Topic:"Regulatory Compliance" in M12696

Taking all of this into account, NSPML submits that Nova Scotia customers should not be concerned by the planned outages in the non-winter months following the Compliance Period. To the contrary, and consistent with the pattern of deliveri...

AI summary NSPML argues that planned outages during non-winter months are not a concern for Nova Scotia customers, as energy delivery remains reliable and consistent with the ECA. Planned outages are conducted in accordance with Good Utility Practice, during lower demand periods, and energy is redelivered promptly. NSPML, NS Power, and NLH agree on scheduling non-critical outages during non-peak periods to benefit customers during winter.

Compliance Period NS Block Delivery Levels Year Month NS Block Contract Amount Base Contract Delivered Base Contract Delivery (%) Make-up Delivered Total NS Block (%) Make-up Balance Make-up Balance (%) May 83,742 82,998 99% 41,674 149% 57...

AI summary The table presents NS Block delivery levels against contract amounts from May 2023 to April 2024, showing base contract delivery percentages and make-up balances. Compliance periods are indicated, with some months meeting 100% of the contract amount and others falling below. The data is part of a regulatory proceeding filed on February 3, 2026.

1 Q18. HAS NSPML MET BOTH CONDITIONS OVER THE COMPLIANCE PERIOD? - 2 A18. If the Board provides relief for planned outages and the extreme weather outage in March - 3 2024/April 2024 (explained in more detail below), Concentric is confiden...

AI summary The document addresses whether NSPML met compliance conditions, noting that Concentric believes NSPML satisfied termination criteria for the holdback mechanism if the Board provides relief for planned outages and an extreme weather outage in March/April 2024.

6 1.3 Segmented Line Lengths versus Full Line Length - 7 In line with CSA standards, the LIL reliability has been assessed based on segmented line lengths (i.e., 11 - 8 individual line segments based on geographical region) versus the full...

AI summary The document discusses reliability assessments of the Labrador-Island Link (LIL) using segmented line lengths versus full line lengths, referencing CSA standards. Haldar & Associates emphasize the importance of full line length analysis, noting increased failure probability compared to global infrastructure benchmarks. Pre-CSA design considerations did not standardize full line length assessments, and current adoption remains unclear.

2.1 EFLA Assessment of As-Designed Structural Capacity of the Labrador-Island Link - 12 In the first stage of the reliability assessment undertaken by Hydro, EFLA Consulting Engineers ("EFLA") - 13 was engaged to complete a comprehensive r...

AI summary EFLA Consulting Engineers assessed the Labrador-Island Link's structural capacity against CSA standards, finding a 1:150 year return period. However, rime icing was excluded as CSA lacks specific requirements. SNC Lavalin's peer review identified discrepancies due to differing ice load inputs and calculation methods based on CSA interpretations.

3.1 CSA 60826 Analysis - 29 Based on CSA 60826, the Haldar & Associates Assessment indicates that the as-built LIL has a return - 30 period of approximately 1:72 years and an estimated annual failure rate of 1.10% where the CSA standard is...

AI summary The Haldar & Associates Assessment, based on CSA 60826, evaluates the Labrador-Island Link (LIL) and concludes its mechanical failure limits are not expected to be reached due to a 60% OPGW tension limit (vs. CSA's 75%), providing a safety margin. While extended outages are unlikely, persistent environmental conditions could cause operational issues.

Executive Summary This report presents the impact of two types of icing on the structural reliability of the Labrador-Island Link (LIL) HVdc transmission line. The two types of icing are (a) glaze icing due to freezing precipitation and (b...

AI summary This report evaluates the structural reliability of the Labrador-Island Link (LIL) HVdc transmission line under glaze and rime icing conditions. It assesses failure rates, validates LIL design against CSA 60826-2010, and compares failure rates normalized by line length with operational data. The study informs reliability planning by quantifying outage risks from extreme weather.

r/NLH's electrical system (almost half of the current electrical peak load). The catastrophic loss of such an important line would result in severe consequences for the island's electric power system. Some national and international standa...

AI summary The text emphasizes the critical importance of the NLH's electrical system and the severe consequences of its failure. It references CSA standards requiring transmission lines to use 50-year return periods, with higher standards (1:150 to 1:500 years) for critical lines. A 2018 judicial inquiry questioned the reliability of the LIL and Nalcor's communication about it.

Article 3. Regulatory Filings 3.1 Filing. Transmission Provider shall file this LGIA (and any amendment hereto) with the appropriate Governmental Authority, if required. Interconnection Customer may request that any information so provided...

AI summary Article 3.1 outlines obligations for filing the Large Generator Interconnection Agreement (LGIA) with governmental authorities, including confidentiality provisions under Article 22. The Interconnection Customer must cooperate with the Transmission Provider to comply with regulatory requirements during the filing process.

5.17 Taxes. - 5.17.1 Interconnection Customer Payments Not Taxable. The Parties intend that all payments or property transfers made by Interconnection Customer to Transmission Provider for the installation of Transmission Provider's Interc...

AI summary The section outlines that payments by Interconnection Customer to Transmission Provider for interconnection facilities and network upgrades are non-taxable under IRS guidelines. It references IRS Notices 2001-82 and 88-129, requiring capitalization of costs as intangible assets over 20 years and limiting dual-use intertie power flows to 5% in the direction of the Large Generating Facility.

- 13.2 Obligations. Each Party shall comply with the Emergency Condition procedures of the applicable ISO/RTO, the Electric Reliability Organization, Applicable Laws and Regulations, and any emergency procedures agreed to by the Joint Oper...

AI summary Article 13 outlines obligations during emergencies, requiring compliance with ISO/RTO and Electric Reliability Organization procedures. Transmission Provider and Interconnection Customer must notify each other promptly of emergencies affecting facilities, detailing the condition, impact, and corrective actions. Immediate action requires Transmission Provider's consent unless urgent.

Article 14. Regulatory Requirements and Governing Law 14.1 Regulatory Requirements. Each Party's obligations under this LGIA shall be subject to its receipt of any required approval or certificate from one or more Governmental Authorities...

AI summary Article 14.1 outlines obligations under the LGIA, requiring parties to obtain governmental approvals and comply with federal acts like the Federal Power Act and PURPA. It emphasizes that the LGIA does not compel actions that could jeopardize the Interconnection Customer's regulatory status under these laws.

14.2 Governing Law. - 14.2.1 The validity, interpretation and performance of this LGIA and each of its provisions shall be governed by the laws of the state where the Point of Interconnection is located, without regard to its conflicts of...

AI summary Section 14.2 of the LGIA establishes that the agreement is governed by the laws of the state where the Point of Interconnection is located, subject to applicable laws and regulations. Parties retain the right to contest or appeal governmental laws, orders, or regulations.

- 18.2 Consequential Damages. Other than the Liquidated Damages heretofore described, in no event shall either Party be liable under any provision of this LGIA for any losses, damages, costs or expenses for any special, indirect, incidenta...

AI summary The article limits liability for consequential damages and outlines insurance requirements under the Large Generator Interconnection Agreement (LGIA). Parties are not liable for indirect or consequential damages, and each must maintain specific insurance coverages, including workers' compensation and general liability insurance.

Article 21. Comparability 21.1 Comparability. The Parties will comply with all applicable comparability and code of conduct laws, rules and regulations, as amended from time to time.

AI summary Article 21.1 mandates that all Parties comply with applicable comparability and code of conduct laws, rules, and regulations, as amended over time.

Article 23. Environmental Releases 23.1 Each Party shall notify the other Party, first orally and then in writing, of the release of any Hazardous Substances, any asbestos or lead abatement activities, or any type of remediation activities...

AI summary Article 23 mandates parties to notify each other promptly (within 24 hours) of environmental releases, including hazardous substances, asbestos, or remediation activities at the Large Generating Facility or Interconnection Facilities. Notifying parties must also share publicly available reports with government authorities.

Chapter 3 Design

AI summary Chapter 3 Design outlines technical and regulatory considerations for power systems, including acronyms related to transmission, standards, and regulatory bodies. The section serves as a reference for terminology used in the proceeding.

- NS Block, measured in MWh (excluding Make-up Energy), is received during each of 12 - consecutive months."[41](#page-18-1) In introducing this requirement, the Board also stated: - NSPML/NS Power may apply to the Board for relief if it c...

AI summary The requirement mandates NSPML to receive twelve consecutive months of NS Block volumes (excluding Make-up Energy) at least 90% of the total monthly volumes called for under the Energy and Capacity Agreement. This prevents over-reliance on Make-up volumes and ensures consistency and predictability in volume delivery.

Q. What is your initial assessment of the Board's threshold? - A. Computationally, the requirement is straightforward and offers a bright-line test for - determining compliance. The collective NS Block deliveries in a month either exceed 9...

AI summary The threshold for compliance is computationally straightforward, using a 90% NS Block delivery benchmark. However, reliance on non-compliance exceptions for 'good utility practice' or 'exceptional circumstances' introduces subjectivity, as these terms lack clear definitions, complicating compliance determinations.

Q. Has NSPML claimed it has met the "Consistent Deliveries" threshold? - A. Yes. NSPML claims that it met this threshold due to results observed over the 12-month - period beginning with May 2023 and ending April 2024.[47](#page-20-2) NSPM...

AI summary NSPML claims to have met the 'Consistent Deliveries' threshold based on a 12-month compliance period (May 2023–April 2024), citing specific attachments and pages from its application and supporting documents.

11 - 13 Q. For the four months in which deliveries were below threshold, did NSPML claim - 14 that the deficiencies were explained by "good utility practice" and/or "exceptional - 15 circumstances?" 48 NSPML Application, page 10 lines 12 t...

AI summary NSPML claims that deficiencies in NS Block volumes during four months were due to 'good utility practice' and 'exceptional circumstances,' specifically citing a planned LIL outage in July 2023 and other factors related to the LIL's performance, not Muskrat Falls or the Maritime Link.

hern California Edison's 2021 general rate case (track 2) on behalf of the Small Business Utility Advocates. Reasonableness of remedial software costs to be included in authorized revenue requirement. Georgia PSC Docket Nos. 4822, 16573 an...

AI summary Expert testimony details involvement in multiple regulatory cases, including fuel adjustment mechanism audits, rate design reviews, and compliance with Commission orders. Key topics include cost recovery, resource planning, and modifications to pricing programs in California and Nova Scotia proceedings.

6 Request IR-2: 7 On p. 3 of Exhibit N-1, NSPML states: 8 9 In its October 2023 Decision in that matter, the Board ordered that the Holdback 10 would continue until (1) at least 90% of the NS Block (excluding Make-up Energy) 11 is received...

AI summary The Board's October 2023 decision requires NSPML to meet specific delivery thresholds for the Holdback to be released. NSPML claims compliance with the 90% delivery requirement, except for September 2023 due to a planned outage. The Board is asked to confirm compliance and provide data on undelivered energy balances.

6 Request IR-2: 7 On p. 3 of Exhibit N-1, NSPML states: 8 9 In its October 2023 Decision in that matter, the Board ordered that the Holdback 10 would continue until (1) at least 90% of the NS Block (excluding Make-up Energy) 11 is received...

AI summary The document requests clarification on NSPML's compliance with the October 2023 Board Decision regarding the Holdback. It questions whether NSPML met the 90% delivery threshold for the NS Block and when the undelivered energy balance falls below 10% of the annual contracted amount, citing Exhibit N-1 data.

- 26 (b) Please explain why this evidence is characterized as "Rebuttal" evidence. 1 Request IR-20: 20 21 22 23 24 (i) The adequacy of planning and coordination in advance of the outage, including the timing and sufficiency of outage reque...

AI summary The document requests an explanation for why the evidence is classified as 'Rebuttal' evidence, focusing on the adequacy of planning and coordination prior to an outage, and the selection of outage timing.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT and the MARITIME LINK ACT and the MARITIME LINK COST RECOVERY PROCESS REGULATIONS - and - IN THE MATTER OF: AN APPLICATION by NSP MARITIME LINK INC. to end the holdback me...

AI summary The Nova Scotia Energy Board is reviewing NSP Maritime Link Inc.'s application to terminate a holdback mechanism, referencing Matter M11009. Bates White LLC has issued information requests regarding financial data in appendices, including Supplemental Block volumes and calculations of outstanding balances under the Maritime Link Cost Recovery Process.

- 3. This Hearing Order be advertised by posting it on the Board website under Notices of Hearing. - 4. The Clerk of the Board provide a copy of this Hearing Order to the list of those interested in electricity matters. DATED at Halifax, N...

AI summary The Hearing Order is to be advertised on the Board's website and provided to interested parties by the Clerk of the Board. The order is dated April 1, 2026, in Halifax, Nova Scotia.

30 volumes affected. 1 2025 M12696 28 the LIL was still operational and energy deliveries could have been made? 29 If so, please identify the specific hours and estimated NS Block delivery 1 2 3 (c) In Bates White's opinion, if NSPML had g...

AI summary The text outlines several requests for information related to NSPML's maintenance scheduling during an LIL outage and the interpretation of force majeure clauses in regulatory contexts. It questions whether NSPML's actions demonstrate optimal operational scheduling and seeks clarification on regulatory guidance for weather-related force majeure.

1 3.0 GOOD UTILITY PRACTICE AND EXCEPTIONAL CIRCUMSTANCES 2 3 3.1 Appropriate Standards 4 5 As set out above, NSPML submits that good utility practice and/or exceptional 6 circumstances necessitated or caused downtime resulting in NS Block...

AI summary NSPML argues that downtime leading to NS Block deliveries below 90% in specific periods was due to good utility practice or exceptional circumstances. The Board did not define these terms, allowing for argument and evidence. NSPML cites definitions from Nova Scotia's Wholesale Market Rules and Regulations, as well as a definition from the Joint Operating Agreement.

April 2024 NSPML seeks relief for April 2024 deliveries on the grounds of "exceptional circumstances," arising from the forced LIL bipole outage caused by significant ice accumulation in late March that continued into April 2024. Ice accum...

AI summary NSPML is requesting relief for April 2024 deliveries due to an ice accumulation event on the LIL, which caused a forced outage. However, the Industrial Group argues that the event does not qualify as 'exceptional circumstances' because the LIL had known design vulnerabilities and prior icing events, indicating that the issue was foreseeable and not truly exceptional.

NSPML Application to Review the Holdback Mechanism (M12696) Final Reply July 23, 2026

AI summary The Final Reply to the NSPML Application to Review the Holdback Mechanism (M12696) was submitted on July 23, 2026. The document outlines the application's request for a review of the holdback mechanism, a key component of the regulatory process.

Q. What do you conclude regarding NSPML's requests in its Application? A. I conclude that NSPML satisfied the "Reduction in Undelivered Volumes" condition for ending the Holdback. Specifically, by the end of March 2024, the net outstanding...

AI summary The conclusion is that NSPML met the 'Reduction in Undelivered Volumes' condition for ending the Holdback, as the outstanding balance was below 10%. However, the 'Consistent Deliveries' threshold remains ambiguous due to reliance on exceptions and potential conflicting evidence, including LIL performance risks. The evidence aims to assist the Board in making a determination.

16 3.13 Post Compliance Period DCCT Work 17 18 NSPML wishes to offer clarity on outages related to DCCT work completed by NLH in 19 Newfoundland on the LIL. At page 7 of its Submission, the IG accused NSPML of 20 purposefully delaying an o...

AI summary NSPML clarifies that it was not responsible for scheduling DCCT work on NLH assets and that delays were due to supply chain issues, not intentional avoidance of holdback conditions. NSPML asserts that it did not influence outage planning to avoid financial impacts and that no evidence supports the IG's accusation of intentional delay.