E-1EfficiencyOne Application - Revised Application see Exhibit E-43
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nd Side Management Plan, filed February 28, 2011 20 Ibid., p. 17 21 NSUARB, NSUARB-E-ENSC-R-10 ORDER, June 30, 2011 ENSC and its stakeholders[22](#page-63-0) as well as industry experts [23](#page-63-1) have noted concerns associated with...
AI summary Efficiency Nova Scotia (ENS) criticizes the Total Resource Cost (TRC) test for inaccuracies, bias, and misrepresenting ratepayer value. ENS advocates shifting to the Program Administrator Cost (PAC) test, citing Dunsky Energy Consulting's recommendations. The 2016-2018 DSM Plan passes current TRC methods, but ENS emphasizes the need for accurate cost-benefit accounting in DSM planning.
perience suggests that in many markets, participants are increasingly driven to spend their money on energy efficiency measures or options because of those very NEBs that the TRC does not account for. It has been suggested – and we concur...
AI summary The text argues that the Total Resource Cost (TRC) methodology underestimates non-energy benefits (NEBs), creating a regulatory bias against energy efficiency investments. This bias, though marginal in the past, is becoming significant with stricter DSM goals and improved baselines, leading to the rejection of high-value measures despite consumer interest. The Washington Utilities and Transportation Commission's 2013 policy statement highlights TRC's failure to quantify risk reduction and NEBs, disadvantaging conservation programs.
SUMMARY OF NEB ISSUES Increasingly, non-energy benefits – especially those that accrue to participants – are viewed as significant benefit streams that the current TRC effectively neglects. This is critical to the extent that the TRC's pur...
AI summary The document critiques the Total Resource Cost (TRC) methodology for neglecting non-energy benefits (NEB), particularly for participants. It notes that some regions modify TRC to include NEB or adopt alternative tests. A study evaluated DSM scenarios with 1.0%-2.5% annual savings, referencing Nova Scotia's 2012 DSM achievement of 1.52% annual sales. The text also mentions deliberate low-rate choices to avoid discounting future generations' interests.
IMPLICATIONS FOR NOVA SCOTIA Nova Scotia has been using the TRC, which attempts to reflect the sum of participant and non-participant perspectives, to screen DSM programs. The Electricity Efficiency and Conservation Restructuring (2014) Ac...
AI summary Nova Scotia uses TRC to evaluate DSM programs, but the TRC may not reflect customer preferences, leading to inefficient spending. The 2014 Act structures DSM procurement as utility-led competition with supply. Only the PAC test considers utility least-cost perspectives. Customer preferences, like valuing solar hot water over heat pumps, could be overlooked by TRC.