N-1-(i)Terms of Reference - Tracked Changes
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ASSESSMENT PERIOD For this IRP, IESO Nova Scotia is proposing a study period of 2029 – 2053. This 25-year period encompasses the implementation dates of several key Federal and Provincial policies that must be considered when developing a...
AI summary IESO Nova Scotia proposes a 25-year assessment period (2029–2053) for the Integrated Resource Plan (IRP) to align with federal and provincial decarbonization policies, including 80% renewable electricity by 2030, coal phase-out by 2030, and Canada's Clean Electricity Regulations (CER) effective 2035. The period allows for modeling resource additions, retirements, and the Reliability Intertie's in-service date (2028) while maintaining consistency with prior IRPs.
KEY QUESTIONS In the NSEB's order for IESO Nova Scotia's Approval of its Proposed Expenditure and Revenue Requirement for the Test Year Ending March 31, 2026 (M12412), the following direction was provided for this IRP: "IESO Nova Scotia is...
AI summary The Nova Scotia Energy Board (NSEB) directed IESO Nova Scotia to address specific issues in its Integrated Resource Plan (IRP), including cost analysis for new supply-side resources, regional system modeling, ELCC portfolio updates, demand response scenarios, and emissions linkage. Additional key questions focus on decarbonization targets, offshore wind opportunities, and Mersey Hydro redevelopment.
102117Responses to Stakeholder TOR Feedback - IESO
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APRIL 17 STAKEHOLDER SESSION QUESTIONS Question/Comment Response However, IESO Nova Scotia needs to evaluate several topics Dunsky recommended IESO Nova Scotia move to a more that require more extensive study than may be feasible under reg...
AI summary The IESO Nova Scotia needs to evaluate topics requiring more extensive study than the proposed timeline allows, including operational reliability related to technologies like synchronous condensers and dynamic line ratings. Dunsky recommended a more regular cadence for conducting IRPs and advancing action plan items between IRPs.
INDUSTRIAL GROUP Question/Comment Response The draft IRP scorecard proposes applying non-cost objectives—such as GHG reduction, economic growth, and energy security—at the resource plan level after capacity expansion and production cost mo...
AI summary The Industrial Group raises concerns about the IRP scorecard's approach to integrating non-cost objectives like GHG reduction and energy security. They suggest applying these factors at the facility level prior to modeling. The response highlights technical and scheduling challenges with modifying the current model setup. Energy security is emphasized as a critical factor given current geopolitical conditions.
1. IRP planning and modeling horizon The ToR states: "An IRP assesses both supply-side and demand-side resources within the context of the Nova Scotia planning environment, including all applicable Federal and Provincial environmental poli...
AI summary The ToR for the IRP emphasizes a 20-30 year planning horizon for Nova Scotia's power grid, but stakeholders recommend clarifying the base case (e.g., 25 years) and retaining flexibility for the Reliability Intertie's in-service date. The ToR's current focus on 2029-2053 is tied to the Reliability Intertie's 2028 in-service date, though delays may require adjustments.
11. Items to consider adding to the ToR There are at least three other considerations that are unmentioned in the ToR that should be considered. First, there is no mention of the role of load forecasting. Our understanding is that load for...
AI summary The text suggests three additions to the Terms of Reference (ToR): load forecasting development, fuel supply considerations for conventional and emerging resources, and grid stability studies. These are critical for the Integrated Resource Plan (IRP) to address reliability, fuel costs, and grid stability as inverter-based resources increase.
1. Schedule Overall, it is reasonable for IESO Nova Scotia to focus the 2026 Integrated Resource Plan (IRP) on an updated resource planning model exercise. Developing confidence in the current resource development outlook is essential, par...
AI summary The text recommends delaying the 2027 Integrated Resource Plan (IRP) to allow thorough evaluation of technologies like synchronous condensers and dynamic line ratings, which could impact reliability. The 2026 IRP should focus on updated resource planning, with the 2027 IRP starting in September 2026 and taking 14-18 months to complete.
4. Hybrid Peak Net Zero Atlantic has published "Mitigating the Impact of Building Electrification on Peak Demand in Atlantic Canada" in August 2025, and NS Power states that a Hybrid Heating study is underway, in which Net Zero Atlantic wi...
AI summary NS Power is conducting a Hybrid Heating study, citing a 2025 Net Zero Atlantic report and a 2026 load forecast showing 48 MW peak mitigation. However, the math suggests limited non-electric heat reduction, conflicting with provincial electrification policies. The TWG is advised to evaluate this in the IRP.
RE: Draft Terms of Reference for the 2026 Integrated Resource Plan Energy Storage Canada (ESC) appreciates the opportunity to provide comments on the Draft Terms of Reference for IESO Nova Scotia's 2026 Integrated Resource Plan (IRP). As t...
AI summary Energy Storage Canada (ESC) supports Nova Scotia's 2026 Integrated Resource Plan (IRP) process, emphasizing energy storage's role in reliability, affordability, and decarbonization. ESC highlights storage's flexibility and resilience benefits as Nova Scotia transitions from coal and integrates renewables and nuclear imports. They offer technical expertise to refine modelling and resource evaluations.
Industrial Group To the IRP Team – On behalf of the iG, we have reviewed the comments previously filed and offer one additional consideration not yet addressed: First, we share the concern of BW regarding weighting of non-least cost factor...
AI summary The Industrial Group (IG) supports using long-term NPV as the primary determinant for the preferred resource plan in Nova Scotia's Integrated Resource Plan (IRP). It criticizes the proposed 10% weighting of the economic growth metric for overstating job creation benefits while ignoring electricity cost impacts on industries and export sectors. The IG urges explicit prioritization of NPV over non-cost metrics in the Terms of Reference (TOR) and final IRP, emphasizing affordability and reliability constraints.
Sensitivity on winter stress events and DR availability DR performance is highly sensitive to the same conditions that create system stress, so the IRP should test this explicitly. Based on Dunsky's April 17 clarification, key stress varia...
AI summary The document emphasizes the need to explicitly model Demand Response (DR) availability during winter stress events in Nova Scotia's Integrated Resource Plan (IRP). It argues that DR performance degrades under cold conditions, increasing reliability risks, and cites the 2022 Winter Storm Elliott analysis as evidence. A sensitivity analysis for sustained cold events (e.g., -15°C) is recommended to align with resource adequacy assessments.
Least-Cost Framework MRC notes that cost is weighted heavily in the evaluation framework, accounting for 70% of the assessment. While we recognize the importance of affordability, we encourage a broader interpretation of cost beyond simple...
AI summary MRC emphasizes that the Least-Cost Framework should consider system-level factors like ELCC and capacity factors, not just LCOE. Offshore wind's higher capacity factor reduces required generation capacity compared to onshore alternatives, while diversification lowers system costs by improving resilience and reducing fuel price risks. The 25-year NPV methodology is critical for capturing these benefits.
Risk of Undershooting Demand The IRP should explicitly recognize the asymmetric risks of underestimating demand in a context of rapid electrification. Constraining electricity supply poses a significant risk to Nova Scotia's economic growt...
AI summary The IRP must address the risks of underestimating demand due to rapid electrification, as constrained supply could hinder economic growth and lead to costly fossil fuel reliance. Proactive planning and export opportunities are recommended to ensure long-term, optimal solutions and system flexibility.
1701 HOLLIS ST. 12th FLOOR, HALIFAX, NS B3J 3M8 (902) 422-9663 NATURALFORCES.CA IESO Nova Scotia April 24, 2026 1791 Barrington St. Suite 1010 Halifax, NS B3J 3K9 RE: IESO's Draft Terms of Reference To whom it may concern; On behalf of Nat...
AI summary Natural Forces submits comments on the IESO's draft Terms of Reference for the 2026 Integrated Resource Plan, emphasizing that cost assessments should align with asset lifespans, sustainability must be prioritized, and risk evaluation should include factors like fuel price variability and geopolitical risks. It also advocates for broader environmental impact assessments, local economic considerations, and explicit energy security measures.
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.
Scenario/sensitivity analysis should provide foundation for action plan and signposts The Draft TOR notes that the IRP "will strive for a reduced set of crisp, focused scenarios" (p. 5). The SBA agrees with the priority of focusing on a so...
AI summary The Draft TOR emphasizes a limited set of focused scenarios for the IRP, but the SBA stresses that scenarios must be sufficiently expansive to address key uncertainties, such as the Reliability Intertie's Phase 2, offshore wind development, and inter-provincial transmission from a recent MoU. These factors could significantly impact IRP outcomes and inform the action plan.