N-1Report
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Introduction This report has been prepared by Concentric Energy Advisors, Inc. ("Concentric") in response to a requirement by the Nova Scotia Energy Board ("NSEB" or "Board") to conduct a detailed review of Federal Energy Regulatory Commis...
AI summary This report, prepared by Concentric Energy Advisors, Inc., reviews FERC Order No. 2023 and compliance filings by Nova Scotia Power, Inc. in response to the Nova Scotia Energy Board's directive. It includes analyses of interconnection processes and recommendations for Nova Scotia, with considerations for the transition to the Nova Scotia Independent Energy System Operator.
nues to play a central role in shaping the rules that govern how new resources access the transmission grid, thereby influencing reliability, market competition, and the pace of the energy transition. The electric system in Nova Scotia has...
AI summary The electric system in Nova Scotia has an installed capacity of approximately 3,100 MW with limited transmission ties, contrasting with larger ISOs in the U.S. that manage much larger systems. FERC Order 2023, designed for larger systems, requires careful consideration for implementation in Nova Scotia due to these differences.
Methodology For this review, Concentric integrated findings from a detailed review of regional compliance filings, with particular attention to requests for exemptions and modifications from the mandates established under Order 2023 and th...
AI summary Concentric reviewed regional compliance filings and exemptions from Order 2023, analyzing how ISOs, RTOs, and transmission providers in the U.S. and Canada propose to comply. The analysis considers operational, regulatory, and market-based rationales and provides recommendations for adopting or rejecting elements of Order 2023 to improve Nova Scotia's interconnection processes.
Table 1: Transmission Providers Included in Order 2023 Review ISOs and RTOs Utilities • New York Independent System Operator (NYISO) • Southwest Power Pool (SPP) • Midcontinent Independent System Operator (MISO) • New England Independent S...
AI summary Table 1 lists transmission providers included in the Order 2023 Review, including ISOs and RTOs such as NYISO, MISO, and PJM, as well as utilities like Duke Energy Florida and BC Hydro.
Cost Allocation for Network Upgrades The cluster study process detailed in Order 2023 identifies a shared cost allocation methodology for network upgrades. Transmission providers must allocate system network upgrade costs based on the prop...
AI summary The document outlines a shared cost allocation methodology for network upgrades in Nova Scotia, requiring transmission providers to use the proportional impact method for system upgrades and equal allocation for substation upgrades. It highlights current practices and recommends defining terms and methods for better cost assignment.
Transmission Heatmap To support prospective interconnection customers in identifying optimal points of interconnection, Order 2023 requires that transmission providers develop, maintain and publicly post available information on generator...
AI summary Order 2023 requires transmission providers to develop and maintain publicly accessible transmission heat maps to support interconnection customers. These maps must avoid disclosing sensitive information and be updated annually and following cluster studies. Nova Scotia currently lacks such a tool, but its development is recommended as part of interconnection reform.
Increased Study Deposits To prevent an inflow of speculative interconnection requests and alleviate the strain on transmission providers' resources, the Commission established a set of reforms in Order 2023 to increase financial commitment...
AI summary The Commission introduced reforms in Order 2023 to increase study deposits and readiness requirements for interconnection requests to prevent speculative applications and reduce strain on transmission providers. Nova Scotia's current structure aims to promote queue discipline, but Concentric recommends against adopting the Order's deposit framework, citing potential financial barriers for viable projects.
Table 4: Withdrawal Penalty Calculation Under Order 2023 Interconnection Request Submission Cluster Study Cluster Restudy (if needed) Facilities Study Execution of LGIA or Request for Filing of Unexecuted LGIA Penalties are not applied to...
AI summary Table 4 outlines the withdrawal penalty calculation under Order 2023, specifying penalties based on the stage of the interconnection request process. Penalties increase from 2x the actual allocated cost during the Cluster Study phase to 20% of estimated network upgrade costs during the execution of the Long-Run Incremental Cost (LGIA) or request for filing of unexecuted LGIA.
Prior to Order 2023, transmission providers only needed to demonstrate "reasonable efforts" to meet study deadlines.[26](#page-10-0) With little to no consequences for missed deadlines, the Commission viewed the reasonable efforts standard...
AI summary The Commission replaced the 'reasonable efforts' standard with financial penalties for transmission providers missing interconnection study deadlines, aiming to improve accountability and process efficiency. Concentric recommends adopting this penalty structure to align with industry best practices and ensure a transparent interconnection process.
Additional Changes Related to Order 2023 The key reforms in Order 2023 focus on improving the speed and efficiency of transmission providers' processing of interconnection requests. However, an interconnection queue is not utilized by ever...
AI summary The text discusses the interconnection processes used by transmission providers, focusing on ERCOT's 'connect and manage' approach and its implications. It contrasts this with systems like PJM and Nova Scotia's current practices, noting that while faster interconnections are possible, they come with increased operational risks. Concentric recommends against adopting the connect and manage model in Nova Scotia.
Stakeholder Workshop and Feedback On August 15, 2025, Concentric conducted a workshop with interveners to present the summary review of Order 2023. The content of the workshop followed Concentric's review of Order 2023, and the conversatio...
AI summary On August 15, 2025, Concentric conducted a workshop with interveners to present a summary review of Order 2023. The workshop included a PowerPoint presentation, which was distributed to interveners afterward. Comments were requested by August 21, 2025. A list of interveners attending the workshop is included in a table.
N-2Interim Interconnection Agreement
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Re: M12524 – Nova Scotia Power Incorporated – Concentric FERC Order 2023 Report Dear Ms. Henwood: IESO Nova Scotia's update letter of August 14, 2026 regarding the above noted matter provided in part the following: Regarding the interim in...
AI summary IESO Nova Scotia has completed and executed an interim interconnections administration agreement with Nova Scotia Power Incorporated, which was previously delayed. The agreement outlines the division of responsibilities under the current Board approved SGIP and has been finalized. A copy of the executed agreement is provided to the NSEB for information.
NOVA SCOTIA INDEPENDENT ENERGY SYSTEM OPERATOR ("IESO NS") Collectively referred to herein as the "Parties" or individually as a "Party". WHEREAS the More Access to Energy Act, SNS 2024, c 2, Sch B (the " Act ") provides for and requires a...
AI summary This agreement outlines the transition of the system operator from NS Power to IESO NS, as mandated by the More Access to Energy Act. It also addresses the interim administration of the SGIP by IESO NS until revised procedures are approved by the Board.
2. Division of Responsibilities. - 2.1 Without alteration to NS Power's lawful obligations, duties and responsibilities as set out in the SGIP, IESO NS hereby agrees to complete certain of NS Power's responsibilities, on its behalf, as set...
AI summary This section outlines the division of responsibilities between NS Power and IESO NS during the interim period, specifying which duties are transferred to IESO NS and which remain with NS Power. It also establishes the terms of the agreement, including its duration and the process for transitioning responsibilities.
7. Dispute Resolution. - 7.1 The Parties shall establish a joint coordination committee consisting of representatives from each Party to address operational matters, interpretive questions, coordination issues, and disputes arising from th...
AI summary The dispute resolution process outlined in section 7 establishes a joint coordination committee to address disputes and operational matters. If unresolved, the issue is escalated to senior representatives for negotiation, and if still unresolved, it is referred to the Board for resolution.
8. General 8.1 Applicable Law. This Agreement is governed by the laws of Nova Scotia and Canada applicable therein. Any legal proceedings shall be subject to the jurisdiction of the courts of Nova Scotia or the Nova Scotia Energy Board, as...
AI summary This section outlines the legal framework governing the Agreement, including applicable law, invalidity clauses, entire agreement provisions, amendments, waivers, successors, force majeure, notice procedures, prevailing legislation, and execution in counterparts. It emphasizes jurisdiction, enforceability, and legal compliance.
100925Letter IESO re: IESO Nova Scotia’s response to the Board’s direction
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February 12, 2026 Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: M12524 – Concentric FERC Order 2023 Report – IES...
AI summary The Nova Scotia Energy Board (NSEB) has directed the Independent Energy System Operator of Nova Scotia (IESO Nova Scotia) to respond to Concentric's FERC Order 2023 report and recommendations, outlining whether they are accepted and providing a plan and timeline for implementation.
Plan and Timeline Those recommendations that IESO Nova Scotia accepts, or is otherwise directed by the Board to adopt, may require revisions to interconnection documentation and processes, including the 5 Concentric Report, Interconnection...
AI summary The document discusses potential revisions to interconnection documentation and processes in Nova Scotia, based on recommendations accepted by IESO Nova Scotia or directed by the Board, referencing a specific report and stakeholder workshop.
SGIP. Those recommendations expected to require work to be fully implemented are listed in the table below, alongside a brief description of the requirements to adopt/complete. Recommendation Requirements Two Cluster Studies Per Year Syste...
AI summary The document outlines several recommendations related to the Standard Generation Interconnection Procedures (SGIP) that require amendments and further consideration, including system upgrade cost allocation, cluster study cost allocation, and the ISO penalty structure. Revisions to the SGIP and updates to interconnection processes documentation are needed.
… as the NSEB may appreciate, IESO Nova Scotia is in its early stages of formation and is working expeditiously to implement its mandate under the More Access to Energy Act (Nova Scotia) (the "Act"). It is foreseeable that further revision...
AI summary IESO Nova Scotia is in the early stages of formation and will revise interconnection processes documentation to reflect its role under the More Access to Energy Act. It plans to consult stakeholders and submit revisions to the NSEB by the end of 2026, potentially earlier. This process will occur alongside or after a Board review of Concentric's report in Matters M10905 and M12174.
– Annual Report, November 28, 2025. Development and completion of information tracking systems are expected on a similar timeline, as well as consideration of alternatives to a transmission heat map. Until the SGIP is revised and approved...
AI summary The document discusses the development of information tracking systems and the need for alternatives to a transmission heat map. It also outlines IESO Nova Scotia's interim solution for interconnection processes administration until the SGIP is revised and approved. IESO Nova Scotia will assume responsibility for reporting on interconnection processes under M12174.
101699Comments - SBA
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April 22, 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: Ml2524 - Nova Scotia Power Inc., Concentric FERC Order 2023 Report On Octo...
AI summary This letter discusses the submission of the Concentric FERC Order 2023 Report by NS Power and the subsequent responsibility transfer to IESO-NS. IESO-NS accepted most recommendations with some exceptions and proposed a 2026 implementation timeline, though no cost estimates were provided. The SBA notes that an interim agreement between IESO-NS and NS Power has not yet been filed.
Review by the SBA IE SO-NS summarized the Concentric Report's nine recommendations and then described four that it would implement only with exceptions. Below are the SBA's comments with respect to IESO-NS positions: Rl: Cluster Studies: I...
AI summary The SBA reviews IESO-NS's response to the Concentric Report, noting concerns about the lack of stakeholder input and clarity on proposed changes. Specific issues include the flexibility in conducting cluster studies, the transmission capacity heat map, study deposit structure, and penalty structure for transmission study deadlines. The SBA emphasizes the need for stakeholder engagement and timely resolution.
Submissions The SBA respectfully submits that the Board should consider requiring IESO-NS to: - 1. Provide confirmation whether the additional costs relating to the implementation of the Recommendations are already included in its 2026/202...
AI summary The Small Business Advocate (SBA) submits to the Board, requesting IESO-NS to clarify if implementation costs of recommendations are included in its 2026/2027 Revenue Requirements, explain its inability to provide a transition capacity heat map, and propose dates for stakeholder workshops to review recommendations.
101878Reply Comments - IESO
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May 6, 2026 Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: M12524 – Concentric FERC Order 2023 Report – IESO Nova Scotia Repl...
AI summary The Nova Scotia Energy Board (NSEB) has directed the Independent Energy System Operation of Nova Scotia (IESO) to respond to recommendations in Concentric Energy Advisors' report on interconnection process improvements. The IESO submitted its reply following comments from the Small Business Advocate and Consumer Advocate.
it, which the Commission requires customers to submit only once–upon entry into the cluster study – is calculated using a tiered approach based on the proposed MW size of the generating facility.19 … The current study deposit structure in...
AI summary The current study deposit structure in Nova Scotia aims to promote queue discipline and deter speculative applications. Concentric argues that adopting the deposit framework from Order 2023 could create financial barriers for viable projects and recommends maintaining existing practices to manage risk and ensure fair interconnection cost allocation.
The CA provided the following: The Consumer Advocate agrees with IESO NS's concerns. Given IESO NS's non-profit status, it is unclear how such a penalty would be paid without being subsidized by ratepayers. That is not to say that IESO NS...
AI summary The Consumer Advocate agrees with IESO NS's concerns about potential penalties for study delays, but emphasizes that ratepayers should not bear the cost. The issue will be further studied as part of SGIP amendments in 2026.
recommendations, its proposed exceptions to them and respond to feedback.[15](#page-4-1) In the IESO's February 12, 2026 comments, it provided the following regarding pending amendments to the SGIP: IESO Nova Scotia intends to consult stak...
AI summary The IESO plans to consult stakeholders on proposed revisions to the SGIP and related interconnection processes, aligning with Board initiatives on Matters M10905 and M12174. An interim agreement is being developed to clarify responsibilities between IESO Nova Scotia and NS Power until the SGIP is revised and approved by the NSEB, expected by Q1 2026.
Additional Costs Regarding the potential of additional costs associated with IESO Nova Scotia's recommendations, the SBA provided the following: IESO-NS's letter did not address how much it would cost to address and implement the recommend...
AI summary The SBA raised concerns about whether additional costs from IESO-NS's recommendations were included in its 2026/2027 Revenue Requirement Application. The IESO clarified that no additional costs are associated with its FERC Order 2023-related recommendations, and no decision has been made on a potential transmission heat map project.
102989Board letter re: directed to file an update
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July 28, 2026 [[email protected]](mailto:[email protected]) Mark Peachey Director, Regulatory Affairs IESO Nova Scotia 1791 Barrington Street, Suite 1010 Halifax, NS B3J 3K9 Dear Mr. Peachey: M12524 – Nova Scotia Power Incorpor...
AI summary Nova Scotia Power Inc. (NS Power) filed a report on FERC Order 2023, focusing on transmission interconnection processes. The IESO NS confirmed responsibility for implementing Concentric's recommendations, accepting most but noting potential revisions to interconnection procedures may be required.
Document: 332093 Recommendation Requirements Two Cluster Studies Per Year System Upgrade Cost Allocation Will require amendments to the SGIP and Cluster Study Cost Allocation corresponding NSEB approval. ISO Penalty Structure Will require...
AI summary The document outlines several recommendations for the System Upgrade and Cluster Study Cost Allocation, requiring amendments to the SGIP and NSEB approval. IESO NS plans to consult stakeholders in 2026 and submit revised SGIP to the Board by December 2026, with an interim agreement with NS Power expected by Q1 2026.
Comments from the Consumer Advocate (CA) and the Small Business Advocate (SBA) were filed on April 22, 2026. The CA submitted comments on the following issues: - Concentric recommended adoption of the penalty structure established under FE...
AI summary The Consumer Advocate and Small Business Advocate submitted comments on April 22, 2026, addressing issues related to interconnection study penalties, cost allocation for network upgrades, SGIP revisions, and an interim agreement between IESO NS and NS Power. They raised concerns about subsidy risks and the need for stakeholder consultation.
on IESO NS's expectation that an interim agreement between IESO NS and NS Power about respective responsibilities for administration of various interconnection processes would be finalized in Q1 2026. In its filing, the SBA provided commen...
AI summary The SBA provided comments on IESO NS's plan to implement Concentric recommendations with exceptions and highlighted concerns about cost inclusion, lack of a transmission capacity heat map, and the need for stakeholder workshops. IESO NS responded to these comments on May 6, 2026.
- Regarding cluster studies, IESO NS clarified its intent to "reserve the ability to conduct more than two cluster studies a year, not less, based on the number and nature of Interconnection Requests (IR) received in a study window". It al...
AI summary IESO NS discusses its approach to cluster studies, transmission capacity mapping, study deposits, penalty structures, and interim agreements with NS Power. It highlights the flexibility in conducting cluster studies, the shift from heat maps to alternative solutions for transmission capacity, and the need to align study deposits with actual costs. It also mentions plans for SGIP amendments and stakeholder consultations in 2026.
s in the process of finalizing the agreement and expects it will be complete and entered into in May 2026. - In responding to potential additional costs to implement recommendations related to FERC Order 2023, the IESO confirmed there are...
AI summary The IESO NS is working on finalizing an agreement expected in May 2026, and confirmed no additional costs for implementing FERC Order 2023. The Board has directed IESO NS to file an update by August 14, 2026, on the SGIP revision process and the status of the interim interconnection agreement with NS Power.