AI-generated summary
· Closing_evidence · 09/04/2025
EfficiencyOne filed rebuttal evidence defending its proposed Benefit-Cost Analysis test framework for DSM evaluation, countering Industrial Group, Daymark, Synapse, and Eastward Energy intervenor arguments
AI summary
- EfficiencyOne (Efficiencyone) rebutted the Industrial Group's expert Patrick Bowman (Bowman Economic Consulting), who argued for the Program Administrator Cost (PAC)/Utility Cost Test as the primary Cost Effectiveness screen and for measure-level rather than portfolio-level screening; E1 argued that 2022 Public Utilities Act amendments (s. 79H(2)) mandate portfolio-level assessment and that the Board previously found measure-level screening a 'restrictive application' (M10437, para. 126–127).
- E1 defended the use of proxy values for hard-to-quantify non-energy benefits (Demand Side Management), citing National Standard Practice Manual (NSPM) guidance that excluding such benefits implicitly values them at zero, which is more distorting than conservative proxies; E1 and Energy Futures Group (EFG, Appendix A) rejected Daymark's recommendation to assign nil values to unquantified NEBs and to delay approval pending further third-party verification.
- On Forecasting Methodology, EFG defended the proposed 2% social discount rate over NS Power's WACC, arguing the social rate reflects multigenerational and decarbonization impacts now legislatively mandated, and endorsed the Difference in Carbon Emissions (DICE) method for calculating avoided GHG emissions, net of outside caps such as Nova Scotia's Output Based Performance Standard.
- E1 proposed an 'evergreen' periodic review process via the Demand Side Management Advisory Group (DSMAG) — anticipated to commence around 2029 for the 2032–2036 DSM Plan — to update all BCA test parameters including NEB proxies, avoided costs, and emissions methodology, addressing Synapse's recommendation for a structured 2029 update.
- E1 declined to include Eastward Energy as a formal DSMAG member given differing economic interests in gas-to-electric conversions, instead offering bilateral engagement; it also reaffirmed the Board-approved Balanced Plan Approach against Bowman's argument that cost-effectiveness should be the singular primary design criterion, noting the Industrial Group was a 2016 Consensus Agreement signatory supporting balanced plan design (M07543).
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-24 Rebuttal Evidence of E1 including Appendix A - Energy Futures Group Rebuttal Evidence
- 99223 Board letter confirming virtual attendance and hearing logistics
- 99226 Letter from E1 enclosing Rebuttal Evidence