AI-generated summary
· Application · 10/21/2025
Reply submissions filed in M12282 as parties dispute whether Nova Scotia's 2024 legislative reforms empower the NSERBT to incorporate non-energy benefits and a 2% social discount rate into DSM cost-effectiveness testing.
AI summary
- Efficiencyone argues its Proposed BCA test — developed following Demand Side Management advisory group consultations and grounded in the National Standard Practice Manual — is the only framework that satisfies the Board's post-2024 statutory obligations under the Energy and Regulatory Boards Act and More Access to Energy Act to give 'appropriate consideration' to sustainable development and sustainable prosperity; E1 requests Board approval of the Proposed BCA with a 2% real discount rate, the Partial Consensus Agreement proxy values, and an evergreen updating process (E1 Reply, pp. 1–20).
- The Consumer Advocate rebuts the Industrial Group's reliance on the Board's 2020 Efficiencyone (Re) decision (2020 NSUARB 56), arguing that the 2024 Energy Reform Act — including repeal of the Utility and Review Board Act and passage of the Energy and Regulatory Boards Act — constitutes a materially changed legislative context that cannot be disregarded under Vavilov principles of statutory interpretation (CA Reply, pp. 1–2).
- The Industrial Group maintains the Cost Effectiveness primary test should be the Program Administrator Cost (PAC) test — not E1's societal BCA — because s. 79I of the Public Utilities Act specifically directs DSM to reduce electricity costs for customers; the IG supports a modified PAC for strategic electrification that adds increased NSPI revenues as a benefit, and concedes the Proposed BCA could serve as a supplementary, not primary, tool (IG Reply, pp. 1–6).
- Nova Scotia Power reiterates that host customer non-energy impacts (e.g., comfort, pride, empowerment) and the social cost of carbon are not linked by any empirical evidence in the record to the statutory concepts of 'sustainable prosperity' or 'sustainable development,' and argues the Board should not approve a test whose core proxy values depend on a 'substantial program of further review and study' to become reliable; NS Power proposes continued joint work among parties before any test is approved (NSPI Reply, pp. 1–7).
- Eastward Energy presses two discrete issues: (1) it should be admitted to the DSM Advisory Group given that even current DSMAG members NSPI and the IG have rejected E1's Proposed BCA, undermining E1's claim that the test reflects DSMAG consensus; and (2) the Board should direct E1 to prioritize hybrid heating measures in the 2027–2031 DSM plan, noting the Gas Distribution Act's policy goal of facilitating gas as a hybrid peaking resource was omitted from DSMAG's policy review (EE Reply, pp. 1–5).
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What was filed
Documents filed on this day
- 99729 Reply Submission - CA
- 99730 Reply Submission - IG
- 99731 Reply Submission - EE
- 99732 Reply Submission - E1
- 99733 Letter E1 re: Reply submission
- 99735 Reply submission - NSPI