AI-generated summary
· Application · 08/19/2025
Efficiency Canada and KMKNO file letters of comment supporting EfficiencyOne's proposed new Benefit-Cost Analysis test for DSM evaluation in M12282
AI summary
- Efficiency Canada (Exhibit E-15) submitted comparative analysis showing a Canadian trend away from the narrowly defined Cost Effectiveness Total Resource Cost (TRC) test toward the Program Administrator Cost (PAC) test or TRC tests augmented with non-energy benefits, with BC Hydro, Efficiency Manitoba, Ontario IESO, efficiencyPEI, and others already using PAC as their primary screening test.
- Efficiency Canada endorsed EfficiencyOne's proposed framework for enumerating specific benefits rather than applying generic adders, and recommended adoption of a social discount rate in place of the Weighted Average Cost of Capital (WACC), arguing the WACC reflects utility investor interests inconsistent with Nova Scotia's independent efficiency utility model and the Energy Reform Act's sustainable development mandate.
- The letter flagged Demand Side Management implications for strategic electrification, arguing the new test's capacity to incorporate multi-fuel costs and benefits will allow EfficiencyOne to pair heat pumps with building envelope improvements and demand response, preventing unstrategic electricity system peak growth.
- Kwilmu'kw Maw-klusuaqn Negotiation Office (KMKNO) and the Assembly of Nova Scotia Mi'kmaw Chiefs submitted a letter supporting the inclusion of non-energy benefits as a step toward equitable Low Income Programs program design, while noting the application contains no explicit reference to Mi'kmaq communities and recommending direct engagement with KMKNO to develop DSM tools addressing Mi'kmaq realities, including continuation of the Mi'kmaw Home Energy Efficiency Program.
- Both letters were filed in August 2025 ahead of Board deliberation on EfficiencyOne's application for approval of the new BCA test framework (M12282).
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-15 Letters of Comment