUM (8) LARGE (9) (10) (11) (12) ALLOCATION (23) CORPORATE TAXES 1,884 1,246 66 342 39 36 41 70 7 27 9 P-14 (24) Non-Operating Revenue: (25) STEAM AND ASH SALES...

AI summary The exhibit presents a detailed breakdown of financial figures, including corporate taxes, non-operating revenue, return on profit/loss, and various adjustments related to demand and allocation. These figures are categorized across different sizes and allocations, with references to specific board orders and direct allocations.

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

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

REDACTED ELID Tariff CA IR-2 Attachment 2 Page 81 of 94 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 9C Page 2 of 3 NOVA SCOTIA POWER INC.

AI summary A redacted exhibit from a Nova Scotia Power Inc. (NSPI) tariff proceeding, referencing the ELID Tariff CA IR-2. The document is part of a regulatory filing involving rate structures and cost recovery mechanisms, though specific details are confidential and redacted.

DETAIL OF MONTHLY CLASS SYSTEM COINCIDENT KW DEMAND FOR THE YEAR ENDING DECEMBER 31, 2027 (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) TOTAL SMALL GENERAL SMALL MEDIUM LARGE SHORE REAL TIME MONTH COMPANY DOMESTIC...

AI summary The document presents a detailed breakdown of monthly system coincident demand (in kW) across various customer classes (e.g., Small General, Large Industrial) for the year ending December 31, 2027, including totals and specific rider demands such as interruptible and firm large industrial demands.

PARTIALLY CONFIDENTIAL 1 Beyond the SA provisions, the notion that PHP would be assigned demand-related costs based on 2 8 MW would be clearly unfair and result is cost transfers to other classes and inconsistent with 3 long-established pr...

AI summary The text argues that assigning PHP a demand-related cost based on 8 MW would be unfair and inconsistent with Nova Scotia's established practices, as PHP's actual load and peak load are significantly higher than this figure, and it would avoid transmission cost responsibility.

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

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

NON-CONFIDENTIAL 1 levels. Subject to the Board's approval of the Tariff and implementation of the PHP 2 Deferral as approved by the Board, subject to the final Board Order, in the 2026-2027 3 General Rate Application (M12451), revenue var...

AI summary The text references a General Rate Application (M12451) and the deferral of revenue variances between settlement agreement assumptions and actual results. It notes that deferral is subject to the Board's final approval of the Tariff and implementation of the PHP (likely a program or mechanism).

NSPI Responses to Industrial Group Information Requests Request IR-5: 18 demand-setting tariff provisions described in the Application, beginning at page 4, which 19 provides, "it is proposed that the PHP demand determinant be reviewed and...

AI summary NSPI explains that the proposed treatment of demand-setting tariff provisions in the GRA process or FAM is appropriate and consistent with ratemaking principles. It facilitates fair cost allocation, provides stability, and aligns with PHP operations focused on minimizing variable costs. A framework for costing PHP demand has not yet been developed but will be informed by the Board's decision and PHP operations.

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

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

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

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

FOR THE YEAR ENDING DECEMBER 31, 2026 (IN THOUSANDS OF DOLLARS) (262) GENERATION 0.0 (263) DISTRIBUTION 6,892.9 0.0 6,893 (264) TRANSMISSION 396.6 0.0 397 (265) DISTRIBUTION/ TRANSMISSION COMMUNICATION 2,394.2 0.0 2,394 (266) DISTRIBUTION/...

AI summary The document presents a financial summary for the year ending December 31, 2026, detailing various costs and allocations across generation, distribution, transmission, and retail operations. It includes depreciation, interest charges, corporate taxes, and various rider allocations such as interruption costs and power factor adjustments.

(17) Int Credit Amount - PHP 558 (2) (5) (1) INTERR. RIDER DMD ADJ. (3) Dmd. in KWs (4) Int Credit Amount 69,857 11,207 (7) (6) PHP DEMAND ADJUSTMENT CALCULATION (8) Demand Usage Annual Credit Amount Calculation (9) Winter Month kW Coincid...

AI summary The document presents a table detailing an interruptible credit amount calculation, including demand usage, annual credit amount, and priority interruption premium calculations. It includes figures related to kilowatts, kilovolt-amps, and monetary values.

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

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

EXHIBIT 6 PAGE 6 OF 6 (2) (5) (7) (1) INTERR. RIDER DMD ADJ. (3) Peak Dmd. in KWs (at Generator) (4) Int Credit Amount (6) PHP DEMAND ADJUSTMENT CALCULATION 69,594 11,165 (8) Demand Usage Annual Credit Amount Calculation (9) (10) Winter Mo...

AI summary The document presents a table with various demand adjustment calculations, including peak demand, credit amounts, and power factor adjustments. It includes values related to winter month demand, kilovolt-amps (kVA), and associated financial figures. The table also references priority interruption demand adjustments and associated credit amounts.

FOR MARCH 2027 (1) MWH (2) ENERGY LINE (3) ENERGY (4) CLASS NON- COINCIDENT (5) SYSTEM COINCIDENT (6) SYSTEM COINCIDENT (7) DEMAND LINE (8) SYSTEM (9) SYSTEM COIN. PEAK COINCIDENT (11) SUB-TOTAL 809,172 7.39% 868,945 1,913,936 81.5% 1,560,...

AI summary The document presents a table with energy-related metrics for March 2027, including various line items and totals. It includes data on energy usage, demand, and system coincidence, as well as subtotals for different categories such as shore power and real-time pricing.

FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (410) (411) TOTAL REVEN...

AI summary The text presents a financial summary for the year ending December 31, 2027, highlighting revenue and cost-related figures across various categories such as Shore Power, Real Time Pricing, and late payment charges. It includes detailed breakdowns of revenue by different classes and associated percentages.

CLASSIFICATION OF OPERATING EXPENSES (1) INTERMEDIATE CLASSIFICATION (20) DEPRECIATION 54,388 35,965 1,904 9,881 1,132 1,035 1,194 2,029 207 774 267 EXH 6D (21) INTEREST NET OF AFUDC 26,257 17,363 919 4,770 546 500 576 980 100 374 129 P-14...

AI summary The document presents a detailed classification of operating expenses, including depreciation, interest, taxes, and other financial items, with specific figures and references to various exhibits and pages. It includes adjustments related to demand and other riders, as well as allocations and classifications for different categories of expenses.

CLASSIFICATION OF OPERATING EXPENSES (1) INTERMEDIATE CLASSIFICATION (19) REG. AFFAIRS - ADVOCACY EXPENSE 628 305 48 247 0 28 0 0 0 0 0 R-2 (19) GRANTS IN LIEU 10,222 6,567 335 1,819 207 186 240 372 307 142 48 P-7 (20) DEPRECIATION 52,732...

AI summary The document presents a classification of operating expenses, including depreciation, interest, taxes, and various adjustments related to demand and revenue. Specific line items include advocacy expenses, grants in lieu, and allocations for demand adjustments.

NOVA SCOTIA POWER INC. 2026 COST OF SERVICE STUDY ANALYSIS R E F E R E N C E G U I D E EXHIBIT COMPARISON OF REVENUE TO EXPENSE RATIOS 1 FUNCTIONALIZATION OF AVERAGE RATE BASE 2 INITIAL CLASSIFICATION OF AVERAGE RATE BASE 2A FINAL CLASSIFI...

AI summary The document outlines Nova Scotia Power Inc.'s 2026 Cost of Service Study, presenting revenue to expense ratios for different customer classes in 2023 and 2026. It includes exhibits detailing the functionalization of rate bases, allocation of expenses, and analysis of revenue and expense components under proposed rates.

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

AI summary This table presents detailed data on non-coin. KW sec., losses, and sub-totals for various categories such as small, general, and large companies, along with percentages for non-coin. KW pri. (before and after bulk power substation) and total losses. The data is organized by different customer types and includes metrics like losses and sub-totals.

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

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

REVENUE TO EXPENSE COMPARISON (1) TOTAL DMD.RELATED (2) TOTAL ENG.RELATED (3) UNIT COST ENG.RELATED (4) TOTAL CUST.RELATED (5) TOTAL OPER. (6) TOTAL RATE (7) % REVENUE VARIANCE CALC (272) (273) GLACE BAY RETIREMENT 0 Interest Charges Corpo...

AI summary The document presents a revenue-to-expense comparison, including interest charges, corporate taxes, and various cost allocations such as FCR deferral and customer solutions allocators. It highlights financial figures and percentages related to different operational and regulatory adjustments.

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

AI summary The document presents a table related to Nova Scotia Power Inc.'s allocation of operating expenses, specifically focusing on demand adjustment calculations and priority interruption credit amounts. The table includes data on peak demand, power factor adjustments, and credit calculations, though many fields are populated with zeros or missing information.

ALLOCATION FACTOR INFORMATION Calendar Month of System Peak 1 (121) REQUIREMENTS - EBS/RTR (122) REQUIREMENTS - EXPORT SALES 48,897 0 56,065 0 54,953 0 43,244 0 37,250 0 42,346 0 39,467 0 37,814 0 38,635 0 42,809 0 43,111 0 48,660 0 153,62...

AI summary The document presents a detailed table outlining allocation factor information, including requirements for the Electricity Billing System/Real Time Pricing (EBS/RTR), interruptible coincident demand, MWH sales, and line loss percentages across various voltage levels and regions in Nova Scotia.

REDACTED 2026 2027 Rate Class As filed in GRA (M12451) If PHP is not Responsib le for FLG2 Costs Difference As filed in GRA (M12451) If PHP is not Responsibl e for FLG2 Costs Difference General Demand 8,208,461 8,653,486 445,025 8,125,533...

AI summary The table compares revenue requirements for different rate classes under the General Rate Application (M12451) for 2026 and 2027, considering scenarios where the Peak Hour Program (PHP) is or is not responsible for Federal Loan Guarantee 2 (FLG2) costs. The differences in revenue requirements are shown for each rate class.

PHP ATL Tariff Development – Priority Interruption - These slides have been prepared for discussion with Port Hawkesbury Paper (PHP) and form the basis of NS Power's current understanding of Priority Interruption. - The information present...

AI summary This document outlines the initial understanding of Priority Interruption by NS Power in the context of PHP ATL Tariff Development. The information provided is directional and nonbinding, and NS Power invites input and feedback from Port Hawkesbury Paper.

NSPI Responses to Industrial Group Information Requests 1 Request IR-12: 29 dispatched down during hours when the margin between generation plus reserve and load 1 is small. In these hours, PHP typically will not have load available to pro...

AI summary NSPI explains that the Dispatchable Rider (DR) in the ELID Tariff allows NS Power to dynamically dispatch PHP during system peak hours, provided certain conditions are met. However, PHP has the right to refuse dispatch directions, subject to System Operator approval. The Operating Protocols for DR are still under development and may not require Board approval.

Part A – Definitions ADC: Active Demand Control. ADC Dispatchable Rider Operating Procedure (Operating Procedure): This Pprocedure document maintained by Nova Scotia Power System Operator (NSPSO) and Nova Scotia Power Energy & Risk Managem...

AI summary This section defines key terms related to Nova Scotia's electricity management, including ADC (Active Demand Control), Dispatchable Rider, and CBL (Customer Baseline Load). It outlines procedures for managing load and calculating benefits under the ELID Tariff.

tual real-time total wind generation – NSPSO; - 7.7.6.6. PHP hourly pulp storage levels PHP; and - 7.8.6.7. PHP discrete line operation (i.e. what lines are in and out of service in a period) PHP. NS Power and PHP agree that, in order to (...

AI summary NS Power and PHP agree to share system information to improve operational efficiency and collaboration, particularly in response to dispatch schedule changes and unplanned system events. NS Power will provide PHP with automated system demand and generation data, and will calculate the ADC benefitDispatchable Rider Credit annually based on actual system conditions.

DRAFT – EXTRA LARGE INDUSTRIAL ACTIVE DEMAND CONTROLDISPATCHABLE TARIFF Page 7 of 8 Schedule 1: Active Demand Control Energy Supply ProtocolDispatchable Rider Operating Procedure NSPSO will be required to dispatch PHP's load consistent wit...

AI summary This document outlines the operating procedure for the Active Demand Control Dispatchable Rider, including load dispatch requirements and energy supply protocols. It specifies that NSPSO will manage PHP's load according to defined schedules and that the procedure can be modified with agreement among PHP, NSPSO, and NS Power.

CONFIDENTIAL (Attachment Only) - The requested timeline for each event where a customer has been provided with an Advisory, Alert, or Interruption request, including showing the dispatch of NS Power resources and PHP load under the ELIADC...

AI summary NS Power explains that detailed timelines for customer advisories, alerts, and interruptions under the ELIADC Tariff are not readily available due to data complexity. They also clarify that no interruption calls have been initiated under the ELIADC Tariff since 2020 and that only interruptible customers with Telemetry & Control are held in reserve.

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

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

NON-CONFIDENTIAL 1 Request IR-14: 2 3 Reference: N-1, ELID Application, page 9 – Priority Interruptible Credit. 4 5 (a) Please provide all workpapers, calculations, and analysis supporting the value of 6 $0.764/kVA and $0.767/kVA as the pr...

AI summary The request seeks clarification on the basis for the priority interruptible credit ($0.764/kVA and $0.767/kVA) and whether it is derived from actual avoided costs or a policy-based 10% uplift over the standard LIIR credit. The response directs to specific filings (M12451, SBA IR-2, and IG IR-13) for detailed calculations and historical context.

NSPI Responses to Industrial Group Information Requests 1 Request IR-15: 2 3 (a) Given the DR enables NSPI to actively manage PHP's load in real time in response to 4 system conditions, please identify the specific incremental system capab...

AI summary NSPI is responding to an inquiry from an industrial group regarding the differences between priority interruptibility and DR dispatch, including the incremental system capability, calculation models, and conditions under which priority interruptibility may be used separately from DR.

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

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

NON-CONFIDENTIAL 1 (iv) Confirmed 2 3 (b) In accordance with the Settlement Agreement, the Company has undertaken to develop an 4 above-the-line (ATL) tariff applicable to PHP and has provided, as part of the 2026-2027 5 General Rate Appli...

AI summary The Company has developed an above-the-line (ATL) tariff applicable to the Peak Hour Program (PHP) as part of the 2026-2027 General Rate Application (GRA), covering fixed cost recovery for 2026 and 2027. No forecast is available for PHP fixed cost recovery under the ELID Tariff from 2028-2037, which will be addressed in future GRAs.

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

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

NSPI Responses to NSEB Information Requests 1 Request IR-1: 2 3 Regarding interruptible service, on page 8, NS Power stated: 4 5 …the relatively low cost of acquiring priority interruptible service 6 7 (approximately $500,000 annually as m...

AI summary NSPI responds to information requests regarding the cost and review of interruptible service, referencing a prior Board decision (M05550) where compensation for Priority Interruptible service was set at 15% of the interruptible credit. The response also notes PHP's use of the Load Retention Tariff and ELIADC Tariff over the past decade.

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

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

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

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

NSPI Responses to Port Hawkesbury Paper Information Requests 1 Request IR-1: 11 12 and very high (e.g. 160 MW), depending largely on system load conditions and the level of PHP demand that produces the lowest cost to serve the system in 13...

AI summary The document discusses NSPI's responses to information requests regarding the determination of PHP coincident peaks, referencing the ELID Tariff and the use of judgment in establishing a demand billing determinant. It highlights the unique nature of the ELID Tariff and the need for judgment due to the characteristics of a single, large customer with dispatchable load.

NON-CONFIDENTIAL 1 Request IR-5: 2 3 Reference: Application, Attachment 1, page 8 of 8: 4 5 "Annually, NS Power shall report to the Board to confirm the dollar value of 6 system savings that have been achieved through the dispatch of the 7...

AI summary The document discusses whether NS Power should include an interest component in the credit payable to PHP for system savings under the Dispatchable Rider. NS Power responds that it does not propose applying an interest component, citing the complexity of factors affecting savings and the difficulty in determining a base for interest calculations.

NSPI Responses to SBA Information Requests 1 Please refer to part (c) and IG IR-5. 2 3 (i) If cost allocation is unchanged and only billing determinants change then the prices would 4 change to produce the same cost recovery. If the foreca...

AI summary NSPI explains that if cost allocation remains unchanged and only billing determinants change, prices would adjust to maintain cost recovery. It also notes that a demand charge mechanism based on maximum monthly demand could be counterproductive under the Dispatchable Rider. Additionally, NSPI highlights differences in how demand-related costs are handled in the Large Industrial Class and the ELID Tariff.

NON-CONFIDENTIAL 1 (g) Please confirm whether, if NS Power used the full avoided capacity as the credit, 2 would the Dispatchable Rider ("DR") be paying for the same underlying flexibility? 3 If not, please explain. 4 5 (h) Please confirm...

AI summary The text contains a series of questions regarding the Dispatchable Rider (DR) and interruptible rider credit calculations used by NS Power, with references to past decisions and studies. The response refers to prior documents and mentions the 1996 General Rate Application (GRA) Decision and the Cost of Service Study (COSS) from the 2023-2024 GRA.

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

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

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-1: 8 please refer to SR-01 Attachment 3 (Exhibit N-91-(i)); 9 • For 2026 BCF, SR-01 Attachment 5 (Exhibit N-91-(i)); and 10 • For 2027 BCF, SR-01 Attachment...

AI summary NSPI provides responses to information requests from Synapse Energy Economics, Inc., referencing various exhibits and filings related to the 2026 BCF, 2027 BCF, and the COSS methodology. The consultative review of COSS was conducted as directed by the NSEB and led to changes in the COSS as part of the 2026/2027 General Rate Application. The Board's decision was issued in March 2026, and a compliance filing was submitted in April 2026.

Response IR-5: (a) The total peak MW load reduction available to NS Power under the Large Industrial Interruptible Rider (LIIR) Tariff for each year from 2022 to 2025, inclusive, is as follows. Note that the MW values are peak quantities a...

AI summary This section provides the total peak MW load reduction available to NS Power under the Large Industrial Interruptible Rider (LIIR) Tariff for the years 2022 to 2025. The values represent peak quantities and may not reflect actual load relief during interruptions.

- Schedule 1: Active Demand Control Energy Supply Protocol - (a) With respect to forecast PHP annual capital shutdowns, PHP will provide a minimum of one month's advance notice of the timing and duration of the shutdowns; and - (b) With re...

AI summary The document outlines protocols for Active Demand Control (ADC) energy supply, including PHP's notice requirements for shutdowns, NS Power's intra-day schedule updates, and NSPSO's role in adjusting demand during system changes. It also references potential rate adjustments by NS Power based on CBL Energy Charge discrepancies, requiring NSUARB approval.

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

AI summary Part C outlines conditions for PHP's adherence to demand schedules, collaboration with NS Power/NSPSO, handling deviations, and maintaining communication. It emphasizes compliance with system reliability, health/safety, and Force Majeure events, with adjustments tracked and reconciled quarterly. ADC credits may be adjusted based on system cost impacts.

CONFIDENTIAL (Attachment Only) 1 Request IR-6: 2 3 Refer to the Application, p. 3, regarding the ELID tariff being based on the Large Industrial 4 tariff. 5 6 (a) In Excel with working formulas and all billing determinants, please provide...

AI summary The document requests Nova Scotia Power Inc. (NSPI) to provide detailed bill calculations for Port Hawkesbury Paper LP (PHP) under the Large Industrial (LI) and Real Time Pricing tariffs for 2023-2024, including load differences and impacts on billing. It also asks whether PHP's load would have varied under these tariffs and how that would affect costs.

NSPI Responses to Synapse Energy Economics, Inc. Information Requests 1 Request IR-7: 26 Response IR-14: 27 28 (a-b) As discussed below, the Dispatchable Rider (DR) included in the ELID Tariff and the 29 Interruptible Rider (IR) to the Lar...

AI summary NSPI explains that the Dispatchable Rider (DR) and Interruptible Rider (IR) are distinct service offerings with different purposes, compliance processes, and compensation bases. The IR has been available to large industrial customers for decades to reduce firm peak demand and compensate customers for the value provided as a system planning tool.

NON-CONFIDENTIAL - Customers to reduce their load as directed by the System Operator (SO) within 10 minutes of notice. A recent innovation to the LIIR Tariff offering allows customers who provide the Company with visibility to their load a...

AI summary The LIIR Tariff requires customers to reduce load rapidly under NSPSO direction, with penalties for non-compliance and strict interruption limits. Customers must provide load visibility and accept potential removal from IR service. A five-year notice period is required for converting to firm service, ensuring adequate time for capacity adjustments.

Dispatchable Rider The Dispatchable Rider (DR) is an operational dispatch tool managed by NS Power's Energy and Risk Management Group and the NSPSO. The service is dynamic in that it requires frequent adjustments to the customer's load. It...

AI summary The Dispatchable Rider (DR) is an operational tool managed by NS Power's Energy and Risk Management Group and the NSPSO. It is used to adjust customer load dynamically and is specifically designed for PHP, NS Power's largest customer. The benefit of the service is quantified annually by comparing actual service costs to costs under a high load factor scenario.

Date Filed: April 10, 2026 NSPI (Synapse) IR-19 Page 2 of 2 1 Request IR-20: 28 one where an interruption request of 50 MW is not applied. For the purpose of calculating 29 these hypothetical bills, NS Power applied the following assumptio...

AI summary The document outlines assumptions used in calculating hypothetical bills under the ELID Tariff, including the use of proposed rates, conversion of charges to weekly billing, peak demand assumptions, and the application of performance penalties based on residual customer demand and average demand during specific intervals.

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

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

REDACTED 1 simultaneously interrupted, such that the remaining load is PHP's firm load 2 at 8 MW. 3 4 (1) If so, please provide a historical example of such splitting. 5 6 (2) If not, please explain how NS Power determines if load will be...

AI summary The text outlines a series of questions regarding load management practices, including load interruption criteria, Operating Reserve definitions, LIIR tariff overrides, and ELID priority interruptible credit calculations. It seeks clarification on NS Power's processes for determining load reduction as interruption vs. dispatch and historical precedents for reserve load handling.

REDACTED (j) Are the Generation Replacement and Load Following Tariff and Shore Power Tariff compensated for their place in the order of interruptibility? If so, what is their compensation for being higher in the order than the interruptib...

AI summary The question asks whether the Generation Replacement and Load Following Tariff and Shore Power Tariff are compensated for their higher position in the interruptibility order compared to the Large Industrial Interruptible Rider (LIIR), requesting supporting workpapers.

Response IR-23: (a) The existing order of interruptibility by rate class was established through regulatory proceedings which gave rise to various interruptible service rates over the last few decades. The priority interruptible status of...

AI summary The document explains the historical basis for interruptible service rate prioritization, noting that the ELID Tariff's second position reflects longstanding practices accommodating large pulp and paper operations. It references regulatory proceedings and specific tariff structures, with GRLF load interruption prioritization detailed in IG IR-25 part (a).

REDACTED (CONFIDENTIAL INFORMATION REMOVED) Application for Approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (NSEB M12661) NSPI Responses to Synapse Energy Economics, Inc. Information Requests

AI summary The document outlines an application for approval of an above-the-line tariff for Port Hawkesbury Paper (NSEB M12661) and NSPI's responses to information requests from Synapse Energy Economics, Inc. The proceeding involves regulatory approval processes and compliance with information disclosure requirements.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 30 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 4 - Detail A PAGE 4 OF 6

AI summary A redacted exhibit from Synapse Energy Economics, Inc.'s ELID Tariff Synapse IR-30 Attachment 1, Page 30 of 96, which is part of a regulatory proceeding. The document is labeled as 'EXHIBIT 4 - Detail A PAGE 4 OF 6,' indicating it is a detailed component of a larger submission.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 45 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 6A

AI summary A redacted exhibit from a Nova Scotia regulatory proceeding related to the ELID Tariff and Interruptible Rider 30 (IR-30), involving Synapse Energy Economics and Nova Scotia Power Inc. The document is part of a broader regulatory filing and includes confidential information removed.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 48 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 6D Page 1 of 2

AI summary A redacted exhibit from a Nova Scotia regulatory proceeding related to the ELID Tariff and Synapse's IR-30. The document is part of a legal filing involving tariff adjustments, though content is confidential and partially obscured.

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

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

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 84 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 9C Page 2 of 3 NOVA SCOTIA POWER INC.

AI summary A redacted exhibit from a Nova Scotia Power Inc. (NSPI) regulatory proceeding related to the ELID Tariff and Synapse IR-30 Attachment 1. The document is part of a larger submission involving rate design and regulatory approval processes.

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

AI summary The document presents monthly demand data across various customer classes (small domestic, large industrial, etc.) for 2026, including real-time pricing and interruptible rider demands. Totals and class-specific demand figures are aggregated, with notable entries for ELI 2P-RTP and GRLF.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 85 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 9C Page 3 of 3

AI summary The document is a redacted page from a Nova Scotia regulatory proceeding related to the ELID Tariff and Synapse IR-30 Attachment 1. The content is confidential and not fully visible, with only the exhibit label 'EXHIBIT 9C Page 3 of 3' explicitly mentioned.

REDACTED ELID Tariff Synapse IR-30 Attachment 1 Page 91 of 96 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Line # AVERAGE RATE BASE RATE BASE 2025 RATE BASE 2026 (394) (395) TOTAL REVENUE OF BTL RATE CLASSES (396) SHORE POWER (397) GEN.REPL...

AI summary The table presents average rate base and revenue data for various rate classes and programs, including Shore Power, ELIADC, and Solar Garden Rider, with figures for 2025 and 2026. It includes line items such as OATT, EBS, and RTR, and highlights total revenue and cost values for the BTL rate classes.

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

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

REDACTED ELID Tariff Synapse IR-30 Attachment 3 Page 27 of 95 REDACTED (CONFIDENTIAL INFORMATION REMOVED) EXHIBIT 4 - Detail A PAGE 3 OF 6 NOVA SCOTIA POWER FUNCTIONALIZATION OF OPERA FOR THE YEAR ENDING DECEM (IN THOUSANDS OF DOL

AI summary The document is a redacted portion of a Nova Scotia Power tariff filing, specifically an exhibit detailing functionalization of operations for the year ending December. It includes references to various acronyms and terms related to energy billing, pricing, and regulatory processes.

NOVA SCOTIA POWER INC. ALLOCATION OF OPERATING EXPENSES FOR THE YEAR ENDING DECEMBER 31, 2027 (IN THOUSANDS OF DOLLARS) (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (22) PREFERRED DIVIDENDS 0 0 0 0 0 0 0 0 0 0 0 P-14 (23) CORPORATE T...

AI summary The document provides a detailed breakdown of Nova Scotia Power Inc.'s allocation of operating expenses for the year ending December 31, 2027, including corporate taxes, preferred dividends, and various revenue and adjustment items such as interruptible rider demand adjustments and ELI 2P-RTP demand adjustments.

And further PHP firm demand service will contribute 8 MW to NS Power firm ATL peak demand. Hence, the firm 8 MW demand charge should reflect the PHP allocated cost of including its 8 MW peak demand in NS Power's 3-CP capacity cost allocati...

AI summary PHP's 8 MW firm demand service contributes to NS Power's capacity costs, with ELID energy rates covering interruptible demand beyond this. The text clarifies that no interruptible credit is needed under this ELID structure, as non-fuel costs in the rate cover excess demand. Questions seek clarification on ELID design and PHP's proposal to exclude interruptible credits above 8 MW.

Response IR-6: PHP acknowledges that there are differences between its proposed modifications to the as-filed ELID tariff and the modeling included as part of the GRA Settlement Agreement. However, the possibility of such differences arisi...

AI summary PHP acknowledges differences between its proposed ELID tariff modifications and the GRA Settlement Agreement, citing the agreement's allowance for parties to take positions during Board reviews. NS Power may seek a deferral account for revenue variances from 2026-2027 scenarios, as outlined in the Settlement Agreement. The Board's decision in Matter M12451 supports this flexibility.

Response IR-4: (a) BAI has not performed the requested analysis. The recommend interruptible credit of $13.107/kVA-month was derived from NS Power's Application, Attachment 1 Extra Large Industrial Dispatchable Tariff, Page 8 of 19, footno...

AI summary BAI did not perform the requested analysis for IR-4 and IR-5. The interruptible credit calculation for ELID class uses winter coincident peak and avoidable peaker costs. Reducing PHP's demand determinant from 65 MW to 8 MW is estimated to reduce revenue requirements by $6.5M (2026) and $9.4M (2027), though BAI has not confirmed reallocation details or secondary cost impacts.

Request IR-6: - (a) Set out in a single consolidated table BAI's recommended rate for each ELID tariff component for 2026 and 2027, compared to NSPI's proposed rate for the same component. - (b) For each component where BAI recommends a ch...

AI summary Request IR-6 asks for a consolidated table comparing BAI's recommended ELID tariff rates for 2026-2027 with NSPI's proposals, and requires analysis of impacts on PHP's annual bill and revenue requirements for other ATL customer classes (including LI and MI).

Response IR-6: - (a) BAI has not recalculated each rate component of BAI's recommended ELID rate. BAI is proposing an Interruptible credit of $13.107/kVA in 2026 for the ELID tariff in contrast to the $7.638/kVA being proposed by NS Power...

AI summary BAI has not recalculated rate components for the ELID tariff, proposing a higher Interruptible credit ($13.107/kVA) than NS Power's $7.638/kVA. BAI also failed to perform the requested analysis, raising concerns about the methodology and justification for the proposed rate adjustments.

Request IR-9: Reference: N-3, Evidence of PHP, page 12. Unless PHP's areas of concern are addressed by the Board in a satisfactory 13 manner it is unlikely PHP will proceed to accept service under the ELID tariff. 14 PHP would need to unde...

AI summary PHP seeks Board approvals for ELID tariff modifications and a below-the-line alternative. It threatens to reject ELID if changes aren't made, emphasizing the need for a tailored tariff meeting the mill's operational needs.

Request IR-11: - Reference: N-3, Evidence of PHP, pages 12-13. - Preamble: PHP states that there are aspects of PHP's load flexibility that are not being - captured in the ELID filing, and that the benefits from the February 13, 2026, Mari...

AI summary PHP argues that its load flexibility and the February 13, 2026, Maritime Link event's ancillary service value are not fully captured in the ELID filing. It seeks compensation for this value beyond ADC and priority interruptible, requesting a tariff mechanism and cost allocation. PHP also asks to quantify the system value of off-protocol curtailments under ELIADC, including methodology.

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

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

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

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

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

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

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

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

026- 2027 GRA and the ultimate rate which PHP may be on for those years, section PHP Treatment item (e) of the Schedule "A" Terms of Settlement of the 2026-2027 GRA Settlement Agreement provided that: "NS Power may seek Board approval for...

AI summary The 2026-2027 GRA Settlement Agreement allows NS Power to request a deferral account for revenue variances arising from PHP tariff decisions, including scenarios related to Active Demand Control Rider outcomes. The Board's decision in M12451 approved this deferral account, citing potential revenue requirement variances and the need for certainty for utilities and customers.

Request IR-2: 1 2 3 Reference: Evidence of Colin T. Fitzhenry and Michael P. Gorman (BAI), page 19. NS Power provided an updated COSS for 2026 and 2027 based on a reduction in PHP's total demand coincident with the winter system peaks redu...

AI summary NS Power provided an updated COSS for 2026 and 2027, leading to a reduction in PHP's rate by approximately $6.5 million in 2026 and $9.4 million in 2027 due to decreased winter system demand from 65 MW to 8 MW in Undertaking U-3.

omponent of the ELID tariff. PHP acknowledges a BTL alternative "may" have embedded cost-based, non-fuel components. It also may not. Request IR-6: Reference: NS Power Application, pages 8-9 of 19. With respect to the SA priority interrupt...

AI summary NS Power argues that maintaining priority interruptible service provisions in the SA is justified due to system reliability benefits, low annual costs (~$500,000), and potential risks from discontinuation during system transformation. The company proposes retaining the service until the next GRA for further review.

Request: Please confirm, or explain otherwise, if it is BAI's understanding that under the proposed ELID Tariff: (a) System energy cost savings produced by the dispatch of PHP load will accrue solely to PHP, not other customers. (b) PHP is...

AI summary BAI requests confirmation that under the proposed ELID Tariff: (a) system energy cost savings from PHP load dispatch accrue solely to PHP; (b) PHP is compensated for avoided generation capacity via interruptible credits, using the same methodology as Large Industrial Interruptible Rider customers; and (c) transmission savings from PHP's interruptible load are minimal, as NS Power's transmission capacity is designed for total system load, not just interruptible loads.

Response IR-9: - (a) Confirmed that the Dispatchable Rider is designed to credit estimated system energy cost savings specifically to PHP. However, BAI cannot confirm that these savings accrue solely to PHP. While the credit is intended to...

AI summary PHP argues the Dispatchable Rider unfairly allocates benefits from load flexibility, while BAI and NS Power disagree on interruptible credit methodologies. BAI asserts transmission costs should not be assigned to PHP's load if it doesn't drive system peaks, aligning with cost-causation principles. Disputes center on credit design, cost allocation, and methodology fairness.

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

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

Request IR-6: Refer to M12661, Exhibit N-2, Evidence of Colin T. Fitzhenry and Michael G. Gorman on behalf of PHP, regarding the non-fuel savings created by the Dispatchable Rider ("DR"), please answer the following: a) Does PHP believe th...

AI summary The document requests PHP's position on the Dispatchable Rider (DR) component, including its inclusion of avoided transmission and production costs, potential overlap with interruptible credit, and whether DR benefits are fully passed to PHP, along with a table of credit attributes.

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

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

Response IR-7: - (a) Confirmed. PHP's estimate would likely be higher as a result of dated peaker capacity cost included in the NS Power estimate. - (b) No, PHP's load must be moved in large increments per approved operating modes. - (c) N...

AI summary Response IR-7 addresses five points: PHP's estimate may be higher due to outdated peaker capacity costs, load must be moved in large increments, no calculation was performed, DR credits capture energy savings beyond capacity costs, and PHP provides priority interruptible service to NS Power.

Response IR-8: (a) The referenced NS Power study is based on BAI's understanding of how these studies are conducted for NS Power's system. (b) PHP is unaware of any high-voltage system upgrades that would be triggered when PHP's winter coi...

AI summary NS Power's study relies on BAI's methodology. PHP states no high-voltage upgrades would be triggered by its winter peak contributions and requests a pricing model reflecting NS Power's costs, including a demand charge with an interruptible credit for excess demand beyond 8 MW.

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

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

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

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

Responses to CA Questions and Topics – 3 of 3 Question NS Power Response Please also refer to 3. Appropriateness of the interruptible credit rate NS Power's position on matters related to the • interruptible credit, in particular, as infor...

AI summary NS Power responds to questions about interruptible credit rates, PHP demand usage in tariff setting, and the Dispatchable Rider, referencing the Settlement Agreement and various intervenor responses (IRs). Topics include rate riders and tariff design, with cross-references to IRs and board orders.

Responses to SBA Questions – 1 of 4 Question NS Power Response Please also refer to I. Historical Load Questions: a) What specific governance or planning criteria does NS Power apply when using the 65MW 3CP demand determinant to assure tha...

AI summary NS Power explains that the 65MW 3CP demand determinant's reasonableness is governed by the Settlement Agreement for 2026-2027, with future methodology proposals required for the next GRA. It agrees to consider a standardized, formula-based metric if it ensures fair cost allocation under the ELID Tariff for PHP.

Responses to SBA Questions – 3 of 4 Question NS Power Response Please also refer to Governance Questions: a) While the pass-through nature DR (Dispatchable Rider) credit does make it cost neutral, retroactive audits do not substitute for c...

AI summary NS Power responds to governance questions about transparency in DR (Dispatchable Rider) protocols and PHP's participation in DR. It claims draft protocols align with ELIADC Tariff and argues performance metrics for PHP are unnecessary due to DR design. Cross-references include IG and NSEB interventions.

Responses to SBA Questions – 4 of 4 Question NS Power Response Please also refer to Credits Questions a) The LIIR (Large Industrial Interruptible Rider) credit allocates the avoided capacity value based on forecasted non-coincident peak de...

AI summary NS Power responds to SBA questions regarding the LIIR credit and priority interruptibility. It explains that the LIIR credit is based on forecasted load and system peak, and that the value of the credit is established by the Settlement Agreement for 2026 and 2027. Regarding priority interruptibility, NS Power acknowledges the lack of comprehensive analysis but proposes retaining the 10% PI credit value as modelled in the GRA.

1.2 OUTLINE OF EVIDENCE This report is organized according to the following headings: - Recommendations; - Overview of the Application; - Merits of Proposed PHP Tariff Revisions; - Proposed ELID Dispatchable Rider; and - Proposed ELID Inte...

AI summary The document outlines the structure of evidence presented in the proceeding, including sections on recommendations, application overview, PHP tariff revisions, and proposed ELID riders. It focuses on regulatory considerations for tariff adjustments and rider mechanisms.

3.1 NSP APPLICATION NSP is applying to the Board for approval of the Extra Large Industrial Dispatchable (ELID) Tariff, an above-the-line (ATL) tariff available to Port Hawkesbury Paper LP (PHP). NSP states it is intended that PHP will sub...

AI summary NSP seeks Board approval for the ELID Tariff for PHP, replacing the expiring ELIADC Tariff. The proposed tariff includes customer, demand, and energy charges, interruptible service, and provisions for wind farm energy. NSP cites a settlement agreement (SA) with PHP for cost modeling, while InterGroup highlights load characteristics and credit calculations in the SA. Alternative plans are needed if approval fails.

3.2 PHP EVIDENCE PHP states in their evidence that they do not agree with certain aspects of NSP's proposed tariff, and specifically: - 1. the use of a 57,000 kW winter month system coincident demand for PHP interruptible load; - 2. the va...

AI summary PHP disputes NSP's proposed tariff, challenging the 57,000 kW winter demand assumption, the Interruptible credit value, the R/C ratio for a new Above-the-Line Tariff, and the 2026-2027 forecast energy requirements. These issues relate to rate design, revenue modeling, and forecasting accuracy.

4.3 VALUE OF INTERRUPTIBLE CREDIT AND UPDATES TO ENERGY SALES FORECASTS PHP's consultant also recommends changes to the interruptible credit to be priced at NSP's marginal cost of capacity and updating the 2026 and 2027 PHP sales forecasts...

AI summary The document discusses NSP's proposal to set the interruptible credit at marginal cost of capacity, conflicting with PHP's argument for a higher rate of $13.107/kVA. NSP cites settlement agreement terms, while InterGroup supports NSP's position. The LIIR rate is noted as lower than NSP's historical practice for interruptible credits.

5.0 PROPOSED ELID DISPATCHABLE RIDER NSP states that the Dispatchable Rider (DR) will allow PHP to operate in a manner which reduces PHP's individual cost of service, enables NS Power to manage PHP's load in response to system conditions,...

AI summary NSP proposes the ELID Dispatchable Rider (DR) to reduce PHP's service costs, enable load management to lower system costs, and compensate PHP for load flexibility. The DR shields ATL customers from PHP's potential cost impacts and credits PHP fully for dispatch value, differing from ELIADC Active Demand Control primarily in nomenclature and dispatch service provisions.

6.0 PROPOSED ELID INTERRUPTIBLE RIDER NSP proposes an Interruptible Service component to the ELID Tariff. NSP states that the ELID Tariff interruptible service provisions, for the most part, adopt the LIIR terms with minor text updates dra...

AI summary NSP proposes an ELID Interruptible Rider with provisions based on LIIR terms and ELIADC Tariff updates. Key features include interruptible demand calculations, penalties for non-compliance, and a 10% monthly demand charge reduction for customers. Interruption limits and compensation mechanisms are outlined, with alignment to ELIADC Tariff processes.

rmation Requests from intervenors (related to sales and generation forecasting, rate design, rate impacts, capital planning, revenue requirement, etc.). Managed projects on development and submission of 2012/14, 2016/19, 2022/23 and 2025/2...

AI summary The text outlines activities related to managing rate applications for NTPC and QEC, providing regulatory support, economic analysis, and load forecasting. Key focus areas include rate design, capital planning, revenue requirements, and fuel stabilization fund rider applications.

Hayitboy Mahmudov - Utility Regulation Experience Utility Proceeding Work Performed Before Client Year Oral Testimony Qulliq Energy Corporation (QEC) 2018/19 Phase I and II General Rate Application Analysis and Coordination; Lead consultan...

AI summary Hayitboy Mahmudov has experience in utility regulation, including work on rate applications, depreciation reviews, and rate design for organizations such as Qulliq Energy Corporation and AltaGas. His work involved coordination, analysis, and legal support in regulatory proceedings.

mmaries, drafting information requests, preparing expert evidence, participating in technical conferences and negotiations settlement and assisting with the preparation of argument and reply argument. For Northwest Territories Power Corpor...

AI summary The text outlines Andrew's professional involvement in rate applications for the Northwest Territories Power Corporation (NTPC) from 2000 to 2024, including technical support, expert testimony on revenue requirements, cost of service, and rate design, as well as current advisory work on the 2024/26 General Rate Application.

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

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

Nova Scotia Energy Board In the Matter of Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Redacted Version

AI summary The Nova Scotia Energy Board is reviewing a request for approval of an above-the-line tariff for Port Hawkesbury Paper. The proceeding involves Bates White Evidence, with a focus on regulatory approval processes and tariff design.

Nova Scotia Energy Board In the Matter of Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Confidential Version

AI summary The Nova Scotia Energy Board is considering the approval of an above-the-line tariff for Port Hawkesbury Paper, with Bates White providing confidential evidence. The proceeding involves regulatory evaluation of the proposed tariff structure.

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

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

Q. Please summarize NSPI's Application. - A. NSPI explains that the ELID Tariff is intended to replace the current tariff applicable to PHP, the - Extra Large Industrial Active Demand Control ("ELIADC") Tariff, on or before January 1, 2027...

AI summary NSPI's application proposes replacing the ELIADC Tariff with a fully cost-based ELID Tariff for PHP starting January 1, 2027. The ELID Tariff, based on the Large Industrial Tariff, includes both embedded and incremental costs and treats PHP as an above-the-line customer, with charges and credits offsetting payments.

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

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

Q. Please summarize your evidence with respect to NSPI's application. - A. Again, our evidence addresses only the Customer Charge, Energy Charge, Dispatchable Rider, - and treatment of Goose Harbour output. Regarding the Customer Charge, w...

AI summary The evidence recommends revising NSPI's proposed Customer Charge to $12,291.67/month with reconciliation for ELID Tariff costs, updating the COSS model for ELID Energy Charge accuracy, and rejecting the DR credit due to insufficient load-shifting safeguards. PHP's cost recovery and Goose Harbour output integration are emphasized.

Q. What is your recommendation regarding the proposed Customer Charge? - A. We recommend that NSPI file additional evidentiary support for its proposed Customer - Charge. Absent this, we recommend NSPI set the Customer Charge for 2026 and...

AI summary The recommendation suggests NSPI must provide additional evidence for the proposed Customer Charge. If not, set it at $12,291.67/month (midpoint of its estimate range) with reconciliation mechanisms ensuring PHP receives credits if actual ELID Tariff costs are below collections. NSPI must also explain cost-tracking methodologies for ELID Tariff administration.

Q. What is the effect of PHP net load being too low in the COSS? - A. In most direct terms, if PHP's net load in 2027 subject to the Energy Charge is 121 GWh rather - than 304 GWh, a 60% reduction, the revenue from PHP to NSPI would be low...

AI summary A lower PHP net load in the COSS reduces NSPI's revenue by ~$21M (60% reduction) and increases ELID Energy Charge rates due to fixed costs not scaling with energy use. This risks under-contributing to system costs, shifting burdens to other FAM customers. NSPI's application uses an inflated PHP net load, leading to undervalued Energy Charge rates.

the proposed Energy Charge? - A. No, not based on our reading of the proposed PHP Deferral account provisions. As specified in - the GRA Settlement, the PHP Deferral account is only intended to address effects from one or more of the - fol...

AI summary The proposed Energy Charge deferral is not applicable under the GRA Settlement, which limits the PHP Deferral account to specific scenarios. The text clarifies that distortions from PHP net load discrepancies with NSPI's ELID Energy Charge modeling are not covered by the deferral provisions.

IV. Assessment of the Dispatchable Rider Credit

AI summary The document section evaluates the Dispatchable Rider Credit, focusing on its implications for rate structures and cost recovery mechanisms within Nova Scotia's energy regulatory framework. Key considerations include alignment with existing programs and impacts on stakeholder interests.

Q. Please describe the DR credit proposed by NSPI in the ELID Tariff. - A. NSPI asserts that the DR credit "will allow PHP to operate in a manner which reduces PHP's - individual cost of service, enables NS Power to manage PHP's load in re...

AI summary NSPI proposes a DR credit in the ELID Tariff to reduce PHP's cost of service, enable load management during system peaks, and compensate PHP for load flexibility. The credit structure aims to shield above-the-line customers from PHP's potential incremental cost impacts by incentivizing system-cost-reducing operations.

Approval of an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (M12661) Bates White Evidence – Confidential Version 1 How is the DR credit Q. calculated? - A. The DR credit is a rate credit that is calculated after the close of a...

AI summary The document discusses the calculation of a Dispatchable Rider Credit (DRCREDIT) under the ELID Tariff, which is determined after the close of an ELID Tariff year.

Q. What is your fourth concern? - A. Our fourth concern is that the DR credit provides NSPI with substantial discretion that will be - difficult or impossible for the Board and stakeholders to verify.

AI summary The fourth concern is that the DR credit grants NSPI significant discretion, which the Board and stakeholders may find challenging to verify, potentially leading to regulatory oversight issues.

Q. Why will the DR credit be difficult (or impossible) for the Board and stakeholders to verify? - A. NSPI is afforded substantial discretion in determining the CBL. While NSPI is not purporting to - change the actual volume of PHP's load...

AI summary NSPI's discretion in levelizing PHP's load and lack of detailed data from PHP create verification challenges for the DR credit. NSPI's method is unclear, relying on limited examples and subjective factors. PHP's reluctance to share data (e.g., financial statements) and NSPI's lack of review exacerbate information asymmetry, undermining stakeholder confidence in the DR credit calculation.

Q. How substantial is NSPI's discretion in calculating the DR credit? A. Quite substantial. While NSPI did not conduct an estimate of the Credit in 2026 or 2027, [94](#page-25-0) NSPI conducted an "initial analysis" of the DR credit using...

AI summary NSPI's discretion in calculating the DR credit is substantial, as its initial analysis using 2025 data showed a potential $7–$11 million credit, but adjustments reduced it by half to $3.5–$5.5 million. NSPI's adjustments, based on subjective factors like system conditions, were not fully disclosed due to a cyber incident, raising concerns about transparency and verification.

Q. Does the DR credit have the potential to be material? - A. Yes. As noted above, and notwithstanding our commentary on the estimate, NSPI estimates that - the DR credit would have been $3.5 to $5.5 million in 2025. All FAM customers woul...

AI summary The DR credit is deemed material, with NSPI estimating it would reach $3.5–$5.5 million in 2025. All FAM customers would contribute, with payments accruing to PHP. The estimate's validity is noted but not contested.

Q. What is PHP's view of the DR credit? - A. Nowhere in the PHP Evidence did PHP criticize or raise concerns with the DR credit, as - proposed. (PHP raised concerns with other aspects of the ELID Tariff.) In response to data requests, PHP...

AI summary PHP did not criticize the proposed DR credit but raised concerns with other aspects of the ELID Tariff. PHP and its consultant believe the DR credit is 'appropriate.' NSPI's prior filings and tariff proposals are referenced in the context of ELIADC-related matters.

Q. What is your recommendation regarding the DR credit? - A. We do not recommend that the Board approve the DR credit as proposed. To be reasonable, at - least two things must be true: (1) any payments to PHP from FAM customers under the D...

AI summary The respondent recommends against approving the DR credit as proposed, citing its vagueness, lack of verifiability, and risk of mismatched payments. Two conditions are required for approval: payments must be tied to load-shifting due to energy prices, and FAM customers must not compensate PHP in hours without load-shifting activity.

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

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

II. SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS Q. Please describe your conclusions and recommendations. A. NS Power's proposed tariff is generally reasonable and represents an appropriate transition from a below-the-line to an above-the-li...

AI summary NS Power's proposed ELID tariff is generally reasonable but requires modifications to address concerns about capacity costs and equitable benefit allocation. PHP, the largest electricity customer, has raised issues regarding interruptible credit compensation and demand charge calculations. The ELID tariff aims to replace the expiring ELIADC tariff and ensure PHP pays its incremental costs while allowing NS Power to manage load for system reliability and cost reduction.

Q. Please summarize the ELID tariff. - A. At a basic level, the ELID Tariff is based on the Large Industrial Tariff and contains a - customer charge, demand charge, and energy charge.[6](#page-6-2) There are also two additional - riders, t...

AI summary The ELID Tariff is based on the Large Industrial Tariff and includes a customer charge, demand charge, and energy charge. It also features two riders: the Dispatchable Rider and the Interruptible Rider. NS Power highlights that the Dispatchable Rider benefits PHP and other customers by increasing PHP's contribution to system costs and reducing risk to other ATL customers.

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

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

NS Power ELID Application, page 14. 1 subject to future recovery from ATL customers, subject to Board approval. These 2 under the customer's dispatched load to a modeled high load-factor baseline 3 scenario, with the difference credited to...

AI summary The ELID tariff differs from the ELIADC tariff in several key aspects, including the basis for energy rates, the inclusion of a demand charge, and the treatment of interruptible capacity. The ELID tariff is based on embedded costs and includes a demand charge, while the ELIADC tariff does not include a demand charge and has different mechanisms for handling interruptible load.

Q. Is the ELID tariff reasonable? A. Generally, yes.

AI summary The ELID tariff is generally considered reasonable. The response affirms the tariff's reasonableness without providing further detailed justification or analysis.

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

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

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

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

EXTRA LARGE INDUSTRIAL ACTIVE DEMAND CONTROL TARIFF Page 5 of 7 Schedule 1: Active Demand Control Energy Supply Protocol - (12) Subject to available generation or load, as the case may be, efforts will be made to reconcile variances in a t...

AI summary This section outlines the Active Demand Control Energy Supply Protocol, detailing how variances in generation or load will be reconciled, the roles of NS Power, PHP, and NSPSO in scheduling and operations, and the alignment of this Protocol with NS OATT and NS Market Rules. It also covers annual planning and dispatch responsibilities.

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

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

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

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

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

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

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

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

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

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

- However, as noted above, it is recommended that new ELID contain stronger dispatch rights for NSP that - would make it even more likely that PHP is already dispatched to minimal load under conditions likely to - lead to calls for interru...

AI summary The text critiques the proposed Integrated Resource (IR) plan, arguing that the Extra Large Industrial Demand (ELID) tariff should provide minimal or no interruptibility credit due to Port Hawkesbury Paper Company's (PHP) limited practical interruptibility. Adjustments to credit values based on load factors are emphasized to reflect actual usage during system peaks, reducing credits for Large Industrial customers and ELID.

3.4 Issues Regarding Transparency and Reporting - The DR mechanism is new and complex. The benefits of the ELID can only be understood with a detailed - comparison of a hypothetical CBL load, as compared to actual PHP load, with the varian...

AI summary The text critiques NSP's proposal to reduce regulatory oversight and reporting for the ELID/DR mechanism, arguing that the complexity of the DR mechanism requires stronger Board oversight. It recommends quarterly reporting on DR status and approval of Operating Procedures by the Board to ensure transparency and accountability.

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

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

Request IR-4: - Reference: Testimony, Section VI, page 35, lines 23-25. "… we recommend that a true-up - mechanism be created to address substantial deviations of PHP net load from expectations…" - (a) Please quantify the term "substantial...

AI summary The text requests clarification on the definition of 'substantial' in the context of a true-up mechanism for PHP net load deviations, whether the mechanism operates in both directions, and how NSP determines forecast energy usage for LIIR customers.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, R.S.N.S. 1989, c.380, as amended -and- IN THE MATTER OF: AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable Above- th...

AI summary Nova Scotia Power Inc. has applied for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper under the Public Utilities Act. The proceeding involves regulatory review of the proposed tariff structure.

1 2025 M12661 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by Nova Scotia Power Incorporated for 5 approval of an Extra Large Industrial Dispatchable Above-the- 6 Line Tariff ap...

AI summary The document outlines an information request related to an application by Nova Scotia Power Incorporated for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The request asks for quantification of impacts on tariff charges and costs under proposed recommendations.

1 Response IR-1: 2 (a) Mr. Bowman cannot quantify the specific impact of each proposal on the 3 proposed ELID tariff with any precision, given that Mr. Bowman does not 4 have an operable version of NSP's Cost of Service Model, among other...

AI summary Mr. Bowman acknowledges limitations in quantifying the impact of proposals on the ELID tariff due to lack of access to NSP's Cost of Service Model. He adopts a 120 MW value for ELID projected demand but recommends it be updated with accurate information. He references a prior model showing impacts of changing peak load and compares it to his recommendation.

30 Added peak demand to 120 MW: $9.4 million (may be less, pending NSP analysis) 1 multiple places, NSP indicates that effectively no PHP is load is typically 21 Recommendation 7 is in support of NSP's proposal that PHP be set at the 22 sa...

AI summary The text discusses cost allocations and adjustments related to PHP (Port Hawkesbury Paper) under NSP's (Nova Scotia Power) proposals, including potential savings from DR (Demand Response) and adjustments to DR credits. The estimated total cost allocation to PHP is approximately $48.5 million, with considerations of DR savings and priority interruptibility adjustments.

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

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

15 Response IR-8: 16 (a) Confirmed. As noted in the Settlement Agreement under "PHP Treatment" 17 item (f): "In the PHP ADC and tariff processes that will be brought forward 18 for approval by the Board later this year, it remains open for...

AI summary The response confirms a settlement agreement regarding PHP treatment, noting that parties may take positions on PHP ADC and tariff filings. It emphasizes that the settlement does not determine PHP Revenue-to-Cost ratios but highlights principles for balancing rate impacts.

beyond 2027, the Board direct NSP to develop an approach for verifying a reasonable baseline capacity for PHP that reflects normal business operating needs. e) In InterGroup's view, the SA load parameters were agreed upon by the parties to...

AI summary The Board directs NSP to establish a baseline capacity verification method for PHP post-2027. InterGroup questions NSP's rationale for increasing DR credit sharing from 25% to 100% under the ELID Tariff, noting PHP's existing VCC contributions under ELIADC. CA confirms InterGroup's view that PHP's status as an ATL customer justifies full DR credit allocation.

And, in its Recommendations at p. 2/pdf p. 4: Recommendation 2: InterGroup recommends that the Board consider the reasonableness of the DR savings proposed to be credited to PHP. a) Please identify the specific factors or criteria that Int...

AI summary InterGroup recommends the Board assess the reasonableness of DR savings credited to PHP, considering ELIADC's ADC mechanism issues, benefit-sharing arrangements, and using VCC percentages as a proxy for credit sharing.

IG Request IR-4: - Reference: N-19, Evidence of InterGroup, p. 12/pdf p. 14. - Preamble: In s. 6.0, Proposed ELID Interruptible Rider, InterGroup stated: NSP confirmed that PHP can simultaneously receive (i) a DR credit for being dispatche...

AI summary InterGroup raises concerns that PHP may receive duplicate credits under both the Dispatchable Rider (DR) and Interruptible Rider (IR) for the same load reduction, potentially exceeding 100% system benefits and disadvantaging other customers. The proceeding questions whether this represents a design flaw, how to prevent double-counting, and if it supports limiting IR credit value.

such, NSP proposes to examine the value of PHP's PI service in the next General Rate Application (GRA). - a) Given that LIIR customers who are not on Telemetry and Control ("T&C") can be, and in practice are physically interrupted ahead of...

AI summary NSP questions InterGroup about the practical benefits of PHP's Priority Interruptible designation, arguing that PHP is often dispatched down under DR during system constraints, making the PI status redundant and questioning the 10% credit in the 2026-2027 test years.

CA Response IR-5: a) Yes. - b) Yes, and this is supported by NSP statement that it remains to be determined whether Priority Interruptible service provides value to the system. - c) InterGroup notes that the 2026-2027 GRA SA stipulated tha...

AI summary The response confirms Priority Interruptible service's value remains undetermined. InterGroup references a 10% credit in the 2026-2027 GRA SA for priority interruptibility, noting load parameters were agreed upon for NSPI's Above-the-Line tariff in 2026-2027 test years.

Reference: N-19, Evidence of InterGroup, p. 13/pdf p. 15. - Recommendation: Based on these considerations, the Board should approve the Interruptible Service component to the ELID Tariff only for the 2026 and 2027 test years with a review...

AI summary InterGroup recommends approving the Interruptible Service component to the ELID Tariff only for 2026-2027, pending a 2028 review. It questions the Board's approval of a 10% premium without quantified value for priority interruptibility service and requests specifics on factual matters requiring review.

IG Request IR-7: - c) Does InterGroup agree that if the review confirms that PHP is essentially never interruptible in practice, having already been optimally dispatched, then the appropriate outcome would be elimination rather than revisi...

AI summary InterGroup addresses questions about the IR credit, recommending elimination if PHP is non-interruptible, opposing reporting obligations for NSPI, and advocating Board approval of Operating Procedures affecting DR credit. It also highlights the complexity of the ELID Tariff requiring a Board review.

the ELID Tariff approved in this Matter after the first year of implementation. - a) Does InterGroup recommend that the Operating Procedures be approved as a pre-condition to approval of the ELID? If not, how or when does InterGroup contem...

AI summary The text raises questions about the approval process for the ELID Tariff, including pre-conditions for approval, the scope and timing of a first-year review, and the frequency of DR credit reporting. It seeks InterGroup's stance on requiring quarterly rather than annual reporting for DR credit calculations.

PHP Request IR-1: Reference: Testimony, page 6. "InterGroup agrees that the revenue-to-cost ratios for 2026 and 2027 were an integral consideration understood by parties to the SA. In InterGroup's experience settlement agreements typically...

AI summary InterGroup agrees that the clauses in the settlement agreement (SA) regarding revenue-to-cost ratios for 2026 and 2027, as well as the deferral account for NSP revenue variances, were integral considerations understood by all parties. They emphasize that other parts of the SA, such as paragraphs e) and f), also play a key role in this understanding.

PHP Request IR-4: Reference: Testimony, pages 6-7. "As confirmed by NSP in various responses to Information Requests from interveners, the billing demand, used in arriving at $13.107/kVA, equals the fixed 65 MW determinant, minus the 8 MW...

AI summary The text discusses the calculation of interruptible demand levels for PHP and LIIR customers, raising questions about metering practices and the appropriateness of using non-coincident PHP peaks and firm demand levels for calculating interruptible demand.

PHP Request IR-5: Reference: Testimony, page 10. "In InterGroup's view, the proposed ELID Tariff includes many moving parts, including changes as compared to the ELIADC Tariff, with complex interactions between different components. Given...

AI summary InterGroup raises concerns about the proposed ELID Tariff, noting its complexity and the significant change in the DR credit ratio to PHP. They suggest the reasonableness of this change should be further tested, highlighting potential interdependencies between different tariff components.

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

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

PHP Request IR-6: Reference: Testimony, page 13. "In InterGroup's view there is a risk the pairing the proposed Dispatchable Rider with the proposed Interruptible Credit credits PHP twice for effectively the same provision." - a) Does Inte...

AI summary InterGroup raises concerns about potential double-counting of benefits if the Dispatchable Rider and Interruptible Credit are paired, as they may both provide savings related to reduced load operations. The questions seek clarification on whether these benefits are distinct and whether the pairing poses a risk.

CA Response IR-6: - a) and b) The stated assertion that the two services are distinct and PHP is being compensated for two separate value streams (IR for planning relief (i.e the avoided cost of building new generation) and DR for operatio...

AI summary The document discusses the potential for duplicate compensation to PHP under two separate mechanisms — the Dispatchable Rider and the Interruptible Credit — due to overlapping load reductions. NSP confirmed that PHP has not been called for load reductions under the ELIADC Tariff and that during capacity scarcity, PHP load is already dispatched down, raising concerns about double-counting of credits.

expected PHP gross load and, most importantly, the likely output from Goose Harbour at a facility capacity of 168 MW" (page 35, lines 11-14); and "[i]n addition to correcting the Energy Charge rates, we recommend that a true-up mechanism b...

AI summary The text discusses adjusting Energy Charge rates and proposes a true-up mechanism to address deviations in PHP net load expectations, referencing the Goose Harbour facility's 168 MW capacity.

Request IR-11: 2 Reference: N-20, Bates White Evidence, p.8, lines 22-24: In addition to correcting the Energy Charge rates, we recommend that a true- up mechanism be created to address substantial deviations of PHP net load from expectati...

AI summary The text recommends creating a 'true-up mechanism' to address significant deviations in PHP's net load from expected levels, including scenarios where annual net load under the tariff rate could be zero. This mechanism would correct Energy Charge rates and account for extreme but plausible deviations.

Request IR-1: - Does Bates White consider the proposed ELID Tariff to be consistent with: - (a) The provisions of the General Rate Application Settlement Agreement? If not, please explain why not. - (b) The provisions of the Power Sales Ag...

AI summary The document contains a request (IR-1) asking Bates White to evaluate the proposed ELID Tariff's consistency with the General Rate Application Settlement Agreement and the Power Sales Agreement.

Response IR-1: - (a) As it relates to our scope of work explained at page 7 of our Evidence, we identified no inconsistencies between the ELID Tariff proposal and the GRA Settlement Agreement. - (b) Our Evidence did not identify any incons...

AI summary The response indicates no inconsistencies between the ELID Tariff proposal and the GRA Settlement Agreement or the Goose Harbour Power Sales Agreement. However, it highlights that the PSA's terms may hinder PHP from paying its properly allocated embedded costs as an above-the-line customer under the proposed ELID Tariff.

Issued at Halifax, Nova Scotia, this 22nd day of June 2026. 1 Request IR-1: 29 (e) Please define precisely what is meant by "induce participation" including: 30 i. The economic threshold or criteria used to determine whether 31 PHP is "ind...

AI summary The document requests a precise definition of 'induce participation' in the context of rate-setting, including economic thresholds, criteria for determining participation, subjective inducement, and how these criteria are measured and verified for regulatory purposes. It also asks for regulatory precedents and analysis on determining a reasonable portion of benefits.

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

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

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

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

Request IR-1: Does Synapse consider the proposed ELID Tariff to be consistent with the provisions of the General Rate Application Settlement Agreement? If not, please explain why not.

AI summary The document poses a question to Synapse regarding whether the proposed ELID Tariff aligns with the provisions of the General Rate Application Settlement Agreement.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

APPROVE? A We disagree with Bates White's flat rejection of the DR credit. While the calculation involves after-the-fact cost simulations, Bates White itself concedes in its response to PHP-IR-2(a) and its direct evidence that the mechanis...

AI summary The text argues against Bates White's rejection of the DR credit, suggesting it could be effective with additional reporting requirements and verifiability measures. The Board is urged to approve the DR credit framework with enhancements agreed upon by NS Power and PHP.

l continue under the ELID to be, why we would shift our load. If we fail to shift our load from time to time to lower cost hours under the ELID we will simply reduce the potential for a larger credit. Q. Continuing on page 28 of Bates Whit...

AI summary The discussion centers on the DR credit mechanism under the ELID, with PHP emphasizing its intent to shift load to optimize the system and meet Bates White's objectives. PHP requested Bates White to provide additional elaboration but received no recommendations, leaving PHP unable to further address the concerns.

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

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

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

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

Finally, there is a variance in this application with respect to the proposed IR service credit. NS Power recognizes that the established IR credit protocol would produce a larger credit applicable to PHP, if the value of this service was...

AI summary The document discusses discrepancies in the proposed IR service credit, noting that the established protocol would produce a larger credit for PHP if not for the SA. NS Power plans to revisit this in the next GRA. The text also highlights an anomaly in the ATL interruptible service classes, where demand costs are offset by interruptible credits, citing InterGroup evidence that this is unreasonable. The ELID Tariff application is noted for its specific billing methodology.

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

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

NOTICE OF PAPER HEARING _____________________________________________________________________________________ IN THE MATTER OF AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable Above-th...

AI summary Nova Scotia Power Inc. has applied for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Board will conduct a paper hearing, and interested parties may submit written comments or request formal intervenor status by specified deadlines.

NOTICE OF PAPER HEARING _____________________________________________________________________________________ IN THE MATTER OF AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable Above-th...

AI summary Nova Scotia Power Inc. has applied for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Board will conduct a paper hearing, and interested parties can submit written comments or request intervenor status by specified deadlines.

Request IR-2: Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Section 2.4 Interruptible Service, starting at page 8 of 19, and please answer the following: - a) Describe the rationale for the use of the interruptible c...

AI summary This request (IR-2) asks NS Power to explain the rationale, derivation, and changes in the interruptible credit used in the LIIR, the difference between ELID and ELIADC rates, avoided peaker costs, and the implications of redefining the interruptible rider's credit, including the 10% priority credit and its relation to ancillary services.

Request IR-4: - Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Section 2.5 Dispatch Rider, starting on page 9 of 19, and please answer the following: - a) Provide the mathematical formulation of the DR credit. - b) Pr...

AI summary This request (IR-4) asks Nova Scotia Power to provide detailed information on the mathematical formulation of the DR credit, methodology for calculating Customer Baseline Load (CBL), explanations of factors influencing CBL, analyses of savings figures, and clarification on the nature of DR credits, ELID charges, and reporting requirements.

Request IR-6: - Refer to M12661, Exhibit N-1, the Application submitted by NS Power, Section 3.1 Consistency with Established Rate-making Practice in Nova Scotia, starting on page 15 of 19, and please answer the following: - a) Confirm if...

AI summary Request IR-6 asks NS Power to clarify and justify the use of incremental and marginal cost-based mechanisms in the ELID Tariff, compare credits under ELIADC and ELID, and provide detailed calculations and workpapers related to interruptible events, including the Maritime Link trip on February 13, 2026.

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

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

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

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

interruptible transmission rate’s demand charge and this proposed Extra Large Industrial Dispatchable (ELID) tariff’s demand rate provide a like-for-like comparison? Please explain. Request IR-2: Refer to M12661, Exhibit N-1, the Applicati...

AI summary The text requests an explanation on whether the interruptible transmission rate’s demand charge and the proposed Extra Large Industrial Dispatchable (ELID) tariff’s demand rate offer a comparable analysis. It also refers to a specific section of an application submitted by NS Power for further clarification.

tion including any workbooks with formulas intact. 10. Does NS Power believe that the 10% priority credit captures the value of ancillary services implicitly? Please explain answer. Request IR-3: Regarding interruptible events since 2020,...

AI summary The document requests NS Power to explain the 10% priority credit for ancillary services and provides detailed information on interruptible events since 2020, including event counts, MW reductions, durations, and causes. It also asks for the mathematical formulation of the DR credit and methodology for determining the Customer Baseline Load (CBL), referencing a specific application and exhibit.

to M12661, Exhibit N-1, the Application submitted by NS Power, Section 3.1 Consistency with Established Rate-making Practice in Nova Scotia, starting on page 15 of 19, and please answer the following: 1. Confirm if the components listed as...

AI summary The text outlines several requests related to NS Power's application, focusing on the ELID Tariff and its components, including the Customer Charge, Interruptible Rider credit, and DR credit. It asks for definitions, calculation methods, and comparisons of credits under different mechanisms, as well as clarification on cost inclusion and reporting practices.

Request IR-6: Refer to M12661, Exhibit N-2, Evidence of Colin T. Fitzhenry and Michael G. Gorman on behalf of PHP, regarding the non-fuel savings created by the Dispatchable Rider ("DR"), please answer the following: - a) Does PHP believe...

AI summary PHP is being asked about the Dispatchable Rider (DR) and its components, including avoided transmission and production capacity costs, overlap with interruptible credit, and whether the DR credit fully passes benefits to PHP. A table is requested to show which credit corresponds to each value attribute.

M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, R.S.N.S. 1989, c.380, as amended IN THE MATTER OF: Application by Nova Scotia Power Inc. for Approval of an Extra Large Industrial Dispatchable Above-the-Line Tari...

AI summary The Nova Scotia Energy Board has issued information requests to Port Hawkesbury Paper regarding events from 2020 to present related to load reductions and dispatchable events. The requests seek details on the reasons for events, their duration, base load reduction, and 5-minute interval load data.

he Extra Large Industrial Dispatchable (“ELID”) tariff, as described in Exhibit N-1, Extra Large Industrial Dispatchable Tariff Application – Attachment 1. Page 6 of 8. Paragraph 4. Request IR-2: Refer to M12661, Exhibit N-3, the PHP Evide...

AI summary The document outlines requests for information regarding the ELID tariff, including improvements to specific provisions, the design of an ATL tariff, and potential interim service arrangements if PHP does not adopt the ELID tariff. It also references specific exhibits and matter numbers.

iff would occur? 2. Would it be a new ATL or a below-the-line tariff? 3. Would PHP require interim service if the alternative tariff was not developed prior to January 1, 2027? If so, under what rate? Request IR-5: Refer to M12661, Exhibit...

AI summary The text contains a series of regulatory questions and requests related to the development of an alternative tariff, the use of NARUC Manual guidance for interruptible capacity allocations, and the potential penalties for non-performance during interruptible events. It also asks for statistical methods aligned with NARUC principles and critiques of historical peak contribution metrics.

ed by NS Power is not appropriate. 8. If 65MWs reflects the historical reliance of interruptibility (including suppressed meter readings), why is this not an appropriate allocation? Request IR-6: Refer to M12661, Exhibit N-2, Evidence of C...

AI summary The text contains several requests for information related to the Dispatchable Rider (DR) and interruptible credit, including questions about the allocation of capacity, the appropriateness of the DR component, and the valuation of capacity. These requests are part of a regulatory proceeding and involve NS Power and PHP.

March 12, 2026 [[email protected]](mailto:[email protected]) Nancy Rubin Stewart McKelvey Suite 600 – 1741 Lower Water Street P.O. Box 997 Halifax, NS B3J 2X2 Dear Ms. Rubin: M12661 - Nova Scotia Power - Application for a...

AI summary The Board has approved an extension request for the Industrial Group to file Information Requests (IRs) related to Nova Scotia Power's application for an Above-the-Line Tariff applicable to Port Hawkesbury Paper, with the new deadline set for March 13, 2026.

Request IR-3: - On page 10, NS Power proposed that the value created by the dispatch of PHP load should be fully credited to PHP. It also proposed that the cost of the DR service should be included as a FAM cost and recovered from all ATL...

AI summary NS Power proposed that the value from dispatching PHP load be credited fully to PHP and that DR service costs be recovered from all ATL customers, who would be held harmless. Questions are raised about the anticipated dollar value of the dispatch, how ATL customers will be held harmless, and what value other ATL customers receive from the ADC component.

Request IR-4: In its evidence, PHP identified several concerns with the proposed ATL tariff and stated it is unlikely to accept service under that tariff if those concerns are not addressed in a satisfactory manner by the Board. In that si...

AI summary PHP has raised concerns about the proposed ATL tariff and indicated it may not accept service under that tariff unless the Board addresses its concerns. The request asks NS Power to explain prior awareness of these concerns, potential impacts of tariff amendments, and whether BTL tariffs were considered as alternatives.

Request IR-6: - Considering the circumstance where the application is not approved, or considered not to be - acceptable by PHP, and the ELIADC is not extended, and no new BTL rate exists on January 1, - 2027, what is NS Power's understand...

AI summary The text asks NS Power about the default rate for service to PHP if the application is not approved, the ELIADC is not extended, and no new BTL rate exists by January 1, 2027.

iscontinue. 1. Please explain how the $500,000 was derived. 2. With reference to “more review”, please elaborate on what additional review is contemplated and what associated metrics are anticipated. On page 10, NS Power proposed that the...

AI summary The document includes questions raised regarding the derivation of a $500,000 figure, the proposed tariff adjustments by NS Power, and concerns from PHP about the ATL tariff. It also asks about the financial and operational impacts of tariff amendments and whether BTL tariffs were considered.

ase explain whether NS Power contemplated any potential BTL tariffs as potential options if PHP does not accept service under the ATL tariff. Were any such discussions held with PHP? Please elaborate. Considering that the system control fu...

AI summary The text asks NS Power to explain whether it considered BTL tariffs if PHP does not accept the ATL tariff, whether discussions with PHP occurred, if NS Power consulted IESO Nova Scotia on the ATL tariff, and what the default rate would be for PHP if the application is not approved and no new BTL rate exists by January 1, 2027.

Request IR-1: - In its evidence, PHP identified several concerns with the proposed ATL tariff and stated it is unlikely to accept service under that tariff if those concerns are not addressed in a satisfactory - manner by the Board. In tha...

AI summary PHP has raised concerns about the proposed ATL tariff and indicated it may develop a below-the-line tariff if issues are not resolved. The request asks whether PHP informed NS Power of these concerns, the potential impacts of the ATL tariff, and if discussions about BTL tariffs occurred.

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

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

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

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

1 Request IR-1: 2 As noted in NSPI's Application: 3 4 The Tariff is based on the Large Industrial (LI) Tariff under which the Company's large 5 industrial customers are served. (N-1, page 3 of 19) 6 7 … 8 9 As noted in the SA, for 2026 and...

AI summary The document requests an explanation for why the Large Industrial Interruptible Rider (LIIR) Tariff applies a lower interruptible credit than the Company's established practice and why PHP's interruptible credit should differ from the LIIR Tariff, excluding the priority interruptibility premium.

22 Request IR-2: 23 24 (a) Please provide COSS and resulting tariff reflecting all parameters proposed by PHP in its 25 evidence, including: 26 27 i. designing the capacity charge to reflect PHP's actual 8 MW firm demand rather 28 than the...

AI summary The request asks for updated cost-of-service (COSS) and tariff calculations based on PHP's proposed parameters, including adjustments to capacity charges, interruptible credit, revenue-to-cost ratios, and forecast energy requirements for 2026 and 2027. It also requests updated rates for all customer classes and supporting calculations.

42 Request IR-3: 43 44 (a) Please provide a summary table showing allocated costs and rates for PHP and all other 45 ATL classes for 2026 and 2027 in these three scenarios: 46 - 1 i. NSPI's proposed ELID Tariff as filed; - 2 ii. PHP's prop...

AI summary The request asks for a summary table of allocated costs and rates for PHP and other ATL classes under three scenarios for 2026 and 2027, as well as an analysis of the implications for NSPI's proposed PHP deferral account balance in 2027.

29 Request IR-5: 30 In their evidence, Brubaker & Associates state: 31 32 If the ELID capacity charge is designed to include the cost of firm demand service for a 65 33 MW tariff capacity, then the interruptible credit should be applied to...

AI summary Brubaker & Associates argue that the ELID capacity charge should reflect the marginal cost of capacity, and that the interruptible credit should be applied to 57 MW of the 65 MW service. They request confirmation that the ELID tariff aligns with this position, except for the interruptible credit price.

14 Request IR-7: 15 What will NSPI decide beyond 2026 (when the current ELIADC tariff expires) in the event PHP 16 does not accept service under the ELID tariff? Please set out NSPI's proposed process and 17 timelines for negotiated BTL ta...

AI summary The request asks NSPI to outline its decision-making process and proposed timelines for a negotiated BTL tariff after the ELIADC tariff expires in 2026, assuming PHP 16 does not accept service under the ELID tariff.

M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , R.S.N.S. 1989, c. 380 as amended -and- IN THE MATTER OF: AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable A...

AI summary The Consumer Advocate has submitted information requests to Nova Scotia Power Inc regarding the proposed Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The requests focus on the discrepancy between the interruptible credit in the proposed tariff and the company’s established pricing practices.

ctice for pricing of the interruptible credit? 2. Please explain why PHP’s interruptible credit should differ from the LIIR Tariff (excluding the priority interruptibility premium)? Request IR-2: 1. Please provide COSS and resulting tariff...

AI summary The text outlines several requests related to the pricing of interruptible credit, tariff design, and cost-of-service models for PHP, including adjustments to capacity charges, revenue-to-cost ratios, and implications for deferral account balances. These requests are part of a regulatory proceeding involving Nova Scotia Power Inc.

d. This interruptible credit should be priced at NS Power’s estimated marginal cost of capacity of $13.107/KVA, and updated in the next GRA filing to reflect the current cost of capacity. (N-2 page 3) Please confirm that other than the int...

AI summary The document discusses the pricing of an interruptible credit for NS Power, the ELID tariff design, and cost recovery for interruptible demand. It also requests clarification on tariff design, cost allocation differences, and NSPI’s plans if PHP does not accept the ELID tariff post-2026.

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

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

1 2 M12661 3 4 NOVA SCOTIA ENERGY BOARD 5 6 7 IN THE MATTER OF: The Public Utilities Act, R.S.N.S. 1989, c. 380 as amended 8 -and 9 10 IN THE MATTER OF: AN APPLICATION by NOVA SCOTIA POWER 11 INCORPORATED for approval of an Extra Large Ind...

AI summary The document outlines an information request related to an application by Nova Scotia Power for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Consumer Advocate is requesting responses from Melanie Gillis of Port Hawkesbury Paper LP by April 10, 2026.

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

AI summary Brubaker & Associates argue that interruptible demand will not require a capacity charge as it is served on an as-available basis, and that NS Power can recover costs through the ELID energy charge. PHP's firm demand contributes 8 MW to NS Power's peak demand, and any demand above this will be covered by the ELID energy rate without an interruptible credit.

3 Request IR-3: 4 In their evidence, Brubaker & Associates state: 5 6 Q IF THE ELID INTERRUPTIBLE CREDIT WAS SET AT NS POWER'S AVOIDED 7 CAPACITY COST OF $13.107/KVA, WOULD PHP PAY ANY CAPACITY COST FOR 8 ITS INTERRUPTIBLE SERVICE? 9 10 A...

AI summary Brubaker & Associates explain that if the ELID interruptible credit is set at NS Power's avoided capacity cost, PHP would still pay capacity costs due to the proposed ELID energy charge exceeding NS Power's average fuel cost, resulting in non-fuel margins being collected by NS Power.

33 Request IR-4: 34 In its evidence, PHP states: 35 36 PHP has the following specific areas of concern with respect to the proposed Above-the-37 Line Tariff: 38 39 (1) the use of a 57,000 kW winter month system coincident demand for PHP 40...

AI summary PHP raises concerns regarding the proposed Above-the-Line Tariff, specifically about the use of a 57,000 kW winter month system coincident demand for interruptible load, the value of the Interruptible credit, the R/C ratio, and outdated energy requirement forecasts for 2026 and 2027.

5 Request IR-5: 6 In its evidence, PHP states: 7 8 Unless PHP's areas of concern are addressed by the Board in a satisfactory manner it is 9 unlikely PHP will proceed to accept service under the ELID tariff. PHP would need to 10 undertake...

AI summary PHP expresses concerns about the ELID tariff and indicates it may not proceed with service under it unless the Board addresses its concerns satisfactorily. It also mentions the possibility of developing a below-the-line tariff with NS Power if the ELID tariff is not acceptable.

17 Request IR-6: 18 In its evidence, PHP proposes the following modifications to the proposed ELID tariff: 19 - 20 1. designing the capacity charge to reflect PHP's actual 8 MW firm demand rather than the 21 proposed 65 MW; - 22 2. adjusti...

AI summary PHP proposes modifications to the ELID tariff, including adjusting the capacity charge, interruptible credit, revenue-to-cost ratio, and updating load forecasts. The request asks whether these changes are consistent with the 2026-2027 GRA settlement agreement and whether they require reopening previous agreements.

M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , R.S.N.S. 1989, c. 380 as amended -and- IN THE MATTER OF: AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable A...

AI summary The Consumer Advocate has requested information regarding the ELID tariff for Port Hawkesbury Paper, including claims by Brubaker & Associates that interruptible demand will not require capacity charges and will be recovered through the ELID energy charge.

non-fuel cost of service. Under this ELID design, the ELID will not require an interruptible credit for NS Power interruptible power supply above PHP’s firm demand of 8 MW. (N-2, page 2) And further PHP firm demand service will contribute...

AI summary The text discusses the ELID design and its implications for interruptible credits and capacity costs. It outlines how PHP’s firm demand contributes to NS Power’s capacity costs and how the ELID tariff structure handles interruptible service. Questions are raised about the application of interruptible credits and capacity costs under the proposed ELID tariff.

ir evidence, Brubaker & Associates state: Q IF THE ELID INTERRUPTIBLE CREDIT WAS SET AT NS POWER’S AVOIDED CAPACITY COST OF $13.107/KVA, WOULD PHP PAY ANY CAPACITY COST FOR ITS INTERRUPTIBLE SERVICE? A Yes. The proposed ELID 2027 energy ch...

AI summary The ELID interruptible credit is based on NS Power's avoided capacity cost of $13.107/KVA. PHP would still pay capacity costs due to the difference between the proposed demand charge and the credit. NS Power argues that the credit should reflect the system benefits of PHP's interruptible load, and PHP's position on the coincident peak parameter is requested.

h firm and interruptible demand (8 MW plus 57 MW)? Request IR-4: In its evidence, PHP states: PHP has the following specific areas of concern with respect to the proposed Above-the-Line Tariff: (1) the use of a 57,000 kW winter month syste...

AI summary PHP raises concerns about the ELID tariff, including the use of a specific winter month system coincident demand value, the Interruptible credit value, the R/C ratio, and outdated energy forecast assumptions. PHP also indicates it may not accept the ELID tariff unless its concerns are addressed and may seek a below-the-line tariff with NS Power if needed.

all its recommendations are fully accepted or does PHP have any flexibility in this respect? Request IR-6: In its evidence, PHP proposes the following modifications to the proposed ELID tariff: 1. designing the capacity charge to reflect P...

AI summary PHP proposes modifications to the ELID tariff, including adjusting the capacity charge, interruptible credit, revenue-to-cost ratio, and energy forecast assumptions. The inquiry asks whether these modifications are consistent with the 2026-2027 GRA settlement agreement.

al ancillary service value, that is in addition to the ADC value and the priority interruptible value associated with any ATL tariff, as part of the approval of a new ATL Tariff for PHP. (N-3 page 13) 1. Does PHP have any proposal on how t...

AI summary The text raises two questions regarding PHP's proposals for an additional ancillary service value in a new ATL Tariff and its plans beyond 2026 if it does not accept the ELID tariff. The questions focus on PHP's approach to tariff approval and its proposed process for a BTL tariff after the ELIADC tariff expires.

March 12, 2026 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M12661 – Application for an Above-the-Line Tariff Applicable to Port Hawkesbury Paper (PHP) – Nova Scotia...

AI summary Nova Scotia Power Inc. (NS Power) has submitted information requests to Port Hawkesbury Paper (PHP) as part of an application for an above-the-line tariff. NS Power is seeking confidential treatment for certain customer-specific information contained in the requests, in accordance with Board Regulatory Rule 12.

M12661 – NS Power Application for Approval of the ELID Tariff NSPI Information Requests to PHP 1 Request IR-1: 2 3 Reference: NS Power Application, page 3 of 19. 4 5 6 7 8 9 10 The Tariff costing and billing parameters are applied as noted...

AI summary The document outlines NS Power's application for the ELID Tariff and includes PHP's response to the proposed Above-the-Line Tariff. PHP raises concerns regarding the winter month system coincident demand, the Interruptible credit value, the R/C ratio, and the forecast energy requirements used in the calculation of the new tariff.

PARTIALLY CONFIDENTIAL 1 (ii) PHP's firm, plus interruptible load, at a forecast of 65 MW based on prior 2 actual PHP metered load at the time of NS Power's 3 coincident peaks (3-CP); 3 4 (iii) PHP energy will be based on PHP's forecast us...

AI summary The document outlines details regarding PHP's load forecasts, interruptible load credits, and revenue-to-cost ratios. It requests confirmation on the revenue-to-cost ratio applied to PHP, the recovery of transmission cost savings, and the transmission costs for Large Industrial Interruptible Rider customers. The ratios provided are 1.04373 and 1.04713 for 2026.

Request IR-2: 10 11 Reference: Evidence of Colin T. Fitzhenry and Michael P. Gorman (BAI), page 19. 12 13 14 15 NS Power provided an updated COSS for 2026 and 2027 based on a reduction in PHP's total demand coincident with the winter syste...

AI summary NS Power has provided an updated COSS for 2026 and 2027, showing a significant reduction in PHP's winter system peak demand, which would result in a rate reduction of approximately $6.5 million in 2026 and $9.4 million in 2027.

M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION by NOVA SCOTIA POWER INCORPORATED for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable t...

AI summary The Nova Scotia Energy Board has issued information requests to Port Hawkesbury Paper in response to Nova Scotia Power Inc.'s application for an Extra Large Industrial Dispatchable Above-the-Line Tariff. The requests pertain to settlement terms, energy supply protocols, and clarification on base load values.

ocol. 1. Refer to the Direct Testimony of Port Hawkesbury Paper, p. 5, lines 3-4. Please confirm that “base load” is 8 MW. If not confirmed, please provide the value and an explanation of the value. 1. Refer to the Direct Testimony of Port...

AI summary The text includes several requests for clarification and explanation related to a regulatory proceeding, including inquiries about base load capacity, tariff options, and references to evidence submissions. It also asks for a reference to another piece of direct evidence.

- a. Please provide NS Power's most recently filed cost of service study in Excel with working formulas. - b. Please provide the allocators associated with each cost category in NS Power's most recent cost of service study along with a bri...

AI summary The document requests detailed information from NS Power regarding their cost of service study, including allocators, derivation of allocators, stakeholder input, and modifications to cost allocation methods. It also asks for an explanation of the LIIR credit amounts for 2026 and 2027, along with associated workpapers.

- b. Please provide the workpapers calculating each rate element of the Large Industrial tariff. 1 c. Please explain why the LIIR credit is lower than that which would have been 2 developed in accordance with the Company's established prac...

AI summary The text includes a series of requests related to the Large Industrial Interruptible Rider (LIIR) and the Extra Large Industrial Dispatchable (ELID) tariff, asking for details on load reductions, interruptions, and system peaks. These requests are part of a regulatory proceeding involving Nova Scotia Power (NSP).

- The application states "In this regard, dispatch service is comparable to interruptible service - available to LIIR customers." On page 8 of the application "the proposed interruptible credit - applicable to PHP is the same as proposed f...

AI summary The document requests clarification on the differences between interruptible and dispatchable riders, the necessity of the dispatchable rider despite the ELID tariff's interruptible credit, and whether PHP could be credited under both riders without double-counting. It also asks for examples of how each rider affects load and if the interruptible rider could be adapted to provide similar benefits.

Request IR-15: Refer to the Application, p. 9, lines 20-24. - a. Please explain if PHP would be incented to reduce load due to priority interruptibility orders if the ELID tariff included the interruptible service credit and priority inter...

AI summary The request seeks clarification on whether the PHP would be incentivized to reduce load under the ELID tariff if the dispatchable rider is excluded, and whether priority interruption depends on the presence of the dispatchable rider. It also asks for an explanation of how past curtailments of PHP load were attributed to interruption credits or the ADC (now the dispatchable rider).

- iii. Interruptible rider to the ELID Tariff 1 1. Billed interruptible demand 2 2. Contracted firm demand requirement 3 3. Total billing demand 4 4. Interruptible demand used for costing the tariff 5 5. Firm billing effective at that time...

AI summary The text outlines the structure of the Interruptible rider and Dispatchable Rider to the ELID Tariff, including billing demand, contracted firm demand, and customer load. It also includes requests for explanations and financial analyses related to the proposed tariff changes and PHP.

- i. If so, could the Order of Interruptibility be broken into two components 2-A and 2-B with the riders ordered appropriately?

AI summary The text raises a question regarding whether the Order of Interruptibility can be divided into two components, 2-A and 2-B, with appropriate riders ordered accordingly.

1. Refer to NS Power’s Application, p. 3, lines 8-10 regarding the expiration of the ELIADC tariff by the end of 2026 and an “alternative course of action” if Port Hawkesbury Paper LP (PHP) will not subscribe to the Extra Large Industrial...

AI summary The text outlines questions regarding the ELIADC tariff expiration, alternative tariffs for Port Hawkesbury Paper LP, and the distinction between above-the-line and below-the-line tariffs. It also requests information on cost allocation in NS Power’s cost of service study.

g whether a tariff is treated as ATL or BTL. 3. Regarding allocation of costs to PHP in NS Power’s cost of service study: 1. Please provide NS Power’s most recently filed cost of service study in Excel with working formulas. 2. Please prov...

AI summary The document requests detailed information on cost allocation methods, tariff structures, and stakeholder input related to NS Power's cost of service study and the Large Industrial Interruptible Rider (LIIR), including formulas, allocators, derivation processes, and feedback received.

t once, and how would this be broken out across different individual customers? 6. Refer to the Application, p. 3, regarding the ELID tariff being based on the Large Industrial tariff. 1. In Excel with working formulas and all billing dete...

AI summary The text requests detailed analysis of billing scenarios for PHP under various tariff structures, including the Large Industrial (LI) tariff, Real Time Pricing tariff, and Large Industrial Interruptible Rider (LIIR). It also inquires about potential differences in load and billing impacts based on these tariff structures.

been enrolled in the Large Industrial Interruptible Rider for 2023 and 2024. 7. Refer to the Application, p. 3, lines 13-15. Are there any differences between the “Dispatchable Rider” under the ELID tariff and the “Active Demand Control” u...

AI summary The text outlines a series of questions directed at an applicant regarding the Large Industrial Interruptible Rider (LIIR), the Dispatchable Rider under the ELID tariff, and the Active Demand Control under the ELIADC tariff. It also requests clarification on the derivation of firm and interruptible load calculations, the use of three coincident peaks (3CP) for billing determinants, and differences in how NS Power manages firm and interruptible load.

from PHP during the winter peak, as well as the PHP firm load amount that the asset was designed to serve. 7. What firm load from PHP was the Port Hawkesbury Biomass plant designed to accommodate? 1. Refer to the Application, p. 8, lines 3...

AI summary The document includes questions about the Port Hawkesbury Biomass plant's capacity to serve PHP firm load, the derivation of a 10% credit for priority interruptible service, and the rationale for matching winter month system coincident demand with negotiated firm plus interruptible demand. It also asks for NS Power’s forecast for avoided costs and the comparison of dispatch service to interruptible service for LIIR customers.

ch service is comparable to interruptible service available to LIIR customers.” On page 8 of the application “the proposed interruptible credit applicable to PHP is the same as proposed for the LIIR.” 1. Please clarify and explain the diff...

AI summary The document requests clarification on the differences between interruptible and dispatchable riders, the necessity of the dispatchable rider despite existing interruptible credits, potential double-counting of credits, and whether the interruptible rider could be adapted to serve the same purpose. An Excel example is also requested to illustrate load changes under each rider.

atchable rider in place. 5. Please provide an illustrative example in Excel of a change in load due to the use of the dispatchable rider compared to a change in load due to the interruptible credit.

AI summary The document requests an illustrative example in Excel format comparing changes in load due to the use of a dispatchable rider versus changes in load due to an interruptible credit.

1. Refer to the Application, p. 9, lines 20-24. 1. Please explain if PHP would be incented to reduce load due to priority interruptibility orders if the ELID tariff included the interruptible service credit and priority interruptible credi...

AI summary The text contains a series of questions directed at clarifying aspects of the PHP tariff, interruptibility credits, dispatchable rider implications, and the financial impact of the Goose Harbour Lake Wind Farm on PHP bills. The questions seek explanations on incentives, calculation methods, and tariff changes.

r each of the following terms within the proposed Tariff, please describe if the PHPW PPA changes the calculation of the value after it enters service. If it does change the calculation of a value after entering service, please provide a w...

AI summary The text requests clarification on how the PHPW PPA affects the calculation of demand charges, minimum charges, and interruptible/dispatchable riders in the ELID Tariff. It also asks for an explanation of NS Power's conclusion regarding the adequacy of firm supply to accommodate an 8 MW increase in 2026.

f 50 MW is fully ignored. Please break the penalty into the threshold and performance penalty components. 2. How would the firm billing be determined for a single month? In this response, please respond to how the “addition” of incremental...

AI summary The text outlines several questions regarding the ELID Tariff, including how penalties are calculated, how firm billing is determined, and the order of interruptibility. It also requests specific data on penalty payments incurred by PHP and details on the capacity and dispatch order of different tiers within the tariff.

ruptibility be broken into two components 2-A and 2-B with the riders ordered appropriately? 2. Can PHP be dispatched for load reduction prior to the first tier of interruptible load being interrupted, that being Generation Replacement and...

AI summary The text outlines a series of questions related to load management, interruptible load, and operating reserve in the context of energy regulation. It seeks clarification on the dispatch order of PHP, the splitting of load, the meaning of holding load as Operating Reserve, and the derivation of the ELID priority interruptible credit.

l examples of a comparable priority interruptible credit, if such a credit existed previously. If such a credit previously existed, please provide workpapers deriving the value of the credit. 10. Are the Generation Replacement and Load Fol...

AI summary The document contains a series of questions regarding interruptible and dispatchable load management, including the difference between dispatching and interrupting load, the application of the Interruptible Rider to load above a customer’s firm contracted load, and the calculation of system costs and load factors. Workpapers and Excel spreadsheets are requested for these inquiries.

f the high load factor customer profile would be entirely firm high load factor load or firm plus interruptible high load factor load. If both firm and interruptible load are included, please explain how much of the high load factor load i...

AI summary The document requests clarification on the composition of high load factor customer profiles, the billing implications of load reduction methods for PHP, and details on deferral accounts related to PHP treatment in NS Power’s application. It also asks for references to settlement terms and tariff proposals.

1. Refer to the Direct Evidence of Port Hawkesbury Paper LP, p. 12, line 15 to page 13 line 9. 1. Please describe if NS Power agrees with the characterization of the event. If not, please provide any corrections. 2. Please describe why the...

AI summary The document contains a series of questions directed at NS Power regarding the implementation of load reductions under the ELIADC tariff, specifically focusing on the 60 MW load reduction event and whether the ADC and interruption protocol were followed. It also inquires about interruptions and direct control actions for PHP during specific peak periods.

Reference: Application, page 5, line 21 to page 6, line 2. "As proposed, rather than relying solely on PHP metered data at the time of the 3CPs, the setting of the PHP coincident peaks for costing and pricing purposes will require judgment...

AI summary The document discusses the proposed method for setting PHP coincident peaks for costing and pricing purposes, emphasizing the need for judgment in determining representative demand levels. It highlights the variability of PHP demand based on system load conditions and the Dispatchable Rider, suggesting that the PHP demand determinant should be reviewed and set during the GRA process or related proceedings like the Fuel Adjustment Mechanism (FAM).

Question: (a) Please confirm that these proposed energy charges do not include any costs associated with the securitization deferral account as proposed in the GRA. (b) Please provide a calculation of the proposed securitization rider appl...

AI summary The question asks about the inclusion of securitization deferral account costs in proposed energy charges, a calculation of the securitization rider for 2026 and 2027, and the impact on demand and energy charges if securitization is not approved. It also references a lower interruptible credit for PHP compared to the company's established practice.

Questions: (a) Please confirm that NS Power simply used the credit applicable to Large Industrial Interruptible customers as the credit to be applied to PHP's interruptible load on the basis that this was the language of section c) of the...

AI summary The document contains several questions directed at NS Power regarding the application of interruptible credits to PHP's load, cost causation, and the inclusion of an interest component in the credit payable to PHP under the Dispatchable Rider. Issues include the use of the Large Industrial Interruptible credit, cost of service treatment, and the approval of the ELID Tariff.

2026 M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and IN THE MATTER OF: An Application by Nova Scotia Power Inc. (“NS Power”) for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applic...

AI summary Port Hawkesbury Paper LP is requesting NS Power to provide a breakdown of hourly Net Load by Customer Class, including PHP, from Figures 4 and 5 of the Cold Weather Event Report. This relates to the allocation of demand-related costs under the ELID Tariff class based on PHP assigned demand at the time of the three coincident peaks (3CP).

justify this outcome. If not, please explain. - h) Please confirm that the Dispatchable Rider costs are recovered from FAM customers. Request IR-10: Please refer to the Goose Harbour PPA and PSA. - a) Please confirm that the PPA and PSA do...

AI summary The text includes several requests related to the Dispatchable Rider costs, the Goose Harbour PPA and PSA, and the ELID Tariff. It asks for confirmation on whether costs are recovered from FAM customers, whether transmission losses are accounted for, and whether penalties apply for delays in commercial operations.

1. Please refer to Exhibit N-1, section 2.1 and Attachment 3. 2. Why did NSPI select the “low range” of costs as the basis for calculating the Customer Charge? 3. If the actual costs to administer the tariff exceed the “low range,” who wil...

AI summary The text contains a series of questions directed to NSPI regarding cost assumptions, tariff administration, and the potential impact of PHP's requests to update energy and generation forecasts on other FAM customers. It also asks whether these requests violate the GRA Settlement Agreement.

25. Please provide PHP’s annual energy demand forecast for 2020, 2021, 2022, 2023, 2024, and 2025. For clarity, this request refers to forecasts developed by PHP and provided to NSPI. 26. Please provide PHP’s actual annual energy demand fo...

AI summary The text contains a series of questions directed at Nova Scotia Power Inc. (NSPI) and Prince Heritage Power (PHP) regarding energy demand forecasts, financial assumptions, and the impact of various scenarios on the FAM balance, as well as inquiries about the ELID Tariff and PHP’s financial condition.

cheduling in any way? Please explain. 47. Under the ELID Tariff, will NSPI be providing PHP with hourly loading schedules that are based on system cost optimization? Please explain. 48. Does the ELID Tariff contain any enforcement or penal...

AI summary The text consists of a series of questions regarding the ELID Tariff, Dispatchable Rider, and related agreements involving NSPI and PHP. It addresses topics such as dispatch instructions, enforcement mechanisms, cost recovery, and the terms of the PPA and PSA.

INFORMATION REQUESTS To: James MacDuff Legal Counsel McInnes Cooper 1300 – 1969 Upper Water Street Purdy's Wharf, Tower II Halifax, NS B3J 2V1 By e-mail: [email protected] From: Bates White LLC Responses Due : Thursday, March...

AI summary The document contains information requests from Bates White LLC to James MacDuff of McInnes Cooper, seeking PHP's financial statements, cost modeling under alternative tariffs, explanations of seasonal demand fluctuations, and energy forecasts for 2026 and 2027, as well as an assessment of potential contraventions of the GRA Settlement Agreement.

18 Request IR-6: 19 Reference: N-1, ELID Application, Attachment 1, ELID Tariff, page 1 of 8. Demand Charge…. Once established through a General Rate Application, Fuel Adjustment Mechanism (FAM) proceeding, Rider proceeding, etc. or as oth...

AI summary This section of the regulatory proceeding document references a 'Rider proceeding' and a 'FAM proceeding' in the context of demand charge establishment. It also asks about the process for conducting a Grid Reliability Assessment (GRA) in the absence of one, within the scope of an AA/BA proceeding or otherwise.

5 Reference: N-1, ELID Application, page 9 – Priority Interruptible Credit. - 6 (a) Please provide all workpapers, calculations, and analysis supporting the 7 value of $0.764/kVA and $0.767/kVA as the priority interruptible credit, and 8 s...

AI summary The text requests detailed explanations and supporting documentation for the calculation of the priority interruptible credit values ($0.764/kVA and $0.767/kVA), specifically how the 10% premium over the standard interruptible credit was derived. It also inquires whether the credit is based on actual incremental avoided costs or is a policy decision, and asks for historical context on its application.

1 Request IR-18: 2 Reference: N-1, ELID Application, page 10, lines 9-12. 21 (i) Does this mean zero increase in costs for ATL classes? 22 (ii) Does this mean zero change in risk? 23 (iii) Does this mean no increased rider volatility? 24 (...

AI summary The text contains a series of questions from Request IR-18, focusing on whether ATL customers are 'held harmless' under the Demand Response (DR) mechanism, and whether there are scenarios where they might not be. It also asks for quantitative analyses, models, and simulations to support these claims.

- 8 (b) If PHP is dispatched down entirely that is, to its firm level of 8 MW 9 through the Dispatchable Rider, will NSPI simultaneously consider that 10 PHP has been "interrupted" within the meaning of the Interruptible Rider? 11 If not,...

AI summary The text raises questions about how Nova Scotia Power Incorporated (NSPI) would handle scenarios where Port Hawkesbury Paper (PHP) is dispatched down under the Dispatchable Rider and whether this would be considered an interruption under the Interruptible Rider. It also inquires if PHP could receive both a DR credit and an interruptible credit for the same load reduction and how NSPI would avoid double-counting.

21 Reference: N-1, ELID Application, Attachment 1, ELID Tariff, page 7 of 8 In situations in which load of the Customer under this Tariff is held as Operating Reserve, NS Power may change the above order of interruption by interrupting Lar...

AI summary The text discusses a provision in the ELID Tariff allowing NS Power to change the order of interruption, potentially interrupting LIIR customers before PHP. Questions are raised about the circumstances under which this might occur, its interaction with the priority interruptible credit, and whether LIIR customers have been interrupted ahead of PHP under ELIADC in the past.

12 Request IR-26: 13 Reference: N-1, ELID Application, Attachment 1, page 8 of 8. Customers taking service under the ELID Tariff will also be subscribed to this Dispatchable Rider (DR). Under this Rider, NS Power will be able to actively m...

AI summary The text discusses the ELID Tariff and the Dispatchable Rider (DR), which allows NS Power to manage customer load under specific terms and conditions. It requests the specific process or operating protocol NSPI will use to document whether load reductions at PHP are made under the Interruptible Rider or the Operating Procedure under the Dispatchable Rider.

purposes throughout the year (i.e. the PHP 3CP figure employed for Tariff costing and pricing would also be applied for billing purposes essentially making the demand cost recovery a fixed charge). 1. Are there any other ATL customer class...

AI summary The text discusses the billing practices for demand charges, specifically the use of the PHP 3CP figure for fixed demand charges and the procedures for revising such charges through regulatory processes. It also references a Rider proceeding and a FAM proceeding, and asks for clarification on these terms and their application.

ID Application, page 7. Preamble: NSPI indicates the cost-of-service information is contained in files associated with M12451, General Rate Application, specifically SR-01 and associated Attachments. Please provide either a copy of the Cos...

AI summary NSPI refers to cost-of-service information in files related to M12451, General Rate Application, specifically SR-01 and attachments. The request is for copies of these files or references to exhibits containing accurate models.

load levels NSPI considers reasonable for each year. 3. For 2026 and 2027, please provide a version based on PHP BTL, using the updated PHP estimates. Reference: N-1, ELID Application, page 7. Preamble: The Application indicates that the E...

AI summary The text requests clarification on the ELID tariff application, COSS modelling assumptions, and potential economic risks associated with ELID energy consumption patterns. It also asks for confirmation of expected load factors for ELID by 2027.

interruptibility provisions of the ELIADC, separate and apart from having been dispatched down? 7. Please identify each year in which priority interruptibility has been a component of the tariff under which PHP (or its predecessor owners o...

AI summary The text asks about the interruptibility provisions of the ELIADC and whether they apply separately from being dispatched down. It also requests identification of years when priority interruptibility was part of the tariff under which PHP (or its predecessor owners) took service, along with the applicable tariff in each case.

under which PHP (or its predecessor owners of the mill) has taken service and specify the applicable tariff in each case. Reference: N-1, ELID Application, page 9 – Priority Interruptible Credit. 1. Please provide all workpapers, calculati...

AI summary The document requests detailed explanations and supporting calculations regarding the priority interruptible credit values, the derivation of the 10% premium, and the distinction between priority interruptibility and DR dispatch. It also seeks clarification on the conditions under which priority interruptibility might be called upon separately from DR dispatch.

erationally necessary; 2. Materially different from DR dispatch; and 3. Not substitutable with DR load reductions. Reference: N-1, ELID Application, pages 9-11, Dispatchable Rider (DR). 1. Please confirm that, under the proposed Dispatchab...

AI summary The document discusses the proposed Dispatchable Rider (DR) mechanism and its implications on the Fuel Adjustment Mechanism (FAM) accounting for non-ELID customers. It raises questions about how FAM calculations would be based on hypothetical system fuel costs and the complexity of future FAM reviews. The text also references estimated savings from optimal load dispatch, noting that actual benefits may be significantly lower due to operational constraints.

at times, conflict with optimal load dispatch. Based on experience with the ELIADC Tariff, the Company estimates that the actual benefit that can be realized will be approximately half this amount. 1. Please elaborate on the sentence that...

AI summary The text discusses the ELIADC Tariff and its impact on the DR credit, noting that the actual benefit may be half of initial estimates. It requests detailed explanations, data, and calculations related to the DR savings, including how the SEA is considered and the impact of Goose Harbour Lake wind contributions. It also mentions that the DR cost will be recovered from all ATL customers, with ATL customers being held harmless.

, it is expected changes will be required to the FAM Plan of Administration to recognize this and potentially other ELID Tariff elements…. ATL customers will be held harmless under the DR construct. 1. Please provide NSPI's current best es...

AI summary The text requests information about the Fuel Adjustment Mechanism (FAM) and its interaction with the Dispatchable Rider (DR), including cost recovery estimates, proposed changes to the FAM Plan of Administration, and the meaning of 'held harmless' for ATL customers. It also asks for quantitative analyses and potential scenarios where ATL customers may not be held harmless.

outcomes where ATL customers would not be held harmless? Please explain, and discuss the risk factors including those within or outside the control of NSPI. Reference: N-1, ELID Application, page 11. Consistent with the ELIADC Tariff, PHP...

AI summary The text discusses the ELID Application, focusing on the Operating Procedures for PHP under the DR and how they differ from the ELIADC Tariff. It raises questions about the assurance of holding ATL customers harmless, the public interest in reviewing Operating Procedures, and the timeline for their development.

the Operating Procedures? Reference: N-1, ELID Application, page 17. In addition to [fixed cost recovery], the ELID tariff will affect fuel costs borne by other customer classes in two respects: 1. DR service will reduce total system costs...

AI summary The ELID tariff will impact fuel costs for other customer classes, particularly through DR service and incremental costs for serving PHP. The GRA includes DR benefits in the fuel budget but lacks compensation for PHP, which will be addressed via the FAM. The excerpt outlines the relationship between marginal and average fuel costs but does not fully explain how DR credit interacts with these variations.

4. If PHP’s annual savings are over-estimated by 10-20%, what is the dollar estimate year-over-year of additional FAM costs to LI and MI? Reference: N-1, ELID Application, pages 14-15, PHP Deferral. 1. Please provide analysis showing the p...

AI summary The text discusses the potential financial impact of overestimating PHP’s annual savings by 10-20% on FAM costs to LI and MI customer classes, referencing the ELID Application and PHP Deferral. It also outlines the conditions for holding monthly demand charges constant and the calculation of interruptible demand credits.

emand is equal to or less than the contracted firm demand, no interruptible credit shall apply. The billed interruptible demand will be equal to the interruptible demand used for costing the tariff. 1. Please confirm that the "billing dema...

AI summary The text discusses billing demand calculations for interruptible credits, the distinction between being dispatched down under the Dispatchable Rider and being interrupted under the Interruptible Rider, and whether PHP can simultaneously receive both a DR credit and an interruptible credit for the same load reduction. It references the ELID Application and ELID Tariff.

S Power may change the above order of interruption by interrupting Large Industrial Interruptible Rider Tariff customers whose load is not held as Operating Reserve before interrupting the Customer. 1. Please explain in what circumstances...

AI summary The text discusses potential changes to the order of customer interruption under the Large Industrial Interruptible Rider Tariff (LIIR) and Extra Large Industrial Dispatchable Capacity (ELID), raising questions about priority status, credit for interruptibility, and how PHP (Port Hawkesbury Paper) compares to other customers in terms of value and priority.

load after DR load shifting as Operating Reserve, please explain how PHP offers any value over and above any other telemetry customer? Reference: N-1, ELID Application, Attachment 1, page 8 of 8. Customers taking service under the ELID Tar...

AI summary The document discusses the ELID Tariff and Dispatchable Rider (DR) under which NS Power manages customer load, including the distinction between load reductions under the Interruptible Rider and the Operating Procedure. It also outlines the requirement for NS Power to report annually on system savings and provide credits based on cost differentials.

tomer will be entitled to a credit equal to the cost differential between the actual annual system cost and the calculated system cost if the Customer was served under the high load factor scenario. 1. Please compare the reporting provided...

AI summary The text discusses the ELIADC and ELID tariff structures, focusing on reporting requirements, fixed cost revenues for PHP, and the need to update tariffs based on revised energy sales forecasts. It also raises questions about transparency, audit mechanisms, and cost recovery.

avoided peaker cost used in determining the proposed $7.661/kVA monthly credit for both Large Industrial Interruptible and for ELID is out of date and undervalues the benefit of interruptible load. 1. Please indicate whether NSPI considers...

AI summary The document raises concerns about the outdated nature of the $7.661/kVA monthly credit for Large Industrial Interruptible and ELID customers, suggesting it undervalues interruptible load benefits. It requests NSPI's position on the matter and explores potential scenarios for updating the rate, considering fairness and practicality.

1 Request IR-6: - 2 (a) Set out in a single consolidated table BAI's recommended rate for each 3 ELID tariff component for 2026 and 2027, compared to NSPI's proposed 4 rate for the same component. - 5 (b) For each component where BAI recom...

AI summary The document requests a consolidated table comparing BAI's recommended rate for each ELID tariff component in 2026 and 2027 with NSPI's proposed rate. It also asks for the impact of any changes on PHP's annual bill and revenue requirements for other customer classes.

Reference: N-1, ELID Application, page 3. Preamble: NSPI’s Application states that "[t]he Tariff costing and billing parameters are applied as noted in the Settlement Agreement (SA) which underpins the Company's 2026-2027 General Rate Appl...

AI summary The document discusses the consistency of the ELID Tariff with the Settlement Agreement (M12451), the reasonableness of estimated system savings from PHP's load dispatch, and the recommended R/C ratio for ELID. It includes questions for PHP and BAI on these topics.

pt service under the ELID tariff. PHP would need to undertake the development of a below-the-line tariff with NS Power that meets the mill’s needs if it chooses to not accept service under the ELID. 1. Please specifically identify what app...

AI summary PHP is seeking approval from the Board for modifications to the ELID tariff or an alternative below-the-line tariff to meet the mill’s needs. If the ELID tariff is not modified, PHP may decline service under it. The document references a specific event where PHP’s demand was significantly reduced during a peak period.

ing, and that the benefits from the February 13, 2026, Maritime Link event are something that needs to be considered as an "additional ancillary service value" beyond ADC and priority interruptible. 1. Is PHP seeking separate compensation...

AI summary The text discusses the need to consider the benefits from the February 13, 2026, Maritime Link event as an 'additional ancillary service value' beyond ADC and priority interruptible. It asks whether PHP is seeking separate compensation for this value and how it would be funded, as well as how to quantify the system value of off-protocol curtailments provided by PHP.

From: [MacDuff, James](mailto:[email protected]) To: [Henwood, Crystal D](mailto:[email protected]); [Blake Williams](mailto:[email protected]) Cc: [Alissa Whalen](mailto:[email protected]); [Andrew M...

AI summary This email is from James MacDuff to multiple recipients, including Crystal Henwood and Blake Williams, regarding a regulatory proceeding (M12661) concerning Nova Scotia Power's application for approval of an Above-the-Line Tariff for Port Hawkesbury Paper. Attachments include responses to various interveners' inquiries.

a.com>; Michael Murphy ; Mike Willett ; Monique MacLean ; Muhammad Syfuddin Tamim ; Nancy Rubin ; Painting-MacLean, Kimberly ; Patrick Bowman ; Paul Dandurand ; Pronko, Steve ; Rebekah Powell ; Sofia Reiner ; Stefanie DeYoung ; Taylor Mont...

AI summary The email notifies Ms. Henwood that non-confidential Information Requests in Matter M12661 have been posted to the Board's website on behalf of PHP, concerning Nova Scotia Power's application for an Above-the-Line Tariff for Port Hawkesbury Paper.

April 24, 2026 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M12661 Extra Large Industrial Dispatchable (ELID) Tariff – Technical Conference Dear Ms. Henwood: Nova Sc...

AI summary Nova Scotia Power and Port Hawkesbury Paper have agreed to a technical conference to address remaining questions about the proposed ELID Tariff. They request an extension of the timeline for filing intervenor and Board Counsel Consultant Evidence to May 7, 2026, which has been agreed upon by all involved parties.

April 27, 2026 [[email protected]](mailto:[email protected]) Karynne Munroe Manager, Regulatory Affairs Nova Scotia Power Inc. PO Box 910 Halifax, NS B3J 2W5 Dear Ms. Munroe: M12661 - Nova Scotia Power Inc. – Extra Large In...

AI summary Nova Scotia Power Inc. requested an extension for filing evidence in the ELID Tariff proceeding, and the Board agreed to extend the deadline to May 8, 2026, due to overlapping deadlines with another matter.

Request IR-2: Refer to Section V of Bates White Evidence, where Bates White notes that PHP receives significant benefits from the treatment of Goose Harbour output as a direct reduction of its purchases of tariff energy under the ELID Tari...

AI summary The document discusses concerns raised by Bates White regarding the treatment of Goose Harbour output under the ELID Tariff and its impact on PHP's cost allocation. It questions whether this affects the need for robust and verifiable elements of the ELID Tariff, including the Customer Charge and Dispatchable Rider, and whether true-up mechanisms are in place for accurate cost recovery.

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

AI summary The document is an application for approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper, identified as NSEB M12661.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 Does Bates White consider the proposed ELID Tariff to be consistent with: 4 5 (a) The provisions of the General Rate Application Settlement Agreement? If not, 6 please explain why not. 7 8 (b) The provi...

AI summary The document is a non-confidential request (IR-1) from Nova Scotia Power Inc. to Bates White, asking whether the proposed ELID Tariff aligns with the General Rate Application Settlement Agreement and the Power Sales Agreement. Blake Williams, VP of Legal and Regulatory at Nova Scotia Power Inc., is the contact person for this inquiry.

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

AI summary This document outlines an application for the approval of an above-the-line tariff applicable to Port Hawkesbury Paper, identified by the matter number NSEB M12661.

- 3 Does Synapse consider the proposed ELID Tariff to be consistent with the provisions of the - 4 General Rate Application Settlement Agreement? If not, please explain why not. 5 6 Contact Person: Blake Williams VP, Legal and Regulatory N...

AI summary Nova Scotia Power Inc. is being asked whether the proposed ELID Tariff is consistent with the General Rate Application Settlement Agreement. Blake Williams, VP, Legal and Regulatory, is the contact person for the company.

1 2025 M12661 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by Nova Scotia Power Incorporated for 5 approval of an Extra Large Industrial Dispatchable Above-the- 6 Line Tariff ap...

AI summary The Nova Scotia Energy Board is handling a proceeding under the Public Utilities Act regarding an application by Nova Scotia Power Incorporated for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Industrial Group has requested Synapse Energy Economics Ltd. to provide a list of evidence reviewed in preparation of their submission and has raised a question about the significance of a reference to a 'transition' in Synapse's evidence.

1 2025 M12661 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by Nova Scotia Power Incorporated for 5 approval of an Extra Large Industrial Dispatchable Above-the- 6 Line Tariff ap...

AI summary The Nova Scotia Energy Board is handling a proceeding related to an application by Nova Scotia Power Incorporated for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The document includes an information request asking for alternative cost allocation methods for interruptible loads in the context of the SA.

33 that PHP was already contributing to some fixed cost recovery via the VCC 1 in the context of the ELID Tariff; and (ii) whether it would produce a demand 2 cost allocation to PHP that is higher or lower than the 65 MW approach 3 adopted...

AI summary The text discusses the cost allocation to PHP under the ELID Tariff, referencing the Variable Capital Charge (VCC) in the ELIADC Tariff and its role in fixed cost recovery. It also questions whether alternative methods of cost allocation, based on PHP's expected load, are consistent with principles of proper cost allocation for ATL customers.

Preamble: In s. 6.0, Proposed ELID Interruptible Rider, InterGroup stated: NSP confirmed that PHP can simultaneously receive (i) a DR credit for being dispatched down through the Dispatchable Rider and (ii) an interruptible credit for havi...

AI summary InterGroup raises concerns about potential double-counting of credits for PHP under both the Dispatchable Rider and the Interruptible Rider, suggesting this may provide undue benefits to PHP at the expense of other customers. The question asks whether this represents a design flaw and what mechanisms could prevent double-counting.

ence of InterGroup, p. 13/pdf p. 15. NSP further confirmed that LIIR customers who are not held as Operating Reserve could be physically interrupted ahead of PHP despite PHP's priority status…. NSP states that it remains to be determined w...

AI summary NSP acknowledges that Priority Interruptible (PI) service may provide system value but is uncertain about its benefits and cost recovery. NSP proposes to evaluate the value of PI service in the next General Rate Application (GRA).

34 (a) Given that LIIR customers who are not on Telemetry and Control ("T&C") 1 can be, and in practice are physically interrupted ahead of PHP in the 22 (b) Please describe the specific factual matters or analytical issues that 23 InterGr...

AI summary The text discusses the interruption practices of LIIR customers not on Telemetry and Control, and whether the current IR credit value proposed by NSPI is appropriately calibrated given the near-zero probability of PHP load being available for interruptible service.

And at p. 28, lines 14-21: We do not recommend that the Board approve the DR credit as proposed. To be reasonable, at least two things must be true: (1) any payments to PHP from FAM customers under the DR credit must demonstrably tied to P...

AI summary The text critiques the proposed DR credit mechanism, arguing it is too vague and unverifiable. Bates White outlines concerns and suggests revisions for approval. Questions are raised about the necessity of resolving all six concerns, the impact of benefit-sharing arrangements, and potential tariff amendments to address overestimation risks.

2026 M12661 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and IN THE MATTER OF: An Application by Nova Scotia Power Inc. ("NS Power") for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applic...

AI summary The Nova Scotia Energy Board is handling a proceeding regarding an application by Nova Scotia Power Inc. for an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. A request is made to Synapse for analysis on whether PHP's interruptible load has driven or is forecasted to drive incremental transmission investment or capacity expansion in Nova Scotia.

osal, would the expected revenue contribution be based on the percentage of PHP's contribution to NSP's planning reserve margin in relation to the total system planning reserve margin? Please explain. (e) Considering that NSP's Application...

AI summary The text discusses the pricing of interruptible credits for large industrial customers, specifically whether the credit should be based on full marginal cost or adjusted to ensure other customers share benefits. It references NSP's established practices and considerations of system costs and avoided capacity.

t of a new generating unit, it would likely be greater than the conservative estimate of a new gas peaker (last set in 2021) used in the calculation of the Interruptible Rider? If not, please explain. (c) Does Ms. Whited agree that under N...

AI summary The text raises questions about the accuracy of NSP's interruptible rider proposal, specifically regarding the assumed price of a new gas peaker unit and whether other customer classes are benefiting from PHP's interruptibility without bearing the full marginal cost of new generation.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and IN THE MATTER OF: An Application by Nova Scotia Power Inc. ("NS Power") for approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff applicable to Port...

AI summary The Nova Scotia Energy Board is considering an application by Nova Scotia Power Inc. for an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. The Consumer Advocate (InterGroup Consultants) has been asked to respond to several questions regarding settlement agreements, load modeling, and the calculation of interruptible credits and demand charges.

Application by NS Power for Approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff Applicable to Port Hawkesbury Paper (NSUARB M12661) PHP Information Requests to the CA (InterGroup) IR-4 Reference: Testimony, pages 6-7....

AI summary The document discusses an application by NS Power for approval of a tariff for Port Hawkesbury Paper, focusing on the calculation of interruptible demand levels and whether they are metered for LIIR customers. Questions are raised about the methodology used to determine the interruptible credit rate and the appropriateness of using non-coincident PHP peaks for this calculation.

Application by NS Power for Approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff Applicable to Port Hawkesbury Paper (NSUARB M12661) PHP Information Requests to the IG (Bowman) IR-2 Reference: Testimony, pages 6-7, line...

AI summary The document discusses NS Power's application for an Extra Large Industrial Dispatchable Above-the-Line Tariff for Port Hawkesbury Paper. It includes testimony regarding the ELIADC tariff's contribution to NSP's fixed costs and the use of marginal power costs. Questions are raised about whether marginal power costs are used to fund NSP's embedded cost of service and the appropriate capacity value for PHP's tariff.

Application by NS Power for Approval of an Extra Large Industrial Dispatchable Above-the-Line Tariff Applicable to Port Hawkesbury Paper (NSUARB M12661) PHP Information Requests to the IG (Bowman) IR-8 Reference: Testimony, page 18 lines 8...

AI summary NS Power is seeking approval for an ELID tariff for PHP. The testimony by Mr. Bowman raises questions about the alignment of PHP's proposed changes to revenue-to-cost ratios with the NSP GRA negotiated settlement, and whether the ELID tariff was approved in Matter M12451. It also asks about the approval of a deferral account for PHP in that matter.

Statement of Confidentiality This message (including any attachments) may contain private or protected information meant for a specific person or organization. If you received this by mistake, please let the sender know, do not communicate...

AI summary This email is a confidentiality notice related to a regulatory proceeding (M12661) concerning the approval of the ELID Tariff by NSPI. It includes a list of recipients and is addressed to various stakeholders involved in the process.

Re: M12661 – NSPI - ELID Above-the-Line Tariff Application available to PHP When the Board issued its timetable, it included a deadline by which parties could request the current written process be converted to an oral hearing. The Industr...

AI summary The Industrial Group requests the conversion of the tariff proceeding to an oral hearing, citing the lack of a consensus proposal, credibility disputes, complex issues requiring clarification, and the significant impact on ratepayers.

3. The Complexity and Novelty of the Proposed Tariff Require an Oral Hearing Bowman's evidence notes that the proposed ELID rate is "complicated and unusual in utility rate regulation" and that "[n]o comparable rate could be identified in...

AI summary The proposed ELID rate is described as complex and unusual in utility regulation, with no comparable rate in Canada. It combines multiple mechanisms, including an above-the-line cost-of-service framework and production cost simulation, raising concerns about cost recovery and potential financial consequences for ratepayers. The Industrial Group argues for an oral hearing due to the novelty and complexity of the tariff.

July 16, 2026 VIA EMAIL Ms. Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M12661 – NSPI – Application for Approval of an Above-the-Line Tariff applic...

AI summary The Small Business Advocate supports the Industrial Group's request to convert the NSPI application into an oral hearing, citing the complexity of the application and the need for cross-examination to test multiple positions.

Please refer to: David Roberts Email: [[email protected]](mailto:[email protected]) Assistant: Alissa Whalen Assistant's email: [[email protected]](mailto:[email protected]) July 17, 2026 VIA WEB PORTAL VIA EMAIL Crys...

AI summary The Consumer Advocate supports the Industrial Group's request for an oral hearing in M12661, citing unresolved issues and disagreements between Nova Scotia Power, Port Hawkesbury Paper, and parties to the GRA Settlement Agreement regarding the proposed Above-the-Line Tariff.

r.ca>; Pronko, Steve ; Rebekah Powell ; Sofia Reiner ; Stefanie DeYoung ; Taylor Montgomery ; Vincent Musco ; Voytek Grus Subject: [EXTERNAL] M12661 - Nova Scotia Power - Application for approval of an Above-the-Line Tariff applicable to P...

AI summary This email pertains to an external communication regarding M12661, a proceeding involving Nova Scotia Power's application for approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper. The subject indicates a regulatory request by the Board.

derlying the proposed ATL tariff. The rationale outlined in the IG's request largely revisits issues that were extensively detailed and explored during the GRA process and throughout this proceeding. First, the IG points to the existence o...

AI summary The IG's request for an oral hearing is based on differing expert opinions and unresolved issues such as the demand determinant, IR credit, DR design, and PI compensation. However, the Company argues that these issues were already thoroughly addressed during the GRA process and that an oral hearing is not necessary. The Company also confirms its agreement with the GRA Settlement Agreement's ELID tariff parameters.

work. Whether, in a party's view, a tariff is considered "complex" does not make an oral hearing necessary, particularly where the issues have been fully explored through this, and the GRA, processes. Importantly, despite the differing vie...

AI summary The document discusses the regulatory proceeding regarding a tariff application by Nova Scotia Power Inc. (NSPOWER), noting that no party has provided evidence that the application incorrectly implemented parameters from the Settlement Agreement. Disagreements are limited to specific rate design issues, which have already been thoroughly examined in the written record.

at the proposed tariff is complicated and unusual, and the record before the Board did not currently provide it with adequate tools needed to resolve the outstanding issues with confidence or clarity. NS Power submitted there is already an...

AI summary NS Power argues that the extensive record and prior review process provide sufficient information for the Board to approve the proposed above-the-line tariff. It notes that key parameters were accepted in a prior settlement agreement and that differing expert opinions are common and do not require oral examination.

Please refer to: David Roberts Email: [[email protected]](mailto:[email protected]) Assistant: Alissa Whalen Assistant's email: [[email protected]](mailto:[email protected]) July 24, 2026 VIA WEB PORTAL VIA EMAIL Crys...

AI summary The Consumer Advocate, represented by David Roberts of Pink Larkin, requests that Andrew McLaren and Hayitboy Mahmudov of InterGroup Consultants Ltd. appear virtually for a hearing related to Nova Scotia Power's application for an Above-the-Line Tariff for Port Hawkesbury Paper. The request is addressed to Crystal Henwood, Clerk of the Board at the Nova Scotia Energy Board.

From: [Henwood, Crystal D](mailto:[email protected]) To: [Nancy Rubin](mailto:[email protected]); [Aishwarya Saha Srishty;](mailto:[email protected]) [Alissa Whalen](mailto:[email protected]); [Andr...

AI summary This email is from Crystal D Henwood to multiple recipients regarding a regulatory proceeding (M12661) concerning Nova Scotia Power's application for approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (PHP).

atrin MacPhee ; Kristine Burke ; Lana Myatt ; Leona Clements ; Lisa Forsey ; Lori Fancy ; Lucia Westin-Eastaugh ; Mark Peachey ([email protected]) ; Matt Drover ([email protected]) ; Melanie Gillis ; Melissa Davies ; Melissa...

AI summary The email discusses the scheduling of Mr. Patrick Bowman's cross-examination for the M12661 proceeding, noting that he will attend in person on September 28 and 29, and requests that his cross-examination be scheduled on those dates.

[email protected])) [ ; Melanie Gillis [ ; Melissa Davies [ ; Melissa MacAdam [ ; Melissa Whited <[[email protected]>](mailto:[email protected]); Michael Murphy <[[email protected]](mailto:[email protected])...

AI summary This document is a list of email addresses and names of individuals and organizations involved in a regulatory proceeding related to Nova Scotia Power's application for approval of an Above-the-Line Tariff applicable to Port Hawkesbury Paper (PHP), referenced as M12661.