102242Submission - IG
4 passages
1. Actual Benefits to Other Customers Remain Below the Original Forecast It bears repeating that NSPI's 2019 ELIADC Tariff Application forecast annual benefits to other customers ranging from $6 to $13 million over the initial term, with a...
AI summary NSPI's 2019 ELIADC Tariff Application forecast annual benefits of $6–$13 million, but 2025 actual benefits were $4.4 million, 63% below the assumed load and 69% of the forecasted per-MWh benefit. Over six years, average annual benefits were $4.2 million, less than half the forecast. The IG argues this shortfall should be considered for the new ELID tariff in M12661.
3. The Fixed Cost Minimum May Still Be Insufficient In the prior review, all intervenors and Board counsel consultant Bates White had recommended increasing the minimum fixed cost contribution above $4/MWh. The Board directed that the $4/M...
AI summary The Board increased the fixed cost minimum payment from $4/MWh to $5/MWh in 2026, but the IG argues this floor remains insufficient to protect ratepayers. Calculations show the $5/MWh rate would generate a $3.5 million annual floor, less than the $4.4 million 2025 fixed cost recovery benefit, requiring load shifting differentials to yield additional value.
6. Recommendation XV-3 — Detailed Load Shifting Quantification Again Deferred In the 2022-2023 FAM Audit, NSPI accepted the recommendations of Bates White to improve the ELIADC annual reporting. In the ELIADC 2024 Annual Report decision, M...
AI summary The document discusses NSPI's repeated delays in providing detailed load shifting quantification as required by Recommendation XV-3, despite Board directives. The Board criticized NSPI for delaying tariff improvements, citing the 2025 Annual Report's omission of required details. NSPI attributed the 2025 delay to a cyber incident but provided no updates by March 2026. The IG urges the Board to impose a firm deadline for this analysis.
8. Inter-Year Adjustments — Transparency and Comparability The ELIADC Revenue Table for 2025 (Att.1, p.1/3) records a 2024 ADC Adjustment of −$1,221,077 and a 2024 VOM Adjustment of +$52,067 within the 2025 annual figures. 6 Matter M12123,...
AI summary The document discusses inter-year adjustments in the ELIADC Revenue Table for 2025, highlighting a $1.22M prior-year adjustment and the need for transparency in annual reporting. The Investigator General (IG) requests standardized tables to enable like-for-like year-over-year comparisons, while NSPI confirms adjustments will continue under US GAAP.
102306Reply Submission - NSPI
4 passages
pproximately $6 million per year, the increase in costs borne by PHP, compared to the 2019 application forecast was approximately $30 million per year over the four-year period (i.e. 2020-2023). // • The complexity of the ELIADC Tariff ope...
AI summary The document discusses the performance of the ELIADC Tariff compared to original forecasts, noting a $30 million annual cost increase over 2020-2023. It acknowledges the complexity of tariff operations and market dynamics, and addresses concerns about the adequacy of the minimum payment under the tariff.
Recommendation XV-1 The Company clarifies that its acceptance of this recommendation reflects its commitment to investigate and develop a feasible approach to enhanced benefit quantification within the capabilities of its system modeling t...
AI summary NS Power accepts Recommendation XV-1 with the understanding that it will explore feasible methods for enhanced benefit quantification. The Industrial Group (IG) and Small Business Advocate (SBA) express concerns over the feasibility and timeline of implementing the recommendation, requesting specific methodologies and firm deadlines. NS Power has identified practical limitations and continues to collaborate with the FAM Auditor.
Monthly Variability, Cost Recovery, and Reporting In its submission, the IG describes month-to-month variability between billed revenues and cost to serve, and requests NS Power "provide in the monthly reporting M-8, a month-bymonth compar...
AI summary The Industrial Group (IG) requests detailed monthly reporting from NS Power to compare billed revenues with the cost to serve, highlighting shortfalls and explaining accruals. NS Power explains that the ELIADC Tariff operates on an annual settlement basis, and monthly values are provisional and subject to reconciliation. The IG also suggests including annual benefits and costs in future reports for better performance assessment.
Interest on Settlement Balances The IG proposes that interest be applied to post-year-end balances.[16](#page-5-0) The balance referenced for 2025 arises from the final annual reconciliation of Tariff components, including the Off-Schedule...
AI summary The IG proposes applying interest to post-year-end settlement balances, noting that the 2025 balance arises from a year-end tariff reconciliation. The balance is described as short-lived and small, with the current approach seen as consistent with established practice.