Topic:"Rates And Money" in M11927

zed (all-in) cost of power, unlike what is available through NSPI ownership and operation. I am available to discuss options. Kind Regards, Kevin Mullen C.E.O. GreenQuest Power M 902.402.4013 [[email protected]](mailto:kevin@greenq...

AI summary Kevin Mullen, CEO of GreenQuest Power, states that GreenQuest Power offers a lower all-in cost of power compared to NSPI ownership and operation and is available to discuss options.

1 (c) Please refer to the table below: In Thousands ($) Description Original Submission ATO Submission Increase in costs INTERNAL LABOUR & TRAVEL Environmental Services labour and travel expenses $19 $126 $107 MATERIALS Fish Passage upgrad...

AI summary The table outlines cost increases related to environmental services, fish passage upgrades, and various environmental consulting activities for the Ruth Falls Main Dam Refurbishment ATO. The costs include labor, materials, contracts, and consulting fees, with significant increases noted in several categories.

6.0 STATEMENT OF QUALIFICATIONS AND LIMITATIONS This report (the "Report") has been prepared by Strum Consulting ("Consultant") for the benefit of Nova Scotia Power Inc. ("Client") in accordance with the agreement between Consultant and Cl...

AI summary This section outlines the qualifications and limitations of the report prepared by Strum Consulting for Nova Scotia Power Inc. It highlights that the report is subject to the constraints of the agreement, based on unverified information, and not updated after issuance. The report is intended for specific purposes and is confidential.

APPLICATION FOR APPROVAL OFFICE USE ONLY Date Received: (yyyy/mm/dd) Application # 6 that are applicable to the specific activities of this application only. PLEASE PRINT OR TYPE. Complete Sections 1, 2, 3, 4 and 7 for ALL Applications. Co...

AI summary This document is an application for approval by Nova Scotia Power Inc. (NSPI), including contact information for the primary applicant, Kailey Osborne, and details about the application process. The application includes sections for applicant information and contact details.

90% REV. 1 REVIEW SUBMITTAL NOT FOR CONSTRUCTION 1 7 1 I x x x x x " " " " x " x 90 % RE V. 1 R S EV IEW UB MI TT AL NO OR C T F ON ST CT IO RU N 1 0 0 0 2 - Nova S cotia PO WE R An Em era Com pany here ener gy ev eryw

AI summary This document appears to be a submission related to a regulatory proceeding, labeled as '90% REV. 1 REVIEW SUBMITTAL NOT FOR CONSTRUCTION.' It contains a table with some entries and the name 'Nova Scotia Power' mentioned as an entity.

CI 50518 CA IR-5 Attachment 21 Page 440 of 465 REDACTED (CONFIDENTIAL INFORMATION REMOVED)

AI summary The text is a page from a regulatory proceeding document, marked as confidential and redacted. It is part of a larger submission, likely related to a proceeding involving Nova Scotia Power, though specific details are not visible due to redaction.

CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO (NSUARB M11927) NSPI Responses to The Consumer Advocate Information Requests 1 Request IR-6: 2 3 Reference: NS Power applied for the FAA from DFO on June 24, 2020 and received four 4 i...

AI summary NS Power applied for a Fish and Aquatic Habitat (FAA) from DFO in June 2020, but received incomplete letters from DFO between August 2020 and September 2023, leading to additional costs for the Ruth Falls Main Dam Refurbishment project. These costs were not accounted for in the original project budget submitted to the Board.

NON-CONFIDENTIAL 2019 $36,107 39.29% $14,186 2020 $71,116 37.16% $26,426 2021 $101,011 40.28% $40,689 2 2022 1F $131,361 46.15% $59,196 2023 $55,732 55.46% $30,912 3 2024 2F $47,588 77.70% $36,973 2025 (Estimated) $134,500 77.70% $104,500...

AI summary The table provides financial data from 2019 to 2026, showing increasing costs and percentages over time. It includes figures for various years, with estimates for 2025 and 2026. The data appears to be related to a financial or regulatory proceeding.

2 (b) Please refer to CA IR-09 (b). 3 4 (c) The increase in administrative overhead (AO) is due to the increase in labour spend and an 5 increase in rates. Please refer to part (a) for a breakdown of labour spend and rates used in 6 the AO...

AI summary The text discusses an increase in administrative overhead due to higher labour costs and increased AO rates, referencing prior and current filings. It also mentions the inclusion of overtime labour in the AO calculation and refers to a specific project (CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO) and a regulatory matter (NSUARB M11927).

Year AFUDC Incurred During the Year End of Year AFUDC Balance Rate Used Note Reference 2017 $6,611 $6,611 Jan 7.01% Feb-Dec 6.96% 2018 $10,865 $17,476 6.89% 2019 $21,125 $38,601 6.84% 2020 $61,646 $100,246 6.62% 2021 $117,331 $217,577 6.47...

AI summary The table outlines the Allowance for Funds Used During Construction (AFUDC) incurred and balances for Nova Scotia Power Inc. (NSPI) from 2017 to 2024, with varying rates applied each year. The data shows increasing AFUDC balances over time, with a notable drop in 2023 and a split rate in 2024.

REDACTED Drawdown monitoring plan Firm pricing by Consultant $55 Updates to the Offsetting Plan Firm Pricing by Consultant $47 Electrical design work for Rubber Dam Controls Building Internal estimate based on judgement $33 Barn Swallow Mo...

AI summary The text presents a table of costs related to various projects and monitoring plans, including drawdown monitoring, offsetting plan updates, electrical design work, and aerial imagery collection. It also references a specific proceeding (CI 50518 - HYD - Ruth Falls Main Dam Refurbishment ATO) and a related NSUARB matter (M11927), with responses from NSPI to information requests by Midgard Consulting.

OPINION OF PROBABLE CONSTRUCTION COST The OPC for each option is included in Tables 1A through 5 (Attachment 3) of this memorandum. The OPC is meant to provide a conceptual level estimate to complete modifications to the spillway structure...

AI summary The document outlines the probable construction costs (OPC) for refurbishing spillway structures, excluding certain taxes, insurance, and embankment modifications. It includes stabilization costs for concrete structures where necessary and refers to detailed tables in Attachment 3.

CONCEPTUAL LEVEL - OPINION OF PROBABLE CONSTRUCTION COST (COST IN $2017) ITEM# ITEM DESCRIPTION QUANTITY UNIT PRICE ($) UNIT TOTAL ($) TOTAL ($) A. GENERAL MOBILIZATION/DEMOBILIZATION 1 LS $ 100,000 $ 100,000 $ 100,000 $ 455,000 1 2 ENVIRO...

AI summary The document presents a conceptual-level estimate of probable construction costs for a project, including mobilization, environmental protection, site access, dewatering, new spillway gates, spillway modifications, and contingency costs, with total direct construction costs estimated at $6,203,000 and contingency at $1,241,000.

References: Elliot Excavators Limited has worked extensively for Nova Scotia Power's Hydro Division for 30 years. For references on our firms' capabilities and reliability contact any or all of the following personnel within Nova Scotia Po...

AI summary The text provides references for Elliot Excavators Limited, including contacts within Nova Scotia Power Inc. and Harbour Developments Limited. It also references a redacted document and an RFP related to the Ruth Falls Dam Refurbishment.

CI 50518 NSUARB IR-12 Attachment 2 Page 50 of 50 REDACTED (CONFIDENTIAL INFORMATION REMOVED)

AI summary The document contains a redacted page from a regulatory proceeding, likely related to Nova Scotia Power Inc. (NSPI), with a figure referenced but no explicit content provided due to confidentiality.

Offsetting Plan o We understand that NSPI would like to combine offsetting work for Sloane and Ruth Falls as they are within the same watershed. With both projects being delayed to 2021, sufficient time is available for NSPI to provide add...

AI summary NSPI seeks to combine offsetting work for Sloane and Ruth Falls projects within the same watershed. Both projects are delayed until 2021, allowing more time for detailed planning. However, determining offsetting for Ruth Falls may be challenging due to residual impacts from the temporary reservoir drawdown, and an additional letter of credit may be required.

90% REV. 1 REVIEW SUBMITTAL NOT FOR CONSTRUCTION 1 7 1 I 90 % RE V. 1 R S EV IEW UB MI TT AL NO OR C T F ON ST CT IO RU N 1 0 0 0 2 - Nova S cotia PO WE R An Em era Com pany here ener gy ev eryw

AI summary The document is a 90% REV. 1 REVIEW SUBMITTAL NOT FOR CONSTRUCTION, likely related to a regulatory proceeding in Nova Scotia. It includes a table with placeholders and acronyms, such as NSP for Nova Scotia Power, and appears to be a draft or preliminary submission.

CI 50518 NSUARB IR-12 Attachment 4 Page 36 of 57 CI 50518 NSUARB IR-12 Attachment 4 Page 37 of 57 CI 50518 NSUARB IR-12 Attachment 4 Page 38 of 57 CI 50518 NSUARB IR-12 Attachment 4 Page 39 of 57 CI 50518 NSUARB IR-12 Attachment 4 Page 40...

AI summary The text contains a series of pages from a regulatory proceeding document, likely related to a utility rate or service review, with references to Nova Scotia Power (NSP) and the NSUARB (Nova Scotia Utility and Review Board). The pages appear to be part of an attachment, possibly including figures or diagrams, but no substantive content is visible in the provided text.

CI 50518 NSUARB IR-12 Attachment 4 Page 53 of 57REDACTED (CONFIDENTIAL INFORMATION REMOVED) ZƵƚŚ&ĂůůƐĂŵZĞĨƵƌďŝƐŚŵĞŶƚ^ϯϱ;ϮͿ;ďͿ&ŝƐŚĞƌŝĞƐĐƚƵƚŚŽƌŝnjĂƚŝŽŶ ^ƵƉƉŽƌƚŝŶŐ/ŶĨŽƌŵĂƚŝŽŶηϭ DŽŶŝƚŽƌŝŶŐĐƚŝǀŝƚŝĞƐ WWE/yʹWƌŽƉŽƐĞĚtĂƚĞƌDĂŶĂŐĞŵĞŶƚ^ƚƌƵĐƚƵƌĞƐ CI 50...

AI summary The document appears to be a regulatory proceeding attachment containing redacted confidential information. It includes technical and financial data related to utility and review board matters, potentially involving rate calculations, cost evaluations, and other regulatory considerations.

Conditions: - The sum total of this Credit shall be reduced from time to time as advised by written notice given to this office from time to time by you. - The Credit will continue until March 17, 2021 and will expire at our above mentione...

AI summary This document outlines the terms and conditions of a Standby Letter of Credit issued to Nova Scotia Power Incorporated, including its validity period, conditions for extension, and requirements for cancellation. The credit is subject to ICC rules and will expire on December 31, 2025, unless renewed.

Table 8 Total Project Budget (all years) Project Total Amount Year 1 $21,520.59 Year 2 $19,923.53 Year 3 $255,544.12 Year 4 $25,823.53 Year 6 $25,823.53 Year 8 $31,205.26 Grand Total $379,840.56 CI 50518 NSUARB IR-12 Attachment 10 Page 522...

AI summary The text presents a table outlining the total project budget across multiple years, with specific amounts listed for each year and a grand total. The table is part of a regulatory proceeding document, and the page number and matter number are indicated.

Conditions: - The sum total of this Credit shall be reduced from time to time as advised by written notice given to this office from time to time by you. - The Credit will continue until March 17, 2021 and will expire at our above mentione...

AI summary This standby letter of credit is issued by the Bank of Nova Scotia and is subject to specific conditions, including its expiration date, automatic renewal terms, and cancellation procedures upon completion of Nova Scotia Power Incorporated's responsibilities under the Authorization. It is governed by ICC Uniform Customs and Practices for Documentary Credits, 2007 Revision.

CI 50518 NSUARB IR-12 Attachment 10 Page 555 of 591 REDACTED (CONFIDENTIAL INFORMATION REMOVED) APPENDIX P – ACCDC REPORT

AI summary The document presents Appendix P of the ACCDC report, which is part of a regulatory proceeding in Nova Scotia. The content is redacted, indicating that it contains confidential information.

REDACTED (CONFIDENTIAL INFORMATION REMOVED) CI 50518 NSUIARB IR-12 Attachment 12 Page 2 of 576

AI summary The text is a redacted portion of a regulatory proceeding document from Nova Scotia, containing confidential information. It appears to be part of a larger submission, possibly related to a proceeding involving Nova Scotia Power and the Department of Fisheries and Oceans.

6.0 CLOSURE This plan has been prepared for the sole benefit of Nova Scotia Power Incorporated (NS Power). This report may not be relied upon by any other person or entity without the express written consent of Stantec Consulting Ltd. Any...

AI summary This closure section of the document states that the report was prepared solely for Nova Scotia Power Incorporated and disclaims liability for third-party reliance. It invites additional information for re-assessment and provides contact details for Matt Steeves of Stantec Consulting Ltd.

Conditions: - The sum total of this Credit shall be reduced from time to time as advised by written notice given to this office from time to time by you. - The Credit will continue until March 17, 2021 and will expire at our above mentione...

AI summary This document outlines the terms and conditions of a Standby Letter of Credit issued to Nova Scotia Power Incorporated, including its validity period, conditions for extension, and requirements for cancellation. The credit is subject to ICC rules and will expire on December 31, 2025, unless renewed.

The Bank of Nova Scotia Trade Services Centre 4th Floor, 1 St. Clair Avenue East Toronto, Ontario M4T 1Z3 Tel: 1-888-722-3867 Fax: 416-866-4286 SWIFT: NOSCCATTTPG Irrevocable Standby Letter of Credit No. OSB62460GWS Amendment no. 1 Dated M...

AI summary This document amends an irrevocable standby letter of credit issued by the Bank of Nova Scotia on behalf of Nova Scotia Power Incorporated for the benefit of Fisheries and Oceans Canada. The amendment was dated May 19, 2021, and all other terms of the original letter of credit remain unchanged.

CI 50518 NSUIARB IR-12 Attachment 12 Page 539 of 576 REDACTED (CONFIDENTIAL INFORMATION REMOVED) APPENDIX P – ACCDC REPORT

AI summary The document includes Appendix P of the ACCDC report, which is part of a regulatory proceeding in Nova Scotia. The content is redacted, indicating that confidential information has been removed.

REVISION CONTROL Revision Description Date 0 Final report submission to the Nova Scotia Utilities and Review Board December 16, 2024 PERMIT TO PRACTICE

AI summary The document provides a revision control section with a final report submission to the Nova Scotia Utilities and Review Board on December 16, 2024, and includes a permit to practice section, though no details are provided in the text.

lt-source/irp/20181221-ns-power-hydro-asset-study-redacted.pdf?sfvrsn=a8dabcf6_1) M11927, Exhibit N-1, p. 1 of 10.

AI summary The document provides an overview of the Ruth Falls Main Dam and includes references to relevant exhibits and pages from a study related to Nova Scotia Power's hydro assets.

1.3 Report Structure - To organize its report, Midgard reviewed a previously stated requirement for an ATO justification noted by - NS Power in its 2012 General Rate Application proceeding: - "In requesting an ATO, Nova Scotia Power must s...

AI summary Midgard's report evaluates NS Power's ATO application by analyzing whether the cost increases are due to prudent actions and if the project remains in the best economic interest of ratepayers. It focuses on environmental permitting, construction timelines, and Mi'kmaq engagement.

Table 1: Relevant Proceeding Documentation Reviewed by Midgard Exhibit # Document N-1 ATO Application N-2 Letter of Comment N-3 NSPI (CA) RIR-1 to 18 N-4 NSPI (IG) RIR-1 to 10 N-5 NSPI (Midgard) RIR-1 to 6 N-6 NSPI (NSUARB) RIR-1 to 13 N-7...

AI summary This section lists the exhibits reviewed by Midgard in the proceeding, including various applications and responses related to the Authorization to Overspend (ATO) and other regulatory documents.

Table 4: Nova Scotia CPI Trend[29](#page-17-4) Description May 2019 October 2024 Increase (%) Nova Scotia CPI (All Items) 137.8 164.6 19.4% - 12 The CPI indicates a general increase in economic pressures, offering context for broader trend...

AI summary Table 4 shows the Nova Scotia CPI (All Items) increased from 137.8 in May 2019 to 164.6 in October 2024, a 19.4% rise. This indicates growing economic pressures and provides context for broader trends.

Table 5: Canada IPPI Trend[30](#page-18-1) Description May 2019 October 2024 Increase (%) Total, IPPI 101.4 127.2 25.4% Plastic and rubber products [P32] 101.5 125.9 24.0% Fabricated metal products and construction materials [P63] 100.3 13...

AI summary Table 5 presents the trend of the Canada Industrial Product Price Index (IPPI) from May 2019 to October 2024, showing a 25.4% increase in total IPPI, with significant increases in categories like fabricated metal products and construction materials (39.3%) and cement, glass, and other non-metallic mineral products (37.0%).

SUMMARY AND CONCLUSIONS - Midgard has structured this review report to address the following questions: - 1. Are the cost increases being sought in the ATO the result of prudent actions by NS Power? To answer this question, Midgard analyze...

AI summary Midgard's review report addresses two key questions regarding NS Power's ATO application: whether cost increases are due to prudent actions and if the project remains in ratepayers' best economic interest after accounting for overspending. The analysis considers environmental permitting, construction timelines, and Mi'kmaq engagement.

ng for project refurbishment application. GASPEREAU LAKE (2020) - Technical advisor to Nova Scotia Utility and Review Board counsel during a rate review hearing for dam refurbishment application. BREMNER CREEK (2019 to 2021) - A 25 MW hydr...

AI summary The text outlines the professional experience of an individual involved in various hydroelectric projects, including technical advisory roles for regulatory agencies and independent engineering work for project acquisitions and refurbishments.

1.3 Report Structure - To organize its report, Midgard reviewed a previously stated requirement for an ATO justification noted by - NS Power in its 2012 General Rate Application proceeding: - "In requesting an ATO, Nova Scotia Power must s...

AI summary Midgard's report structure is based on NS Power's 2012 General Rate Application proceeding, focusing on whether the ATO cost increases are due to prudent actions and whether the project remains economically justified for ratepayers. The report reviews reasons for variance, including environmental permitting, construction timelines, and Mi'kmaq engagement.

Table 3: Nova Scotia CPI Trend[30](#page-18-3) Description May 2019 October 2024 Increase (%) Nova Scotia CPI (All Items) 137.8 164.6 19.4% - The CPI indicates a general increase in economic pressures, offering context for broader trends t...

AI summary Table 3 presents the Nova Scotia CPI trend from May 2019 to October 2024, showing a 19.4% increase. This reflects rising economic pressures and provides context for broader trends.

Table 4: Canada IPPI Trend[31](#page-19-1) Description May 2019 October 2024 Increase (%) Total, IPPI 101.4 127.2 25.4% Machinery and equipment [P72] 100.0 121.9 21.9% Cement, glass, and other non metallic mineral products [P81] 100.4 137....

AI summary Table 4 presents the Canada IPPI Trend, showing a 25.4% increase in the Industrial Product Price Index from May 2019 to October 2024, with significant increases in machinery and equipment and cement, glass, and other non-metallic mineral products.

5.4.3 Analysis – Archaeology - As discussed in Section [4.1,](#page-22-2) Midgard is of the opinion NS Power should have been aware that archaeological - costs for the Project would be several orders of magnitude higher than its estimate i...

AI summary Midgard argues that NS Power underestimated archaeological costs for the Project, which were significantly higher than estimated in the 2019 ACE. These costs were not categorized as first-level costs in the ACE or ATO Application, and there is ambiguity regarding how consulting costs under 'Archaeological Reconnaissance' align with NS Power's stated archaeology costs.

Table 28: Cost Increase – AFUDC Interest[80](#page-46-6) Year AFUDC Incurred During the Year End of Year AFUDC Balance Rate Used Feb-Dec 7.01% 2017 $6,611 $6,611 Jan-Dec 6.96% 2018 $10,865 $17,476 6.89% 2019 $21,125 $38,601 6.84% 2020 $61,...

AI summary Table 28 outlines the AFUDC interest costs from 2017 to 2025, showing increasing balances and varying rates. AFUDC was ceased in 2023 due to construction delays and is expected to resume in 2025. The table also references supporting documents and exhibits.

6.1.3 Midgard Conclusion - NS Power's justification for not considering an alternative that did not require drawdown of the headpond appears reasonable. Therefore, the "repair or replace" alternatives considered by NS Power are appropriate...

AI summary Midgard acknowledges NS Power's rationale for not considering an alternative without headpond drawdown but criticizes the lack of re-evaluation of decommissioning options despite increased project costs. Midgard argues that the NSUARB should have the opportunity to review whether decommissioning would be in the best interest of ratepayers.

7.3.1 Considered Alternatives - Despite Project costs increasing by 113% and $8.2M, NS Power has not re-evaluated its decision to not - consider a decommissioning option. Midgard understands the stated justifications for this (that the Pro...

AI summary Midgard argues that despite a 113% increase in project costs, NS Power has not reconsidered its decision to not evaluate a decommissioning option. Midgard suggests that the NSUARB should have had the opportunity to assess whether decommissioning would be in the best interest of ratepayers.

NON-CONFIDENTIAL 1 Request IR-2: - Reference 1: Section 7.3 Economic Interest of Ratepayers

AI summary The document references Section 7.3 Economic Interest of Ratepayers, indicating a focus on how ratepayer interests are considered in economic evaluations within a regulatory proceeding.

CI 50518 – HYD Ruth Falls Main Dam Refurbishment - $15,445,508 (ATO) (NSUARB M10632) Midgard Consulting Inc. Responses to Industrial Group Information Requests 1 Request IR-1: 2 Reference: N/A 3 (a) Midgard has now filed a second version o...

AI summary Midgard Consulting Inc. revised its report on the Ruth Falls Main Dam Refurbishment ATO after realizing it did not fully address overspending issues. The revision included additional cost analyses and clarifications to assist the Board in its consideration of the ATO. Discrepancies were noted between the 2019 ACE and the ATO application's scope line items.

NON-CONFIDENTIAL 1 2 3 d) Midgard does not have a better estimate for archaeological costs for the Ruth Falls Project. If such an exercise were to be undertaken, a potential method would be to closely compare the scope of archaeological wo...

AI summary Midgard states that NS Power's estimate for archaeological costs for the Ruth Falls Project is significantly lower than actual costs based on similar projects like Tusket and Gaspereau. Midgard suggests that without a decommissioning option, it is unclear at what point archaeological costs would make the project no longer in ratepayers' best interests.

NON-CONFIDENTIAL - 1 Request IR-26: - 2 Reference: N-9, page 51, lines 14-20. - 3 Midgard quotes NSPI with respect to how it determined the contingency amount. Please confirm - 4 the source of this statement. - 5 Response IR-26: - 6 The so...

AI summary This document refers to a request (IR-26) asking for confirmation of the source of a statement made by NSPI regarding the determination of a contingency amount. The response indicates that the source is Exhibit N-4, response to Industrial Group IR-5(a), page 1 of 1.

14 Figure 2: Cost Savings Description 2019 UARB Submission costs, ($k) 2024 ATO Application costs, ($k) Variance ($k) Gates and actuators $450 $194 ($256) Rubber dam supply $1,050 $750 ($300) Total $1,500 $944 ($556) 15

AI summary Figure 2 presents cost savings between the 2019 UARB submission and the 2024 ATO application, showing reductions in costs for gates and actuators, rubber dam supply, and total costs.

7, Document 322217, NSUARB Decision Letter, Nova Scotia Power Inc. - CI 50518 – HYD Ruth Falls Main Dam Refurbishment – $15,445,508 (ATO), June 18, 2025, page 1. July 4, 2025 C. Henwood in the HIP. Please refer to Partially Confidential At...

AI summary Nova Scotia Power Inc. is amending its ATO request for the Ruth Falls Main Dam Refurbishment project due to updated cost estimates confirmed under the Fisheries Act Authorization. The company requests an expedited decision from the Board, citing prior regulatory processes and the project's assumed construction timeline in 2025.

Dam Refurbishment Avoided Applicable 2034 - (181,857.8) 3,611,970.9 (453,517.2) 473,110.6 11,513,374.0 2,976,596.0 (857,530.7) 2,119,065.2 1,204,695.2 0.57 (1,620,284.7) 2035 - (187,568.4) 3,684,210.4 (465,210.5) 471,634.3 11,468,302.3 3,0...

AI summary The table presents financial data related to dam refurbishment from 2034 to 2043, including figures such as avoided costs, applicable costs, and net present value. The data shows a mix of positive and negative values across different years, indicating varying financial impacts over time.

Partial Decommissioning Avoided Applicable 2035 - - - (1,685,056.7) 1,685,056.7 (2,162,960.6) (1,685,056.7) 488,666.5 (1,196,390.3) (642,804.7) 0.54 (37,924,729.6) 2036 - - - - - (2,162,960.6) - - - - 0.51 (37,924,729.6) 2037 - - - - - (2,...

AI summary The table presents financial data related to a partial decommissioning process, with figures indicating costs and net present values across multiple years from 2035 to 2053. The data includes avoided costs, applicable costs, and NPV calculations, highlighting the economic impact of the decommissioning over time.

0 Avoided Applicable Year Total Revenue Operating Costs Expenses Capital CCA UCC CFBT Taxes CFAT PV of CF Discount Factor CNPV 2024 - - - - - - - - - - 1.0 0 - 2025 - - - - - - - - - - 0.9 5 - 2026 - - - - - - - - - - 0.8 9 - 2027 - - - -...

AI summary The document presents a table with financial metrics for various years, including revenue, costs, capital, and net present value calculations. However, all data fields are empty, and the document appears to be a template or placeholder for financial analysis. It is marked as confidential and redacted.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by NOVA SCOTIA POWER INCORPORATED (NS Power) for approval of an Authorization to Overspend (ATO) in the amount of $8,201,086 on capital application project C...

AI summary This document outlines an application by Nova Scotia Power Incorporated (NS Power) for approval to overspend on a capital project related to the HYD Ruth Falls Main Dam Refurbishment, increasing the total requested capital cost to $15,445,508.

ning horizon. [29] Midgard analyzed NS Power's IR responses about why it did not re-evaluate the other refurbishment options as part of the ATO application. Midgard provided the following conclusion: NS Power's justification for not consid...

AI summary Midgard reviewed NS Power's ATO application and concluded that while NS Power's justification for not considering alternatives to the refurbishment project was reasonable, it did not reevaluate decommissioning options despite significant cost increases. Midgard also raised concerns about potential further cost increases related to environmental, archaeological, and geotechnical risks.

d decommissioning the dam was found to be more cost effective than refurbishing the dam and utilizing its 7.2 MW hydro generation, then that approach would have served the best interest of ratepayers. [77] The Board's approval of the Ruth...

AI summary The document discusses the decommissioning of the Ruth Falls main dam, comparing it to refurbishment. It notes that the Board's 2019 approval of refurbishment accepted NS Power's position, but with increased costs, decommissioning is now being reconsidered as a viable alternative. NS Power has committed to providing decommissioning costs in future hydro applications.

M11927 – Nova Scotia Power Incorporated – CI 50518 – HYD Ruth Falls Main Dam Refurbishment – $14,839,116 (Amended ATO) On June 18, 2025, the Nova Scotia Energy Board (Board) issued a decision in Matter M11927 Nova Scotia Power Incorporated...

AI summary The Nova Scotia Energy Board has approved an amended Authorization to Overspend (ATO) for the Ruth Falls Main Dam Refurbishment Project following receipt of the Fisheries Act Authorization. The amended ATO reduces the requested amount by $606,392 to $14,839,116. A Net Present Value analysis shows the refurbishment option is more favorable compared to decommissioning. Intervenors and consultants have submitted comments on the application.

Board will not consider any requests for additional costs associated with not meeting the March 31, 2026, completion date resulting from claimed delays in receiving Board approval for the current ATO. Both the SBA and Industrial Group subm...

AI summary The Board will not consider additional costs due to delays in meeting the March 31, 2026, completion date caused by delays in receiving ATO approval. The SBA and Industrial Group recommend regular project updates from NS Power, while NS Power believes existing reporting tools are sufficient. The Board agrees that semiannual reporting would be beneficial given the project timeline and cost concerns.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: The Public Utilities Act - and - IN THE MATTER OF: an application by NOVA SCOTIA POWER INCORPORATED (NS Power) for approval of an Authorization to Overspend (ATO) in the amount of $8,2...

AI summary NS Power is requesting approval from the Nova Scotia Utility and Review Board to overspend $8,201,086 on the HYD Ruth Falls Main Dam Refurbishment project, increasing the total project capital cost to $15,445,508.

NOTICE OF INTERVENTION OF: CONSUMER ADVOCATE TAKE NOTICE that the Consumer Advocate hereby intervenes in the above Application and proceeding. The Consumer Advocate represents the interests of residential ratepayers, who may be impacted by...

AI summary The Consumer Advocate intervenes in the proceeding, representing residential ratepayers who may be affected by the Application. The Advocate will address issues raised by the Utility and Review Board and will be represented by David Roberts, Michael Murphy, and their consulting team.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION by Nova Scotia Power Incorporated ("NS Power") for approval of Capital Work Order CI 50518 – HYD Ruth Falls Main Dam R...

AI summary The Nova Scotia Utility and Review Board has issued a request for redacted information related to an application by Nova Scotia Power Incorporated for approval of a Capital Work Order for the HYD Ruth Falls Main Dam Refurbishment project. Responses are due by December 3, 2024.

1 2024 M11927 2 3 NOVA SCOTIA UTILITY AND REVIEW BOARD 4 IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended 5 - and - 6 7 8 9 10 11 12 IN THE MATTER OF: An application by Nova Scotia Power Incorporated for approval of...

AI summary The Nova Scotia Utility and Review Board is considering an application by Nova Scotia Power Incorporated for an Authorization to Overspend (ATO) on the HYD Ruth Falls Main Dam Refurbishment project, which has more than doubled in budget. The Industrial Group has requested confirmation that Option 4 remains the most cost-effective choice.

- 31 (b) When did NSPI become aware that the FAA was required? Given the 32 significant additional expenses tied to the FAA, why did NSPI not reapply 33 to the Board at that time? 1 Request IR-4: 2 Reference: Page 3.

AI summary The question asks when NSPI became aware of the FAA requirement and why it did not reapply to the Board despite significant additional expenses. The text references page 3 and includes a request for IR-4.

1 M11927 2 3 NOVA SCOTIA UTILITY AND REVIEW BOARD 4 5 6 IN THE MATTER OF: The PUBLIC UTILITIES ACT 7 8 9 IN THE MATTER OF: An application by NOVA SCOTIA POWER 10 INCORPORATED for approval of an Authorization to 11 Overspend (ATO) in the am...

AI summary This document is an information request from the Consumer Advocate to Nova Scotia Power Inc. regarding an application for an Authorization to Overspend (ATO) on a capital project related to the refurbishment of the HYD Ruth Falls Main Dam. The request is part of a proceeding under the Public Utilities Act.

December 17, 2024 VIA EMAIL Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M11927 -Application by NOVA SCOTIA POWER INCO...

AI summary The Small Business Advocate (SBA) has reviewed NS Power's application for an Authorization to Overspend (ATO) on the HYD Ruth Falls Main Dam Refurbishment project and will file closing submissions, though no evidence will be submitted at this time.

3 While subject to debate, it can be argued that the drawdown of the reservoir 4 would have resulted in non-permanent effects. 5 6 Midgard concludes that NS Power was acting reasonably in expecting that, 7 at the time of its original ACE f...

AI summary The text discusses NSPI's original ACE filing and the subsequent DFO response regarding the Ruth Falls project, highlighting the permanent instream footprint and potential impacts on fish habitat. NSPI initially expected no FAA requirement, but the DFO raised concerns about fish habitat disruption.

- 33 (d) On what basis has Midgard concluded this would not have "materially 34 affected the outcome" of the original approval of this project? 1 (e) Does Midgard view the estimated engagement costs included in the ATO 2 to be reasonable?...

AI summary The text raises questions about Midgard's reasoning regarding the impact of a project on prior approvals, the reasonableness of engagement costs in an ATO, and the increase in the AO rate. It also references cost management practices by NS Power and asks about lessons learned from previous regulatory applications.

gested by DFO since this rate was used by NS Power on a previous project. It is not clear why NS Power now believes that the unit rate suggested by DFO is more appropriate than its original estimate.

AI summary The text discusses the use of a unit rate previously suggested by the Department of Fisheries and Oceans (DFO) by NS Power on a previous project, and questions why NS Power now considers this rate more appropriate than its original estimate.

- 28 (f) How are offsetting measurements usually determined on hydro projects 29 such as this? (g) Has Midgard considered the DFO's concerns with respect to "high 3 4 (b) Please outline whether there would be additional costs to ratepayers...

AI summary The text discusses questions raised about hydro projects, specifically how offsetting measurements are determined and whether pausing a project would incur additional costs for ratepayers. It also references Midgard's involvement in the Tusket Main Dam ATO and the process of obtaining FAAs from the DFO.

Delivered by E-mail Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 3rd Floor, 1601 Lower Water Street PO Box 1692, Unit "M" Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M11927 - NSPI - CI 50518 – HYD Ruth...

AI summary The Industrial Group opposes the approval of NSPI's ATO for the Ruth Falls Main Dam Refurbishment, citing a significant cost increase due to delays in environmental permitting and a lack of diligence in the original application. They argue that NSPI should resubmit with a more thorough analysis of alternatives or have the application placed in abeyance.

Test for ATOs In reviewing an application for an ATO, the Board is asked to consider whether the overspend claimed is necessary and prudent. In doing so, the Board must analyze whether the capital project continues to be economically justi...

AI summary The Board reviews ATO applications to ensure overspending is necessary, reasonable, and prudent, emphasizing NSPI's burden to prove economic justification and ratepayer benefit. The 2010 Tufts Cove 6 decision is referenced as a guide for evaluating such applications.

Midgard Revised Report, pages 54-55. Group would submit that this is also relevant for determining whether the project remains economically justified, or if some other option ought to be considered. Despite the ballooning costs of the proj...

AI summary The document highlights concerns about the economic justification of the Ruth Falls project, noting the lack of detailed decommissioning cost analysis and the delayed submission of required offsetting information to the DFO. These issues raise questions about the project's overall feasibility and regulatory compliance.

ptions and costs, estimated that Option 4 was only $250,000 less than the next closest option.[22](#page-5-14) There is no explanation on the evidence which explains this discrepancy.[23](#page-5-16) NSPI has failed to complete any updated...

AI summary The document highlights that NSPI has not provided updated economic analysis for the project, despite questions from multiple intervenors. It also notes a discrepancy in cost estimates for Option 4, with no explanation provided, and criticizes the lack of evidence supporting the claim that the project remains in the best interest of ratepayers.

has transformed this project into a significantly more expensive refurbishment, it should have alerted the Board and intervenors of that possibility in the original application and assessed the risk. As articulated by the Board in its Lett...

AI summary The text discusses how NSPI failed to disclose critical information about increased project costs and amendments to the Fisheries Act during the original application for an ATO. It references the Board's decision in Matter M11003 regarding the evaluation of imprudence in granting an ATO and highlights evidence from another related application, Matter M10197.

(4) The Amounts applied for are not the lowest reasonable cost to ratepayers NSPI has failed to establish that Option 4 remains the lowest cost option for ratepayers, and that it remains in the best interest of customers. As noted above, t...

AI summary NSPI has not demonstrated that Option 4 is the lowest reasonable cost for ratepayers, citing a lack of updated cost comparisons. Midgard also has not evaluated the ATO application for cost reasonableness, relying on outdated justifications.

Conclusion The issue in this ATO is that NSPI failed to account for the need for an FAA in the original application, and the approach to the FAA application and Watercourse Alteration Approval has resulted in significant delays and costs o...

AI summary The ATO application for the Ruth Falls refurbishment project is criticized for significant delays and increased costs due to NSPI's failure to account for the need for an FAA in the original application. The Industrial Group argues that due diligence could have prevented these costs. The submission requests an updated cost analysis to determine if Option 4 remains the least costly and questions whether ratepayers should bear the additional costs.

CONCLUSION NS Power submits that the three-part test for ATO's has been met, as follows: 1. Were the utility's decisions reasonable in the context of information which was known (or should have been known) at the time? NS Power's decision...

AI summary NS Power argues that its decision to proceed with the Ruth Falls project was reasonable, prudent, and based on available information at the time, despite higher-than-expected archaeology costs. The company emphasizes that the project was necessary for dam safety and remains the lowest-cost solution for customers.

ecent submission. In the Board's opinion, without the FAA in hand, the project remains exposed to potential cost increases, as this issue has been a key factor to date in significant cost escalations. [71] The Board has, therefore, decided...

AI summary The Board has decided to delay the approval of the ATO application until the final FAA is received from DFO. This is to address potential cost increases and ensure updated project cost estimates are provided. The Board acknowledges NS Power's concerns but expects them to manage associated risks.

of when specific capital expenditures over the eleven-year timeframe of the decommissioning option would be made. The lack of this information also limits the ability to test NS Power's cost estimate. [82] Considering this, the Board is co...

AI summary The Board is concerned that the current ATO proceeding does not include a full comparison of the Ruth Falls decommissioning option. The Board has put the application on hold until NS Power receives the FAA from DFO and will require a detailed NPV analysis comparing decommissioning with refurbishment in the amended application.

July 4, 2025 [[email protected]](mailto:[email protected]) Annie Beth Sampson, P. Eng. Manager, Regulatory Nova Scotia Power Incorporated 1223 Lower Water Street Halifax, NS B3J 2W5 Dear Ms. Sampson: M11927 – Nova Sco...

AI summary Nova Scotia Power Inc. has submitted an updated ATO request for the Ruth Falls Main Dam Refurbishment Project after receiving the Fisheries Act Authorization. The request is for $14,839,116, a reduction from the original amount. The Board has set a timetable for parties to review and comment on the updated application.

Conclusion The Industrial Group respectfully requests the Board direct NSPI to: - 1. Manage offsetting expenses on this project within the allowance of unit cost applied for of $25 /m 2 ; - 2. Include a range of decommissioning options for...

AI summary The Industrial Group requests the Board to direct NSPI to manage project expenses within approved allowances, include decommissioning options in future hydro projects, and provide regular updates on project progress and spending.

July 18, 2025 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M11927 – CI 50518 – HYD – Ruth Falls Main Dam Refurbishment – Closing Submission Dear Ms. Henwood: On Octo...

AI summary NS Power submitted a revised Authorization to Overspend (ATO) for the Ruth Falls Main Dam Refurbishment after receiving a Fisheries Act Authorization. The ATO amount was reduced to $14,839,116 due to lower offsetting costs. The Board requested comments on the updated ATO, with submissions received from various parties, and NS Power appreciates the timely responses.

REPLY TO SUBMISSIONS OF THE SMALL BUSINESS ADVOCATE In its letter dated July 14, 2025, the SBA indicated that it had no further comments but reiterated: that it remains concerned about costs and continues to respectfully request that the B...

AI summary The Small Business Advocate (SBA) reiterated its concern about costs and requested regular updates from NSPI. NS Power responded that such financial updates are not necessary or warranted.

M11927 – Nova Scotia Power Incorporated – CI 50518 – HYD Ruth Falls Main Dam Refurbishment – $14,839,116 (Amended ATO) On June 18, 2025, the Nova Scotia Energy Board (Board) issued a decision in Matter M11927 Nova Scotia Power Incorporated...

AI summary The Nova Scotia Energy Board (Board) has put the Authorization to Overspend (ATO) application for the Ruth Falls Main Dam Refurbishment on hold until the Fisheries Act Authorization is obtained. NS Power has now submitted an amended ATO application with a reduced cost estimate of $14,839,116 and a Net Present Value (NPV) analysis showing that the refurbishment option is more economically favorable than decommissioning.

Submissions/Comments The SBA had no further comments beyond those noted in its March 25, 2025, closing submissions from the original ATO application. Nonetheless, the SBA continued to request that the Board require NS Power to provide regu...

AI summary The SBA has no new comments but requests regular updates from NS Power. Midgard states the finalized FAA reduces risk and adjusts project costs based on confirmed offsetting amounts, but questions the reasoning behind the decrease in the 'Offsetting (West River Project)' cost estimate and requests additional detail from NS Power.

January 19, 2026 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M10013, M10197, M11927 – Various Hydro Projects Reporting – Extension Request Dear Ms. Henwood: Nova Sc...

AI summary Nova Scotia Power Incorporated (NS Power) is requesting an extension for the submission of reports related to three hydro projects: Annapolis Tidal Generation Station Retirement, Tusket Main Dam Refurbishment, and Ruth Falls Main Dam Refurbishment. NS Power cites year-end reporting requirements as the reason for the delay and requests an extension to February 13, 2025.

January 20, 2026 [[email protected]](mailto:[email protected]) Annie Beth Sampson Manager, Regulatory Nova Scotia Power Inc. PO Box 910 Halifax, NS B3J 2W5 Dear Ms. Sampson: M10013, M10197, M11927 – Various Hydro Proj...

AI summary NS Power Inc. has requested an extension to file reporting status on three hydro projects: Annapolis Tidal Generation Station Retirement, Tusket Main Dam Refurbishment, and Ruth Falls Main Dam Refurbishment. The Board has approved the extension, setting the new filing deadline for February 13, 2026.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 1 Appendix A Page 1 of 2 REDACTED (CONFIDENTIAL INFORMATION REMOVED) NSEB Approved Contingency/ Unbudgeted Spend Account Amount Spend-to-Date to-Date Comments Regular Labour (53...

AI summary The contingency report outlines unbudgeted expenses related to the Ruth Falls Main Dam refurbishment, including additional internal labour, overtime for hydro operations, and travel expenses. The report highlights the need for extra resources due to unforeseen activities such as headpond drawdown and environmental monitoring.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 2 Appendix A Page 1 of 1 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Account NSEB Approved Amount Spend-to-Date Contingency/ Unbudgeted Spend-to-Date Comments Regular Labour (53...

AI summary The document outlines contingency spending related to the Ruth Falls Main Dam refurbishment, including additional labour and travel costs incurred for activities such as headpond drawdown, monitoring barn swallows, and community engagement. These costs exceed the initially approved budget.

REDACTED Ruth Falls Main Dam Refurbishment Contingency Report 3 Appendix A Page 1 of 1 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Account NSEB Approved Amount Spend-to-Date Contingency/ Unbudgeted Spend-to-Date Comments $0.00 $3,485.17 op...

AI summary The document outlines additional costs incurred during the Ruth Falls Main Dam refurbishment project, including travel expenses for community engagement and construction support, and material costs for spillway resurfacing and rubber dam installations. These costs exceed the initially approved budget.