AI-generated summary
· Application · 06/13/2018
Intervenors filed final submissions in EfficiencyOne's 2019 DSM Plan proceeding, raising concerns about low-income program continuity, cost-effectiveness methodology, and demand reduction pilot trade-offs
AI summary
- Synapse Energy Economics (Exhibit E-13), on behalf of Board Counsel, found the 2019 Demand Side Management plan reasonable within its budget cap ($34.05M, PAC ratio 3.9, TRC ratio 2.3), but recommended that future plans—particularly the 2020–2022 plan—start from a full potential study and incorporate updated avoided costs, including the value of avoided CO2 under Nova Scotia's Cap And Trade framework and Equivalency Agreement
- The Affordable Energy Coalition (Exhibit E-12) urged Efficiencyone to commit unconditionally to continuing the Affordable Multifamily Housing And Non Profit Organizations Amf pilot in 2019, arguing it is too early to condition continuation on 2018 evaluation results given unresolved landlord-tenant split-incentive barriers and the precedent set by the slow early development of the Homewarming program
- The Small Business Advocate (Exhibit E-14) raised five concerns for the record: targets were driven by the statutory budget ceiling rather than resource-planning objectives; cost-effectiveness testing was performed only after program selection rather than to screen options; lighting measures still dominate savings (≈49% of energy, ≈80% of Direct Installation/Small Business Energy Solutions); the Affordable Multifamily Housing And Non Profit Organizations Amf pilot and SBES results should be separately reported; and supporting documentation should be filed with the initial application, not only in IR responses
- The Consumer Advocate (Exhibit E-15) flagged the opportunity cost of the $1M demand reduction pilot budget, noting that E1's own alternate portfolio analysis (NSUARB IR-15) shows the allocation reduces incremental annual energy savings by 4%, lifetime savings by 4.6%, and demand savings by 8%, and called for careful scrutiny of justification for that trade-off
- The Consumer Advocate also renewed its standing request that Nova Scotia Power deliver a more realistic Rbia model—capable of capturing rate-making effects of avoided costs and cross-class fixed-cost reallocation—to the DSM Advisory Group in a timely manner
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What was filed
Documents filed on this day
- E-12 Submission - AEC
- E-13 Evidence - Synapse (BCC)
- E-14 Submission - SBA
- E-15 Submission - CA