E-1-1Application
10 passages
11 5.2.1.1 Residential 12 13 For residential customers, the Preferred Plan focuses on the barriers of affordability and 14 up-front costs, lack of information and awareness of energy efficient technologies and 15 benefits, lack of time and...
AI summary The residential section discusses barriers to participation in energy efficiency programs, including affordability, upfront costs, lack of information, and split incentives between landlords and tenants. The Preferred Plan aims to address these barriers through targeted program components, as detailed in Table 6.
1 Table 6: Residential barriers to participation and mitigating strategies Program Program Component Brief Description of Program Component Target Market Segment Barriers Addressed in Preferred Plan and How EFFICIENT PRODUCT REBATES Applia...
AI summary Table 6 outlines residential barriers to participation in the Efficient Product Rebates program and strategies to mitigate them. Key barriers include affordability, awareness, short decision periods, and lack of trust. Mitigation strategies include financial incentives, marketing across Nova Scotia, and delivery agent support for appliance replacement.
20 5.2.1.2 BNI 21 22 For business, non-profit and institutional customers, the Preferred Plan focuses on the 23 barriers of affordability and upfront costs, internal competition for capital, short 24 payback periods, lack of resources and...
AI summary The Preferred Plan targets barriers for business, non-profit, and institutional customers, such as affordability, upfront costs, capital competition, short payback periods, and lack of resources or information. It addresses these issues as detailed in Table 7.
1 Table 7: BNI barriers to participation and mitigating strategies Program Program Component Brief Description of Program Component Target Market Segment Barriers Addressed in Preferred Plan and How CUSTOM Custom Customized incentives for...
AI summary Table 7 outlines barriers to participation in the BNI program and strategies to mitigate them. Key barriers include upfront costs, internal competition for capital, payback periods, time and capacity constraints, and lack of internal commitment and technical expertise. Mitigating strategies include financial incentives, rebates, financing, and technical assistance.
1 6. APPROPRIATE INVESTMENT LEVEL 2 - 3 The Preferred Plan requires an investment of $43 million per year. In determining this 4 investment level, EfficiencyOne considered the following factors: - 5 affordability; - 6 alignment with the IR...
AI summary The Preferred Plan requires an annual investment of $43 million, determined by EfficiencyOne considering factors such as affordability, alignment with the Integrated Resource Plan, past expenditures, balanced participation among rate classes, and other considerations including NS Power expenditures and long and short-term affordability.
12 Is the Preferred Plan Affordable? 13 14 Affordability is recognized as a key factor in DSM planning. In its decision on the 15 2016-2018 DSM Plan, the Board stated it is "specifically directed by the 2014 amendments to the PUA to addres...
AI summary The document discusses the affordability of the Preferred Plan under Nova Scotia's DSM framework. The Board emphasized balancing short-term and long-term affordability, citing its 2015 decision (M06733) that exclusive focus on short-term costs harms ratepayers. The Preferred Plan is deemed affordable as it aligns with the Board's guidance on long-term benefits.
16 Assets acquired on or after Implementation Date 17 8. Any assets of the Corporation acquired on or after the Implementation Date 18 must be transferred to Nova Scotia Power Incorporated for the benefit of the 19 customers of Nova Scotia...
AI summary The text discusses the transfer of assets acquired by the Corporation on or after the Implementation Date to Nova Scotia Power Incorporated for customer benefit. It also outlines a proposal by EfficiencyOne to apply an HST refund across the 2020–2022 DSM Plan to reduce required investment and enhance affordability.
- 30 The result is a Plan which is carefully designed to yield access to all sectors and rate 1 classes, providing maximum value to Nova Scotians. 3 Affordability
AI summary The Plan is designed to ensure access across all sectors and rate classes, providing maximum value to Nova Scotians. The section on affordability highlights the importance of making energy services accessible and affordable for all consumers.
- increase customer and retailer awareness of energy efficiency opportunities; 1 increase system-peak demand for energy efficient products; • 2 increase the availability of energy-efficient products at retailers; • 3 increase customer and...
AI summary The Efficient Products Rebates program aims to increase awareness of energy efficiency opportunities, promote the use of energy-efficient products, and remove inefficient appliances from the Nova Scotia electricity system. The program targets residential customers, including low-income and renter groups, and addresses barriers such as affordability, awareness, short decision periods, lack of trust, and lack of information.
Market Barriers - Barriers to participating in the Existing Residential program include: - Affordability lack of financial resources to cover upfront costs (product/equipment, installation, energy assessments). - Awareness lack of informat...
AI summary The document outlines barriers to participation in the Existing Residential program, including affordability, awareness, and lack of resources. Split incentives, where landlords don't cover utility costs, also hinder energy efficiency upgrades.
E-3E1 (NSPI) RIRs to IR-1 to IR-69
29 passages
ement for Electricity Efficiency and Conservation Activities between E1 and Nova Scotia Power Inc. (DSM 2020- 2022) M09096 (E-ENS-R-19) E1 Responses to Nova Scotia Power Inc. (NS Power) NON-CONFIDENTIAL 1 Request IR-02: 2 3 For the 2019 DS...
AI summary EfficiencyOne (E1) states that all DSM programs for 2019 and 2020-2022 are funded by NS Power customers and the Province of Nova Scotia for non-electric residential components. Shared costs are allocated using the Nova Scotia Utility and Review Board's approved methodology. Funding breakdowns and cost allocations are detailed, with references to prior responses for specific figures.
comments on the following two questions: 22 • What are you hearing from your clients? 23 • Is there anything we are missing? 24 EfficiencyOne received the following general comments: 25 • general support for increasing the emphasis on dema...
AI summary EfficiencyOne received general support for increasing demand reduction emphasis and helping underserved markets benefit from energy efficiency. EfficiencyOne addressed stakeholder comments by considering alternate scenarios with lower investment levels ($34M and $27M annually).
ting various investment levels without regard to considerations such as 25 deliverability, balanced portfolio, short and long term affordability, and related factors 26 considered in the development of an appropriate and deliverable DSM Pl...
AI summary EfficiencyOne (E1) developed three investment scenarios for the DSM 2020-2022 Plan, considering affordability, balanced portfolios, and deliverability. The scenarios included $34M and $27M annual investments, with alignment to the 2020-2022 DSM Resource Plan's key considerations: maximizing energy savings, balanced portfolios, and appropriate investment levels.
ement for Electricity Efficiency and Conservation Activities between E1 and Nova Scotia Power Inc. (DSM 2020- 2022) M09096 (E-ENS-R-19) E1 Responses to Nova Scotia Power Inc. (NS Power) NON-CONFIDENTIAL 1 Request IR-10: 2 3 Reference: Evid...
AI summary EfficiencyOne explains that affordability of its DSM plan is determined by balancing short-term and long-term rate and bill impacts. It highlights that the three-year investment of $129.1M yields $622.7M in energy savings, resulting in a 4.8 return on every $1 invested. Bill increases are projected to be between 0.8% and 1.7%.
ement for Electricity Efficiency and Conservation Activities between E1 and Nova Scotia Power Inc. (DSM 2020- 2022) M09096 (E-ENS-R-19) E1 Responses to Nova Scotia Power Inc. (NS Power) NON-CONFIDENTIAL 1 between 1 percent and 4 percent, t...
AI summary The document discusses the affordability of the DSM 2020-2022 plan, referencing historical investment levels approved by the UARB and noting that these plans were determined to be in the best interest of ratepayers and therefore affordable.
ment levels, was subject to 13 rigorous stakeholder and regulatory review and ultimately determined to be in the best 14 interest of NS Power ratepayers; and therefore affordable. 15 At an average annual investment of $43.0M, the Efficienc...
AI summary The text discusses the approval of EfficiencyOne’s Preferred DSM Plan, which was subject to stakeholder and regulatory review and determined to be in the best interest of NS Power ratepayers. The plan involves an average annual investment of $43.0M over a 9-year period.
ement for Electricity Efficiency and Conservation Activities between E1 and Nova Scotia Power Inc. (DSM 2020- 2022) M09096 (E-ENS-R-19) E1 Responses to Nova Scotia Power Inc. (NS Power) NON-CONFIDENTIAL 1 history and is closer to the avera...
AI summary EfficiencyOne argues that its proposed DSM Plan for 2020-2022 is affordable and requires lower ratepayer contributions than historical averages, citing amortization of HST settlement recovery and underspend from previous plans.
(2.5) (2.5) Underspend / Interest Earned HST recovery (5.0) (5.0) (5.0) Net Ratepayer 34.4 35.8 36.4 Contribution 3 4 The required investment, net of cumulative underspend and HST recovery, amounts to an 5 annual average of $35.53M over th...
AI summary The document discusses the affordability of EfficiencyOne's 2020-2022 Preferred DSM Plan, noting that the required investment is $35.53M annually over three years, representing a 1.4% increase from the 5-year average and a 10.1% decrease from the 9-year average. EfficiencyOne affirms the plan is affordable based on historical investment levels and expert testimony, though no specific affordability surveys were conducted with Nova Scotians.
involves customer feedback and If any measures or technologies could lead to a large annual incentive Understand Customer CSAT/QA surveys; and expenditure (over $400,000 over multiple years), it may be worth conducting Motivation and Bar...
AI summary The text emphasizes the importance of understanding customer motivation and barriers to participation in energy programs, particularly in light of rising electricity prices. It suggests conducting research such as CSAT/QA surveys, specialized program design studies, and price sensitivity analyses to better address affordability concerns and improve customer engagement.
Systems.aspx 93 We change the way people use energy Date Filed: March 29, 2019 NS Power IR-15 Attachment 1 Page 110 of 206 APPENDIX A-2: ONTARIO GAS (UNION GAS) The incentive setting methodology and cost effectiveness section was based on...
AI summary This document discusses Ontario Gas, specifically Union Gas and Enbridge Gas Distribution Inc., their customer base, and load and consumption information for 2014, including the number of customers and sales data categorized by rate classes.
the final sample of eight employees roughly mirrors ENS’s total employee pool for the selected criteria.8 Table 2. Generation of All ENS Staff and of Interviewed Employees Generation Z Millennial Xennial Generation X Younger Boomer ENS Sta...
AI summary The text presents data on the age distribution and employment levels of ENS staff and interviewed employees, showing that the sample of eight employees roughly mirrors the overall employee pool. The tables break down the data by generation and employment level.
ement for Electricity Efficiency and Conservation Activities between E1 and Nova Scotia Power Inc. (DSM 2020- 2022) M09096 (E-ENS-R-19) E1 Responses to Nova Scotia Power Inc. (NS Power) NON-CONFIDENTIAL 1 Request IR-22: 2 3 Reference: Appe...
AI summary The document outlines barriers to participation in various energy efficiency programs, with affordability and upfront costs being major issues. EfficiencyOne highlights that financial constraints, lack of access to affordable capital, and long payback periods hinder program participation, particularly for businesses and residential users.
ese commitments will provide benefits to Canadians through energy cost savings and improved environmental outcomes, which lead to increased productivity, competitiveness and energy affordability. In December 2016, First Ministers adopted t...
AI summary The text outlines international and national commitments to energy efficiency and climate change mitigation, including the Pan-Canadian Framework on Clean Growth and Climate Change, and efforts to align energy efficiency standards between Canada and the United States. These initiatives aim to reduce greenhouse gas emissions, improve energy affordability, and support economic growth.
re than recovered through energy savings. The analysis found payback ranges of less than eight years for all product categories, with nine product categories having paybacks of two years or less. The Amendment is estimated to result in an...
AI summary The Amendment is expected to reduce greenhouse gas emissions by 1.54 Mt annually in 2030 and improve energy efficiency, leading to cost savings and increased productivity. It is classified as an 'OUT' under the 'One-for-One' Rule, resulting in a net reduction in administrative costs for businesses, including small businesses.
esult in significant net benefits over the lifetime of affected product models. The benefits vary by individual user depending on enduse sector, geographical location and operational practices. Annual reductions in energy consumption asso...
AI summary The Amendment is expected to result in significant energy consumption and GHG emission reductions over time, with estimated annual energy savings increasing from 3.76 PJ in 2020 to 15.76 PJ in 2030. It is projected to yield $4.55 billion in net benefits by 2030, with total benefits exceeding total costs by a ratio of almost five to one.
fits exceeding total costs by a ratio of almost five to one. By 2030, the present value of benefits and costs from the Amendment is estimated to be $5.75 billion and $1.20 billion, respectively. For all product categories affected by the A...
AI summary The Amendment is expected to generate significant energy savings and reduce GHG emissions, with benefits far exceeding costs. The analysis shows that energy savings over the product lifecycle will offset any increased retail prices, with payback periods of less than eight years for all product categories. The document provides a detailed cost-benefit analysis.
by comparing the following scenarios: the businessasusual case (i.e. excluding the Amendment); and the policy case (i.e. the businessasusual case including the Amendment). Businessasusual case The Canadian and U.S. markets for regula...
AI summary This analysis compares a business-as-usual scenario with a policy case that includes an amendment to the Regulations. It assumes that the Canadian and U.S. markets are integrated, and that regulatory changes in one country are analyzed independently, without considering spillover effects. The analysis uses 2016 market conditions as a baseline and acknowledges the difficulty in estimating cross-border market impacts.
2030. The quantified costs include incremental technology costs to meet the more stringent standards, administrative costs and costs to Government associated with regulatory implementation. While not quantified as part of this analysis, en...
AI summary The text discusses the quantified costs of implementing more stringent energy efficiency standards, including technology, administrative, and regulatory costs. It also highlights economic and non-energy benefits, such as increased productivity and household comfort. The amendment is classified as an 'IN' under the 'One-for-One' Rule and impacts small Canadian manufacturers. The amendment resulted from domestic and international cooperation to meet GHG and energy consumption goals.
Covers shipments impacted by the proposed Regulations between 2019 and 2030. All benefits and costs are discounted at 3% to the year 2018. Table 3: Summary of benefits and costs to Canadians Aggregate Total Cumulative Annual Totals Present...
AI summary The text discusses the economic impacts of proposed regulations from 2019 to 2030, including benefits such as fuel savings and avoided GHG damages, and costs related to technology, installation, and compliance. All values are discounted to 2018 prices.
$0.12 administrative costs Government administration Government $0.10 $0 $0.10 $0.01 Total costs $34.89 $146.67 $1,040.49 $104.53 Net benefits $132.28 $231.54 $1,804.06 $181.24 B. Quantified impacts (in non$) Energy savings (petajoules) 1...
AI summary The table outlines administrative and total costs, as well as net benefits and quantified impacts such as energy savings and GHG emission reductions from 2019 to 2030. It also highlights additional benefits of energy efficiency, including cost savings, productivity, and environmental improvements, while noting the lack of data on certain non-energy benefits.
. It would result in an increase of $72,161 in annualized average administrative costs to industry. Assumptions underlying administrative burden estimates Familiarization with the Amendment Familiarization with new information obligations...
AI summary The text discusses the administrative costs associated with a new amendment, estimating an increase of $72,161 annually. It outlines the one-time task of familiarizing stakeholders with the amendment and energy efficiency reporting forms, impacting approximately 710 companies under specific HS codes.
input the data has been estimated to take 36 seconds per data element. These activities would be undertaken by administrative support staff with a wage rate of approximately $29. Consultations No comments were received from stakeholders on...
AI summary The amendment introduces new reporting requirements for small importers, estimated to increase administrative costs by $50,513 annually. Stakeholders are generally supportive, but challenges include lack of awareness. Natural Resources Canada plans to undertake outreach to mitigate these issues.
NS Power IR-28 Attachment 2 Page 21 of 44 3/15/2019 Canada Gazette, Part 1, Volume 152, Number 42: Regulations Amending the Energy Efficiency Regulations, 2016 (Amendment 15) According to the International Energy Agency, policies and progr...
AI summary The document discusses the cost-effectiveness of energy efficiency policies in reducing GHG emissions and highlights the benefits of stricter MEPS regulations. It argues that despite higher initial costs, compliance with these standards will lead to long-term energy savings and monetary benefits for consumers.
the Amendment is estimated to be $1.15 billion and $335 million, respectively. On an annualized average basis, this equates to benefits and costs of $116 million and $34 million, respectively. The quantified benefits have been calculated a...
AI summary The Amendment is estimated to have benefits of $1.15 billion and costs of $335 million over its service life, with annualized benefits and costs of $116 million and $34 million, respectively. Benefits include energy savings and GHG emission reductions, while costs include technology, administrative, and regulatory implementation expenses. The Amendment is considered an 'IN' under the 'One-for-One' Rule and impacts seven small Canadian manufacturers, most of whom already comply with the requirements.
ducts will be required to learn about the requirements of the Regulations and submit information before shipping or importing energyusing products in accordance with subsection 5(1) of the Act. The Amendment is considered an “IN” under th...
AI summary The amendment to the regulations increases administrative burden for manufacturers by approximately $55,508 annually. It requires them to familiarize themselves with new reporting requirements and submit import reports. The estimate is based on 697 stakeholders identified under specific Harmonized System codes.
importers would be affected by this incremental activity, which would occur 2 082 times per year. It is assumed that clerical staff with a wage rate of approximately $30 would undertake this task. To estimate the time required per event, N...
AI summary The text discusses the administrative burden introduced by an amendment requiring the submission of energy performance reports for imported products. It estimates the time and cost associated with this task based on data from the U.S. Department of Energy and assumes a wage rate for clerical staff involved in the process.
g product is imported or shipped across provinces. The added burden applies to products that have reporting elements that differ from reporting requirements already in place in other jurisdictions. The data used to calculate incremental ad...
AI summary The text discusses the administrative burden on manufacturers of residential portable air conditioners due to new reporting requirements. The burden arises from differences in reporting requirements between jurisdictions, with data collection relying on various sources. Around 30 manufacturers are affected, and the time and cost of compliance are estimated. Stakeholders generally support alignment with U.S. regulations, except for portable air conditioners.
across these product categories, which includes the alignment of reporting requirements. The calculations take into account that there is an administrative burden for portable airconditioners. Small business lens The small business lens a...
AI summary The regulatory proposal impacts small businesses and increases administrative burden, with an annualized cost of $61,577 for small importers and $7,779 for small manufacturers. The proposal includes minimal reporting requirements and most small manufacturers already produce compliant products.
rization 24 to produce the demand savings attributable to the demand reduction portion of Custom. 25 That analysis is provided in Attachment 1 to this IR response. 26 27 Date Filed: March 29, 2019 E1 (NS Power) IR-40 Page 3 of 4 Efficiency...
AI summary EfficiencyOne considers affordability at the DSM Plan investment level, using cost-effective programs and providing Total Resource Cost screening tests for demand reduction measures. The analysis assumes 25% of Custom Retrofit investment is repurposed for demand-related projects and 50% first-year demand unit cost for demand-focused projects.
E-9NSPI Evidence
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M08604, EfficiencyOne Application for Approval of the 2019 DSM Resource Plan and Supply Agreement, NSPI Reply Evidence, June 20, 2018. 1 customers pay through electricity rates, which are among the highest in the country. 2 Additional rate...
AI summary The document discusses the affordability of DSM spending in 2020, noting that customers already pay high electricity rates. It highlights that NS Power has access to cheaper market-based energy and that load growth is being curbed by DER and non-regulated DSM. The focus is on determining the best level of DSM spending for customers during the 2020-2022 period.
DSM funding from $27 to $34 million. NS Power considers this range to be a more reasonable level of funding, given the other components and associated costs of Nova Scotia's clean energy transformation. The Company's goal is to arrive at a...
AI summary NS Power proposes increasing DSM funding from $27 to $34 million, arguing this range is more reasonable given the costs of Nova Scotia's clean energy transformation. They aim to balance affordability and long-term benefits, while expressing concerns about E1's proposed budget being too high and not meeting affordability requirements.
Affordability / Proportionality Affordability of electricity service continues to be of paramount concern to NS Power customers. E1 is seeking a first-year increase over its 2019 plan of approximately 23 percent with its Preferred Plan (an...
AI summary NS Power customers are concerned about the affordability of electricity service. E1 is proposing a 23% increase in its first-year plan, which is significantly higher than the 0.8% annual increase in residential rates since 2014. Customers expect NS Power, as a regulated utility, to manage costs and provide stable, affordable rates. NS Power has successfully reduced costs since 2014 despite inflationary pressures.
Appendix A, Evidence of Richard Levitan, page 74, lines 4-6 and 14-15. 1 Historic under-spending 2 3 Historically, E1 has been capable of delivering higher energy savings at lower than 4 forecast spending levels, while still meeting or exc...
AI summary E1 has historically underspent its budget while meeting energy and capacity savings goals. NS Power believes that current system requirements are well met and that sufficient DSM measures can be funded within the existing 2019 funding envelope, without the need for additional capacity additions.
https://www.novascotia.ca/finance/statistics/archive_news.asp?id=14410&dg=&df=&dto=0&dti=3. Figure 2: Nova Scotia Household Spending Growth (2017) Nova Scotians have to reduce spending because economic growth has averaged below 1 percent o...
AI summary Nova Scotians face economic challenges, including low income and slow economic growth, which have led to the need for reduced spending. The province has the lowest income in Canada, tied with New Brunswick, and figures illustrate the disparity in average household incomes across Canada.
EfficiencyOne 2017 Progress and Evaluation Report, page 17, line 13. 1 6.0 DSM NEGOTIATION 17 status quo. In NS Power's view, in order to fully assess the affordability of E1's 18 proposed DSM budget, E1 should have provided, at a minimum,...
AI summary NS Power argues that EfficiencyOne (E1) should have provided high, medium, and low DSM plan scenarios relative to its current budget to assess the affordability of E1's proposed DSM budget. E1 responded by providing results from the scenarios requested by NS Power, but NS Power requests further vetting or a second alternate plan in the $27 to $34 million range.
DATE FILED: April 12, 2019 Page 33 of 37 1 1. Annual fuel costs reduced by avoided fuel cost of DSM programs should be 7 awarded the first DSM franchise in 2015. While NS Power continues to support E1 in its 8 overall mandate of cost savin...
AI summary The text discusses the disagreement between Nova Scotia Power and E1 regarding the appropriate level of spending for the 2020-2022 DSM Supply Agreement. E1 proposes a 23% budget increase from the 2019 DSM Plan, but Nova Scotia Power opposes this due to concerns about short-term rate impacts on customers. The UARB is required to consider these impacts under section 79L(9) of the Act.
Q. Does Nova Scotia differ from the states represented in Mr. Reed's chosen group of program administrators in other important ways? A. Yes. When it comes to average income, the states Mr. Reed chose are enjoying a more robust economy than...
AI summary Nova Scotia differs from the states in Mr. Reed's peer group in terms of average income, with Nova Scotians having significantly lower average incomes. This raises concerns about the affordability and fairness of implementing more aggressive DSM programs in Nova Scotia, where the financial burden may be greater due to lower incomes.
5 Q. Should Nova Scotia pursue implementation of high-cost measures to achieve higher 6 levels of energy savings? 2 A. No. Nova Scotia has achieved satisfactory levels of energy savings and should forego implementation of high cost measure...
AI summary Nova Scotia should not implement high-cost energy-saving measures due to affordability concerns, existing satisfactory savings, and NS Power's capacity constraints. The province can use its energy surplus until 2022 to meet demand and delay costly measures until they are more cost-effective, avoiding trade-offs seen in other regions.
4 Q. What does this mean in terms of customer benefits and avoided cost? 1 2 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. EfficiencyOne says that it considers the determination of affordability to be a balancing of short- and long...
AI summary EfficiencyOne argues that its Preferred Plan provides significant long-term savings for Nova Scotians, but the response cautions that short-term affordability concerns and intergenerational equity issues should be considered. The response suggests that the most expensive energy efficiency measures may need to be postponed to balance immediate customer impacts with long-term benefits.
Q. Mr. Levitan, does EfficiencyOne state that its Preferred Plan is affordable? 23 A. Yes, in its evidence EfficiencyOne states that the "Preferred Plan is affordable based 24 upon the guidance provided by this Board. The Preferred Plan st...
AI summary EfficiencyOne asserts its Preferred Plan is affordable based on the Board's guidance, balancing short and long-term affordability considerations. The response references specific evidence from EfficiencyOne's submission.
Q. Are you familiar with the previous Board guidance on affordability that EfficiencyOne is referring to? A. Yes. In its decision approving the 2016-2018 DSM Plan, the Board stated: The Board finds that the inclusion of Section 79L (9) of...
AI summary The Board's 2016-2018 DSM Plan decision emphasizes balancing short-term affordability with long-term cost savings, referencing Section 79L of the PUA. The Board stresses that exclusive focus on short-term rates could harm customers by neglecting long-term benefits.
Q. Can you describe the average long-term rate increases associated with EfficiencyOne's proposed DSM activities? A. Yes. From 2020 to 2035, the average annual impact will be 0.8% for residential customers, 1.1% for small general customers...
AI summary EfficiencyOne's proposed DSM activities from 2020 to 2035 are expected to result in average annual rate increases ranging from 0.8% to 1.7% across different customer classes. However, concerns are raised about the uncertainty of benefits from peak demand reduction programs and whether these justify the costs, particularly given the lack of results from previous DSM pilots and uncertain capacity avoidance capabilities.
Q. Do you agree with EfficiencyOne's explanation? A. No, I disagree. EfficiencyOne appears to believe that cost-effectiveness and affordability are synonymous. In my view, EfficiencyOne has incorrectly interpreted the high Total Resource C...
AI summary The respondent disagrees with EfficiencyOne's conflation of cost-effectiveness and affordability. The Total Resource Cost (TRC) test measures cost-effectiveness, not affordability, which considers upfront costs relative to income. The Board's definition of affordability balances short-term and long-term factors, and the respondent argues demand reduction measures' high upfront costs fail this standard.
Q. Why do you think the proposed demand reduction measures are not affordable? A. EfficiencyOne proposes to invest $3.3 million per year in the peak demand reduction program and assumes these measures will reduce peak demand by 20.7 MW ove...
AI summary EfficiencyOne's proposed demand reduction measures are questioned for their affordability due to reliance on uncertain 2019 pilot results, simplified projections, and assumptions about participation and TOU tariff adoption. The effectiveness depends heavily on TOU rate parameters, which may not provide sufficient incentive for behavior change.
Q. Mr. Levitan, what are your key findings and observations? - A. I have eight key findings and observations. - First, EfficiencyOne's Preferred Plan does not meet the Board's definition of affordability as the certain and significant near...
AI summary Mr. Levitan outlines eight key findings: EfficiencyOne's Preferred Plan lacks affordability, the Alternate scenario is suboptimal, lifetime energy savings are uncertain, less costly DSM plans are feasible, organic efficiency measures exist, jurisdictional analysis is flawed, ProCESS modeling is subjective, and inflated fuel costs skew cost-effectiveness. These critiques focus on DSM plan evaluation, cost-benefit analysis, and modeling methodologies.