102117Responses to Stakeholder TOR Feedback - IESO
12 passages
BATES WHITE Question/Comment Response likely' base case, (c) represent holistic and distinct possible futures, (d) are vetted by stakeholders, (e) are complemented by targeted sensitivities." This language mixes critical elements, such as...
AI summary The text critiques the language in the Terms of Reference for its use of vague and undefined terms such as 'reduced set,' 'crisp,' and 'holistic,' suggesting that the enumeration of objectives may imply more specific and defined goals than intended.
The reference in the final sentence to the LOLE study appears unconnected to the discussion of the ELCC study commissioned by the IESO. It may be that the final sentence attempts to explain how the ELCC study will be conducted, and that th...
AI summary The text discusses the ELCC study commissioned by the IESO and suggests clarifying the final sentence regarding the LOLE study. It also recommends specifying which stakeholders were involved in developing the ELCC study scope of work, noting that feedback was received from various groups in 2025.
NRSTOR Question/Comment Response While these Acts and regulations establish minimum compliance requirements, the IESO also has an opportunity to lead by example and position Nova Scotia as a national leader in climate action and clean elec...
AI summary The text recommends that the IESO adopt the 2050 CER emissions requirements early to avoid future costs and position Nova Scotia as a climate action leader. It notes that alternative environmental policies are typically explored during an IRP.
SMALL BUSINESS ADVOCATE Question/Comment Response The Draft TOR does not include explicit discussion of risk Scenarios and sensitivities will be used to vary and test analysis, aside from the "Technology Risk" factor included in different...
AI summary The Small Business Advocate (SBA) raises concerns about the Draft Terms of Reference (TOR) for the Integrated Resource Plan (IRP), emphasizing the need for explicit risk considerations and clarity in the scoring methodology. The IESO Nova Scotia responds by acknowledging the need for stakeholder engagement and updating the TOR to address these issues.
April 24, 2026 IRP Team Independent Energy System Operator of Nova Scotia Vincent Musco Collin Cain Bates White Economic Consulting Vía e-mail Subject: Bates White's Comments Regarding IESO's Draft Terms of Reference
AI summary Bates White Economic Consulting submitted comments regarding the Independent Energy System Operator of Nova Scotia's (IESO-NS) draft Terms of Reference. The submission was made via email on April 24, 2026, by Vincent Musco and Collin Cain from the IRP Team.
10. Evaluation criteria The ToR proposes to plan future resource portfolios based on cost (70%) and other non-cost factors (30%).[20](#page-59-0) We recommend the IESO reconsider this weighting to more heavily weigh cost, particularly wher...
AI summary The ToR proposes a 70% cost and 30% non-cost weighting for resource portfolio planning. The IESO is advised to prioritize cost further, noting that GHG reduction can be addressed via OBPS carbon intensity allowances, while technology risk and economic growth metrics face implementation challenges. Non-cost criteria weights should be reconsidered.
5. Decisional vs Deliberative The Dunsky analysis includes a well-characterized discussion of the benefits and drawbacks of decisional and directional IRPs. In particular, I agree with the concerns about inefficiencies and re-work of issue...
AI summary The text discusses the Dunsky analysis on decisional vs. directional Integrated Resource Plans (IRPs), recommending a hybrid approach. It emphasizes aligning IRPs with Requests for Proposal (RFPs) and suggests the Nova Scotia Energy Board (NSEB) review submissions to approve IRPs. Complex resource decisions may require separate capital applications for detailed analysis.
Role of the IRP The Dunsky report noted that the question of whether the IRP results should be directional or decisional was a matter for consideration. The draft Terms of Reference indicate that the final IRP report outlining modelling as...
AI summary The Dunsky report considers whether the IRP should be directional or decisional. The draft Terms of Reference require the IRP report to be filed with the NSEB under the More Access to Energy Act. Eastward supports a directional IRP focused on near-term (3-5 year) resource procurement, while project-specific approvals under the Public Utilities Act remain required.
IRP scorecard: treatment of demand-side resources I support the move beyond pure least-cost optimization. The multi-criteria scorecard (Least Cost 70%, GHG Reduction 10%, Technology Risk 10%, Economic Growth 10%) is a meaningful improvemen...
AI summary The text supports a multi-criteria IRP scorecard (70% least cost, 10% GHG reduction, 10% technology risk, 10% economic growth) as an improvement over the 2020 IRP. It argues that the technology risk metric fails to reward proven demand-side resources over speculative supply-side ones (e.g., SMRs) and that economic growth metrics exclude local DR program jobs. Recommendations include adjusting technology risk scoring and expanding job-count methodologies.
Nova Scotia Power TOR Section Details/Component NS Power Feedback/ Questions Process Phases of the IRP, which includes the following: - Pre-IRP studies - Terms of Reference - Assumption and Scenario development - Modelling - Analysis and C...
AI summary Nova Scotia Power supports the phases of the Integrated Resource Plan (IRP) as outlined in the Terms of Reference (TOR), including stakeholder engagement and iterative modelling. They inquire whether stakeholder feedback will be captured in an IR process with the Nova Scotia Energy Board (NSEB) or shared publicly by the IESO-NS.
Below are PHP comments on the ToR: - Transmission and distribution, as well as needed ancillary services, are key parts of the development of the grid that do not appear to be included in the IRP, as was the case for the previous IRP. The...
AI summary PHP emphasizes the need to include transmission, distribution, and ancillary services in the IRP, advocate for building on prior IRP findings, reduce scenario complexity while retaining sensitivities, and ensure stakeholder representation. They request adequate time for review, integration of the 10-year system outlook, and inclusion of large-scale projects in the IRP scorecard.
Small Business Advocate Good Afternoon, With apologies for the delay in getting these comments to the group, please find the SBA's comments on the draft Terms of Reference outlined below. I note that we also echo many of the comments made...
AI summary The Small Business Advocate (SBA) submits comments on the draft Terms of Reference (ToR), aligning with other stakeholders' inputs. The SBA emphasizes the importance of stakeholder engagement and transparency in the regulatory process, ensuring small businesses' concerns are addressed in the ToR.