Topic:"Regulatory Oversight" in M12524

INTERCONNECTION PROCESS RECOMMENDATIONS FOR THE NOVA SCOTIA ELECTRICITY SYSTEM FOLLOWING REVIEW OF FERC ORDER NO. 2023 AND AUGUST 2025 STAKEHOLDER WORKSHOP PREPARED FOR: NOVA SCOTIA ENERGY BOARD OCTOBER 2025 [CEADVISORS.COM](http://www.cea...

AI summary This document provides interconnection process recommendations for the Nova Scotia electricity system following a review of FERC Order No. 2023 and an August 2025 stakeholder workshop. It was prepared for the Nova Scotia Energy Board in October 2025 by Concentric Energy Advisors, Inc.

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.

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.

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.

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.

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.

Facilities Studies - (b) The IESO NS shall engage NS Power in Interconnection System Impact Study results meetings. Within three (3) Business Days following the Interconnection System Impact Study results meeting, NS Power shall provide to...

AI summary The document outlines procedures for engaging NS Power in Interconnection System Impact Study results meetings, submitting Facilities Study Agreements, and handling new applications or requests related to interconnection facilities. These processes are governed by the SGIP and the IESO NS.

6.3 Deposit Responsibility and Limitation of Liability. - (a) Each Party shall be solely responsible for the proper receipt, custody, accounting, application, and return of any deposit or other funds held by it from time to time in relatio...

AI summary Section 6.3 outlines the responsibilities and limitations of liability regarding deposits and funds handled by parties under the SGIP. Each party is solely responsible for the handling of deposits, and liability is limited except in cases of breach by a party.

NOVA SCOTIA POWER INCORPORATED Per: Matthew Drover Title: VP, Strategy & Customer Witness NOVA SCOTIA INDEPENDENT ENERGY SYSTEM OPERATOR Witness Per Chris Milligan Title: VP, System Planning & Grid Integration - 9 -

AI summary The document lists two witnesses from Nova Scotia Power Incorporated and the Nova Scotia Independent Energy System Operator, providing their names and titles. It includes a page number reference.

October 23, 2025 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M10905 - Concentric FERC Order 2023 Report Dear Ms. Henwood: In its Decision on June 11, 2024, the Nova...

AI summary The Nova Scotia Energy Board directed Nova Scotia Power to review FERC Order 2023 and update the Board on the progress by October 31, 2024. The deadline was extended to November 29, 2024, and Concentric Energy Advisors was engaged to assist with the review. A stakeholder conference was held in August 2025 to discuss findings and recommendations.

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.

R6. Penalty Structure IESO Nova Scotia notes that the penalty structure recommendation by Concentric focuses primarily on transmission providers, with only the following brief reference to applicability to independent system operators (ISO...

AI summary IESO Nova Scotia notes that Concentric's penalty structure recommendation primarily targets transmission providers and only briefly mentions ISOs. Since some interconnection responsibilities have transferred to IESO Nova Scotia, it suggests that applying penalties to it may not be appropriate without further study. IESO Nova Scotia plans to reconsider this as part of its 2026 SGIP revisions.

… 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.

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.

Penalty Structure The SBA provided the following comments with respect to the IESO's February 12, 2026 comments on penalty structure: IESO-NS recognized that, as a transmission provider, it would be subject under existing rules to a penalt...

AI summary The SBA comments on the IESO's penalty structure, noting that IESO-NS, as a not-for-profit transmission provider, should not face penalties for missing transmission study deadlines. The SBA emphasizes the need for timely and thorough consideration of this issue.

BA also noted the importance of the penalty structure issue and the need for a fulsome consideration in an expedient manner. On May 6, 2026, IESO NS responded to the comments from the CA and the SBA:

AI summary The document highlights the importance of addressing the penalty structure issue with thorough consideration and efficiency. IESO NS responded to comments from the CA and SBA on May 6, 2026.