AI-generated summary
· Application · 07/24/2026
EfficiencyOne files rebuttal evidence defending its 2027–2031 DSM Plan against challenges from Synapse, the Consumer Advocate, NS Power, Solar Nova Scotia, and Eastward Energy
AI summary
- Efficiencyone filed rebuttal evidence (E-41) on July 24, 2026, responding to intervenor and Synapse Energy Economics evidence on the 2027–2031 Demand Side Management Plan, addressing Demand Response, Heat Pumps, Residential Programs, BNI Custom Incentive Program, and Solarhomes components.
- On Cost Effectiveness, E1 defended its residential BNI Demand Response PAC BCR of 0.5–0.9 as reflecting early-stage program development with fixed start-up costs spread over a small participant base, and argued against scaling enrollment before optimizing delivery costs and participant performance.
- E1 rejected the Consumer Advocate's recommendation to fix low-income savings targets at 14.9% of residential savings (matching population share), citing the absence of disaggregated load data, existing PAC ratios below 1.0 for dedicated low-income components, and the risk of stranded budget; E1 noted that total dedicated and incidental low-income savings already represent 22.7% of residential sector savings.
- Apex Analytics rebuttal testimony defended E1's unit costs and Incentive Structures against NS Power (Brattle Group) and the Consumer Advocate, arguing that fleet-wide U.S. utility averages from the ACEEE Faster and Cheaper report are inappropriate comparators for a cold-climate, winter-peaking, mature portfolio, and that comparable cold-climate jurisdictions (e.g., Maine, New Hampshire, Vermont) show unit costs within or above E1's range.
- E1 maintained that Enabling Strategies Es and pilot work are the appropriate vehicle for Strategic Energy Management electrification research, noting that modelled SE measures failed the Board-approved modified PAC test even under best-case zero-peak-impact assumptions, and that Brattle itself acknowledged 'there is not a robust path for comprehensive strategic electrification in Nova Scotia at this time.'
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What was filed
Documents filed on this day
- E-41 Rebuttal Evidence - E1
- 102929 Board letter re: Provide a list of specific sections of evidence and IR responses that each panel is responsible for
- 102944 Letter E1 re: Rebuttal Evidence