AI-generated summary
· Application · 07/29/2025
Industrial Group expert witness recommends rejection of EfficiencyOne's proposed societal-cost BCA test, urging the NSERB to adopt the Program Administrator Cost test as the primary DSM screening tool
AI summary
- Expert Patrick Bowman (Bowman Economic Consulting Inc.), retained by the Industrial Group of Nova Scotia, filed revised pre-filed testimony (Exhibit E-14) on July 28, 2025, recommending the Board reject Efficiency One's proposed Demand Side Management Benefit-Cost Analysis test as the primary screening tool, calling it "excessively expansive" and misaligned with most Canadian peer jurisdictions.
- Bowman argues that Efficiency One's Proposed BCA — essentially a Societal Cost Test — is fundamentally delinked from NSPI customers who fund DSM programs; he contends the Program Administrator Cost (PAC) test, with added revenue benefits for beneficial electrification, should serve as the primary Cost Effectiveness screening tool, consistent with Manitoba, BC, Ontario, New Brunswick, PEI, Saskatchewan, and Yukon.
- The testimony challenges E1's position that Program Evaluation need only occur at the Portfolio level, arguing the Board cannot fulfill its statutory mandate under Public Utilities Act ss. 79H(1) and 79L(4) — including determining cost-effective DSM at the activity and program level and ensuring DSM is in the best interests of NSPI customers — without granular measure- and program-level BCA data.
- Bowman disputes E1's proposed 2% social discount rate, asserting it violates National Standard Practice Manual Principle 1 (treating DSM as a utility system resource comparable to generation) and Treasury Board guidance requiring consistent discount rates; he recommends using NSPI's Weighted Average Cost of Capital (WACC) instead.
- The testimony raises concerns about E1's avoided-cost and GHG benefit inputs, questioning whether simple inflation-adjusted baselines appropriately reflect evolving system conditions and whether purported avoided GHG emissions are real if system emissions are externally capped regardless of DSM deployment.
Disclaimer: This summary was generated by AI from the filings it describes. We take care to make it accurate, but errors are possible - and it isn't advice. Only the filings themselves are the record: if you're relying on something here, confirm it against the source documents or the Nova Scotia Energy Board's own record. Full disclaimer →
What was filed
Documents filed on this day
- E-14 Evidence of P. Bowman, on behalf of IG - Revised (Old evidence filed under E-8)