N-52024-2025 Bates White FAM Audit Report - Redacted
10 passages
XI.B.4. Port Hawkesbury Paper Port Hawkesbury Paper ("PHP") takes service from NSPI under the Extra Large Industrial Active Demand Control ("ELIADC") tariff. The tariff allows NSPI to manage PHP load to reduce system costs to the benefit o...
AI summary Port Hawkesbury Paper operates under the ELIADC tariff, allowing NSPI to manage its load for system cost reduction. However, the methodology for measuring ADC benefits is inadequate, and real-time dispatch deviations impact FAM customers. PHP's load is not consistently used for reserve requirements due to operational interruptions.
XV.A. Background Port Hawkesbury Paper ("PHP") has been taking service under the Extra Large Industrial Active Demand Control Tariff ("ELIADC") since January 1, 2020. The Tariff was approved for an initial term of three years, 2020-2023.80...
AI summary Port Hawkesbury Paper (PHP) has been under the ELIADC tariff since 2020, with extensions approved in 2023 and 2025. The tariff aims to improve efficiency in serving PHP's load and benefit other NSPI customers. However, the recorded benefits to FAM customers have been lower than anticipated, primarily due to mandatory fixed cost contributions.
XV.B.1. Implementation of the ELIADC There are several important features of the ELIADC that relate to active demand control and pricing: - PHP's load is incorporated within PortOps during the Day Ahead and Intra Day schedule creation and...
AI summary The ELIADC (Extra Large Industrial Active Demand Control Tariff) incorporates PHP's load into PortOps for scheduling and optimization, with fixed rate payments based on forecasted costs. Due to the 2025 cyber incident, PortOps was unavailable for a period, leading to manual scheduling using PLEXOS and impacting real-time schedules until August 2025.
XV.B.1.a. ELIADC Price Components There are four main charge elements under the ELIADC: - 1. Customer Baseline Energy Charge ("CBL Energy Charge") - 2. Customer Baseline Adder ("CBLA") - 3. Variable Capital Charge ("VCC") - 4. Active Deman...
AI summary The ELIADC tariff includes four main charge elements: Customer Baseline Energy Charge, Customer Baseline Adder, Variable Capital Charge, and Active Demand Control Credit. PHP is subject to additional adjustments for deviations from dispatch instructions, meeting minimum payment requirements, and capturing ADC benefits.
CBL Energy Charge The CBL Energy Charge includes all incremental, non-capital costs to serve PHP load.816 Prior to each tariff year, PHP is required to provide NSPI a forecast of annual and monthly energy requirements, including anticipate...
AI summary The CBL Energy Charge is a flat rate based on forecasted incremental costs to serve PHP load, determined by NSPI using forecast information provided by PHP. This charge is applied monthly and can vary throughout the year.
CBLA The Customer Baseline Adder is a charge to PHP "to contribute to the reduction of the cost of service to other NS Power customers."821 It is determined relative to a reference rate specified in the tariff, which has been $61.75/MWh in...
AI summary The Customer Baseline Adder (CBLA) is a charge applied to PHP to offset the cost of service for other NS Power customers. It is calculated based on a reference rate of $61.75/MWh. When the CBL Energy Charge is below this rate, the CBLA is calculated as 75% of the difference plus $1/MWh. When it is above, the CBLA is set at $1/MWh. From March 2024 onward, the CBLA was $1/MWh, while it was higher in previous years.
ts but rather the weighted average costs of fuel inventories. See NSUARB, "Board Decision Letter", M11021, July 5 2023, p. 2. b. $4.00 multiplied by the total number of MWh supplied in the year.832 In 2024, actual costs to serve PHP load w...
AI summary The text discusses the financial implications of the ELIADC tariff on PHP, including ADC benefits, Off-Schedule Charges, and net costs. In 2024, PHP had to make an additional payment, while in 2025, it received a benefit that was partially allocated to FAM customers. The Off-Schedule Charge was reduced and netted against a CBL Credit, resulting in a net cost to PHP.
XV.B.4.c. The Identification of PHP Deviations from Schedule Under the ELIADC tariff, NS Power/NSPSO is required to track the timing, magnitude, and reason for deviations,844 In the case of NS Power or PHP's inability to follow the dispatc...
AI summary The document discusses the responsibility for tracking deviations from the schedule under the ELIADC tariff. It highlights that PHP, rather than NS Power/NSPSO, tracked these deviations, creating a conflict of interest and violating the tariff, particularly with Cause Code 5 (PDN), which penalizes PHP for deviations. The recommendation is that PHP should not be allowed to determine and record off-schedule deviations.
Figure XV-19: Deficiencies in NSPI's Reported Information Requested Information Provided in 2024 ELIADC Annual Report Provided in 2025 ELIADC Annual Report 2022-2023 FAM Audit – Recommendation XV-3 More detailed quantification of actual lo...
AI summary The document highlights deficiencies in NSPI's reported information regarding the ELIADC tariff, including a lack of detailed quantification of load shifting benefits, incomplete narrative discussions on beneficial deviations, and insufficient information on tariff improvements. NSPI has partially complied with previous audit recommendations but continues to provide incomplete data, which limits the ability of FAM customers to assess the ELIADC tariff objectively.
XV.D. Recommendations Recommendation XV-1: In the 2026 ELIADC annual report and all future reports, NSPI should report the amounts collected under the $4/MWh (or any other) mandatory contribution to fixed costs, but should not characterize...
AI summary The recommendations focus on improving reporting and cost allocation practices related to the ELIADC and PHP. They include changes to how fixed costs are reported, modifications to ADC benefits, real-time deviation reporting, and adjustments to the calculation of Cause Code 5 penalties.