N-52024-2025 Bates White FAM Audit Report - Redacted
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XI – Commitment and Dispatch Conclusion XI-2: The processes that NSPI uses for committing, scheduling, and dispatching units were not changed during the period before the cyber event, January 1, 2024 through April 25, 2025. The concerns th...
AI summary The audit findings highlight that NSPI's commitment and dispatch processes remained unchanged during the 2024-2025 period, with frequent manual adjustments to optimization plans. The low capacity factors of generation units suggest inefficiencies, and a new Economic Dispatch Optimization Solution is expected in 2026. Lingan 2 was kept online for extended periods for system security, and the Board is recommended to establish criteria for its operation.
XII – Power Purchases and Sales Conclusion XII-14: NSPI and NLH agreed that all undelivered volumes during the Audit Period were Block A volumes. However, the parties remain in dispute regarding classification of 61.2 GWh of "undelivered"...
AI summary NSPI and NLH disagree on the classification of 61.2 GWh of undelivered Base Block energy, with implications for compensation. NSPI argues it should be classified as Block B, requiring NLH to provide compensation energy, while NLH claims it should be Block A. NSPI is recommended to update the Board on efforts to resolve the dispute. Additionally, NSPI is advised to report NLH's Surplus Energy offered under the EAA in its FAM Annual Report.
VI.B.14. Bates White's 2022-2023 Audit Recommendations In our report for the prior audit period, we offered five recommendations related to biomass fuel. This section assesses NSPI's actions related to those recommendations. 309 2022-2023...
AI summary This section of the audit report discusses NSPI's implementation of five recommendations from the 2022-2023 Bates White audit, focusing on biomass fuel procurement, inventory processes, and agreement amendments. NSPI has taken several actions to address the recommendations, including revising RFP processes, updating the Fuel Manual, and executing agreement amendments.
VII.B. Findings NSPI evaluated various firm and interruptible pipeline transportation options and made decisions on whether to contract for pipeline capacity based on short-term analyses that corresponded to the terms of the contracts. It...
AI summary NSPI evaluated pipeline transportation options, including a 10-year firm transportation offer from Dawn to Westbrook, but did not adequately consider potential economic offsets or alternate scenarios. NSPI properly evaluated and supported its decision to renew and expand a transportation contract on M&NE-CA and participated in pipeline regulatory proceedings regarding rates.
rily disallows a complete quantification of the characteristics described in the recommendation. We therefore consider this recommendation unaddressed, and we reiterate our prior audit recommendation. Our second recommendation stated: Reco...
AI summary Bates White's recommendations regarding NSPI's participation in upstream pipeline tariff negotiations and periodic review of gas supply assumptions were partially addressed. NSPI accepted the recommendations and committed to ongoing engagement, but some aspects remain unaddressed.
X.B.3.d.ii. Status and Operation of Lingan 2 The Board considered the issue of the retirement of Lingan 2 and its relation to the commencement of the NS Block volumes in a February 8, 2022 Decision.446 The Board noted that in NSPI's integr...
AI summary The Board addressed the retirement of Lingan 2 in a February 2022 decision, noting that NSPI planned to keep the unit operational until one year after the NS Block commenced. The Board disallowed recovery of Lingan 2 operating costs beyond August 15, 2022, without further approval. NSPI phased out economic dispatch after that date but kept the unit in cold reserve. The IESO forecasts Lingan 2's retirement until 2029/2030, requiring NSPI to maintain the unit for 2-3 additional years.
XI.B.11. Bates White 2022–2023 Recommendations In the 2022-2023 Audit Report, BW made two recommendations relating to economic commitment and dispatch. These recommendations were addressed as follows: Recommendation XI-1: NSPI should provi...
AI summary Bates White recommended that NSPI provide a detailed report on how commitment and dispatch issues were addressed by selected optimization solutions and retain hourly system marginal cost data. NSPI accepted the recommendations but provided only high-level responses, which were deemed insufficient. However, NSPI confirmed in its February 2026 Update that it retained the data, and Bates White concluded that this recommendation was fully addressed.
XI.D. Recommendations Recommendation XI-1: NSPI should be required to comply with 2022-2023 Recommendation XI-1 and provide a detailed and comprehensive report that explains how the new functionality in the Economic Dispatch Optimization a...
AI summary The recommendations focus on NSPI's need to report on new system functionalities and establish criteria for maintaining Lingan 2's operation. The first recommendation requires a detailed report on how new solutions address system issues, while the second calls for criteria to be approved by the Board for Lingan 2's continued operation.
a form of PPA that was similar to that used in the Rate Base Procurement since that PPA had been approved by the Board. The Green Choice PPAs were reviewed and approved by the Board in matter M11455. - Goose Harbour PPA and PSA: On October...
AI summary The document discusses the execution of a PPA and PSA for the Goose Harbour Lake Wind Farm project between NSPI, Port Hawkesbury Paper Wind Ltd., and Port Hawkesbury Paper Limited Partnership. The agreements were issued by the Minister following input from NSPI and PHP, and NSPI was obligated to execute them under the Electricity Act.
XII.B.1.d.i. Background on Transactions over the Maritime Link The Maritime Link was placed into service on January 15, 2018.638 However, as a consequence of delays in the construction and commissioning of both the Muskrat Falls Generating...
AI summary The Maritime Link was commissioned in 2018, but delays in the Muskrat Falls Generating Station and Labrador Island Link projects affected NSPI's contractual energy delivery from NLH. Three key agreements, including the Energy and Capacity Agreement, outline the provision of energy blocks to NSPI over a 35-year term.
XII.B.3.a. NSPEMI NSPEMI is an affiliate of NSPI created to allow NSPI to transact for power and natural gas in the United States without the use–and added cost—of an agent. While technically an affiliate, NSPEMI's operations are conducted...
AI summary NSPEMI, an affiliate of NSPI, operates with NSPI employees and executes power and REC transactions. NSPI proposed a flow-through pricing protocol, which was approved by the Board. The NSUARB confirmed NSPI's compliance with the Affiliate Code of Conduct and approved pricing protocol.
XII.B.3.c. NSPML The Maritime Link is owned by NSPML, a wholly-owned subsidiary of Emera and an affiliate of NSPI. Recovery of Maritime Link costs were subject to Board-approved annual assessments. Revenue of up to $163.5 million and $197....
AI summary NSPML, a subsidiary of Emera, is subject to revenue holdbacks until certain conditions are met. NSPML applied to end the holdback mechanism in M12696. In 2024 and 2025, NSPML received approved revenue amounts, and NSPI reported cost reductions related to the Maritime Link and FAM balance. Financial details and applications are discussed in various matters and decisions.
ee to an arbitration procedure or litigation. In our view, NSPI has reasonably pursued this issue and we include a recommendation that NSPI update the Board upon resolution. (Recommendation XII-1) Conclusion XII-15: NSPI worked constructiv...
AI summary NSPI has worked with Bates White to determine the value of undelivered and makeup energy volumes related to NS Block. While they agree on the makeup energy value, they differ on the undelivered volumes' value, leading to conflicting net benefit and cost calculations for FAM customers. NSPI's decision to receive makeup energy in non-winter months was supported as reasonable.
XIII.A. Background To fuel its generating units, NSPI must buy fuel on the open market, which exposes NSPI—and FAM customers—to price risk. If fuel prices rise, NSPI must pay more (and charge FAM customers more) for fuel; if fuel prices fa...
AI summary NSPI must purchase fuel on the open market, exposing it and FAM customers to fuel price volatility. Hedging strategies are used to mitigate this risk and stabilize rates. The EPIA required NSPI to submit a Fuel Stability Plan for Board approval. NSPI updated its hedging plan in 2022 and 2023, aligning it with Nova Scotia's OBPS. The Fuel Hedging Plan remained largely unchanged during the Audit Period.
XV.B.4.b. The Number of PHP Deviations from Schedule During the audit period, we identified hours with a deviation from schedule when in the same hour NSPI did not. Also, we identified hours in which we found no deviation but NSPI did find...
AI summary The audit identified discrepancies in the number of PHP deviations from schedule compared to NSPI's findings, attributed to ramping issues and measurement problems. It recommends hourly identification of deviations for consistency with independent system operators. Cause Code 3 (PFL) and 5 (PDN) deviations show varying trends over the 2020-2025 period, with PNA deviations doubling between 2023 and 2024. In 2025, deviations were not tracked during a cyber event.