Multiple intervenors file evidence in EfficiencyOne's 2023–2025 DSM Plan proceeding, broadly supporting the Settlement Plan while raising concerns about low-income performance targets, demand response assumptions, cost-effectiveness testing, and incentive design.

M10473 · E-ENS-R-22 EfficiencyOne 2023-2025 Demand Side Management (DSM) Plan Application

AI summary

The Consumer Advocate (Theodore Love/GEEG) recommends adopting the Settlement Plan ($173M, 412.7 GWh over three years) over the Alternate Plan, citing its stronger alignment with 2020 IRP optimal investment levels and a near-tripling of low-income residential spending to $35.2M; Love recommends the Board set cumulative low-income savings of 39.4 GWh as a hard performance target rather than a metric, given E1's historical failure to meet low-income goals.
Synapse Energy Economics (Napoleon/Takahashi, on behalf of Board Counsel) finds the Settlement Plan highly cost-effective at a portfolio PAC of 2.9 and TRC of 2.0, confirms DSM cost is competitive with onshore wind on a levelized basis, but flags that E1's inclusion of avoided non-electric fuel and water costs in the BCA contradicts the Board's M08888 decision; Synapse also recommends a pilot-only approach to the Behavioural DR program given lack of evidence for winter peak reductions, and urges E1 to use NSPI's EV load forecast (projecting 15,680 EVs by 2025) rather than its own far more conservative assumption, which understates EV Charging Control program potential by an order of magnitude.
The Small Business Advocate (John Athas/Daymark) supports the plan but warns that non-participant small businesses face near-term rate impacts of 3.5–4.5% over 2023–2025, argues the 50/50 residential-BNI investment split should not constrain future budget growth, and recommends redirecting 80% of spending above 2022 levels to highest-TRC measures regardless of customer class, noting BNI lifetime savings cost less than half as much per MWh as residential savings.
The Industrial Group witness (Mark Drazen, section map only) challenges E1's incentive-setting methodology, arguing that incentives should account for customer payback periods and that eliminating incentives for measures with payback periods of 36 months or less could reduce costs by approximately $8–9M; Drazen also argues demand response interruptible rate programs should be managed by NS Power rather than E1.
The Affordable Energy Coalition, Ecology Action Centre, Membertou First Nation, and municipal utilities each support the Settlement Plan but variously call for: recognition that 21% low-income investment still understates the ~33–37% energy poverty prevalence in Nova Scotia; stronger UNDRIP- and TRC-aligned Mi'kmaw program investment; and avoided costs to be updated to reflect the Environmental Goals and Climate Change Reduction Act and the 2030 Renewable Electricity Standard.

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-19 Evidence - AEC exhibits
E-19-(i) Appendix A - Evidence of Brian Gifford re Energy Poverty exhibits
E-20 Direct Evidence of Theodore Love, on behalf of CA exhibits
E-21 Direct Evidence of Mark Drazen, on behalf of IG exhibits
E-22 Evidence - Membertou First Nation exhibits
E-23 Evidence - MUNIS exhibits
E-24 Evidence of John Athas, on behalf of SBA exhibits
E-24-(i) John Athas CV exhibits
E-25 Evidence of A. Napoleon and K. Takahashi, on behalf of BCC Synapse exhibits
E-25-(i) Resume of A. Napoleon exhibits
E-25-(ii) Resume of K. Takahashi exhibits
E-26 Evidence - EAC exhibits