Ratepayer Impact Assessment of Time-Varying Pricing Pilot
Office of the Consumer Advocate | Nova Scotia
After a cybersecurity breach at Nova Scotia Power Inc. (NSPI) disrupted access to Advanced Metering Infrastructure (AMI) data, the utility faced challenges maintaining accurate billing for participants in its time-varying pricing (TVP) pilot. NSPI proposed a temporary billing approach that would keep the pilot running while metering data was unavailable. The Nova Scotia Energy Board (NSEB) requested stakeholder comments on an expedited 10-day timeline.
The Nova Scotia Consumer Advocate (CA) engaged GEEG to evaluate NSPI's proposal and assess its potential impacts on pilot participants and other ratepayers. GEEG reviewed the proposed billing approach, historical usage data, pilot evaluation findings, and alternative solutions to assess customer impacts, financial implications, and the feasibility of maintaining the pilot.
The pilot served approximately 8,000 customers, representing about 1.5% of NSPI's customer base. GEEG's analysis found that NSPI's proposal provided participating customers with rates that were comparable to or lower than the standard offer rate. Estimated under-collections associated with the temporary solution were approximately $500,000, less than 0.03% of 2024 residential revenues. GEEG also evaluated an alternative based on usage-weighted winter averages, an approach that could have resulted in higher charges for some participants and risked reduced pilot enrollment.
GEEG recommended that the CA support NSPI's proposed temporary solution, provided two open questions were addressed: how to handle the loss of price signals that encourage participants to shift their usage away from peak periods, and whether any under-collected revenue would be recovered from ratepayers. GEEG’s analysis gave the CA an assessment of the proposal's financial and customer impacts to inform its comments to the NSEB.
