Topic:"Affordability" in M06733

4.1.3 Affordability The Province of Nova Scotia issued an Electricity Review Report on February 18, 2015, which states that a "large part of Nova Scotia's electricity future relates to increasing energy efficiency. One of the best ways to...

AI summary The Province of Nova Scotia's 2015 Electricity Review Report emphasizes energy efficiency and affordability. ENS's 2016-2018 DSM plan reduces short-term costs compared to the Mid-DSM Scenario while preserving long-term benefits, balancing affordability and efficiency.

4.1.4 Cost Efficiency Opportunities The 2016-2018 DSM Resource Plan is cost effective, per legislative and UARB requirements for DSM. Results from Navigant's EL-RAM show that all programs are cost-effective in each year of the Plan, using...

AI summary The 2016-2018 DSM Resource Plan is deemed cost-effective using TRC and PAC tests. ENS aims to reduce unit costs through program adjustments like removing the Home Energy Report and reducing Enabling Strategies investment. Navigant's 2015 report is cited for affordability considerations.

1. INTRODUCTION The 2016-2018 DSM Resource Plan has been developed based on ENS's growing experience and history in delivering successful DSM programs and services to Nova Scotians. As part of the process, ENS engaged Navigant Consulting a...

AI summary The 2016-2018 DSM Resource Plan by Efficiency Nova Scotia (ENS) outlines energy efficiency programs, emphasizing flexibility for mid-course adjustments based on market conditions and evaluations. It balances affordability, avoids electrical system capacity additions, and includes residential, business, and enabling strategy programs. The Plan is for planning and cost-effectiveness testing, not direct implementation.

2.4 Update on Energy Saving Actions Efficiency Nova Scotia's 2016-2018 DSM Resource Plan does not include a target or investment for Energy Saving Actions. ENS piloted the Home Energy Report in 2013, and it will continue until early 2016....

AI summary Efficiency Nova Scotia (ENS) discontinued the Home Energy Report pilot due to affordability concerns, opting for a lower DSM Plan level. ENS will continue exploring behavior-based energy efficiency incentives and conduct R&D through Enabling Strategies. Future DSM plans may revisit the Home Energy Report if higher energy savings are required.

1. EXECUTIVE SUMMARY The rate and bill impact analysis completed by Efficiency Nova Scotia (ENS) provides an overall trend-based picture of the rate and bill impacts of DSM at a rate-class level to help inform stakeholders and the UARB of...

AI summary Efficiency Nova Scotia (ENS) conducted a rate and bill impact analysis for its 2016-2018 DSM Resource Plan, showing rate increases but overall bill savings across all rate classes. While residential rates rose 3.5%, average bills decreased by 4% due to DSM measures, highlighting affordability considerations for stakeholders and the UARB.

Rates versus Bills (Affordability) ENS has taken an in-depth and focused view of affordability in its 2016-2018 DSM Resource Plan Application. This analysis provides information on which to analyze the impacts of DSM, providing additional...

AI summary ENS's 2016-2018 DSM Resource Plan analysis shows that while short-term rates increase with 100% expensing, long-term rates decrease due to avoided capacity costs. Residential customers see bill reductions despite higher rates, but model discrepancies from removing the Home Energy Report affect savings estimates. ENS plans to address these issues in future models.

Investing in Demand-side Resources: Considering Affordability

AI summary The document examines the integration of demand-side resources in Nova Scotia's energy strategy, emphasizing affordability. It discusses balancing cost-effective energy efficiency programs with consumer affordability, involving entities like Efficiency Nova Scotia (ENS) and Nova Scotia Power Inc. (NSPI), while considering regulatory frameworks and stakeholder input.

1.2 Summary of Findings - 1. Since 2011, excluding 2015, Nova Scotia has invested in demand-side resources at or above the level (in real terms) proposed by ENS in the 2016-2018 Demand-Side Resource Plan. - 2. Demand-side resource investme...

AI summary Nova Scotia's demand-side resource investments since 2011 (excluding 2015) meet or exceed ENS's 2016-2018 plan. These investments yield over $200M in net benefits, enhance affordability, and reduce Nova Scotia Power's revenue requirements. DSM is highlighted as cost-effective, with the Province's plan emphasizing its role in improving electricity affordability and economic competitiveness.

2.2 Demand-Side Management is an Investment, Not a Cost Since 2008, demand-side resource investments have provided significant benefits to Nova Scotian households and businesses. On behalf of Efficiency Nova Scotia, Navigant's Electricity...

AI summary Since 2008, demand-side management (DSM) investments in Nova Scotia have delivered benefits to households and businesses. Efficiency Nova Scotia, using Navigant's EL-RAM model, assessed cost-effectiveness. The 2016-2018 plan optimized DSM investment for cost-effectiveness and broad participation, with program participants benefiting from lower bills and improved affordability.

2.6 Affordability of Demand-side Resource Investments in Nova Scotia Utility resource planning efforts face a long-term responsibility to deliver reliable service at least cost for ratepayers. In the context of this guiding principle, the...

AI summary The text argues that under-investing in demand-side resources (DSM) in Nova Scotia could lead to higher long-term costs and reduced benefits for ratepayers. While ENS reduced short-term DSM investments compared to Nova Scotia Power's Preferred Resource Plan, the analysis suggests that long-term benefits are still significant. Alternative rate mitigation strategies, like rate smoothing, are recommended over reducing DSM investments.

Free-ridership Free-ridership for ARet corresponds to the energy consumption of the appliances that would have been disposed of in the absence of ARet. It does not include the consumption of appliances that would have been transferred to a...

AI summary Free-ridership in the context of ARet refers to the energy consumption of appliances that would have been disposed of without the program. The Evaluator surveyed participants to determine how they would have disposed of their refrigerators, identifying those who would have discarded them as free-riders. The results are presented in a table, with further details provided in Appendix III.

TABLE B: EXPECTED COMPLIANCE RATE IN NOVA SCOTIA (2014) LED street lights Expected compliance rate for 2014 ? ? ? TABLE C: CANADA MARKET SIZE Q15.Number of units sold in LED street lights Canada in 2013 (actual) Q16. Number of units sold i...

AI summary The text includes tables with placeholders for data on LED street light compliance rates in Nova Scotia for 2014 and projected LED street light sales in Canada for 2014. The tables lack specific data entries and are incomplete.

e Filed: March 27, 2015 E1 (NSPI) IR-10 Page 1 of 1 2016-2018 Supply Agreement for EECA M06733 (E-ENS-R-15) E1 Responses to NSPI Information Requests NON-CONFIDENTIAL 1 Request IR-11: 2 3 Reference: EfficiencyOne, Appendix A – 2016-2018 DS...

AI summary The document outlines a request for detailed information on how the 2016-2018 DSM Resource Plan balanced short- and long-term considerations, including bill impacts, rate impacts, and long-term planning analyses, as well as the relative weights used in the balancing process. E1 refers to pages 31-37 of its Application Evidence for this information.

March 27, 2015 E1 (NSPI) IR-25 Page 2 of 2 2016-2018 Supply Agreement for EECA M06733 (E-ENS-R-15) E1 Responses to NSPI Information Requests NON-CONFIDENTIAL 1 Request IR-26: 2 3 Reference: EfficiencyOne, Evidence - Page 33, Lines 23-24: 4...

AI summary E1 argues that reducing program capacity now may not be cost-effective if it leads to future rebuilding. E1 refers to its Application Evidence for analysis and discusses a reduced investment plan to address affordability while preserving industry capacity. No further mitigation measures were considered beyond the proposed plan.

1.7% 1.5% 1.5% 1% 0% B.C. Alberta Sask. Manitoba Ontario Québec Maritimes Nfld. Labrador Compensation elements: Salary Sub-sector: Combined Approved & not Including 0%: Yes Geographies: Separated yet approved:Combined NOTES: Insufficient d...

AI summary The text presents base salary projections for British Columbia, with percentages and geographic breakdowns. It includes notes about data insufficiency and mentions Hay Group as the source.

e for compensation that is fair relative to other jobs within the organization in consideration of the required levels of skill, effort, working conditions and responsibility for each job.  “Market Increase” – A market-driven annual incre...

AI summary The text outlines EfficiencyOne's compensation framework, including market-driven increases, pay grades based on job evaluation factors, and internal equity guidelines. It emphasizes maintaining fair pay relative to market benchmarks and ensuring proper pay grade differentiation.

o an employee of E1 (e.g. medical, dental, 4 life insurance, pension, etc.). 5 6 Response IR-45: 7 8 Please refer to the table below. EfficiencyOne matches employee contributions for benefits. 9 Employee Benefit Description (Simplified) of...

AI summary EfficiencyOne provides various employee benefits, including pension matching, life insurance, disability coverage, and health and paramedical services, with specific contribution levels and maximum coverage amounts outlined in a table.

April 10, 2015 1 TABLE OF CONTENTS 2 3 1.0 EXECUTIVE SUMMARY 3 4 2.0 INTRODUCTION 7 5 2.1 Transparency and Accountability 9 6 3.0 AFFORDABILITY 14 7 3.1 DSM Spending Levels 15 8 3.2 Lowering the Cost of DSM 24 9 3.3 Affordability from a Sy...

AI summary NS Power supports acquiring affordable and cost-effective demand side management (DSM) to ensure stable electricity prices. However, it believes the E1 DSM Plan is not sufficiently affordable or cost-effective for customers.

7 Navigant, 2014 IRP, Nova Scotia 2015 ‐ 2040 Demand Side Management (DSM) Potential Study , Presented to Efficiency Nova Scotia Corporation, NSUARB M05522/P-884.14, January 7, 2014. 1 period, customer impacts can be mitigated by implement...

AI summary The text references a 2014 study on demand-side management potential in Nova Scotia and highlights the importance of considering the affordability of electricity efficiency and conservation activities to NS Power customers under Sections 79L(8) and (9) of the Act.

15 Please refer to Appendix A, Direct Testimony of David Pickles, April 10, 2015, page 7, lines 8-16. 16 Please refer to Appendix A, Direct Testimony of David Pickles, April 10, 2015, pages 30-32. 1 3.0 AFFORDABILITY 2

AI summary The text references appendices containing the direct testimony of David Pickles from April 10, 2015, and mentions the topic of affordability in a table. No further details or arguments are provided in the given text.

3 Affordability of electricity service is of paramount concern to NS Power customers. This 4 is evident through NS Power engagements with our customers and stakeholders, both in 5 regulatory forums such as General Rate Applications and the...

AI summary NS Power emphasizes the affordability of electricity service for customers and highlights the impact of demand-side management (DSM) on rate pressure. The company notes that removing the energy efficiency charge from bills has left no dedicated funding for DSM, and additional DSM spending increases revenue requirements, thereby raising rates. NS Power seeks to balance DSM efforts with cost-effectiveness to avoid economic impacts on the province.

16 3.1 DSM Spending Levels 17 18 NS Power understands and agrees cost-effective and affordable DSM can provide long 19 term value to customers. Through our partner, Clean Nova Scotia, NS Power will 20 finance efficiency upgrades for an est...

AI summary NS Power agrees that cost-effective and affordable DSM can provide long-term value to customers. They plan to finance efficiency upgrades for 6,600 low-income homeowners through Clean Nova Scotia, using up to $37 million over 10 years, funded by shareholders. This initiative aims to address affordability concerns without passing costs to customers.

is, and accounting for the time value of money, the 22 collective payback period for recovering these up-front DSM costs is approximately 7 23 years. 24 DATE FILED: April 10, 2015 Page 22 of 51 30 Please refer to Appendix A, Attachment B,...

AI summary The text discusses the payback period for DSM costs, noting a 7-year mid-term realization of benefits but near-term rate pressures. It highlights concerns about intergenerational inequity and cost recovery limits under Section 79M(6) of the Act, and notes that not all customers benefit from DSM in the short-term, raising affordability concerns.

20 (a) Selection of Lower Unit Cost Options (Measures and Programs) 21 22 E1's primary DSM planning tool in the development of the E1 DSM Plan was the 23 ELRAM. This is a proprietary spreadsheet-based model developed by Navigant 24 which u...

AI summary NS Power analyzed E1's DSM Plan using ELRAM and found that selecting lower unit cost measures could reduce costs significantly. E1's consultants argue that only choosing the lowest cost measures is not viable, but other Canadian utilities achieve lower unit costs. NS Power urges E1 to explore lower-cost options, noting E1's refusal to prepare such plans for analysis.

17 3.3 Affordability from a System Planning Perspective 18 19 Through the course of the 2014 IRP, the Company analyzed revenue requirements 20 resulting from a variety of different DSM profiles. NS Power has further considered the 21 affor...

AI summary NS Power analyzed the affordability of DSM profiles via NPV of revenue requirements over time horizons. The $22M annual DSM plan (Contract Period) yields the lowest long-term NPV beyond 2030, while the $25M plan (CRP 1-1) is more affordable in the short term. NS Power argues this balances cost-effectiveness and rate stability.

5.1 NS Power's Alternative DSM Plan E1 did not develop or model any DSM investment scenarios lower than that contained in the proposed E1 DSM Plan. NS Power had requested E1 develop different plan scenarios, including one within an annual...

AI summary NS Power requested E1 (NSPI) to model lower DSM investment scenarios but was declined. E1's analysis lacks quantitative evaluation of lower expenditure options, limiting informed decision-making. NS Power proposes an alternative DSM plan aligned with Canadian benchmarks, emphasizing affordability and cost-effectiveness.

NON-CONFIDENTIAL 1 Request IR-4: 2 3 With reference to Appendix B, residential lighting and other elements 4 5 Does NS Power acknowledge that low income renters will experience hardship replacing 6 their lights with efficient bulbs due to...

AI summary The document addresses a request (IR-4) asking if NS Power acknowledges that low-income renters face hardship replacing bulbs with efficient ones due to costs and whether a direct install program will continue. NS Power responds by affirming support for low-income initiatives, collaboration with stakeholders like AEC, and alignment with affordability goals under the Public Utilities Act.

NON-CONFIDENTIAL 1 Request IR-2: 2 3 Reference: 2016-2018 DSM Plan NS Power Evidence Section 3.2 4 5 What level of unit costs does NSPI determine is not affordable for ratepayers and why? 6 7 Response IR-2: 8 9 Please refer to CA IR-38. Da...

AI summary NSPI is asked to explain the level of unit costs it considers unaffordable for ratepayers. The response refers to CA IR-38 for further details.

2016-2018 DSM Plan (NSUARB M06733) NSPI Responses to Consumer Advocate Information Requests 1 Request IR-15: 2 3 Regarding the statement on slide 11 of the NSPI presentation "Review of DSM Scenarios, 4 Avoided Costs and Associated Planning...

AI summary The NSPI responds to the Consumer Advocate's request regarding the 'limited benefit' of avoided transmission and distribution costs from DSM programs. NSPI defines 'limited' as restricted or reduced and attributes this to broad-based program delivery. NSPI suggests that focused DSM efforts, with coordination and geographic targeting, could yield T&D benefits.

NON-CONFIDENTIAL 1 savings – provided the right amount of DSM for the system. Contracting additional DSM to 2 avoid capacity additions beyond 2032 is costly and uncertain. 3 4 Spending in other jurisdictions 5 6 Once the Company determined...

AI summary The document analyzes Nova Scotia Power Inc.'s (NSPI) Demand Side Management (DSM) strategies, noting that Nova Scotians spend more than the national average on DSM. It highlights the cost and uncertainty of expanding DSM beyond 2032, advocates for efficiency to ensure affordability, and references alternative DSM options achievable for ~$22 million. A 2016-2018 DSM Plan (NSUARB M06733) is cited.

NON-CONFIDENTIAL 1 Request IR-38: 2 3 In determining whether a given amount of DSM spending in a given year is affordable 4 over what period of time should the impact of the DSM spending be calculated? 5 6 Response IR-38: 7 8 With respect...

AI summary The document discusses the affordability of Demand Side Management (DSM) spending, referencing Section 79L (9) of the Nova Scotia Public Utilities Act. It highlights that the UARB is responsible for determining DSM affordability, based on the Company's evidence about balancing short-term affordability and long-term cost effectiveness.

NON-CONFIDENTIAL 1 Request IR-2: 2 3 Please explain how NS Power's interpretation of affordability takes into account how much 4 customers pay for fuel and operating costs for generation, as opposed to solely looking at 5 capacity addition...

AI summary The request asks NS Power to explain how it considers fuel and operating costs in its affordability interpretation, rather than focusing only on capacity additions. The response directs the reader to refer to CA IR-38 for further information.

2016-2018 DSM Plan (NSUARB M06733) NSPI Responses to EfficiencyOne Information Requests 1 Request IR-3: 2 3 Reference: On page 14 of its Evidence, lines 16-17, NS Power mentions "the objective of 4 lowering costs for customers" 5 6 Please...

AI summary NS Power explains that in its evidence, the term 'costs' refers to increased rates customers may face if more DSM is procured than needed or is affordable. It clarifies that this does not include long-term cost reductions from efficiency measures. NS Power also notes that DSM spending adds to rate pressure, especially with the amortization of past DSM expenditures.

2016-2018 DSM Plan (NSUARB M06733) NSPI Responses to Multeese Information Requests 1 Request IR-1: 2 3 In Section 3 beginning on page 14, NSPI discusses affordability. That discussion does not 4 appear to include any reference to customer...

AI summary NSPI responds to an information request regarding affordability in their 2016-2018 DSM Plan. They state customer bills are part of affordability, noting non-participants may face bill increases. They reference Synapse IR-21 for further analysis on rate and bill impact comparisons.

NON-CONFIDENTIAL 1 Response IR-10: 2 3 (a) Confirmed. 4 5 (b) The Company analyzed the franchise holder's 2016-2018 ELRAM and determined that 6 DSM energy and capacity savings costs could be significantly reduced such that the 7 "Low" DSM...

AI summary The Company confirmed its analysis of the franchise holder's ELRAM data, indicating that DSM energy and capacity savings costs could be reduced, allowing the 'Low' DSM levels from the Navigant study to be achievable at a lower cost. The 'low' scenario was chosen for its balance of cost effectiveness and affordability, and the Company requested alternate DSM plans but did not receive them.

1 Request IR-1: 2 - 3 In the interest of ratepayer affordability, please explain any reasons why the DSM - 4 programs should not be financed solely from debt as opposed to debt plus equity, in order - 5 to minimize the total ratepayer cost...

AI summary NS Power explains that financing DSM programs solely from debt could lead to inequities in financing costs across different customer segments, as their capital structure is maintained within a targeted range of debt and equity to meet overall financing requirements.

1 Request IR-5: 4 p.55 of 64, with respect to such future costs, please provide: 5 6 (a) Detail of how NSPI covers future severance, pension and retirement obligations. 7 8 (b) The total revenue collected through rates, by NSPI, in the pas...

AI summary The document includes a request for details on how NSPI covers future pension, retirement, and capital obligations, as well as the revenue collected through rates related to these obligations. It also asks how NSPI's approach differs from E1's and what would happen if E1's franchise is terminated. A response outlines that future costs are accrued under GAAP and included in revenue requirements.

NON-CONFIDENTIAL 1 Request IR-14: 2 3 At several points in the 2016-2018 DSM Plan NS Power Evidence, there is mention of 4 affordability. 5 6 (a) Please provide NSPI's definition of "affordability" as used in this document. 7 8 (b) Please...

AI summary The text discusses a request (IR-14) related to the 2016-2018 DSM Plan by NS Power, focusing on the definition of 'affordability' and historical rate changes. A response (IR-16) refers to another document (CA IR-38) and provides Matter and Exhibit numbers from the UARB for NS Power's submissions.

4 NS Power DSM Evidence, pages 9-10, April 10, 2015. 1 Request IR-19: 2 3 NSPI notes that it is concerned with the "description and understanding" of the scope of 4 DSM services and suggests that other jurisdictions commonly require variou...

AI summary NSPI is concerned with the scope of DSM services and suggests that other jurisdictions require detailed information. E1, despite being a new organization, has been running DSM programs and achieving targets. NS Power argues that more detailed information is needed to ensure cost-effective and affordable DSM programs as required by legislation.

NON-CONFIDENTIAL 1 Request IR-21: 28 (a) Please refer to SBA IR-5. 29 1 NS Power has suggested that there could be ways for E1 to reduce the overall cost of 2 DSM to address the issue of affordability, including focusing on lower unit cost...

AI summary NS Power suggests that EfficiencyOne (E1) can reduce the overall cost of DSM by focusing on lower unit cost measures and programs, while delaying more expensive technologies that may become cheaper in the future. They emphasize affordability and note that E1 achieved lower unit costs than initially proposed, exceeding its 2014 DSM goals. NS Power also states that 'near net zero goals' are not embedded in Nova Scotia's public policy.

he $53 million that was in rates for DSM in 2014 and which amount was subsequently repurposed by Order of the Board for 2015 fuel expenses. It expanded on these points in its post-hearing submission: - It is $69 million, or 38 percent. les...

AI summary The document discusses the repurposing of funds allocated for demand-side management (DSM) in 2014 for 2015 fuel expenses and outlines the proposed DSM Plan's investment levels. It emphasizes affordability, cost-effectiveness, and participation balance across sectors, ensuring long-term planning and avoiding new capacity additions until 2032.

3.5.3 Affordability - [76] Having determined the parameters of a preferred plan, the Board is specifically directed by the 2014 amendments to the PUA to address the issue of affordability. The most relevant sections are Section 79L(8) and...

AI summary The Board must assess affordability of electricity efficiency programs under PUA amendments (Sections 79L(8)-(9)), shifting from traditional lowest long-term cost criteria. Affordability has long been relevant in rate shock discussions and capital expenditure reviews, with Section 79L(9) explicitly requiring affordability evaluation. The Industrial Group emphasizes affordability in its post-hearing submission.

3.5.3.1 Findings [88] The Board notes that the DSM amount of $33,210,000, as set by the Board for 2016, is below DSM spending in each of the last four years. It is also an amount significantly below that recommended in the IRP, and the Boa...

AI summary The Board acknowledges that the 2016 DSM amount of $33,210,000 is below recent spending levels and the IRP recommendation. It considers the amount affordable under the PUA while aligning with ratepayer interests.

Program NSPI's DSM • $22.0 million Plus 2014 ENSC surplus $8.4 million • $8.4 million still in rates 2008-09 amortization Plus • DSM $1.1 million based evidence absorbed the can be Total of NSPI, (which, on • increase in 2016) rate without...

AI summary The Board evaluates the affordability of NSPI's demand-side management (DSM) program, noting a potential revenue shortfall of approximately $2 million. It believes NSPI should be able to find offsetting savings to avoid a rate increase and would consider deferral if necessary.

aving considered the history of underspending on DSM programming, the history of overachieving savings and demand targets, and as an inducement to bring greater rigor to the calculation of incentives. [142] The Board considers that the tar...

AI summary The Board approves the El DSM Plan within approved spending, acknowledges affordability under PUA s.79L, but warns against short-term focus. It rejects the Quantum Agreement but approves aspects like DSM Expenditure Justification Criteria. The Consensus Agreement is approved with referrals to the DSM Advisory Group, and TRC remains for cost effectiveness.

1. INTRODUCTION 1 2 3 4 5 The 2016-2018 Demand-Side Management (DSM) Resource Plan has been developed based on ENS's growing experience and history in delivering successful DSM programs and services to Nova Scotians. As part ofthe process,...

AI summary The 2016-2018 Demand-Side Management (DSM) Resource Plan was developed by ENS with input from consulting firms. It outlines a comprehensive suite of programs for Nova Scotia electricity users, not intended as an implementation plan but for planning and cost-effectiveness testing. Adjustments will be made based on market conditions, technology, and stakeholder agreements, including those from the Consensus Settlement Agreement and a 2015 Board decision.

2.4 Update on Energy Saving Actions 1 2 3 4 5 6 7 8 9 Efficiency Nova Scotia's 2016-2018 DSM Resource Plan does not include a target or investment for Energy Saving Actions. ENS piloted the Home Energy Report in 2013, and it will continue...

AI summary Efficiency Nova Scotia's 2016-2018 DSM Resource Plan excludes Energy Saving Actions targets. The Home Energy Report pilot, though successful, is ending due to affordability concerns, with ENS prioritizing a balanced portfolio. ENS may explore alternative services for energy efficiency.

AFFORDABLE ENERGY COALITION FINAL STATEMENT

AI summary The Affordable Energy Coalition submits its final statement in a Nova Scotia regulatory proceeding, emphasizing the importance of Demand Side Management (DSM) programs to ensure affordable energy solutions for consumers.

Context: Energy burden and efficiency As noted in our Opening Statement, we are strong supporters of efficiency programming and funding for expanded programs for low income rental accommodations within the E1 proposal. Low income household...

AI summary The text emphasizes support for efficiency programs, particularly for low-income rental accommodations in the E1 proposal. Low-income households face a high energy burden (11.8% of income on energy vs. 3.8% average), with half of costs attributed to electricity. Efficiency is highlighted as a key solution to reduce energy use and bills. References include the 2016-2018 DSM Plan (NSUARB M06733) and Affordable Energy Coalition (AEC) information requests.

a. Principles of Equity – Clause 9 Clause 9 of the Settlement Agreement reads: "All ratepayers are entitled to an equitable opportunity to participate in DSM programs. Low income tenants and homeowners as well as marginally viable commerci...

AI summary Clause 9 of the Settlement Agreement emphasizes equitable access to Demand Side Management (DSM) programs for low-income and marginalized customers, requiring cost-effectiveness screening to account for their unique challenges. It addresses affordability, cost-effectiveness screening, evaluation, and compliance with the 2014 Electricity Efficiency and Conservation Restructuring Act. This 3-year contract under the 2014 Act will establish principles influencing regulatory decisions.

Issue 5a – Affordability and Issue 5-c – Cost effectiveness screening: Four expert witnesses in this year's hearing for the 2016-18 Electrical Efficiency Supply Agreement argued that equity of access must be recognized as an important elem...

AI summary Expert witnesses and the Affordable Energy Coalition argue that equity of access must be central to affordability and cost-effectiveness screening, emphasizing the challenges of serving low-income households. They urge the DSM Advisory Group to incorporate Clause 9 of the Settlement Agreement to prevent exclusion of hard-to-serve customers. Clause 7 mandates collaborative methodology development for cost-effectiveness screening.

Issue 11 – Compliance with Electricity Efficiency and Conservation Restructuring (2014) Act . Section 79-L subsection 9 of the Act states that "The Board's assessment of the proposed electricity efficiency and conservation activities for t...

AI summary The Affordable Energy Coalition (AEC) argues that equity of access is a critical component of affordability under the Electricity Efficiency and Conservation Restructuring (2014) Act. They assert that Section 79-L subsection 9 of the Act allows the Board to consider equity in determining electricity supply agreements and that requiring equity in cost-effective testing aligns with the Act's intent.

drastic reduction would make a new low income rental program highly unlikely if not impossible. It would also threaten the less substantial direct install program that benefits low income households. 10 See EfficiencyOne Reply Evidence, Ju...

AI summary The text discusses the impact of reducing DSM investments on low-income rental programs and direct install initiatives. It notes that drastic reductions could make new low-income rental programs unlikely and threaten existing ones. It also highlights the affordability concerns for low-income households and the potential cost implications of increased rates.

AFFORDABLE ENERGY COALITION FINAL STATEMENT

AI summary The Affordable Energy Coalition submitted a final statement in a Nova Scotia regulatory proceeding, though the provided text contains no further details on arguments, claims, or specific issues addressed.

Page 12: In its response to Consumer Advocate IR-29, Efficiency One estimates that NS Power's alternate DSM scenario reduces total DSM funding by approximately 46 percent, including a reduction in lighting and domestic water heating measur...

AI summary Efficiency One argues that NSPI's alternate DSM scenario reduces funding by 46%, disproportionately affecting low-income participants. Affordability concerns are highlighted, though the HomeWarming Program (funded by NSPI) may offset some impacts. The program targets homeowners, excluding renters.

Page 34: VI. Affordability Issues Q: How should the Board deal with affordability of the DSM portfolio? 8 A: The concern with affordability requires a two-step process. First, the Board (or 9 parties working under the Board's guidance) mus...

AI summary The NSUARB must address DSM affordability through a two-step process: assessing rate impacts on customer groups and adjusting via cost allocation, enhancing cost-effective DSM services for underserved groups, and managing spending without lost revenues.

Page 38: B. Improving Affordability and Equity of a DSM Portfolio Q: How can concerns about affordability be addressed in DSM portfolio development? - A: One of the best solutions is to have a well-balanced portfolio of DSM programs that g...

AI summary The discussion focuses on how to address affordability concerns in DSM portfolio development. NS Power's proposed DSM budget is criticized for disproportionately allocating funds to commercial and industrial sectors, while EfficiencyOne's plan is seen as more balanced. Suggestions include removing market barriers and targeting vulnerable customers to reduce bill inequities.

Page 28: - 19 Affordability - 20 Q. Do you agree that NSPI's alternative DSM plan will be more affordable than E1's - 21 DSM plan? - 22 A. No. There are several different aspects of affordability, with regard to electricity services. - 23...

AI summary The discussion on affordability focuses on whether NSPI's alternative DSM plan is more affordable than E1's, with the respondent arguing that affordability depends on factors like electricity rates and bills, not just the plan itself.

Page 31: - 17 Please summarize your points regarding the affordability of the E1 DSM Plan and 18 the NSPI alternative DSM plan. - 19 A. NSPI's discussion of affordability is incomplete, because it focuses only on the short - 20 term rate i...

AI summary The response argues that NSPI's affordability analysis of its DSM plan is incomplete, focusing only on short-term rate impacts while ignoring bill impacts and long-term effects. A complete analysis shows E1's DSM Plan has lower net costs and similar long-term rates, making it more affordable. Affordability is important but not the sole factor in evaluating DSM plans.

DSM Investment Level As outlined in the SBA's Opening Statement, Nova Scotia small businesses are primarily concerned with affordability. While the SBA understands the value of Demand Side Management ("DSM") programs in Nova Scotia, the be...

AI summary The SBA supports the $113.5M DSM investment level, balancing program benefits with ratepayer costs. EOne commits to maintaining this budget, and the SBA aligns with BOne's proposal to credit over-recovery to reduce costs. The Monetary Consensus is cited as a key reference.

The Public Utilities Act Focus on Affordability - 4. Amendments to the PUA in 2014 added new provisions relating to Electricity Efficiency and Conservation. These amendments place an explicit obligation on NSPI to "undertake cost-effective...

AI summary The 2014 amendments to the Public Utilities Act (PUA) require NSPI to implement cost-effective electricity efficiency programs via a franchise agreement. The Board must approve such agreements, ensuring they benefit customers and consider affordability. E1 holds the first efficiency franchise under the PUA, with obligations similar to public utilities.

The Affordability of DSM in the Context of other Rate Pressures - 16. The Province's Electricity System Review engaged the general public and stakeholders about their views on key elements of our future electricity system and more than 130...

AI summary The Province's Electricity System Review gathered feedback from over 1300 Nova Scotians, highlighting ratepayer pressure. Evidence shows Nova Scotia has some of Canada's highest electricity rates. NSPI projects significant under-recovery from its fuel adjustment mechanism and expects higher base fuel costs. Additional costs from the Maritime Link and DSM amortization are also expected to impact rates.

Short on Options 24. The IRP was an important starting point in the development of the E1 2016-2018 DSM Resource Plan. 36 The Province agrees that this is an important consideration, but one must be mindful of 33 NSPI has noted that energy...

AI summary The Province critiques E1's DSM plan for relying too heavily on the IRP without adequately addressing affordability and long-term capacity needs. E1's plan avoids significant generation capacity additions until 2032 but may not align with the IRP's broader goals. The Province argues E1 could have provided alternative scenarios for affordability discussions, while E1 cites resource constraints.

The Inherent Flexibility of DSM 29. The adjustability of DSM was noted by several witnesses in the proceeding, including Mr. Sampson who commented: MR. SAMPSON: I'd say for a resource like DSM, which has flexibility where there are numerou...

AI summary The document highlights DSM's flexibility compared to traditional resources, citing witnesses like Mr. Sampson and Philippe Dunsky. E1's track record of meeting targets under budget is noted, with arguments that adjusting DSM budgets may not compromise savings. Affordability and capacity requirements are emphasized as key considerations.

Conclusions - 51. The amendments to the PUA in 2014 bring a new focus to the affordability of DSM in Nova Scotia. In the context of current and anticipated rate pressures, and in light of the fact that DSM is not required to address near t...

AI summary The Province argues that E1's DSM plan is overly expensive and unnecessary given current rate pressures and lack of near-term capacity needs. It requests a more modest plan, affordability-focused alternatives, and NSPI to address rate pressures. The Province also emphasizes assessing DSM effectiveness and proper handling of Supply Agreement costs.

1 1.0 OVERVIEW 2 3 Nova Scotia Power Inc. (NS Power or Company) is required under the Public Utilities 4 Act (Act) to enter into a supply agreement with EfficiencyOne (E1) for the supply of 5 cost-effective and affordable demand side manag...

AI summary Nova Scotia Power Inc. (NS Power) is required to enter into a supply agreement with EfficiencyOne (E1) for demand side management (DSM) from 2016 to 2018. E1 applied for approval of its DSM Resource Plan, proposing 405.9 GWh of energy savings over three years at a cost of $121.5 million. The Act mandates that the DSM plan must be affordable and in the best interests of NS Power's customers.

24 In the face of these challenges to affordability, NS Power has, amongst other things, 25 significantly reduced its workforce and its capital expenditure program. These efforts 26 have been very challenging for NS Power and for those Nov...

AI summary NS Power has reduced its workforce and capital expenditure to address affordability challenges, but this has come at a cost to ratepayers, contributing to high electricity rates in Nova Scotia. The discussion highlights the unique energy efficiency model in Nova Scotia with EOne as a utility under the Public Utilities Act and the use of benchmarking to assess spending levels.

DATE FILED: July 8, 2015 Page 8 of 50 1 3.0 LEGISLATIVE REQUIREMENTS 2 3 Unlike the Company's environmental and renewable generation requirements, the 4 expenditure level of DSM has not been legislatively mandated. There is nothing in the...

AI summary The document discusses the legislative requirements for Demand Side Management (DSM) in Nova Scotia, noting that DSM expenditure levels are not mandated by law. It outlines the responsibilities of EfficiencyOne (E1) and Nova Scotia Power Inc. (NS Power) under the Public Utilities Act, emphasizing the need for DSM programs to be affordable and in the best interests of customers.

33 Power's customers. Subsection 79L(6) states: DATE FILED: July 8, 2015 Page 9 of 50 Q _ (6) Notwithstanding subsection (5), in the application, the franchise holder is primarily responsible to provide information and evidence to the Boar...

AI summary The document discusses the lack of sufficient evidence provided by E1 to justify the affordability of its DSM programs. E1 did not present a lower-cost plan or alternative options to the Board, despite requests from NS Power. E1's preliminary scenario was not introduced as evidence and thus could not be used to assess affordability.

of affordability, but rather only to provide a plan based on a spend level that E1 was prepared to support. When asked about the $35 million preliminary scenario by the Board Mr. Crandlemire stated: MR. CLARKE: Mr. Crandlemire, why didn't...

AI summary The discussion centers on the provision of a demand-side management (DSM) plan based on a specific funding level supported by E1. Mr. Crandlemire is questioned about not presenting data to the Board or stakeholders, and a reference is made to the Public Utilities Act and a prior DSM Resource Plan.

DATE FILED: July 8, 2015 Page 11 of 50 11 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 16, 2015, pages 526-527, lines 13-22 and lines 1-2. 12 2016-2018 Demand Side Management Resource Plan (M06733), Transcript,...

AI summary NS Power argues that E1's failure to present alternative scenarios in the 2016-2018 Demand Side Management Resource Plan (M06733) prevents a full examination of affordability and does not meet statutory requirements to justify the proposed plan.

DATE FILED: July 8, 2015 Page 12 of 50 1 4.0 AFFORDABILITY 2 3 There has been considerable argument put forward in this proceeding as to what is meant 4 by the requirement of "affordability" under the Act. The IG suggested the requirement...

AI summary The document discusses the interpretation of 'affordability' under the Act, emphasizing short-term affordability as a priority. The Industrial Group and the Department of Energy (DOE) argue that rates in Nova Scotia are already high, and affordability should be the primary consideration, with a balance between short-term and long-term costs and benefits. The Act requires recalibration of affordability considerations every three years.

27 28 1 2 3 MR. GOGAN: So what do you consider to be the appropriate time period for consideration of affordability? 4 5 MR. BLUNDEN: It certainly varies by class. You know, when we talk to customers, in particular the business customers i...

AI summary The discussion focuses on the appropriate time period for considering affordability in energy rates. Business and residential customers generally consider affordability over a three to five-year period, while low-income customers are more concerned with immediate affordability. There is no evidence that customers consider affordability over a 20 to 25-year period, particularly in the context of DSM programs.

17 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 16, 2015, page 538, lines 5-6. 18 Ibid, page 538, lines 12-13. Mr. Faulkner, on behalf of E1, also acknowledged on cross-examination by the IG that it would be ap...

AI summary NS Power acknowledges the benefits of DSM but emphasizes the need to balance short-term affordability with long-term savings. It recommends a DSM plan that provides 100 GWh of annual energy savings at a cost of $22 million per year, avoiding additional capacity requirements until 2032. E1 acknowledges that NS Power's proposal aligns with compliance requirements and could be more affordable for customers over the long term.

& lt;sup>24 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 19, 2015, pages 780-781. 1 Although NS Power is confident E1 can deliver a program in the range of $22 million 2 that would produce the required demand a...

AI summary NS Power is confident that E1 can deliver a demand side management program worth $22 million, which would produce required demand and energy savings to avoid additional capacity requirements until 2032. However, the savings needed for the next 10 years are less than the average annual demand reduction required until 2032. E1 acknowledges that non-participants in the DSM Plan will see increased bills over the three-year contract period.

and strategies, which it did not do. It should have compared alternate incentives to E1's proposed amounts. Further, there was no comprehensive comparison to incentives in non-high cost jurisdictions. & lt;sup>51 Exhibit E-54, Opening Stat...

AI summary The document criticizes E1's process for not adequately considering the cost-effectiveness and affordability of incentives for NS Power customers. It highlights the lack of comprehensive comparison to non-high cost jurisdictions and the overemphasis on customer and trade ally input, potentially leading to inflated incentive requests.

Exhibit E-60, Best Practices in Electric Utility Integrated Resource Planning Examples of State Regulations and Recent Utility Plans (Synapse), filed by NS Power, June 15, 2015. 1 examination from the Board that industry capacity was one o...

AI summary NS Power argues that the impact of DSM infrastructure on industry capacity should not be considered when determining DSM spending levels, citing the Public Utilities Act's focus on customer affordability and best interests. NS Power's expert testified that DSM capacity should fluctuate based on demand, similar to generation capacity.

64 Exhibit E-40, Evidence of the Drazen Consulting Group, on behalf of the Industrial Group, June 2, 2015, page 19, lines 7-14. 1 when sort of that stable level of activity and I believe in the Province's 2 energy report that one of the th...

AI summary The document discusses the changing supply and demand balance in Nova Scotia's electricity system, noting a significant decrease in demand due to the loss of major industrial customers and energy efficiency programs, as well as an increase in supply from new wind farms and COMFIT projects. It argues that affordability is more important than maintaining stable spending levels on demand-side management (DSM) programs.

22. E1's reliance on past practices, however, fails to account for the legislative changes to the DSM system in Nova Scotia. First, the Act now creates a new franchise system and deems the franchise holder to be a public utility for the pu...

AI summary E1's reliance on past practices is criticized for not accounting for legislative changes to the DSM system in Nova Scotia, which now require the Board to ensure affordability and customer interests. NS Power argues that E1 is unwilling to consider lower annual expenditure amounts, potentially increasing DSM costs in the future.

72 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 18, 2015, page 635. 1 DSM spending is not immediately offset by reduced fuel costs within the year the funds 2 are spent on DSM activities. The funds are spent bu...

AI summary The text discusses the delayed financial benefits of DSM spending, highlighting that while DSM activities reduce fuel costs over time, the initial costs are borne by customers in the short term. It notes that customers may face increased rates in the near term, with financial benefits only becoming apparent after 19 years if energy savings are achieved as forecasted.

1 12.0 CONCLUSION 2 3 E1 has failed to discharge the burden placed on it under the Act. E1 has not provided the 4 evidence necessary to justify the DSM programs and level of expenditure put forward in 5 the E1 DSM Plan as being affordable...

AI summary E1 has not met its burden of proof to justify the DSM programs and expenditure levels in its plan as affordable or in customers' best interests. The proposed energy savings and costs are not necessary for regulatory compliance or system demand, and many incentives are deemed unreasonable. NS Power recommends a reduced DSM plan to support affordability and avoid additional capacity needs until 2032.

Response: Please refer to EfficiencyOne's response to NSPI IR‐10 Attachment 1, filed electronically, for measure‐level incentives modelled in the EL‐RAM, which are provided in column BK. The modelled incentive dollars provided reflect actu...

AI summary The response critiques EfficiencyOne's (E1) use of the ELRAM model for incentive calculations, citing lack of rationale, excessive incentives compared to other jurisdictions, and failure to consider cost-effectiveness or affordability. It highlights flaws in E1's process, including reliance on customer input without quantitative criteria and benchmarking against high-cost states, leading to potentially inappropriate incentive levels.

2 3 Nova Scotia's success in reducing electricity consumption and lowering costs for Nova Scotians 4 is the result of the input and knowledge of a broad spectrum of stakeholders. Without this, Nova 5 Scotians would pay more on their power...

AI summary Nova Scotia's success in reducing electricity consumption and costs is attributed to stakeholder collaboration. EfficiencyOne has reached an agreement with major stakeholders, including the Consumer Advocate and the Small Business Advocate, on an efficiency plan for 2016-2018. The plan does not impact rates and avoids using efficiency funds for other purposes, ensuring affordability.

e legislation, EfficiencyOne 25 proceeded to develop what it considered to be the appropriate DSM Plan for the contract period 26 2016-2018. In doing so, it relied upon a number of factors, including: 27 - 28 (1) The franchise holder's his...

AI summary EfficiencyOne developed a DSM Plan for 2016-2018, considering factors like NS Power's market knowledge, the 2014 IRP, affordability, NS Power feedback, and DSM system viability. Legal references include the Public Utilities Act and Exhibit 33.

25 AFFORDABILITY 26 27 Section 79L of the Public Utilities Act deals with the Board's requirement for approval of 28 agreements. Significant amongst these requirements, as it relates to this Application, are ss 79L 29 (8) and (9): 48 Trans...

AI summary Section 79L of the Public Utilities Act requires the Board to consider the best interests of customers and affordability when approving agreements, particularly those involving electricity efficiency and conservation activities. EfficiencyOne argues that these considerations have been central to previous approvals and are not new requirements.

50 Public Utilities Act , RSNS 1989, c 380, ss 79L (8) & (9). 1 In developing its DSM Resource Plan Application for 2016-2018, EfficiencyOne considered 2 affordability. The CEO of EfficiencyOne stated in his opening statement: 3 4 The 2016...

AI summary EfficiencyOne's 2016-2018 DSM Resource Plan Application emphasizes affordability, highlighting cost-effectiveness, long-term savings, and alignment with Nova Scotia Power's Integrated Resource Plan. The plan aims to ensure long-term affordability for Nova Scotians by incorporating energy efficiency as a key supply strategy.

1 EfficiencyOne has factored in affordability to its Quantum Agreement investment level of 2 $113.5 million: 3 4 • It is $69 million, or 38 percent, less (over the three-year term) than the Mid-DSM level of 5 the IRP's Preferred Resource P...

AI summary EfficiencyOne's Quantum Agreement investment level of $113.5 million is significantly lower than previous DSM investment levels and aims to balance short and long-term affordability. It avoids new capacity additions until 2032 and ensures a balanced participation across sectors.

ordability 28 while ensuring that DSM can be gradually "ramped up" in future years, as needed. 29 30 • It addresses long-term affordability through avoidance of new capacity additions until 31 2032. 2 None of the above factors were success...

AI summary The text discusses the affordability and balance of NS Power's DSM budget, highlighting that NS Power's proposal allocates only 25% of the DSM budget to residential customers, despite their significant share of energy load and revenues. This is contrasted with EfficiencyOne's more balanced approach, which allocates 48% of the DSM budget to residential customers.

Exhibit 42. Direct Evidence of Paul Chernick. Page 38, lines 6-20. 1 customer inequities, and is not consistent with best practices in DSM program 2 design.54 3 4 … 5 6 NSPI discusses affordability almost entirely in terms of the amount of...

AI summary The text discusses concerns about the affordability of DSM programs, emphasizing that NSP's approach focuses on budget reduction rather than broader affordability indicators. It argues that the most important affordability indicator is the impact on electricity system costs, measured by the net present value of revenue requirements (PVRR), and supports using the PAC test to evaluate DSM resources.

15 [emphasis added] 16 - 17 The uncontradicted evidence presented in the hearing established an estimated average - 18 generation cost of 12 cents per kWh while the corresponding cost of avoiding this kWh of - 19 generation through DSM equ...

AI summary The document highlights that DSM investments cost 3 cents per kWh, significantly lower than the 12 cents per kWh generation cost, making them affordable for Nova Scotia ratepayers. EfficiencyOne's plan, under the Quantum Agreement, achieves savings at 1.7 cents per kWh. The Consumer Advocate emphasizes DSM's focus on bill savings, not just generation avoidance, countering NSP's framing.

18 LEGISLATIVE FRAMEWORK 19 20 The introduction of the Electricity Efficiency and Conservation Restructuring (2014) Act in 2014 21 brought with it a revised legislative framework for the delivery of demand side management 22 activities in...

AI summary The 2014 Electricity Efficiency and Conservation Restructuring Act revised Nova Scotia's legislative framework for demand-side management (DSM), requiring NS Power to negotiate with EfficiencyOne. The legislation assigns the Board authority to determine DSM investment levels, considering 'affordability' (undefined). EfficiencyOne argues undefined affordability hinders negotiations but cites the Quantum Agreement as evidence of balancing short-term and long-term DSM benefits.

1. This submission is filed on behalf of the Industrial Group. Below we outline our position on the following matters: (I) The all-party Consensus Agreement Respecting Non-Budgetary items; (II) The Dollar Budget and Program Savings; (III)...

AI summary The submission outlines the Industrial Group's position on several matters, including the all-party Consensus Agreement, budget and program savings, affordability, operational flexibility, and customer impact, concluding with recommendations.

(III) AFFORDABILITY - 59. All participants have spoken about affordability and what it means. The Industrial Group wishes to make it clear that it does not favour short-term affordability at the expense of long-term risks. The Industrial G...

AI summary The Industrial Group emphasizes balancing short-term and long-term affordability, advocating for a 10-20 year IRP horizon and regular reviews of DSM spending. They note NSPI's existing rate capacity for DSM and recommend future transparency and scenario modeling by E1 and NSPI.

; correct? Ms. Vincent: Unanticipated, because when that forecast was built there was no history of Efficiency Nova Scotia's administration of DSM in order to inform that forecast.[41](#page-17-0) - 69. Mr. Faulkner's assurance that E1 wil...

AI summary EfficiencyOne (E1) faces criticism for unanticipated DSM program forecasts and budget overruns, with the Industrial Group arguing that E1's approach risks rate instability. E1 prioritizes demand reduction across all rate classes, but stakeholders emphasize the need for prudent cost management and affordability. Regulatory obligations to customers are highlighted as a key concern.

THE IMPORTANCE OF DSM TO NOVA SCOTIA It is the view of the Consumer Advocate that an effective and robust DSM program is an important component in meeting the energy requirements of Nova Scotians. We continue to rely heavily on fossil fuel...

AI summary The Consumer Advocate emphasizes that DSM is crucial for Nova Scotia's energy needs due to reliance on fossil fuels and limited alternative sources. While renewable options like wind and hydro exist, they face cost, supply, or capacity challenges. DSM is highlighted as cost-effective, reducing demand cheaper than generation, though upfront costs concern ratepayers, particularly small businesses.

AFFORDABILITY The Board has the mandate to ensure rates that recover the cost of a DSM program are just and reasonable. The Province has recently added the terminology of "affordability". It is the submission of the Consumer Advocate that...

AI summary The Board must ensure that DSM program rates are just and reasonable. The Consumer Advocate argues that the proposed DSM program by EfficiencyOne is affordable, citing consistency with past spending, adherence to a provincial cap, and no rate increases. The Province’s cap of $35 million is presumed to be within the range of affordability.

SUMMARY The Ecology Action Centre wishes to: - (1) express support for the stakeholder settlement agreement presented to the Board; - (2) articulate that the proposed settlement agreement represents a significant concession in the interest...

AI summary The Ecology Action Centre supports a stakeholder settlement agreement but highlights its deviation from the Integrated Resource Plan's activity levels, emphasizing short-term affordability concessions. They advocate linking avoided costs to program benefits, reaffirming mid-course adjustments, proposing a revised discount rate for DSM programming, and requesting cost-recovery.

DSM Investment Level At $113.5 million, the Settlement Agreement proposes a level of investment $8 million lower than the level of investment initially proposed by E1 ($121.5 million) and $69.1 million lower than the mid-level DSM investme...

AI summary The Settlement Agreement proposes a DSM investment level of $113.5 million, which is $8 million lower than E1's initial proposal and $69.1 million lower than the mid-level investment from the Navigant study. E1 plans to absorb the budget reduction while maintaining savings targets. EAC argues that the investment level ensures affordability and highlights the importance of DSM as the lowest cost option for ratepayers.

Benefit Description Avoided cost of energy Avoided marginal cost of energy produced Avoided cost of capacity Avoided cost of generating capacity Avoided cost of transmission and distribution Value of avoiding or deferring the construction...

AI summary The text outlines various categories of avoided costs, including energy, capacity, transmission, distribution, environmental compliance, and renewable portfolio standards, as well as nonenergy benefits to utilities. It also notes the overlap between Baatz's and Woolf's perspectives on beneficial avoided costs.

COMPLIANCE WITH THE PUBLIC UTILITIES ACT - NS Power has stated that EfficiencyOne has failed to discharge its burden under the Public - Utilities Act : - E1 has failed to discharge the burden placed on it under the Act. E1 has not - provid...

AI summary NS Power argues EfficiencyOne failed to justify its DSM programs and expenditure under the Public Utilities Act, citing insufficient evidence to prove affordability and customer benefit. The claim references NS Power's closing submission, page 49.

bmission, Page 37, Lines 20-24. 15 Exhibit E-60, Best Practices in Electric Utility Integrated Resource Planning Examples of State Regulations and Recent Utility Plans (Synapse), Page 31. realize the benefit of the fuel savings and then on...

AI summary EfficiencyOne disputes NS Power's use of Figure 3.8, arguing it shows rate effects, not revenue requirements, and challenges NS Power's affordability claims. Both NS Power and the Department of Energy emphasize affordability in DSM plans, referencing legislation from other jurisdictions. The debate centers on DSM plan accuracy, rate design, and affordability criteria.

1 Distinction between regulatory perspective and political perspective The Province refers to the recent public consultation process during which it heard from the public that ratepayers were concerned about rates and that supported the co...

AI summary The Province highlights public concerns about ratepayer affordability of the EfficiencyOne DSM program, while the Board emphasizes regulatory criteria (affordability, reasonableness, ratepayer interests) for assessing the program. The political perspective may prioritize avoiding rate increases regardless of regulatory standards.

2 Affordability Adding the provision of "affordability" does not significantly alter the existing legislative regime. If the cost of a DSM program is not affordable it would be considered unreasonable. While the terminology of reasonablene...

AI summary The text argues that adding 'affordability' to the legislative regime does not significantly change existing criteria, as unaffordable DSM programs would already be deemed unreasonable. The EfficiencyOne program's cost is lower than previous DSM budgets, and no evidence links its approval to future rate increases. Ratepayer affordability perceptions depend on total rates, not individual charges, with COMFIT and biomass boilers also influencing perceptions.

DATE FILED: July 15, 2015 Page 4 of 32 1 CA Closing Submission, July 8, 2015, page 7. 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 15, 2015, page 5-15. 1 It is noteworthy that this statement was not questioned...

AI summary The document discusses NS Power's recommendation for a Demand Side Management (DSM) plan that avoids capacity additions until 2032, arguing it is in customers' best interests. It also raises concerns about E1's potential self-interest in obtaining DSM funding, despite affordability concerns, and references a conflict of interest based on E1's incentive process.

is the evidence of the inherent 17 bias in E1's incentive process which was brought forward during the IG's crossexamination of the E1 panel.3 18 As summarized by the IG in its Closing Submission: 19 20 In addition, the Industrial Group is...

AI summary The text discusses concerns raised by the Industrial Group regarding inherent bias in E1's incentive process, as highlighted during the IG's cross-examination. It notes that E1's performance is tied to energy savings targets, which discourage the elimination of incentives. The evaluation process does not allow E1 to count non-incentive measures like education and advertising toward its targets, potentially affecting customer affordability.

14 CA Closing Submission, July 8, 2015, page 5. 1 4.0 NOVA SCOTIA DEPARTMENT OF ENERGY CLOSING SUBMISSION 2 3 In its discussion of the affordability of DSM in the context of other rate pressures, the 4 DOE referred to costs included in rat...

AI summary The Nova Scotia Department of Energy discusses the affordability of Demand Side Management (DSM) in the context of rate pressures. It notes that the FAM AA/BA is being used to pay down underrecoveries from 2013 and 2014, but some rate classes will not see a reduction in 2016 due to extended repayment obligations.

1 5.0 E1'S CLOSING SUBMISSION 2 3 NS Power submits this proceeding has suffered from an overly aggressive interpretation 4 of the enabling legislation by E1. This has resulted in a departure from the typical 5 regulatory construct under wh...

AI summary NS Power argues that E1 has misinterpreted the enabling legislation, leading to a regulatory process that deviates from standard practices. E1 claims expertise in DSM and affordability, asserting that it should not be required to justify its incentive levels. NS Power counters that E1 failed to provide alternative scenarios and did not substantiate its assumptions.

31 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 19, 2015, pages 904-905, lines 16-22 and 1-9. Regardless of the reasons, the cost pressures noted above are real and must be factored into the assessment of this...

AI summary The Province emphasizes the need to consider affordability in the context of rising cost pressures, arguing that energy efficiency savings can avoid new generation capacity and that DSM costs should be scrutinized. E1 did not address these cost pressures or acknowledge DSM's role in them.

nly realized after expressing the upfront costs over the energy saved for the 15 year life of the measures. First year costs of DSM programming as proposed by E1 are 29 cents/kWh to 31 cents/kWh. 22. DSM above the levels required to avoid...

AI summary The text discusses the long-term benefits of Demand Side Management (DSM) programs, noting that while upfront costs are significant, energy savings and cost benefits may not be realized for many years. NS Power highlights that customers may not see fuel savings until 2034, if savings are achieved as forecasted.

5.8 Affordability E1 states that the Board should "fundamentally reject a definition of affordability grounded largely on the "here and now" as espoused by NS Power." NS Power submits that this statement is a mischaracterization of Company...

AI summary E1 argues against NS Power's affordability definition, emphasizing short-term focus. NS Power claims E1 mischaracterizes its evidence, advocating for balancing short and long-term affordability through a 100 GWh DSM plan costing $22 million. This plan aligns with the Province's interpretation of affordability as avoiding unnecessary spending, per the DOE's Closing Submission.

he $53 million that was in rates for DSM in 2014 and which amount was subsequently repurposed by Order of the Board for 2015 fuel expenses. It expanded on these points in its post-hearing submission: - It is $69 million, or 38 percent. les...

AI summary The document discusses the repurposing of a $53 million DSM rate allocation from 2014 for 2015 fuel expenses, and how the proposed DSM investment level balances short and long-term affordability. It emphasizes the cost-effectiveness of the Mid-DSM scenario in the IRP and contrasts the proposed plan with NS Power's alternative, which relies heavily on energy savings from the BNI sector.

3.5.3 Affordability - [76] Having determined the parameters of a preferred plan, the Board is specifically directed by the 2014 amendments to the PUA to address the issue of affordability. The most relevant sections are Section 79L(8) and...

AI summary The Board is directed by 2014 PUA amendments to assess affordability in DSM programs under Section 79L(9). Affordability, previously considered in rate shock discussions and Annual Capital Expenditure Plans, now requires explicit evaluation. The Industrial Group highlights affordability's importance in its posthearing submission, while the Board must determine if Section 79L(9) alters its assessment of DSM expenditures.

3.5.3.1 Findings [88] The Board notes that the DSM amount of $33,210,000, as set by the Board for 2016, is below DSM spending in each of the last four years. It is also an amount significantly below that recommended in the IRP, and the Boa...

AI summary The Board observes that the 2016 DSM amount of $33,210,000 is below recent spending levels and the IRP recommendation. It considers this amount affordable under Section 79L of the PUA while aligning with ratepayer interests.

Program NSPI's DSM • $22.0 million Plus 2014 ENSC surplus $8.4 million • $8.4 million still in rates 2008-09 amortization Plus • DSM $1.1 million based evidence absorbed the can be Total of NSPI, (which, on • increase in 2016) rate without...

AI summary The Board considers a potential revenue shortfall of approximately $2 million for NSPI to be manageable, as it believes NSPI can find offsetting savings. If not, the Board would consider deferral evidence before allowing a rate increase, deeming the program affordable.

ogramming for low income renters within the Plan approved by the Board. [136] The Board notes, however, its limited role, as pointed out by Counsel for the Industrial Group in its closing submission: 32. It is not the role of the Board to...

AI summary The Board clarifies its limited role in job creation and affordability under the Public Utilities Act (PUA), emphasizing that job creation is a provincial policy matter. It reaffirms its focus on ensuring DSM plans align with customer interests and affordability, noting that businesses outside E1's preferred providers can deliver efficiency programs.

aving considered the history of underspending on DSM programming, the history of overachieving savings and demand targets, and as an inducement to bring greater rigor to the calculation of incentives. [142] The Board considers that the tar...

AI summary The Board approves the DSM Plan, finding it achievable within approved spending, but rejects the Quantum Agreement. It emphasizes long-term cost considerations over short-term affordability, approves aspects of the Quantum Agreement, and endorses the Consensus Agreement with referrals to the DSM Advisory Group. The TRC cost-effectiveness screening remains in place.

1. INTRODUCTION The 2016-2018 Demand-Side Management (DSM) Resource Plan has been developed based on ENS's growing experience and history in delivering successful DSM programs and services to Nova Scotians. As part of the process, ENS enga...

AI summary The 2016-2018 Demand-Side Management (DSM) Resource Plan outlines ENS's comprehensive suite of programs and services for Nova Scotia electricity users. It emphasizes flexibility for mid-course adjustments based on market conditions and stakeholder agreements, while addressing affordability and long-term planning considerations.

- Education and Outreach; - Development and Research; and - Other Enabling Strategies: - o Property-Assessed Clean Energy (PACE) Financing Support; - o Working with Governments; - o Capacity Building; and - o Regulatory Affairs. Enabling S...

AI summary The document discusses Enabling Strategies implemented by ENS to increase awareness of DSM programs, improve service delivery, and drive market transformation. These strategies include initiatives like market research, outreach activities, and innovation in financing and codes development. ENS emphasizes the importance of these strategies for long-term energy efficiency goals despite short-term affordability concerns.

1. INTRODUCTION The 2016-2018 DSMDemand-Side Management (DSM) Resource Plan has been developed based on ENS's growing experience and history in delivering successful DSM programs and services to Nova Scotians. As part of the process, ENS e...

AI summary The 2016-2018 DSM Resource Plan by ENS outlines programs and services for Nova Scotia electricity users, developed with consulting firms and aligned with the UARB's 2015 decision. The plan emphasizes flexibility for mid-course adjustments, affordability, and compliance with NS Power's IRP. It includes residential, BNI, and enabling strategies sections, with revised investment targets to meet annual DSM funding requirements.

2.4 Update on Energy Saving Actions Efficiency Nova Scotia's 2016-2018 DSM Resource Plan does not include a target or investment for Energy Saving Actions. ENS piloted the Home Energy Report in 2013, and it will continue until early 2016....

AI summary Efficiency Nova Scotia's 2016-2018 DSM plan lacks energy-saving targets. The Home Energy Report pilot ends in 2016 due to affordability concerns, with ENS opting to discontinue it to minimize impact on portfolio balance and industry capacity. Future plans may revisit the program if higher savings are needed. Behavior-based efficiency remains a priority, with ENS exploring alternative incentives through research.

27. SURVIVAL 27.1 Subject to the provisions of the Act, all provisions of this Agreement which by their express terms or nature are continuing shall survive the expiration or termination of this Agreement, including, without limitation, th...

AI summary This section outlines the survival of specific provisions in the Agreement upon its expiration or termination, including those related to the EECA Plan, confidentiality, indemnity, and intellectual property, among others.

2.4 Update on Energy Saving Actions Efficiency Nova Scotia's 2016-2018 DSM Resource Plan does not include a target or investment for Energy Saving Actions. ENS piloted the Home Energy Report in 2013, and it will continue until early 2016....

AI summary Efficiency Nova Scotia's 2016-2018 DSM Resource Plan lacks Energy Saving Actions targets. The Home Energy Report pilot (2013-2016) will end due to affordability concerns, despite its energy-saving success. ENS prioritizes minimizing impact on portfolio balance and industry capacity. Behavior-based programs remain important, with ENS exploring alternatives via Enabling Strategies.

SCHEDULE B

AI summary The document is Schedule B from a Nova Scotia regulatory proceeding involving utility and energy-related stakeholders. Key entities include Nova Scotia Power Incorporated, the Nova Scotia Utility and Review Board, and various advocacy groups. The context highlights regulatory acronyms and potential topics related to energy policy and consumer advocacy.

1. INTRODUCTION 1 2 3 4 5 The 2016-2018 Demand-Side Management (DSM) Resource Plan has been developed based on ENS's growing experience and history in delivering successful DSM programs and services to Nova Scotians. As part ofthe process,...

AI summary The 2016-2018 Demand-Side Management (DSM) Resource Plan was developed by ENS with input from consulting firms. It outlines a range of programs and services for Nova Scotia electricity users, emphasizing flexibility for mid-course adjustments based on stakeholder agreements and regulatory decisions. The plan balances affordability and long-term planning while avoiding unnecessary system capacity additions.

2.4 Update on Energy Saving Actions 1 2 3 4 5 6 7 8 9 Efficiency Nova Scotia's 2016-2018 DSM Resource Plan does not include a target or investment for Energy Saving Actions. ENS piloted the Home Energy Report in 2013, and it will continue...

AI summary Efficiency Nova Scotia's 2016-2018 DSM plan lacks energy-saving action targets. The Home Energy Report pilot, successful in energy savings, will end by early 2016 due to affordability concerns, leading to reduced DSM investment. ENS plans to explore alternative strategies while emphasizing the importance of behavior-based energy efficiency.