AI-generated summary
· Application · 09/18/2025
Intervenors file closing submissions in EfficiencyOne's 2026 DSM Extension Application, generally supporting approval while raising concerns over demand response cost-effectiveness, residential budget allocation, and mid-course spending controls.
AI summary
- The Small Business Advocate (Exhibit 99385) supports the extension but argues that contested issues raised by Synapse Energy Economics and Econoler—including program-level Cost Effectiveness of Demand Side Management demand response programs and novel benefit valuation concepts from the Peach Savings Verification Review—fall outside the legislatively prescribed scope of M12249 and should be deferred to the 2027–2031 five-year plan application.
- The Consumer Advocate (Exhibit 99386) supports the extension with modifications recommended by consultant Green Energy Economics Group (Exhibit E-16), including reallocating $2.1 million back to the residential sector to restore a 55% spending allocation; Efficiencyone declined this reallocation, which the Consumer Advocate characterizes as unsatisfactory and maintains as a live issue before the Board.
- The Industrial Group (Exhibit 99389) raises procedural concerns that EfficiencyOne failed to comply with prior Board directives requiring justification for measures failing cost-effectiveness testing and payback period disclosures, noting the data existed but was only produced through information requests (Exhibits E-4, E-6, E-8), thereby limiting intervenor scrutiny.
- The Industrial Group highlights that residential demand response fails both TRC and PAC tests at 0.3, and collectively DR programs fail both tests; it supports Synapse's recommendation requiring a PAC ratio of at least 1.0 for future DR programs and recommends the Board direct EfficiencyOne and NS Power to coordinate data sharing—including substation-level customer mapping—to enable locational DSM development.
- Both the Industrial Group and Consumer Advocate flag the NS Power cybersecurity incident as an unresolved operational risk: the breach has suspended the residential behaviour program by cutting off AMI data transfer, with EfficiencyOne acknowledging a material impact on 2025 targets but providing no remediation plan in its reply evidence (Exhibit E-17).
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What was filed
Documents filed on this day
- 99385 Submission - SBA
- 99386 Submission - CA
- 99389 Submission - IG