EfficiencyOne and verifier H. Gil Peach file competing information request responses disputing the practical significance of savings from Residential Behaviour, Demand Response, and Compressed Air programs in the 2026 DSM Extension proceeding

M12249 · EfficiencyOne - 2026 DSM Extension ApplicationIN THE MATTER OF An Application by EfficiencyOne for Approval of the 2026 DSM Extension for Demand-Side Management Activities between EfficiencyOne and Nova Scotia Power Inc., and for Approval of the Amendment to the 2023-2025 Demand-Side Management Purchase Agreement between EfficiencyOne and Nova Scotia Power Inc.

AI summary

Efficiencyone (Exhibits E-9, E-10) disputes H Gil Peach Associates' recommendations SVR24-G-1 and SVR24-G-2, asserting that the Residential Behaviour (6.270 GWh), Residential DR (0.057 MW), and BNI DR (8.034 MW) programs were evaluated correctly by Econoler per approved protocols, and that NSUARB approval of the 2023-2025 DSM Plan implicitly validated these programs' practical value.
Peach (Exhibits E-11, E-13) defends its "practical significance" framework, explaining that when test power is 100% due to very large sample sizes (up to 289,440 households), statistical significance becomes an artifact of sample size and must be replaced by practical significance assessment; Peach estimates average residential behaviour savings at approximately 4 kWh/month per household and 0.06% of the NSP 11,326.3 GWh system load, which it characterizes as below any meaningful cutoff.
EfficiencyOne (Exhibit E-9, IR-06) quantifies the impact of accepting Peach's recommendations: 2024 adjusted energy savings would fall from 172.8 GWh to 157.7 GWh, available capacity would drop to zero, and the 2023-2025 cumulative available capacity target would be met at only 13% (2.4 MW vs. 17.9 MW approved); unit cost per kWh would rise from \$0.36 to \$0.40 for 2024.
On the Compressed Air Leak Audit issue (Exhibit E-14, IR-12/13), Peach clarifies that while its site visit access to two large facilities was denied by the customer, further internal review found tracked savings fall within the Uniform Methods Protocol's 10% system demand upper bound; EfficiencyOne (Exhibit E-9, IR-04) details its ultrasonic detection methodology and cross-references Minnesota, Wisconsin, Illinois, and Maryland technical reference manuals as comparable jurisdictional practice.
Peach (Exhibit E-12, IR-1c) recommends that the evaluator's responsibility be extended to flagging programs with inadequate practical returns for cancellation or redesign, feeding into Program Evaluation and benefit-cost analysis development, while acknowledging it has no direct role in E1's proposed new BCA test.

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-10 E1 (SBA) RIR 1 to 5 exhibits
E-11 Peach (CA) RIR 1 to 5 exhibits
E-12 Peach (IG) RIR 1 exhibits
E-13 Peach (SBA) RIR 1 to 5 exhibits
E-14 Peach (E1) RIR 1 to 14 - Redacted exhibits
E-14(C) Peach (E1) RIR 1 to 14 - Confidential exhibits
E-9 E1 (IG) RIR 1 to 7 exhibits
98357 Letter E1 re: RIRs other_documents