Topic:"Affordability" in M12780

2 1.1 APPROVAL OF 2027–2031 DSM RESOURCE PLAN - 3 EfficiencyOne ("E1") requests approval by the Nova Scotia Energy Board (the "Energy Board" or "NSEB") - 4 of its Demand Side Management ("DSM") Resource Plan ("DSM Plan") for the term 2027...

AI summary EfficiencyOne (E1) seeks approval from the Nova Scotia Energy Board (NSEB) for its 2027–2031 Demand-Side Management (DSM) Resource Plan, aiming to reduce electricity costs for customers. The plan aligns with NSEB's 2025 decision on DSM's statutory purpose, emphasizing affordability, energy savings, and climate goals through programs and cost-benefit analysis.

be included where justified. As the NSUARB held in 2020 NSUARB 56 (M08888), "cost-effective" DSM is that which is "affordable" and results in the "lowest long-term cost of electricity."[8](#page-15-0) Given the affordability concerns raise...

AI summary The text discusses compliance with statutory requirements for Demand-Side Management (DSM), referencing the NSUARB's 2020 decision (M08888) defining 'cost-effective' DSM as affordable and achieving the lowest long-term electricity costs. The Preferred Plan limits investment to 2026 levels without annual inflation increases, balancing affordability and long-term benefits. E1's approach aligns with the NSEB's direction and ERBA section 6(2) requirements.

2.1.4 PROVINCIAL CLIMATE CHANGE POLICY The statutory considerations outlined in ERBA's section 6(2), as well as the goals of DSM as set out in section 79A of PUA, establish the primary mandate for DSM. While the Province's climate and ener...

AI summary Nova Scotia's Provincial Climate Change Policy emphasizes demand-side management (DSM) under the Public Utilities Act (PUA) to reduce electricity costs while aligning with climate goals. The Clean Power Plan outlines transitioning to renewable energy, grid modernization, and affordability, guided by legislative acts like the Environmental Goals and Climate Change Reduction Act. The Nova Scotia Energy Board (NSEB) balances regulatory mandates with environmental objectives.

2.3.1 THE 2022 INTEGRATED RESOURCE PLAN - The Standardized Filing Framework directs that the Resource Plan identified in NS Power's Integrated - Resource Plan ("IRP") will serve to inform the development of a Preferred DSM Plan by E1. The...

AI summary NS Power's 2022 Evergreen IRP includes 683.1 GWh energy savings and 123.9 MW demand savings through 2031. E1 must balance long-term DSM benefits with short-term affordability, guided by the 2016 Consensus Agreement and referenced decisions (M07543, M10473, M12249).

3 3.1 AFFORDABILITY - THE PRIMARY DESIGN CONSIDERATION 4 Consistent with the PUA and the NSEB's regulatory framework, affordability is the primary consideration 5 in the design of the 2027–2031 DSM Plan. The NSEB confirmed in its 2025 BCA...

AI summary Affordability is the primary focus for the 2027–2031 DSM Plan, with E1 maintaining $63.75M annual investment (total $318.75M) to avoid inflationary increases. This prioritizes short-term cost stability over long-term savings, reflecting economic pressures and DSMAG feedback. Customer incentives now account for 71% of costs, emphasizing direct rebates.

3.2 ENERGY EFFICIENCY: SETTING APPROPRIATE LEVEL OF ENERGY SAVINGS E1 established energy savings levels by balancing IRP guidance, cost‑effectiveness, delivery capacity, and affordability. The Preferred Plan reflects a continuation and evo...

AI summary E1 set energy savings at 0.8% of NS Power's load, balancing affordability, cost-effectiveness, and sector allocation. This aligns with APEX's jurisdictional scan and the 2023-2026 DSM Plan. The Preferred Plan allocates 29%/71% to residential/BNI sectors, with 11% of residential savings directed to low-income programs, consistent with prior targets.

Deferred Matters, Consensus Agreement, Appendix 1: Standardized Filing Framework, July 22, 2016. identified in NS Power's 2022 IRP Evergreen established an objective DSM target which is considered to provide the greatest benefits to Nova S...

AI summary The document discusses NS Power's 2022 IRP Evergreen setting DSM energy savings targets (683.1 GWh, 123.9 MW demand savings) for 2027–2031. E1 supports these targets as stakeholder-aligned and cost-effective, but adjusted scenarios to address DSMAG concerns about short-term affordability. E1's preferred plan prioritizes affordability while maintaining energy efficiency as a lower-cost option than supply-side alternatives.

1 4. AFFORDABILITY 2 Affordability continues to be a critical factor in determining the level of investment in a DSM Plan. E1 has 3 heard from several members of the DSMAG over the past several DSM Plans that consideration of short-4 term...

AI summary Affordability remains a key consideration in DSM Plan investments. E1 maintains annual investment at the 2026 level of $63.75 million without inflationary increases, balancing short-term affordability concerns (e.g., rising housing/energy costs) against NS Power's IRP-driven long-term economic benefits for ratepayers.

9 5.4 NON-ELECTRIC AND NON-ENERGY BENEFITS - Non-electric and non-energy benefits—such as improved comfort, health and safety, housing quality, - productivity, and market awareness—are realized as ancillary outcomes of cost-effective DSM -...

AI summary The section discusses non-electric and non-energy benefits from DSM programs, highlighting their role in improving living conditions and operational reliability, particularly in residential, low-income, and business sectors. The Plan emphasizes affordability and cost-effectiveness, ensuring these benefits support, but do not override, long-term system value and ratepayer savings.

5 9.1 OVERVIEW - Pursuant to the NSUARB directive,[27](#page-73-4) 6 E1 is required to file one or more alternate scenarios (the "Alternate - 7 Scenario") in addition to its Preferred Plan filing. In the stakeholder engagement process prec...

AI summary E1 is required by the NSUARB to file an Alternate Scenario as part of its Preferred Plan, incorporating energy efficiency, demand response, solar-PV, and strategic electrification. Stakeholders emphasized addressing short-term affordability impacts, prompting E1 to provide a fully costed DSM scenario.

2 The 2027–2031 DSM Resource Plan sets out E1's Preferred Plan for the delivery of demand-side - 3 management (DSM) programs and services over the five-year Plan period (herein referred to as the - 4 "2027–2031 DSM Preferred Plan" or "Pref...

AI summary The 2027–2031 DSM Preferred Plan focuses on maintaining affordability and delivering cost-effective demand-side management programs, including energy efficiency and solar-PV support for Mi'kmaw communities, without increasing annual investment levels.

1.1 OBJECTIVES OF THE 2027–2031 DSM PREFERRED PLAN - E1's objectives for the 2027–2031 DSM Preferred Plan include: - 1. deliver cost-effective demand side resources that support the successful implementation of a long-term electricity stra...

AI summary E1's 2027–2031 DSM Preferred Plan aims to deliver cost-effective demand-side resources aligned with ratepayer interests, ensure equitable access to services, and foster transparent stakeholder collaboration in resource planning.

3.2 PORTFOLIO DESIGN CONSIDERATIONS AND ASSUMPTIONS - E1 was guided by the following key considerations in developing the Preferred Plan: - cost-effectiveness; - determining appropriate energy and demand savings established using a percent...

AI summary E1's Preferred Plan prioritizes cost-effectiveness, achievable energy savings via a percent-of-load approach, support for Mi'kmaw communities post-2027, and balanced portfolio principles. Emphasis is on affordability, performance targets, and long-term ratepayer benefits through appropriate investment levels.

3.2.1 RESOURCE SCENARIO DESIGN In developing the Plan's design approach, E1 considered feedback from the DSMAG indicating limited support for the three design objectives historically used to guide recent DSM Plans: a 50/50 investment DATE...

AI summary E1 revised its DSM Plan design approach based on feedback from the DSMAG, maintaining the annual investment level, adjusting energy savings targets and allocations, and ensuring support for low-income and equity communities. The plan aligns with recommendations from APEX and includes a residential/BNI energy savings split of 29/71, with dedicated low-income savings of 11% of residential savings.

11 Table 19: Existing Residential - Overview, Objectives, Opportunity Existing Residential Barriers • Affordability: lack of financial resources to cover upfront costs (energy assessments, product/equipment, installation). Cost difference...

AI summary The table outlines barriers to participation in residential energy efficiency programs, focusing on affordability and awareness. Affordability issues include the lack of financial resources to cover upfront costs, while awareness issues involve a lack of information about energy-efficient technologies and their benefits.

11 Table 40: Direct Installation – Overview, Objectives, Opportunity Direct Installation Overview • Provides small businesses with access to financial incentives and technical assistance for the installation of energy efficient equipment u...

AI summary The Direct Installation program provides small businesses with financial incentives and technical assistance for energy efficiency upgrades. It aims to help them identify savings opportunities, overcome financial barriers, and improve profitability. The program has evolved over time, expanding from localized initiatives to province-wide offerings, and includes components like Business Energy Solutions and Rental Properties and Condos Common Area services.

1 Table 49: Overview, Objectives, Opportunity Solar-PV Overview • Post-installation incentives are provided for solar-PV systems installed on new homes in Mi'kmaw communities. • The program consists of one component: Residential Solar-PV....

AI summary This table outlines the Solar-PV program, which aims to increase the adoption of solar-PV systems in Mi'kmaw communities by reducing upfront costs and building awareness. The program targets residential new home construction projects, addressing barriers such as affordability, awareness, and uncertainty about solar-PV technology and payback periods.

14. CONCLUSION The 2027–2031 DSM Preferred Plan delivers cost-effective DSM resources in accordance with the requirements of the PUA , which directs that DSM be undertaken in the best interests of NS Power customers. With a portfolio level...

AI summary The 2027–2031 DSM Preferred Plan meets cost-effectiveness thresholds under the PUA, delivering $682.5M in ratepayer benefits with a 2.4 PAC result. It prioritizes affordability, avoids growth, and integrates solar-PV for Mi'kmaw communities while maintaining investment levels from the 2026 DSM Extension. The plan balances short-term affordability with long-term system benefits.

trates how past DSM investments continue to influence customer rates and bills today and into the future. This analysis extends to 2041 when the modelled impacts of energy efficiency measures expire. 1 Two DSM plans have been modelled with...

AI summary The Rate and Bill Impact Analysis (RBIA) evaluates E1's 2027–2031 Demand Side Management (DSM) plans, comparing scenarios with and without DSM. It isolates DSM effects on rates and bills, focusing on non-participant impacts and affordability. The analysis extends to 2041, examining long-term trends and cost-effectiveness of DSM investments.

iency Nova Scotia? - 1. Very confident - 2. Somewhat confident - 3. Not very confident - 4. Not at all confident - 98. I am unsure - 99. I prefer not to say - I4. [SINGLE RESPONSE] Which one of the following best represents the impact of t...

AI summary The text presents survey questions assessing the impact of Efficiency Nova Scotia's financial incentives on building projects, focusing on budget adherence, financial justification, and likelihood of hiring energy modeling consultants. Respondents are asked about confidence levels and the influence of incentives on project decisions.

3.4.1 Enrollment and Participation Challenges Among Non-participants

AI summary This section addresses challenges related to enrollment and participation in energy efficiency programs among non-participants, focusing on barriers to involvement and potential strategies for improvement.

Participant Eligibility Criteria Eligibility criteria for participation in residential DR programs are similar across jurisdictions and device types. The standard requirements include: - > Being a customer of the utility and the account ho...

AI summary Residential DR program eligibility requires utility account ownership, eligible devices, and internet access. Tenants are eligible if they meet criteria. Rebates and incentives vary, with changes planned for 2026. Jurisdictions differ on variable pricing plan enrollment, with some automatically assigning variable rates to DR participants.

3.7.3 Lessons Learned and Future Opportunities

AI summary This section outlines lessons learned from past initiatives and identifies future opportunities for energy efficiency and demand-side management programs in Nova Scotia, referencing programs like DSM, ARet, and CGH Grant, and considering factors such as affordability and technology adoption.

C. Perceived Potential Benefits - C1. What do you see as the potential benefits of taking part in the program? Select all that apply. [MULTIPLE RESPONSE. RANDOMIZED 1-6] - 1. Receiving financial incentives for enrolling in the Eco Shift Pr...

AI summary The section outlines perceived benefits of the Eco Shift Program, including financial incentives, reduced peak demand, sustainability support, and grid reliability. It also asks for additional information needed to reconsider enrollment.

in-nova-scotia/) concluded that as of early December 2023, an estimated 43 percent of households in Nova Scotia were experiencing energy poverty (defined as paying 6 percent of income on home energy).

AI summary The Canadian Energy Regulator (CER) found that 43% of Nova Scotia households faced energy poverty (defined as spending 6% of income on home energy) as of early December 2023, highlighting affordability challenges in the province's energy sector.

ible to review data such as median and average wages, home counts, ownership percentage, age of households, electric and non-electric sources of heating, and other variables related to energy poverty. - The dashboard can calculate how ener...

AI summary The dashboard integrates multiple datasets (household income, energy consumption, home assessments, and property data) to analyze energy poverty across Nova Scotia. It tracks energy poverty rates based on energy costs, wage changes, and efficiency upgrades, using machine learning and statistical analytics for granular insights.

Request IR-01: Reference: 2027-2031 DSM Plan Application, Exhibit E-1, Evidence ("Evidence"), p. 1. "The Preferred Plan is one which will provide the benefits of DSM at an affordable cost, appropriate to the economic challenges being faced...

AI summary The response to Request IR-01 discusses the Preferred Plan for the 2027-2031 DSM Plan, emphasizing affordability and ratepayer value. It acknowledges that increased DSM spending can lower bills for participants but raises concerns about non-participants facing higher rates. The response refers to EfficiencyOne's (E1) earlier response to NSEB IR-03 (a).

RP scenario. The proposed energy savings of 435.4 GWh represents 64 percent of the IRP target. This approach is not inconsistent with IRP direction. The IRP identifies optimal levels of DSM over a long-term planning horizon (i.e. 25 years)...

AI summary The proposed energy savings of 435.4 GWh (64% of the IRP target) aligns with IRP direction by maintaining long-term savings trajectory while prioritizing short-term affordability (2027–2031). The response directs to prior filings for specific DSMAG feedback, IRP alignment rationale, and future savings gap expectations.

DATE FILED: May 28, 2026 E1 (CA) IR-04 Page 3 of 3 1 Request IR-05: 2 3 Reference: Evidence, page 38. 4 5 "E1 has heard from several members of the DSMAG over the past several DSM Plans that 6 consideration of short-term affordability via...

AI summary The document contains two information requests related to affordability and cost-effectiveness of demand-side management programs. Request IR-05 asks about DSMAG members' views on short-term versus long-term affordability, while IR-06 inquires about evidence provided by IESO regarding the cost-effectiveness of E1's demand response program. Responses refer to prior filings and clarify that IESO did not provide specific evidence for E1's program.

savings while remaining consistent with the current economic conditions facing Nova Scotia ratepayers. E1 does agree that the IRP identifies a higher level of DSM investment as optimal for ratepayers over the long term; however, in develop...

AI summary E1 acknowledges the IRP's long-term DSM investment benefits but adjusted the 2026 plan to balance affordability pressures. The $63.75M annual investment aims to maximize GWh savings while maintaining manageable bill impacts for ratepayers in Nova Scotia's current economic climate.

vel that is reasonable and manageable for ratepayers in the unique economic landscape. (b) Please refer to E1's response to Synapse IR-10 part (e). DATE FILED: May 28, 2026 E1 (CA) IR-07 Page 2 of 2 Request IR-08: Reference: Evidence, p. 3...

AI summary E1 asserts that short-term affordability (5-year period) should prioritize ratepayer impacts over long-term benefits, maintaining $63.75M annual DSM investment without inflationary increases. It acknowledges affordability's ongoing relevance but emphasizes current economic challenges like rising housing, food, and energy costs.

part of the "unique economic landscape" are not, in fact, unique only to the present time, and have been relevant factors in the past, and may remain relevant factors in the future? Response IR-08: (a) EfficiencyOne (E1) characterizes the...

AI summary EfficiencyOne (E1) explains that the 2027-2031 DSM Plan is termed 'short-term' due to its five-year cycle, contrasting with NS Power's longer-term IRP. E1 emphasizes affordability as a critical, evolving consideration in DSM planning, balancing immediate and long-term impacts on ratepayers.

e decreased spending (on average per year) in the 2027–2031 Preferred Plan – an average decrease of $2.1 million per year in the General rate class, and $0.6 million in the Small General rate class. Request IR-02: Reference: Exhibit E-1, A...

AI summary The document discusses a decrease in spending in the 2027–2031 Preferred Plan and addresses affordability considerations in the design of the DSM Plan. E1 explains its affordability framework and references its response to another inquiry for details.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL 1 Request IR-01: 14 (a) Please explain specifically why E1 believes that its proposed annual $63.75M investment 15 is "affordable" for ratepayers. 16 17...

AI summary E1 is responding to the Nova Scotia Energy Board's request regarding the affordability of its proposed annual investment and the impact of the DSM Rider on residential customers. The 2027–2031 DSM Plan was designed with affordability as a primary consideration.

lion for the 2026 one-year extension. The investment of 12 $63.75 million for the 2026 DSM Extension represented a modest increase of 2 percent for 13 inflation from the 2025 approved investment. 14 E1 understands that affordability balanc...

AI summary E1 has maintained the 2026 DSM Extension investment at $63.75 million, with no annual inflationary increases, due to current affordability pressures. This decision reflects a balance between short-term and long-term considerations, acknowledging economic challenges such as rising unemployment, interest rates, and oil prices.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL 1 concluded that maintaining current investment levels - rather than seeking growth - was 2 the appropriate and responsible approach at this time. 3 4 E1...

AI summary E1's 2027–2031 DSM Plan prioritizes customer incentives and long-term affordability, with a focus on maintaining current investment levels rather than pursuing growth. The plan emphasizes customer benefits, including long-term savings and a five-year payback period, while capping spending at previously approved levels. E1 acknowledges that this approach may result in lower long-term energy savings compared to the Integrated Resource Plan.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL 1 affordability is the appropriate course at this time. E1 wishes to be clear that this 2 constrained investment level is a response to specific and extr...

AI summary E1 acknowledges constrained DSM investment due to economic conditions but reaffirms long-term commitment to Base-level DSM (1.2% load savings) aligned with the IRP. They provide an estimated PCR for the 2027–2031 DSM Plan, noting it is subject to change upon NS Power's DCRR filing.

1 within these definitions. The increase in customer incentives from 66 percent to 71 percent 2 of total plan costs does not change the nature of the activities funded; rather, it reflects a 3 deliberate choice to direct a greater share of...

AI summary The Preferred Plan focuses on reducing electricity costs for customers by maintaining a fixed DSM budget, increasing customer incentives, and ensuring long-term value through avoided utility costs. The plan aligns with short-term affordability goals and limits rate pressure on NS Power customers.

3. Conclusion After analyzing comparable jurisdictions in North America, as well as E1's historical achievements, market demand, and organizational capability, Apex recommends a net savings target of 0.8%-1.0% of sales for the 2027-2031 Pl...

AI summary Apex recommends a net savings target of 0.8%-1.0% of sales for the 2027-2031 Plan, considering increased costs and affordability. The split between residential and BNI savings is recommended as up to 30%/70%, based on lower BNI acquisition costs. The target balances energy efficiency and affordability needs.

1 M09096, Document No. 84486, DSMAG Revised Terms of Reference, September 20, 2021, page 7 1 Request IR-16: 2 proceeding."1 3 4 The current version of the DSMAG Terms of Reference was filed with the Nova Scotia 5 Utility and Review Board o...

AI summary The document discusses a request (IR-16) related to the DSMAG Revised Terms of Reference and includes a request (IR-17) regarding affordability in the Application, specifically asking for detailed breakdowns of expenditures, salaries, FTEs, and program support for the 2027-2031 DSM Plan and 2026 DSM Extension.

18 Email Communication from EfficiencyOne Program Management Staff – May 25, 2016 Program Identified Barriers Incentive Strategy 1) Residential customers worry about upfront costs. For example, LED penetration, despite dropping upfront cos...

AI summary The email communication discusses the barriers faced by residential customers in adopting energy-efficient appliances, such as upfront costs and complexity of incentive applications, and outlines strategies like point-of-sale incentives and instant discounts to address these barriers.

Understand Customer Motivation and Barriers for Participation Currently, EfficiencyOne uses four different methods to understand customer motivation and barriers to participation: 1. Market research to assess customer awareness of programs...

AI summary EfficiencyOne uses four methods to understand customer motivation and barriers to participation in energy efficiency programs, including market research, annual surveys, active program management, and specialized research. The recommendation includes continuing these activities and introducing an annual survey on key technology portfolios to track participation trends and affordability concerns due to rising electricity prices.

r>sig n h ig he su cc es err ca w se cu re a p os n. inc tiv ts for "h ard -to -hi re" les to fer ral s f en e a mo un ro en co ura ge re or the itic al ies ( E 1 m be ch all d t o i lem t th is se cr va ca nc ay en ge mp en nd ati du e t...

AI summary The text discusses the importance of addressing challenges in hiring for critical roles, the need for incentives to attract talent, and the necessity of ensuring that the Public Service Commission (PSC) and Finance Committee (FC) are adequately resourced. It also highlights the need for further discussion on potential solutions and opportunities for improvement.

- 16 ii) Please refer to part (b) of this IR response. 1 Request IR-24: 16 design decision to prioritize near-term affordability for Nova Scotia ratepayers while 17 continuing to deliver long-term value. The $63.75 million annual investmen...

AI summary The document discusses a design decision to prioritize near-term affordability for Nova Scotia ratepayers while continuing to deliver long-term value. A $63.75 million annual investment is allocated to energy efficiency, demand response, and solar-PV. The downward trend in energy savings and peak demand savings is attributed to changes in investment allocation, including a front-loaded energy efficiency investment and a shift to accommodate the planned ramp-up in demand response.

1 feedback and E1's affordability focused design approach reflecting current economic 2 circumstances facing NS Power ratepayers. 4 ii) E1 prioritized short term affordability for the Preferred Plan by maintaining the 5 annual investment o...

AI summary The document discusses E1's approach to designing the 2027–2031 DSM Preferred Plan with a focus on short-term affordability and maintaining an annual investment of $63.75 million. It emphasizes deliverability and cost effectiveness, highlighting a cost effectiveness result of 2.4 for the proposed plan.

Request IR-01: Refer to M12780, Exhibit E-1, Efficiency One (E1)'s application for approval of its 2027–2031 Demand Side Management (DSM) Resource Plan, dated March 31, 2026, (the "DSM Plan") Section 1.1 Approval of the 2027-2031 DSM Resou...

AI summary EfficiencyOne (E1) argues that affordability of its DSM Plan should consider lifetime unit costs ($0.05/kWh) rather than first-year costs ($0.66/kWh), emphasizing deeper measures like building upgrades. The Plan maintains a $63.75M annual budget (71% to customer incentives) without inflationary increases, prioritizing near-term affordability and long-term value. References to NSEB IR-03 and IG IR-10 are made for further analysis.

Additional affordability considerations are addressed in E1's response to NSEB IR-03. (b) Please refer to Attachment 1 of E1's response to IG IR-10 for a detailed analysis of first year unit costs. (c) E1 has long supported a mix of low-co...

AI summary E1 outlines affordability strategies, emphasizing a mix of low-cost and high-impact energy efficiency measures. It highlights efforts to expand deeper savings initiatives post-2029 lighting baseline changes and offers energy audits with third-party support for small businesses. The response addresses NSEB's IR-03 and IG IR-10 requests.

DATE FILED: May 28, 2026 E1 (SNS) IR-12 Page 5 of 5 1 Request IR-13: IRP Benchmark, Preferred Plan, and Affordability Trade-off 2 3 Reference: 2027-2031 DSM Plan; Preferred Plan; IRP-aligned savings scenario. 4 5 (a) Provide the analysis s...

AI summary The document outlines a request for analysis on the 2027–2031 DSM Plan, focusing on the balance between short-term affordability and long-term ratepayer value. It asks for details on program changes, bill impacts, and strategies to reduce affordability impacts. Responses reference prior submissions and confirm considerations of lower-cost delivery models.

Table 1: STANDARDIZED FILING FRAMEWORK ITEM DESCRIPTION 3.1 Development of the Upcoming Period's DSM Program Targets and Investment A summary of: - the parties involved in developing the proposed DSM Resource Plan; - NS Power's the most re...

AI summary The document outlines the standardized filing framework for the upcoming period's DSM Program Targets and Investment, including the parties involved in developing the proposed DSM Resource Plan, NS Power's most recent Integrated Resource Plan results, affordability considerations, cost-efficiency opportunities, and key global assumptions.

Table 1: STANDARDIZED FILING FRAMEWORK ITEM DESCRIPTION 3. DEVELOPMENT OF THE UPCOMING PERIOD'S DSM RESOURCE PLAN 3.1 Development of the Upcoming Period's DSM Program Targets and Investment A summary of: - the parties involved in developin...

AI summary The text outlines the development of the upcoming period's Demand Side Management (DSM) Resource Plan, including the parties involved, recent Integrated Resource Plan results, affordability, cost-efficiency opportunities, and key assumptions.

please explain why this portfolio does not comply with the direction in the NSEB Decision in Matter 12282 (E1 Application for approval of a New Benefit-Cost Analysis Test for Evaluating DSM Plans). - (b) Does E1's response to (b) reflect E...

AI summary The text raises questions about the compliance of a portfolio with the NSEB Decision in Matter 12282 and the interpretation of this decision by E1. It also asks why investment was constrained to 2026 levels with no annual inflationary increases, and whether alternative approaches were considered.

NSPI has a contractual obligation to pay NSPML, a related party, for the use of the Maritime Link over approximately 38 years from its January 15, 2018, in-service date. On December 23, 2025, NSPML received an Interim Order from the NSEB t...

AI summary NSPI has a long-term contractual obligation to pay NSPML for the use of the Maritime Link. An interim order allows NSPML to collect up to $199 million from NSPI in 2026 for the recovery of costs, with a monthly holdback. NSPI's financial obligations include debt, pension contributions, and operating leases.

PENSION FUNDING For funding purposes, NSPI determines required contributions to its registered defined benefit pension plans based on smoothed asset values. This reduces volatility in the cash funding requirement as the impact of investmen...

AI summary NSPI uses smoothed asset values to determine pension contributions, reducing cash funding volatility. Contributions are tax deductible and funded from operations. Defined benefit plans have a long-term asset allocation strategy managed by external investment managers. Defined contribution plans are projected to require $9 million in 2026.

Guarantees and Letters of Credit As at December 31, 2025, the Company had $94 million USD (2024 - $104 million USD) of guarantees outstanding with terms of varying lengths, all of which are issued on behalf of NSPEMI. As at December 31, 20...

AI summary As of December 31, 2025, the Company had $94 million USD in guarantees and $6 million USD and $8 million CAD in letters of credit outstanding, all issued on behalf of NSPEMI. These figures decreased slightly from the previous year.

Physical Risk: Changes in climate may negatively impact the Company's operations as a result of increased frequency and intensity of weather events and related physical risks, any of which could result in a Material Adverse Effect (for mor...

AI summary Climate change may increase physical risks to the Company's operations through more frequent and intense weather events, potentially leading to a Material Adverse Effect. These risks could also raise insurance costs, affect credit ratings, and impact liquidity and capital markets.

Transition Risk: As government policy related to the environment, renewable energy, and decarbonization continues to shift, the Company is exposed to increased uncertainty and risk arising from policy, legal, regulatory, technology, and ma...

AI summary The Company faces increased transition risks due to evolving environmental policies, renewable energy mandates, and decarbonization efforts. These risks include regulatory uncertainty, capital investment needs, and potential impacts on insurance and litigation. The energy transition may also affect the Company's ability to recover costs through rates and could lead to material adverse effects.

General Economic Risk The Company has exposure to the macro-economic conditions in Nova Scotia. Like most utilities, economic factors such as consumer income, employment and housing affect demand for electricity, and in turn the Company's...

AI summary The Company is exposed to general economic risks in Nova Scotia, including factors like consumer income, employment, and housing, which can affect electricity demand and financial results. Adverse economic conditions and inflation may hinder customers' ability to afford rate increases, leading to potential credit risks, policy shifts, and challenges in recovering costs.

Commercial Relationship Risk The Company is exposed to commercial relationships risk in respect of its reliance on certain key partners, suppliers and customers. For the year ended December 31, 2025, NSPI's five largest customers contribut...

AI summary NSPI faces commercial relationship risk due to its reliance on key partners, suppliers, and customers. In 2025, its five largest customers accounted for 7% of electric revenues, and losing a major customer could significantly impact operating revenues.

Fuel Supply Disruptions: NSPI is also exposed to the risk of fuel supply chain disruptions, both within and outside NSPI's service territory. Fuel supply disruptions which may be caused by damage to, operational issues with, terrorist or c...

AI summary NSPI faces risks from fuel supply chain disruptions, including operational issues, cyberattacks, and natural disasters, which could increase commodity price risk, disrupt operations, and harm its reputation, potentially leading to a Material Adverse Effect.

Commodity Price Risk The Company's fuel supply is subject to commodity price risk. The Company's fuel supply is exposed to broader global market conditions, which may include impacts on delivery reliability and price, despite contracted te...

AI summary The Company's fuel supply is exposed to commodity price risk due to global market conditions, including currency fluctuations, geopolitical risks, and supply disruptions. NSPI aims to hedge 50-100% of fuel costs for 2026 and 50-90% for 2027 to ensure fuel cost stability and manage affordability risks.

Future Employee Benefit Plan Performance and Funding Risk NSPI has both defined benefit and defined contribution employee benefit plans that cover both employees and retirees. The defined benefit plan is closed to new entrants. The cost of...

AI summary NSPI has defined benefit and defined contribution employee benefit plans. The defined benefit plan is closed to new entrants, and its costs depend on investment performance, interest rates, inflation, and actuarial assumptions. Future changes in these factors could lead to larger contributions, potentially causing a Material Adverse Effect.

Labour Risk NSPI's ability to deliver service to its customers depends on attracting, developing and retaining a skilled workforce. Utilities are faced with demographic challenges related to trades, technical staff and engineers with an in...

AI summary NSPI's service reliability depends on maintaining a skilled workforce, but demographic challenges and an aging workforce may hinder this. Approximately 42% of NSPI employees are unionized, with their collective agreement expiring in 2026. Failure to negotiate new agreements could lead to increased costs and service disruptions, potentially impacting customers.

Uninsured Risk NSPI maintains insurance to cover accidental loss suffered to its facilities, and to provide indemnity in the event of liability to third parties. A significant portion of NSPI's transmission and distribution assets are not...

AI summary NSPI insures some of its assets but leaves a significant portion of its transmission and distribution assets uninsured due to high costs. It also has deductibles and self-insured retentions. Uninsured claims or claims exceeding coverage could lead to a Material Adverse Effect if regulatory recovery is not available.

Q4 2025 compared to Q4 2024 Q4 2025 net income decreased by $49 million compared to Q4 2024. The decrease is due to decreased income tax recovery and increased OM&G expenses. Income tax recovery decreased due to the utilization of tax loss...

AI summary Q4 2025 net income decreased by $49 million compared to Q4 2024 due to lower income tax recovery and higher OM&G expenses, driven by increased storm costs and cybersecurity incident-related expenses.

Request IR-35: Please refer to Tables 9, 10, 11, 12, and 13: DSM Preferred Plan Savings and Investment by Program Component for 2027, 2028, 2029, 2030, and 2031 respectively starting on page 29 of Appendix A – Preferred Plan. (a) The Resid...

AI summary The response to IR-35 explains that E1's 2027–2031 DSM Preferred Plan focuses on affordability and cost-effectiveness. The Residential Instant Savings program has high cost-effectiveness and broad accessibility, while the Home Energy Assessment program is seeing increased investment to boost participation after the Canada Greener Homes Grant ended.

1 Request IR-37: 2 3 Page 39 of Appendix A – Preferred Plan states, "The conclusion of the federal government's 4 Canada Greener Homes Grant program in 2025 which provided incentive top ups and 5 subsidized energy audit costs directly impa...

AI summary The response to IR-37 discusses the impact of the Canada Greener Homes Grant program ending in 2024, which led to a significant decline in energy evaluations. E1 proposes increased incentives for the Home Energy Assessment program to boost enrollments and affordability, though at a lower level than the federal program due to cost considerations.

ssage " Error! Reference source not found " at the top of page 22, in the 4th bullet on page 25, and below Figure 8 on page 29. - Refer to Exhibit E-17 errors and missing references. - Response: - These are editorial issues. On p. 22, repl...

AI summary The text addresses editorial errors in a document, including references to Exhibit E-17 and the Peach Report. It raises questions regarding the consideration of recommendation questions, vendor cost comparisons, appliance recycling post-ARet, and the allowance of specific values under legislation and Board orders.

16 Q. WHAT DOES IT MEAN TO HAVE AFFORDABLE ENERGY? 17 A. There are many different definitions of affordability, and there has never been a clear one 18 used as it relates to the E1 DSM Plan. What is clear is that 40% of Nova Scotia homes,...

AI summary Affordable energy is defined in part by the impact on low-income households, many of whom spend over 6% of their after-tax income on energy. The E1 DSM Plan emphasizes the importance of direct-install and affordable housing programs for these customers, while market-rate programs benefit others. A full portfolio of DSM programs helps reduce overall energy bills and offsets DSM delivery costs.

11 Q. EARLIER YOU SAID E1 MEASURED AFFORDABILITY USING THE WRONG 12 METRIC. PLEASE EXPLAIN. 13 A. E1's affordability argument focuses on the near-term rate impacts. Customers pay bills, 14 not rates. Affordability is properly assessed by w...

AI summary E1 argues that affordability should be measured by total customer bills, not just per-kWh rates, as DSM programs can lower overall bills even if they slightly increase rates. The Board supports a long-term perspective, emphasizing that short-term rate impacts should not override long-term cost savings from DSM programs.

19 Q. DO YOU HAVE ANY OTHER CONCERNS WITH E1'S APPROACH TO MINI- 20 SPLIT AND CENTRALLY DUCTED HPS IN THE RESDIENTIAL SECTOR? 21 A. Yes. I am concerned that E1 is increasing incentives unnecessarily in its current plan. E1 22 has not provi...

AI summary The respondent expresses concern over E1's proposed increase in incentives for mini-split and centrally ducted heat pumps in the residential sector, citing a lack of justification and potential affordability issues.

Economic and Policy Analysis Consumer Advocate – Nova Scotia (March 2019 – Present) - Member of DSM Advisory Group (DSMAG) on behalf of the Consumer Advocate of Nova Scotia to provide ongoing support for design and implementation of progra...

AI summary The Consumer Advocate of Nova Scotia has been actively involved in the design and implementation of demand-side management (DSM) programs, including providing analysis and testimony on various DSM Plans and studies. The Advocate has also commented on proposals related to time-varying pricing tariffs and service interruption due to cyberattacks.

Testimony and Proceeding Participation Forum On Behalf Of Docket/Matter Date Issues Addressed Nova Scotia Utility and Review Board The Consumer Advocate of Nova Scotia Matter No. M10473 An Application by EfficiencyOne for Approval of a 202...

AI summary The document outlines various regulatory proceedings involving entities such as the Consumer Advocate of Nova Scotia and the Massachusetts Office of the Attorney General. Key topics include demand side management plans, energy efficiency programs, and cost recovery for wildfire mitigation. These proceedings address issues like affordability, program design, and cost-effectiveness.

_________ Demand-side management (DSM) is an important electricity system resource. Properly designed and delivered, DSM can reduce the amount of electricity and capacity that Nova Scotia must supply, defer or avoid higher-cost system inve...

AI summary The document emphasizes the importance of demand-side management (DSM) in Nova Scotia's electricity system and highlights the unique role of EfficiencyOne (E1) in delivering DSM programs. It raises concerns about the affordability, resource balance, and scope of E1's proposed 2027–2031 DSM Plan, questioning whether it adequately addresses rising rate pressures and the need to shift toward demand response and strategic electrification.

High Level Assessment of E1's Preferred Plan At a high level, E1's proposed 2027–2031 DSM Plan is framed around affordability, near-term ratepayer protection, and continuity of DSM programming. That framing is appropriate. Nova Scotia cust...

AI summary E1's 2027–2031 DSM Plan focuses on affordability, ratepayer protection, and continuity of DSM programming. It maintains a consistent investment level of $63.75 million annually, totaling $318.75 million over five years, with a PAC ratio of 2.4 and estimated lifetime benefits of $682.5 million. However, the plan is urged to undergo stronger scrutiny regarding the allocation of DSM funds and alignment with system needs.

4. 13 Mike Specian and Alex Aquino, Faster and Cheaper: Demand-Side Solutions for Rapid Load Growth , ACEEE, February 2026, p. 33. shifts toward deeper and more complex measures such as building envelope upgrades, heat pumps, and custom co...

AI summary E1 highlights increased costs for its DSM plan due to higher first-year costs for complex measures, reduced savings from residential heat pumps, and inflationary pressures. E1 argues that while some factors are unique to Nova Scotia, the higher cost of delivering energy savings compared to other jurisdictions remains unexplained. The Board is urged to evaluate the plan's affordability at two levels: total portfolio revenue requirement and resource allocation within the budget.

Representation of Demand Response in E1's Preferred Plan E1 presents the Preferred Plan as a deliberate affordability choice. It states that the Plan prioritizes short-term affordability and ratepayer value and focuses on services for whic...

AI summary E1's Preferred Plan prioritizes short-term affordability but is criticized for limiting the expansion of residential demand response (DR) programs, which could increase capacity costs in the future as the system becomes more winter-peaky. The plan relies heavily on BNI customers for DR capacity growth, raising concerns about long-term system reliability.

B. Recommended Path Forward in Demand Response NS Power's annual system peak has been increasing on average by around one percent per year since 2015. As weather conditions fluctuate and a greater share of households use electric space hea...

AI summary NS Power's annual system peak has been increasing by one percent annually since 2015. As electrification of heating and transportation continues, demand response (DR) will become increasingly important in managing peak demand. DR can reduce system peak, defer capacity investments, and enhance reliability and affordability.

Conclusion _________ We reviewed E1's 2027–2031 DSM Plan based on E1's application filing and supporting evidence, responses to information requests, and other evidence submitted in this proceeding. Our review focused on whether E1's Prefe...

AI summary The conclusion reviews E1's 2027–2031 DSM Plan and evaluates its alignment with affordability, system needs, and decarbonization goals, focusing on spending levels and the treatment of DR, SE, and Solar PV measures.

A. E1 indicates that it chose this plan to improve affordability. In its Evidence, E1 states: "Consistent with the PUA and the NSEB's regulatory framework, 1 affordability is the primary consideration in the design of the 2027–2031 DSM 2 P...

AI summary E1's 2027–2031 DSM Plan prioritizes short-term affordability by maintaining a flat annual investment of $63.75 million, resulting in a total of $318.75 million over the plan period. This approach may increase electricity costs for ratepayers over time but aims to lower fuel costs and benefit ratepayers through the fuel adjustment mechanism (FAM).

A. There are five reasons for focusing electrification investments on this subset of customers. First, affordability concerns should not limit DSM investments that benefit those who struggle most with affordability. Low-income customers ar...

AI summary The text outlines five reasons for focusing electrification investments on low-income customers, emphasizing affordability concerns and the potential impact of the war in Iran on oil-heated households. Oil-heated households are noted to spend significantly more on home energy compared to electrically heated ones.

0 percent more on home energy than electrically heated households. [36](#page-26-2) Any solutions that focus on reducing the reliance of customers on oil for home heating will help with affordability. The Oil to Heat Pump Affordability (OH...

AI summary The rationale for focusing electrification investments on low-income oil-heated customers is to improve affordability. The Oil to Heat Pump Affordability (OHPA) program provides grants and one-time payments to help eligible homeowners switch to electric heat pump systems, reducing reliance on oil heating.

Fifth, the Nova Scotia Energy Poverty Task Force's home energy affordability program recommendations call for continuing to expand support for targeted energy efficiency and electrification for low- and moderate-income households as a high...

AI summary The Nova Scotia Energy Poverty Task Force recommends expanding support for energy efficiency and electrification in low- and moderate-income households as a key affordability strategy.

PUBLICATIONS Knight, P., S. Kwok, E. Ashley, A. Glaser Schoff, S. Schadler, S. Sharaf, A. Zeng, A. Napoleon. "Making Energy More Affordable in New York." Presentation prepared for the Natural Resources Defense Council and the Evergreen Col...

AI summary The text lists publications and reports prepared by various authors and organizations, focusing on energy affordability, efficiency programs, and utility practices in different regions. These include reports for the Natural Resources Defense Council, the Office of the People's Counsel, and the New Brunswick Energy and Utilities Board.

TESTIMONY New York Public Utilities Commission (Case Nos. 25-E-0072 and 25-G-0073): Direct and Rebuttal Testimony of Alice Napoleon in the Matter of Consolidated Edison Company of New York, Inc. regarding proposed gas-side investments, par...

AI summary The text outlines direct and rebuttal testimony provided by Alice Napoleon on behalf of the Natural Resources Defense Council and Synapse Energy Economics in various regulatory proceedings across New York and Michigan, focusing on gas-side investments, rate increases, and decarbonization policy.

5.1 Strategic Electrification Should Be a Core DSM Resource Solar Nova Scotia supports strategic electrification as a core component of Nova Scotia's DSM framework. Strategic electrification is no longer merely an adjacent climate-policy o...

AI summary Solar Nova Scotia supports strategic electrification as a core component of Nova Scotia's DSM framework, emphasizing its role in reducing emissions, improving affordability, and supporting system planning. While agreeing that strategic electrification has value, it argues that the DSM Plan should be designed to capture this value in a cost-effective way, including assessing full benefits such as avoided non-electric fuel costs and emissions reductions.

5.4 Energy Manager-Type Support for End-of-Life Replacement Decisions Strategic electrification should also be linked to affordability and asset management. Electric technologies are often more efficient than fossil-fuel systems, but custo...

AI summary Strategic electrification should be linked to affordability and asset management, requiring customer support to understand lifecycle costs and rate options. Energy Manager-type support is critical for DSM delivery, particularly for small business and institutional customers. Flexible electrification can support renewable integration and distributed energy resources if designed intentionally.

- For an energy equipment manufacturer, prepared materials to educate the leadership on large load pricing principles and implementations across the USA. The Brattle team also analyzed the large load tariffs and implications for the develo...

AI summary The text outlines various rate design and impact evaluation studies conducted by Brattle for energy equipment manufacturers, utilities, and other stakeholders. These studies include large load pricing principles, clean transition tariffs, tariff reviews, and analyses of rate designs for residential and non-residential customers. A specific study focuses on the operating cost of electric heat pumps and natural gas-fueled heating equipment under alternative rate designs.

Request IR-3: Reference: Brattle Evidence, Section IV: Representation of Demand Response in E1's Preferred Plan, page 14, footnote 25: "In October 2022, IESO received a ministerial directive that increased the CDM budget by $342 million, f...

AI summary The document discusses the affordability of E1's preferred plan, referencing a ministerial directive in Ontario that expanded the CDM budget and launched the Peak Perks program. It contrasts this with Nova Scotia's statutory framework, where E1 operates under the Public Utilities Act and must meet the Program Administrator Cost (PAC) test. The response confirms that Peak Perks was launched under an Ontario directive and highlights the differences in regulatory and funding contexts.

as water-heater control, EV charging, batteries, and locational DR. The goal should be to convert enrolled customers into dependable, accredited winter capacity before committing to broader expansion. Request IR-8: On page 19 of 39, the Re...

AI summary The response to Request IR-8 by The Brattle Group explains that E1's residential DR program is limited, expensive, and passive. It suggests that residential DR can become a significant resource if developed in a disciplined and affordable manner, focusing on controllable loads like smart thermostats, without immediate affordability challenges.

Request IR-2: Does E1 acknowledge the apparent contradiction between its focus on short-term affordability and the affect the spending levels in its Proposed Plan will have on electricity costs for ratepayers?

AI summary The document asks whether E1 recognizes the contradiction between its focus on short-term affordability and the potential long-term impact of its Proposed Plan on electricity costs for ratepayers.

Response IR-2: Yes, page 40 of E1's evidence states, "DSM, and particularly its energy efficiency programs, is demonstrably lower in price than the fuel option it displaces, making it a logical and affordable first choice investment for ra...

AI summary E1 argues that DSM programs are more cost-effective than fuel options, citing a lower cost per kWh and long-term benefits for ratepayers. The cost of fuel has fluctuated, but DSM has consistently been cheaper, supporting its use as an affordable and logical first choice investment.

Response IR-6: Page 2 of Appendix A – Preferred Plan state that "E1's objectives for the 2027–2031 DSM Preferred Plan include: • deliver cost-effective demand side resources that support the successful implementation of a long-term electri...

AI summary E1's 2027–2031 DSM Preferred Plan emphasizes affordability and equitable access to demand side management services. It highlights the disproportionate energy costs faced by low-income oil-heated households and the potential impact of ongoing geopolitical uncertainty on heating affordability.

In the absence of thresholds, I am concerned that E1 would not be inclined to formally file mid- cycle adjustments when actual performance deviates from the plan in material ways, which has impacts for energy affordability. Additionally, a...

AI summary The concern is that without performance thresholds, E1 may not file mid-cycle adjustments when actual performance deviates from the plan, impacting energy affordability. The lack of defined materiality thresholds also raises transparency concerns, with the suggestion that the Board should define materiality upfront with stakeholder input.

Summary of the DSM Plan NB Power's DSM Plan has many notable features: - It contains energy efficiency, renewable energy, demand response, and electrification offerings. - It addresses a variety of market segments and customer types. In pa...

AI summary NB Power's DSM Plan includes energy efficiency, renewable energy, demand response, and electrification offerings, with notable features such as LMI funding and support for non-electric savings. However, the plan does not aim to meet minimum DSM savings requirements, which are lower than achievable potential and those of other jurisdictions.

Support for LMI customers NB Power funding is relatively stable over time. However, funding from other sources (which LMI programs rely on completely) is variable and uncertain for the 2025/26 and 2026/27 plan years. As a result of a lack...

AI summary NB Power's LMI program funding is unstable, leading to a decline in support and long waitlists. Current funding only covers partial demand-side management measures. The author recommends securing stable funding and involving LMI customers in discussions.

As an alternative to including the strategic electrification from the Round 2 modeling, E1 could develop strategic electrification offerings for low- and moderate-income customers who heat with oil. … I estimate that 17,600 low-income home...

AI summary The text discusses potential strategic electrification offerings for low- and moderate-income oil-heated customers in Nova Scotia, referencing Synapse's recommendations and the need to address affordability and energy poverty. It also raises questions about program structure, funding mechanisms, and statutory requirements for including such initiatives in a DSM Plan.

Request IR-2: Refer to M12780, Exhibit E-23, Synapse Evidence, Page 27 of 47, Lines 11-21, and M12780, Exhibit E-16, E1 (Synapse) RIR 46(b), pages 1-4. In response to Synapse IR-46(b), E1 states that it has not assumed the funding that had...

AI summary The request addresses concerns regarding E1's financial support for non-electrically heated homes, the meaning of 'affordability' in the context of reducing oil reliance, and the cost-effectiveness of E1 filling the funding gap after federal support ends.

Response IR-2: a) When available, other funding sources should be used to provide financial support for strategic electrification of customers that are not primarily heating with electric space heating. In the absence of support from other...

AI summary The response discusses the use of electric ratepayer funds for strategic electrification, emphasizing the preference for other funding sources. It also addresses affordability in terms of individual homeowners' ability to afford energy use and questions the cost-effectiveness of E1's initiative to fill a funding gap after federal support ends.

Professional Focus Energy efficiency and utility planning executive with deep experience leading, facilitating, and supporting multi-year demand-side management (DSM) plans, energy efficiency portfolio strategy, demand response, strategic...

AI summary Michael is an energy efficiency and utility planning executive with extensive experience in developing demand-side management plans, energy efficiency strategies, and regulatory filings. His work includes program design, affordability considerations, and aligning energy efficiency with decarbonization and grid flexibility goals.

Apex Analytics — Principal 2023–Present - Supports utilities and program administrators on energy efficiency and DSM planning, including plan development processes, project timelines, stakeholder engagement structures, drafting templates,...

AI summary Apex Analytics, as a principal, supports utilities and program administrators in energy efficiency and DSM planning, including regulatory filings, stakeholder engagement, and policy development. They have worked on the Mass Save planning process and provide expertise in affordability, cost recovery, and program design.

Regulatory & Testimony Support Commission-facing narratives, discovery, interrogatories, stakeholder comments, cost recovery, affordability, and customer impact analysis.

AI summary The text outlines the scope of regulatory and testimony support activities, including Commission-facing narratives, discovery, interrogatories, stakeholder comments, cost recovery, affordability, and customer impact analysis.

1 costs which would result in lower cost effectiveness results, placing additional pressure on portfolio cost 2 effectiveness and on the affordability objective that frames the Plan. 3 2.1.3 RETAIN HOME ENERGY ASSESSMENT REQUIREMENT FOR

AI summary The text highlights concerns about costs resulting in lower cost effectiveness and added pressure on portfolio costs, affecting affordability goals outlined in the Plan.

Synapse - At page 30, line 14 page 31, line 2, Ms. Napoleon recommends that E1 target electrification to low- and moderate-income customers: - Lastly, a 2024 report titled A Way Forward: A Made-In-Nova Scotia Home Energy Affordability Prog...

AI summary Ms. Napoleon recommends that E1 target electrification efforts towards low- and moderate-income customers with high energy use and arrears, citing a 2024 report. NS Power has data to identify these customers and can refer them to E1 for further action, which would improve affordability and reduce fossil fuel use.

E1 Rebuttal Evidence E1 respectfully disagrees that the dedicated low-income and equity savings target should be fixed at 14.9 percent of the Residential Savings target, being Mr. Love's proposed 3.76 GWh, because approximately 14.9 percen...

AI summary E1 argues against fixing the low-income and equity savings target at 14.9% of the residential savings, citing the lack of achievable data and the potential for increased costs. They highlight that the current plan already exceeds this target and emphasize the importance of realistic, cost-effective planning aligned with affordability goals.

E1 Rebuttal Evidence E1 agrees that incentives should be set no higher than necessary to secure participation, and as such applies the Board approved incentive setting methodology. In preparation for the 2027–2031 Plan, E1 engaged Apex to...

AI summary E1 argues that its current incentive-setting methodology, which aligns with the Board's approved approach, is sufficient and does not require additional measure-specific primary research. E1 highlights the high cost and impracticality of such research, especially given the fixed deadline proposed by Green Energy Economics Group, and notes that its existing incentives are already at or below recommended thresholds.

Q. DO YOU HAVE ANY OTHER CONCERNS WITH E1'S APPROACH TO MINI-SPLIT AND CENTRALLY DUCTED HPS IN THE RESDIENTIAL SECTOR? A. Yes. I am concerned that E1 is increasing incentives unnecessarily in its current plan. E1 has not provided any justi...

AI summary The respondent is concerned about E1's plan to increase incentives for mini-split and centrally ducted heat pumps in the residential sector by 67% to 80% over four years without justification or an updated potential study, especially given affordability concerns and rising unit costs.

E1 Rebuttal Evidence E1 notes at the outset that Brattle does not dispute that the Preferred Plan grows total Demand Response capacity by approximately 80 percent over the plan term, from 16.3 MW in 2026 to 29.3 MW in 2031. The Preferred P...

AI summary E1 argues that the Preferred Plan's focus on BNI Demand Response is prudent due to its strong cost-effectiveness (PAC of 2.4) compared to residential Demand Response (PAC of 0.7). E1 asserts that Brattle's concern about risk is not quantified and that the BNI program's small participant base allows for better management and reliability.

Q. Does Apex believe that the 2027-2031 DSM Plan savings goals are reasonable? A. In our opinion, E1's 2027-2031 goals seem reasonable and appropriate given the mature nature of the programs and the emphasis in this Plan on near-term affor...

AI summary Apex considers E1's 2027-2031 DSM Plan savings goals reasonable, particularly due to their focus on affordability and alignment with similar jurisdictions. The goals are lower than the IRP Base Scenario but consistent with comparable regions. Apex notes that market conditions and costs have changed since the last IRP, and the Consumer Price Index has increased significantly, impacting the economic context.

EfficiencyOne Opening Statement M12780 FILED WITH THE NOVA SCOTIA ENERGY BOARD July 29, 2026 Good morning, Chair, Board Members, and stakeholders, Thank you for the opportunity to be here today as we begin the hearing for EfficiencyOne's p...

AI summary EfficiencyOne's 2027–2031 Demand Side Management Resource Plan aims to help Nova Scotians reduce energy costs, support business growth, and advance a cleaner energy future. The plan emphasizes the economic benefits of DSM, avoiding more expensive investments in generation and infrastructure, while addressing current affordability challenges.

e work within their own communities. The impact of the program is clear as provided in the Mi'kmaw Home Energy Efficiency Project Impact Report 2025 available on the Efficiency Nova Scotia's website: - More than 1,800 Mi'kmaw homes have be...

AI summary The Mi'kmaw Home Energy Efficiency Project has benefited over 1,800 homes, saving millions in energy costs and reducing emissions. The proposed Demand-Side Management Plan aims to continue supporting energy efficiency upgrades, contributing to climate goals and energy affordability.

46 1 Customer projects increasingly combine efficiency, electrification, distributed generation, storage, and 2 controllable equipment. Siloed programs increase customer complexity and administrative costs and 3 make it more difficult to c...

AI summary Customer projects now combine efficiency, electrification, and distributed generation, but siloed programs increase complexity and costs. As efficiency opportunities become more capital-intensive, rebates are less effective. Modern DSM should focus on technical assistance, financing, and integration rather than separate programs. Affordability should be measured by value delivered per dollar invested.

Introduction Chair and members of the Energy Board and representatives of EfficiencyOne and Nova Scotia Power and other intervenors: I represent the Affordable Energy Coalition as past Chair from 2012 to 2025. The Affordable Energy Coaliti...

AI summary The Affordable Energy Coalition opposes a proposed cut in EfficiencyOne spending and the shift of savings from residential to business. They argue that the earlier IRP-based plan was more beneficial for Nova Scotians, especially low-income households, despite a slightly higher initial cost. They emphasize that demand-side management measures are crucial for long-term affordability.

- My name is Thomas Kayter, counsel for the Department of Energy. - The Department intervenes in this proceeding to support approval, substantially as filed and - subject to the Board's usual oversight, of EfficiencyOne's application for a...

AI summary The Department of Energy supports EfficiencyOne's application for approval of the 2027–2031 Demand-Side Management Purchase Agreement and Resource Plan, emphasizing its affordability, cost-effectiveness, and public interest. The plan aims to reduce electricity demand, lower bills, and support the transition to cleaner energy with a total investment of $318.75 million and projected $680 million in bill savings.

ensive kilowatt- - hour is often the one that customers do not need to buy and the system does not need to - produce, transmit, or deliver. Efficiency Nova Scotia programs reduce consumption and peak - demand, thereby lowering customer bil...

AI summary Efficiency Nova Scotia programs reduce energy consumption and peak demand, lowering customer bills and system costs. The proposed DSM plan's bill savings exceed investment levels, and maintaining flat investment reflects sensitivity to affordability. The plan supports reliability through demand response and load reduction, reducing the need for expensive supply-side resources.

sts, targets, and agreement terms. - Nor should the Board view DSM as a discretionary add-on to the electricity system. It is a - resource. Properly designed and evaluated, DSM competes with and complements supply-side - resources by reduc...

AI summary The Department emphasizes that demand-side management (DSM) should be treated as a core resource, not a discretionary add-on. It argues that multi-year DSM planning provides stability while allowing for Board oversight and accountability. The Department supports the approval of EfficiencyOne's application, stating it aligns with public interest goals such as affordability, reliability, and emissions reduction.

1 M12780 2 3 NOVA SCOTIA ENERGY BOARD 4 5 6 IN THE MATTER OF: The Public Utilities Act 7 8 – and – 9 10 11 IN THE MATTER OF: An Application by EfficiencyOne for approval of the 2027–2031 Demand-Side Management (DSM) Purchase Agreement 12 b...

AI summary EfficiencyOne is seeking approval for its 2027–2031 Demand-Side Management (DSM) Plan, which aims to deliver 435.4 GWh of energy savings. The plan prioritizes near-term affordability due to current economic pressures, including rising interest rates and electricity rate increases, and is expected to cost $318.7 million.

36 Many parties have filed IRs and evidence in this matter, including the Consumer Advocate. In a 37 report authored by Theodore Love, of Green Energy Economics Group, Inc. (GEEG), Mr. Love 38 raises several concerns regarding E1's Applica...

AI summary The document discusses concerns raised by Theodore Love of Green Energy Economics Group, Inc. regarding EfficiencyOne's Application, particularly focusing on affordability and the under-delivery of energy savings compared to Nova Scotia Power's Integrated Resource Plan. Affordability is highlighted as a central consideration in the decision-making process.

e Plan ("IRP"). The IRP included anticipated 7 DSM energy savings of 683.1 GWh during the relevant period - a difference of 247.7 GWh 8 compared to the savings projected by E1 in this current plan. 9 10 Maintaining short-term affordability...

AI summary The text discusses the Integrated Resource Plan (IRP) and highlights a discrepancy between projected and actual DSM energy savings. It emphasizes the importance of balancing short-term affordability with long-term benefits of DSM programs, noting that DSM can lead to cost savings for participants and is a least-cost resource. The Consumer Advocate supports changes to E1's application.

r shift peak demand, include managed EV charging as part of transportation electrification, and that E1 recognize that failed modified-PAC results should not be viewed as evidence that SE lacks value. • Brattle also recommends that E1 remo...

AI summary Brattle recommends removing standalone solar PV from DSM funding due to its limited value in Nova Scotia's system, while NS Power supports DSM's role but emphasizes the need to align funding with system needs and affordability. Both parties agree on the importance of DSM but differ on the inclusion of solar PV.

e that Nova Scotia's DSM portfolio remains aligned with emerging system needs, customer priorities and affordability concerns, and planning realities that Nova Scotia is expected to face through 2031. NS Power respectfully submits that the...

AI summary NS Power submits that the Board should consider Brattle's recommendations and other evidence to modify the Preferred Plan, ensuring alignment with affordability, winter peak demand, system flexibility, and long-term policy goals. It suggests developing demand response as a verifiable capacity resource and addressing funding issues for standalone solar PV.

Introduction Chair and members of the Energy Board and representatives of EfficiencyOne and Nova Scotia Power and other intervenors: I represent the Affordable Energy Coalition as past Chair from 2012 to 2025. The Affordable Energy Coaliti...

AI summary The Affordable Energy Coalition opposes a proposed cut in EfficiencyOne spending and the shift of savings from residential to business. They argue that the earlier IRP-based plan was more beneficial to Nova Scotians, noting that the current plan would result in higher monthly electricity bill increases for households over time.

sible to infer or approximate a salary for a specific individual if other information outside of the report is known, particularly in the higher bands where there are fewer people in those positions). On the second point, E1 submits the sa...

AI summary E1 argues that maintaining Board Confidential treatment of executive compensation is in the public interest, citing lack of intervenor objections, lower relevance of executive compensation compared to previous cases, and the fact that E1 engages in both regulated and non-regulated activities. It also suggests that salary information may need to be more specific to ensure proper allocation between regulated and unregulated activities.

2. INTEREST IN THE PROCEEDING Solar Nova Scotia has an interest in this proceeding as it relates to: - The scope and interpretation of demand-side management (DSM), including strategic electrification; - The role of distributed energy reso...

AI summary Solar Nova Scotia outlines interests in the proceeding related to demand-side management (DSM) scope, distributed energy resources (DERs) role in reducing costs and enhancing grid reliability, DSM program design impacts on market innovation, and balancing near-term affordability with long-term system benefits.

NOTICE OF INTENTION TO PARTICIPATE (AFFORDABLE ENERGY COALITION)

AI summary The Affordable Energy Coalition submits a notice of intention to participate in a Nova Scotia regulatory proceeding, advocating for affordable energy solutions. The coalition emphasizes Demand-Side Management (DSM) programs as a key strategy to reduce costs and improve energy efficiency for consumers.

1 Request IR-1: 2 3 Reference: 2027-2031 DSM Plan Application, Exhibit E-1, Evidence ("Evidence"), p. 1. 4 5 "The Preferred Plan is one which will provide the benefits of DSM at an affordable cost, 6 appropriate to the economic challenges...

AI summary The Preferred Plan emphasizes affordable Demand-Side Management (DSM) to reduce electricity costs for Nova Scotians, prioritizing short-term and long-term affordability. It raises questions about economic conditions enabling more DSM investment and whether increased DSM spending further lowers energy costs.

26 Request IR-3: 27 28 Reference: Evidence, page 27. 29 30 "… For the period of 2027–2031 the level of energy savings in the IRP is 683.1 GWh, 31 123.9 MW of demand savings, and 44.3 MW from demand response (excluding rates – 32 CPP & TVP)...

AI summary Request IR-3 discusses energy savings targets (683.1 GWh, 123.9 MW demand savings) for 2027–2031, aligning with DSMAG feedback on short-term affordability. E1's Preferred Plan proposes 64% of IRP targets, prioritizing affordability while maintaining long-term trajectory. Questions raised include DSMAG members' feedback, consistency with IRP, future savings gaps, supply needs, rate impacts, and GHG reductions.

6 Request IR-8: 7 8 Reference: Evidence, p. 38 9 10 "Affordability continues to be a critical factor in determining the level of investment in a 11 DSM Plan. E1 has heard from several members of the DSMAG over the past several DSM 12 Plans...

AI summary E1 maintains that affordability is a critical factor in determining investment levels in the DSM Plan, prioritizing short-term affordability over long-term considerations. E1 has kept the annual investment in the Preferred Plan at the 2026 DSM Plan level of $63.75 million without inflationary increases, despite the long-term benefits of the optimal DSM level.

Request IR-3: - Pdf pg. 16 of the Application states: "Given the affordability concerns raised by DSM Advisory Group (DSMAG) members, as discussed in Sections 3.1.1 and 4.1, the Preferred Plan constrains investment to 2026 levels with no a...

AI summary The document addresses Request IR-3, questioning E1's claim that its proposed $63.75M annual investment is affordable. The Application argues that the Preferred Plan, which limits investment to 2026 levels without inflationary increases, aligns with the NSEB's affordability and long-term cost reduction goals, while complying with ERBA section 6(2) requirements.

Request IR-7: Regarding Section 2.3 "Standardized Filing Framework" of the Application: a. Section 2.3.1 "The 2022 Integrated Resource Plan", pdf pgs. 28-29 state: "The Standardized Filing Framework directs that the Resource Plan identifie...

AI summary The document discusses Section 2.3.1 of NS Power's 2022 Integrated Resource Plan (IRP), which outlines 683.1 GWh of energy savings and 123.9 MW of demand savings through energy efficiency by 2031. It emphasizes balancing long-term Demand-Side Management (DSM) benefits with short-term affordability challenges for Nova Scotia residents and businesses.

independently pass the cost-effectiveness test, E1 has responded to this specifically under Board Directives section 2.2.2.1." Please answer the following questions regarding the quote above: a. If one or more of the portfolio-level assess...

AI summary E1's response to non-confidential information requests addresses compliance with NSEB's Decision in Matter 12282 regarding DSM Plan cost-effectiveness, affordability constraints, and investment decisions. The Preferred Plan balances near-term affordability with long-term value by capping investment at 2026 levels, avoiding annual inflationary increases while aligning with NSEB directives.

Request IR-6: Refer to Exhibit E-1, the DSM Plan, Section 3.1 Affordability, page 24 of 71, Line 10 and page 25 of 71, Lines 1-2 and provide detail as to how E1 has adjusted the DSM Plan in later years to account for inflationary impacts t...

AI summary Request IR-6 asks E1 to explain adjustments to the DSM Plan for inflationary impacts on labor and fixed costs without annual inflation increases, and to describe the resulting effects on future expenditure breakdowns as shown in Figure 3.

- 2 Reference: Exhibit E-1, Application, page 36/71; and Exhibit E-1, Appendix B, Section 9, 27 2027–2031, representing approximately 64% of the 683.1 GWh savings target in NSPI's 26 Preamble: E1's Preferred Plan proposes 435.4 GWh in cumu...

AI summary The document discusses questions related to the affordability of energy efficiency investments, particularly focusing on whether maintaining the 2026 approved investment level of $63.75 million is acceptable or affordable over the 2027–2031 period. It also asks how E1's definition of affordability aligns with that used by NSPI and whether it is consistent with the PUA and NSEB's regulatory framework.

INFORMATION REQUEST 4 Efficiency One produced a report titled "Energy Poverty and an Equitable Transition to a Net-Zero Carbon Future in Nova Scotia" December 8, 2023. Please provide the % of Nova Scotia households that this report conclud...

AI summary Efficiency One's December 8, 2023 report, 'Energy Poverty and an Equitable Transition to a Net-Zero Carbon Future in Nova Scotia,' is requested to disclose the percentage of Nova Scotia households in energy poverty (defined as spending 6% of income on home energy) and related conclusions about population-wide energy poverty struggles.

INFORMATION REQUEST 7 EfficiencyOne created an excellent Energy Poverty Visualization Tool which provides the most reliable and up to date estimates of Energy Poverty in Nova Scotia, as the energy prices and incomes change over time. Pleas...

AI summary EfficiencyOne's Energy Poverty Visualization Tool is requested to explain its methodology for estimating energy poverty in Nova Scotia as energy prices and incomes change, along with a table showing historical energy poverty levels calculated by the tool.

rejects the proposition that the Intervenors should have any access to any part of the Mercer Reports. The Board observes that executive compensation is included in the Final Issues List for this GRA. The Province noted that NS Power is a...

AI summary The Province argues that executive compensation information in the Mercer Reports should not be classified as 'Board Confidential' and should be accessible to intervenors. It emphasizes that transparency is essential for ensuring fairness in the GRA process and for allowing stakeholders to provide informed submissions on executive compensation.

The Industrial Group submitted: …NSPI's ratepayers have an interest in whether NSPI's executives and management team are appropriately compensated (not excessively or inadequately compensated) to attract and retain talent, and they are pro...

AI summary The Industrial Group emphasizes the importance of appropriate executive compensation for NSPI to attract talent and act in ratepayers' best interests, especially within the Emera Group. The Consumer Advocate links NS Power's request for increased ROE and equity thickness to potential executive compensation, arguing that without evidence of reasonableness, ratepayers cannot fully assess the justification for these increases.

sible to infer or approximate a salary for a specific individual if other information outside of the report is known, particularly in the higher bands where there are fewer people in those positions). On the second point, E1 submits the sa...

AI summary E1 argues that maintaining Board Confidential treatment for executive compensation is justified due to privacy and commercial interests, and that public interest in disclosure is lower than in previous cases. It also notes that even with unregulated activities, proper allocation of salaries to regulated and unregulated work is necessary.

EXPERT TESTIMONY AND REGULATORY FILINGS Report filed before New Jersey Board of Public Utilities (NJBPU), "An Assessment of Energy Affordability in New Jersey and Alternative Policy and Rate Options," March 30, 2025 (with Goksin Kavlak, Ka...

AI summary The text outlines various regulatory filings and expert testimonies submitted by organizations before different regulatory bodies across the United States, including the New Jersey Board of Public Utilities, Washington, D.C. Public Service Commission, Nevada Public Utilities Commission, and others, concerning energy affordability, electrification impacts, integrated resource plans, and rate adjustments.

- For an energy equipment manufacturer, prepared materials to educate the leadership on large load pricing principles and implementations across the USA. The Brattle team also analyzed the large load tariffs and implications for the develo...

AI summary The text outlines various rate design and impact evaluation studies conducted by Brattle for multiple utilities, including analyzing large load pricing, developing clean transition tariffs, and evaluating the cost implications of electric heat pumps under different rate structures. These efforts aim to support innovative rate design and improve affordability and efficiency.

Refer to M12780, Exhibit E-23, Evidence of Alice Napoleon, Synapse Energy Economics, Inc., ("Synapse Evidence") Page 23 of 47, Lines 22-25 and Page 24 of 47, Lines 1-2. a) In this section you state that neither the Board nor the statute is...

AI summary The text references Synapse Energy Economics' evidence and requests clarification on the assessment of electricity costs, including the level of assessment, time period, and perspective. It also asks about concerns regarding financial support for non-electrically heated homes, the meaning of 'affordability' in the context of reducing oil reliance, and the cost-effectiveness of filling a funding gap in the DSM Plan.

Issued at Halifax, Nova Scotia, this 6th day of July, 2026. 1 Request IR-01: 2 Reference: Brattle Evidence, Section III: Affordability of E1's Preferred Plan, page 6: 3 4 "While E1 and its consultant (Apex Analytics) did conduct a Jurisdic...

AI summary The document contains information requests related to the affordability and cost performance of E1's preferred plan, including critiques of peer group analysis and budgeting differences between Ontario and Nova Scotia. It also asks for quantification of cost differentials and clarification on regulatory frameworks.

1 Request IR-8: 2 3 On page 19 of 39, the Report states "E1's current residential DR design is too limited, too 4 expensive and too passive in its approach to program development". 5 6 A. Please explain this statement. 7 8 B. Please explai...

AI summary The Report criticizes E1's current residential demand response (DR) design as being limited, expensive, and passive. The request asks for an explanation of this criticism and how residential DR programs can become a key systems resource without immediate affordability challenges.

15 Request IR-2: 16 17 Does E1 acknowledge the apparent contradiction between its focus on short-term affordability and 18 the affect the spending levels in its Proposed Plan will have on electricity costs for ratepayers? 19 20

AI summary The document raises a question about whether E1 recognizes the contradiction between its focus on short-term affordability and the long-term impact of spending levels in its Proposed Plan on electricity costs for ratepayers.

to the 2022 IRP. That IRP was thoroughly researched and vetted by many stakeholders. These savings will never be recovered in spite of suggestions of catching up in future when the timing is better. The primary argument for freezing spendi...

AI summary The text discusses the affordability implications of freezing spending levels in the 2022 Integrated Resource Plan (IRP) versus the Preferred Plan. It argues that increased spending on DSM, Strategic Electrification, and Demand Response is necessary for affordability. Calculations show non-participants would face higher bills, but the Affordable Energy Coalition recommends aligning with the 2022 IRP's savings targets for long-term affordability.

5. Concern: Deferral of Strategic Electrification Recommendation: Develop strategic electrification offerings for low and moderate income customers who heat with oil. In the evidence presented by the Board Counsel's consultant Alice Napole...

AI summary The document discusses the deferral of strategic electrification for low and moderate-income oil-heating customers in Nova Scotia. Alice Napoleon of Synapse Energy Economics argues that electrification can improve affordability, citing energy poverty data linked to oil price spikes. The Affordable Energy Coalition supports this recommendation, urging the Board to direct E1 to develop such offerings.