30 Date Filed: March 29, 2019 NS Power IR-44 Attachment 1 Page 35 of 46 We note that accounting for environmental externalities goes beyond what is needed to more accurately reflect the TRC’s stated “all consumers” perspective (it is in fa...
AI summary The text discusses the importance of accounting for environmental externalities and revisiting discounting practices in the context of energy efficiency programs. It notes that environmental costs already internalized, such as compliance with regulations, should not be double-counted. It also highlights the need to reassess the use of the weighted average cost of capital (WACC) for discounting future energy savings, especially in regions with shareholder-owned utilities.