AI-generated summary
· Application · 06/09/2026
Consumer Advocate and Small Business Advocate filed Information Requests to NSEB consultant H. Gil Peach regarding the 2025 Savings Verification Review (Exhibit E-17) in the EfficiencyOne 2027–2031 DSM Plan proceeding (M12780)
AI summary
- The Consumer Advocate filed six IRs (Exhibit 102324) to H Gil Peach Associates probing the scope and rigour of the 2025 Savings Verification Review (Exhibit E-17), including how many of the sixteen Program Evaluation impact evaluations had their calculations independently checked, the methodology behind 108 site-visit inspections, and the statistical basis for the savings multipliers reported in Figure 3 (pp. 19–20).
- IRs 4 and 5 (CA set) focus on Demand Side Management demand response underperformance: Eco Shift delivered only 0.854 MW against a 7.135 MW target and BNI DR delivered 5.941 MW against a 10.726 MW target (Exhibit E-17, pp. 71–72), with the Consumer Advocate pressing the verification team to define quantitative milestones for 'practical significance' and to reconcile the new SVR25-G-2 recommendation against the team's refusal in Matter M12249 to specify a savings threshold.
- CA IR-6 and SBA IR-3 both interrogate General Recommendation SVR25-G-3 (Exhibit E-17, p. 74) on Advanced Metering Infrastructure-enabled Normalized Metered Energy Consumption (NMEC) evaluation, asking whether the verification team is recommending full adoption of Energy Efficiency NMEC methods for any programs or only enhanced transparency practices drawn from the California CPUC framework.
- The Small Business Advocate filed eight IRs (Exhibit 102325) covering a broader range of Exhibit E-17 findings, including the BNI-vs-Residential lifetime savings distribution gap (p. v), the cybersecurity incident that paused the Residential Behaviour program in May 2025 (Recommendation No. 3, p. 53), and the reliability of updated Free Ridership Measurement adjustment ratios for Business Energy Rebates (p. 55), where the peak-demand ratio of 0.514 is flagged as carrying a higher-than-expected margin of error.
- SBA IR-6 raises a Regulatory Compliance question about whether Peach's Recommendation No. 2 (p. 31)—calling for inclusion of environmental protection, low-income service, and social inclusion values alongside benefit-cost analysis—is permissible under current legislation and Board orders; responses to both IR sets are due June 16, 2026.
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What was filed
Documents filed on this day
- 102324 CA (Gil Peach) IR 1 to 6
- 102325 SBA (Gil Peach) IR 1 to 8