Intervenors file opening statements in M12282, revealing significant disagreement over EfficiencyOne's proposed Benefit-Cost Analysis test for DSM plans

M12282 · EfficiencyOne - New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans Application for Approval of New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans

AI summary

Efficiencyone has applied to the Nova Scotia Energy Board for approval of a new Demand Side Management Benefit-Cost Analysis (BCA) test to replace the Total Resource Cost (TRC) test in use since 2010, intended to govern DSM plan evaluation starting with the 2027–2031 plan cycle (E-26, E-27).
The Consumer Advocate expressed general support for the proposed BCA test, with its consultant Francis Wyatt of Green Energy Economics Group calling it a 'more balanced test,' while recommending that new benefit values be stakeholder-vetted and that internalized and externalized carbon costs be kept separate within the Program Administrator Cost (PAC) test (E-26).
The Small Business Advocate (representing Small General, General, and Small Industrial ratepayer classes) raised concerns about the inclusion of unquantified non-energy benefits for which proxy percentages are used, questioning whether such values are appropriate in a test designed to avoid bias (E-25).
The Industrial Group, relying on evidence from consultant Patrick Bowman, opposed the proposed BCA as the primary test, arguing it is 'excessively expansive,' discordant with other Canadian regulators, and that the PAC test should serve as the primary Cost Effectiveness measure, with the societal BCA applied as a secondary consideration alongside rate impact assessments (E-27).
The Industrial Group explicitly cautioned that DSMAG discussions should not be interpreted as consensus or endorsement of the proposed BCA test or its non-energy proxy values (E-27).

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-25 Opening Statement - SBA exhibits
E-26 Opening Statement - CA exhibits
E-27 Opening Statement - IG exhibits
99314 Letter E1 re: Opening Statement other_documents