Topic:"Bca" in M12282

EfficiencyOne IN THE MATTER OF The Public Utilities Act, RSNS 1989, c 380, as amended - and – IN THE MATTER OF An Application by EfficiencyOne for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Pla...

AI summary EfficiencyOne seeks approval from the Nova Scotia Energy Board to implement a new benefit-cost analysis test for evaluating Demand Side Management (DSM) Plans. The application follows the extension of the 2023-2026 DSM Plan through legislative amendment, with EfficiencyOne holding the Efficiency Nova Scotia Franchise under the Public Utilities Act.

was extended through a legislative amendment to the PUA that does as follows: a) extends the term of the existing 2023-2025 DSM Plan by one additional year, to December 31, 2026; b) extends the existing approved demand-side management purc...

AI summary The PUA was amended to extend the 2023-2025 DSM Plan to 2026, set a $63.75M investment, and require E1 to seek Energy Board approval for 2026 targets. The TRC Test is used to evaluate DSM Plan cost-effectiveness.

embers of the Demand Side 11 Management Advisory Group (DSMAG) on a Nova Scotia specific benefit cost framework for screening 12 distributed energy resources, I make the following recommendations: 13 1. E1 adopt the jurisdictionally specif...

AI summary The testimony discusses the adoption of a jurisdictionally specific benefit cost analysis (BCA) framework for screening distributed energy resources in Nova Scotia. The recommendation is for E1 to use the 'Nova Scotia BCA test' as the primary cost-effectiveness test for future DSM plans, including the 2027-2031 plan. The EFG Report provides further detail on the development of this framework.

Page 6 of 18 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A 1 A: Throughout 2024 EFG worked with E1 and the DSMAG to review and develop a new 2 jurisdictionally specific benefit cost analysis test. The National Standard Pr...

AI summary EFG collaborated with E1 and the DSMAG to develop a jurisdiction-specific benefit-cost analysis (BCA) test for Nova Scotia based on the National Energy Screening Project's NSPM. The report outlines EFG's recommendations for the new BCA test, informed by feedback from stakeholders.

costs and 21 benefits, then host-customer non-energy benefits also need to be accounted. EFG’s 22 work included proposing proxy adders for host customer non-energy benefits that 23 are more difficult to quantify. 24 Q: Based on this proces...

AI summary EFG proposed proxy adders for host customer non-energy benefits in the Nova Scotia benefit cost test. The recommendation includes specific impact categories, with some impacts assumed to be embedded in other categories. EFG also conducted a screening for elements of E1’s 2027-2031 DSM plan using the recommended test.

in the new BCA test are found in the attached EFG report. 8 Q: Has EFG conducted a screening for elements of E1’s 2027-2031 DSM plan using the 9 recommended Nova Scotia benefit cost test? 10 A: No. Preliminary portfolio development is now...

AI summary EFG has not conducted a screening of E1’s 2027-2031 DSM plan using the new BCA test. Preliminary portfolio development is underway, and EFG’s report focused on identifying impact categories for the test and providing illustrative examples for the DSMAG.

Page 10 of 18 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A 1 Table 2: Nova Scotia Policy and Impact Category Matrix 2 3 The EFG team’s interpretation of the results, represented in the final row in Table 2 above, 4 indic...

AI summary The EFG team's analysis supports the inclusion of various policy and legislative impacts in the BCA test, including system impacts, resilience, GHG emissions, and DEI considerations. However, the NSPM suggests that certain impacts like jobs and economic development should be analyzed separately to avoid double counting.

tely 13 used by E1 for screening the 2027-2031 DSM portfolio are likely to be from the same sources, but in 14 many cases will be updated from the values used by EFG for the illustrative examples. 15 Table 3: Data Sources and Application i...

AI summary The document discusses data sources used by E1 for the 2027-2031 DSM portfolio, noting that they are likely from the same sources as EFG but may be updated. It also references the National Energy Screening Project and National Standard Practice Manuals used in benefit-cost analysis and utility system impacts.

ne Benefit-Cost Analysis Test Application Appendix A 1 Figure 2: Illustrative Results Using Prior TRC Test1 2 3 4 The most significant difference between the recommended new Nova Scotia test and the prior 5 TRC test is the latter excludes...

AI summary The text discusses the differences between the new Nova Scotia test and the prior TRC test, noting that the latter excludes other fuel impacts and certain benefits. It also references a direct testimony by David G. Hill, Ph.D., on behalf of EfficiencyOne, regarding the development of the new test and interactions with the DSMAG.

to gather feedback and discuss issues in 18 detail. These meetings to address members questions and issues continued after the final workshop, 19 with the most recent occurring in late April 2025. 20 At the first workshop, EFG reviewed the...

AI summary EfficiencyOne participated in workshops to develop a BCA framework, reviewing Nova Scotia energy policies and the 2023-2025 DSM Plan BCA test for DERs. The working group discussed USIs and NUSIs, identifying areas of agreement, varying opinions, and dissenting views.

the BCA 3 test. For both USIs and NUSIs, the group discussed areas of general agreement, varying opinions, 4 identified categories which may not be material, and identified dissenting opinions. 5 At the third workshop, the working group re...

AI summary The testimony discusses the development and refinement of the Benefit-Cost Analysis (BCA) framework, including workshops focused on quantifying impacts, reviewing draft reports, and gathering feedback from the Demand Side Management Advisory Group (DSMAG). The process involved multiple stages of review and discussion, culminating in feedback on the final BCA report and the recommended Nova Scotia BCA test.

Page 1 of 9 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A - Attachment 1: David Hill Professional Resume David Hill Managing Consultant

AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, containing the professional resume of David Hill, a managing consultant.

before the South Carolina Public Service Commission submitted on behalf of Southern Alliance for Clean Energy and the South Carolina Coastal Conservation League on the characterization Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05...

AI summary The document includes a resume for David Hill, a managing consultant at Energy Futures Group, Inc., submitted as part of an EfficiencyOne Benefit-Cost Analysis Test Application before the South Carolina Public Service Commission.

Page 2 of 9 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A - Attachment 1: David Hill Professional Resume David Hill Managing Consultant

AI summary This document contains the resume of David Hill, a managing consultant at EfficiencyOne, in the context of a Benefit-Cost Analysis Test Application.

Page 5 of 9 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A - Attachment 1: David Hill Professional Resume David Hill Managing Consultant

AI summary This document contains the resume of David Hill, a managing consultant at EfficiencyOne, and is part of a Benefit-Cost Analysis Test Application. It is included as Appendix A - Attachment 1.

2010 “National RPS Now!” Solar Today. July / August 2010. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-4874 [email protected] DATE FILED: May 16, 2025 Page 6 of 9 EfficiencyOne Benefit-Cost Analysis Te...

AI summary This document includes a professional resume for David Hill, a managing consultant at EfficiencyOne, and references a benefit-cost analysis test application. It also cites a publication from 2010 about a national renewable portfolio standard and includes contact information for Energy Futures Group, Inc.

Page 6 of 9 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A - Attachment 1: David Hill Professional Resume David Hill Managing Consultant

AI summary This document is an appendix to the EfficiencyOne Benefit-Cost Analysis Test Application, containing the professional resume of David Hill, a managing consultant.

Information System and Report on LEAP Training Activities. Prepared for the Ministry of Natural Resources and Energy, Government Kingdom of Swaziland. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-4874 dhill@energ...

AI summary The document outlines a benefit-cost analysis test application by EfficiencyOne, prepared for the Ministry of Natural Resources and Energy in Swaziland. It includes a resume for David Hill, a managing consultant at Energy Futures Group, Inc.

Page 7 of 9 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A - Attachment 1: David Hill Professional Resume David Hill Managing Consultant

AI summary This document is an appendix containing the professional resume of David Hill, a managing consultant at EfficiencyOne, submitted in the context of a Benefit-Cost Analysis Test Application.

ropriate Technology and International Development, University of Pennsylvania, Philadelphia, PA, 1989. B.A., Geography and Political Science, Middlebury College, Middlebury, VT, 1986. Other Qualifications Nepal, Himalayan Light Foundation....

AI summary The document provides information about an individual's educational background, professional qualifications, and experience in renewable energy and international development. It also references the National Standard Practice Manual (NSPM) for Benefit-Cost Analysis of Distributed Energy Resources, as well as the National Energy Screening Project (NESP).

pendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual     !" # $ %# #&'() "+ ', -./.012323 DATE FILED: May 16, 2025 Page 1 of 302 Appendix A - Effici...

AI summary This document is an attachment to an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It includes a filing date of May 16, 2025, and appears to be part of a regulatory proceeding.

Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual

AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, which includes Attachment 2 referencing the National Standard Practice Manual. It outlines the procedural and analytical framework for evaluating energy efficiency programs.

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AI summary The document lists various entities involved in a regulatory proceeding, including organizations and individuals, and references a Benefit-Cost Analysis Test Application and the National Standard Practice Manual. It appears to be part of a proceeding related to energy efficiency and regulatory compliance.

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AI summary This document is an attachment from an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It contains various sections and references related to energy efficiency programs and regulatory processes.

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AI summary The document includes an application for a Benefit-Cost Analysis Test by EfficiencyOne and references the National Standard Practice Manual. It is part of a regulatory proceeding and was filed on May 16, 2025.

Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual

AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It appears to be part of a regulatory process involving the evaluation of energy efficiency programs.

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AI summary The document is an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It outlines procedures for conducting a benefit-cost analysis, which is a key part of regulatory proceedings.

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AI summary The document is an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It discusses the application of benefit-cost analysis in the context of energy efficiency programs and regulations.

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AI summary The document includes an EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It discusses the application of benefit-cost analysis in regulatory proceedings, indicating a focus on evaluating the economic impact of energy efficiency initiatives.

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AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It provides context for evaluating energy efficiency programs through a benefit-cost analysis framework.

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AI summary The text appears to be a regulatory proceeding document containing sections and headings related to energy efficiency, demand-side management, and utility operations. It includes sections such as benefit-cost analysis, test for regulatory compliance, and discussions on energy efficiency programs. The content suggests a structured regulatory review process.

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AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It includes sections related to benefit-cost analysis and other procedural elements of the application.

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AI summary The document is an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It outlines sections related to the benefit-cost analysis, application procedures, and standards for energy efficiency programs.

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AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It appears to be part of a regulatory proceeding, likely involving the evaluation of energy efficiency programs.

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AI summary This document outlines an EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It includes sections related to energy efficiency programs and regulatory compliance.

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AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It is part of a regulatory proceeding and includes a filing date of May 16, 2025.

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AI summary The document discusses the application of a benefit-cost analysis test by EfficiencyOne, referencing the National Standard Practice Manual. It outlines procedures for evaluating efficiency programs and their impact on energy use and costs.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the application process and considerations for benefit-cost analysis in regulatory proceedings.

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AI summary This text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and its attachment related to the National Standard Practice Manual. It mentions the use of benefit-cost analysis in energy efficiency programs and references various positions and practices within the regulatory process.

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AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, including Attachment 2 which references the National Standard Practice Manual. It is part of a regulatory proceeding involving EfficiencyOne and Nova Scotia Power.

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AI summary This document is an appendix from a regulatory proceeding, containing a benefit-cost analysis test application related to EfficiencyOne and referencing the National Standard Practice Manual. It appears to be part of a larger filing, likely involving energy efficiency programs or regulatory compliance.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It addresses the application of benefit-cost analysis in regulatory proceedings, including considerations of efficiency programs, cost-benefit evaluation, and the use of standardized practices for analysis.

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AI summary This text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the process for evaluating efficiency programs, including benefit-cost analysis and the role of 456 in assessing program effectiveness and impact.

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AI summary The text discusses the regulatory process involving a fuel-cost-adjustment mechanism and its implications on base rates, as well as the evaluation of efficiency programs and the application of a benefit-cost analysis test. It also references the EfficiencyOne Benefit-Cost Analysis Test Application and the National Standard Practice Manual.

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AI summary The text discusses the application of a benefit-cost analysis framework (678) in evaluating the impact of various regulatory proceedings, including those related to Nova Scotia Power (NOP) and Hydro-Informatics and Jurisdiction (HIJ). It emphasizes the importance of assessing the economic implications of regulatory decisions and the need for accurate analysis in these proceedings.

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AI summary The text appears to be a portion of a regulatory proceeding document, specifically an EfficiencyOne Benefit-Cost Analysis Test Application. It references an attachment from the National Standard Practice Manual and includes various technical terms and acronyms related to the analysis process.

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AI summary The text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines a framework for evaluating energy efficiency programs, including the application of benefit-cost analysis and the use of standardized practices.

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AI summary The text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the application of benefit-cost analysis in evaluating energy efficiency programs, including the use of the 678 framework and the role of the Nova Scotia Power (NSP) in the process.

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AI summary The text discusses the filing of a document related to an EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It includes a date filed and page number, indicating it is part of a larger proceeding.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the use of the _ a framework for benefit-cost analysis, including the evaluation of programs and their impact on efficiency and cost recovery.

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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It outlines the application of benefit-cost analysis in regulatory proceedings, including topics such as cost-effectiveness, standard practice, and the evaluation of efficiency programs.

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AI summary The text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It touches on topics like the Fuel Adjustment Mechanism and the application of benefit-cost analysis in regulatory proceedings.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It includes sections on benefit-cost analysis and other procedural elements, though specific details are limited in the provided text.

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AI summary The text discusses various regulatory matters related to energy efficiency programs and proceedings, including topics like demand-side management, benefit-cost analysis tests, and regulatory proceedings. It references entities like Nova Scotia Power and EfficiencyOne, as well as regulatory processes and legal frameworks.

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AI summary This document discusses the application of the EfficiencyOne Benefit-Cost Analysis Test, referencing the National Standard Practice Manual and outlining procedures for evaluating demand-side management programs. It includes references to regulatory processes and the use of benefit-cost analysis in decision-making.

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AI summary The text discusses the implementation and evaluation of the 789$ demand-side management (DSM) plan, including its impact on cost recovery, efficiency, and regulatory considerations. It outlines the role of the 789$ plan in managing energy demand, evaluating benefit-cost analyses, and addressing challenges related to program design and implementation.

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AI summary The text discusses the National Standard Practice Manual, with sections on procedures, regulations, and standards, particularly related to energy efficiency, cost analysis, and regulatory compliance. It includes references to benefit-cost analysis tests and regulatory processes.

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AI summary The document discusses the use of a benefit-cost analysis test application and references a National Standard Practice Manual. It mentions the EfficiencyOne program and outlines various procedures and standards related to energy efficiency and regulatory compliance.

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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the methodology for evaluating efficiency programs and includes specific practices related to benefit-cost analysis.

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AI summary The text references a benefit-cost analysis test application related to EfficiencyOne and mentions the National Standard Practice Manual. It also includes a date filed and page reference from a legal document.

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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the application of benefit-cost analysis in the context of energy efficiency programs, including the use of the BCD (Benefit-Cost Analysis) framework to evaluate energy efficiency initiatives and their impact on energy use and cost recovery.

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AI summary The text discusses the Benefit-Cost Analysis (BCD) and its application in regulatory proceedings, particularly in evaluating the cost-effectiveness of energy programs and interventions. It outlines how BCD is used to assess the financial implications of various initiatives, including the impact of fuel-cost-adjustment mechanisms and the evaluation of programs such as the Low-Income Energy Assistance Program (LML).

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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the process for conducting a benefit-cost analysis, including considerations for evaluating energy efficiency programs and their impact on utility operations and customer benefits.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the application of benefit-cost analysis in the context of energy efficiency programs, emphasizing the role of the MNO (Mandatory Net Output) and the importance of aligning cost and benefit assessments with regulatory standards.

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AI summary The text discusses benefit-cost analysis in the context of energy efficiency programs, referencing the EfficiencyOne application and the National Standard Practice Manual. It touches on topics such as program evaluation, regulatory processes, and the use of standardized filing procedures.

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AI summary The document includes an EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It is part of a regulatory proceeding and was filed on May 16, 2025.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It includes sections about benefit-cost analysis, efficiency programs, and related regulatory processes.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual and the use of Benefit-Cost Analysis (BCD) in evaluating energy efficiency programs. It outlines the process for assessing the economic benefits and costs of such initiatives.

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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the process for evaluating benefit-cost analyses in energy efficiency programs, focusing on the application and evaluation of such analyses.

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AI summary The text discusses the evaluation of various energy programs and initiatives, including benefit-cost analysis (BCD), energy efficiency, and affordability considerations. It touches on regulatory processes, program performance, and the impact of initiatives on stakeholders.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the application process and considerations for benefit-cost analysis, emphasizing the evaluation of programs and their impacts.

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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the process for evaluating benefit-cost analyses, including the use of standardized practices and procedures for assessing energy efficiency programs.

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AI summary The text discusses the evaluation of a benefit-cost analysis (BCD) and its implications for energy programs such as the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML). It outlines the methodology used in assessing the economic impact of these programs and references regulatory frameworks and analysis procedures.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It outlines the process for evaluating efficiency programs through a benefit-cost analysis, including the consideration of program design, implementation, and outcomes.

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AI summary The document refers to a Benefit-Cost Analysis Test Application and includes Attachment 2, which is the National Standard Practice Manual. This suggests the application involves regulatory procedures related to cost-benefit analysis.

Page 1 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 2

AI summary This document is an appendix to the EfficiencyOne Benefit-Cost Analysis Test Application, prepared by energyfuturesgroup.com. It outlines the analysis and evaluation of the EfficiencyOne program's benefits and costs.

......................................................... 40 3. Host Customer Impacts...................................................................................................... 41 Energy Futures Group, Inc PO Box 587, Hinesburg,...

AI summary This document is an appendix to the EfficiencyOne Benefit-Cost Analysis Test Application, prepared by Energy Futures Group, Inc. It outlines the structure of the analysis and includes a section on host customer impacts, as well as information about the filing date and contact details for the consulting firm.

Emissions Intensity: .................................................................................................. 66 F. National Energy Screening Project Summary of Host Customer Impacts............................. 67 Energy Futures...

AI summary The document outlines a Benefit-Cost Analysis (BCA) test application for the EfficiencyOne program, conducted by Energy Futures Group, Inc. It includes sections on emissions intensity and a summary of host customer impacts from the National Energy Screening Project.

Page 4 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 5 List of Figures Figure 1: Illustrative Example of Recommended Nova Scotia Test .............................................. 21 Figure 2...

AI summary The document is an appendix to an application for a Benefit-Cost Analysis Test under the EfficiencyOne program. It includes figures related to the Nova Scotia test, benefit-cost analysis principles, and estimated benefits of reduced air pollutants.

PUA Public Utilities Act RPS Renewable portfolio standard SCC Social cost of carbon TRC Total resource cost test Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FIL...

AI summary The document outlines the definitions and uses of complementary or secondary tests in the context of the Benefit-Cost Analysis (BCA) test application for EfficiencyOne. These tests are used to inform decisions on DER prioritization, program effectiveness, and consistency in BCA analyses.

ry perspective, informing decisions when a program or plan is marginally cost effective, and encouraging consistency in BCA analyses across different types of distributed energy resources. 1 Discount Rate: Discount rates are used to reflec...

AI summary The text discusses the use of benefit-cost analysis (BCA) in evaluating distributed energy resources (DERs), emphasizing consistency in analyses across different DER types. It explains the role of discount rates in reflecting the time value of money and how they vary based on the perspective of the impacted party. DERs are defined as resources on the customer side of the utility meter, including energy efficiency, demand response, and distributed generation.

oject.org/national- standard-practice-manual/. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 7 of 68 EfficiencyOne Benefit-Cost Analysis...

AI summary The document discusses the development of a jurisdictional Benefit-Cost Analysis (BCA) test for Nova Scotia, focusing on demand-side management programs and distributed energy resources. It highlights how EfficiencyOne (E1) targets low- and moderate-income households through incentives and outlines the framework for assessing the cost-effectiveness of energy efficiency measures.

alled at a customer site. The demand side management programs being developed and screened by E1 for inclusion in their next plan are composed of individual measures and supporting services. Non-Energy Benefits: Many DERs provide benefits...

AI summary The text discusses the development of a Jurisdiction Specific Test (JST) for Nova Scotia to evaluate the cost-effectiveness of energy efficiency and distributed energy resources (DERs). It highlights that non-energy benefits from DERs, such as improved comfort and health, are harder to quantify and may be relatively small. The report recommends using a proxy adder approach to estimate these benefits and suggests that if not included in a jurisdictional test, host customer costs should be excluded.

economic metrics of supply-side investments. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 8 of 68 EfficiencyOne Benefit-Cost Analysis Te...

AI summary The document discusses the evaluation of demand-side management (DSM) programs under the Public Utilities Act, emphasizing the use of a jurisdictional-specific benefit-cost analysis test. It outlines the structure of the DSM plan, the role of proxy adders in accounting for non-energy benefits, and the importance of reliability in reducing electricity outages.

-energy benefit, while recognizing that excluding non- energy benefits is an implicit valuation of zero. Reliability: A reduction in the frequency or duration of electricity system outages. Resilience: Increased ability for customers and t...

AI summary The text defines key terms related to benefit-cost analysis in energy efficiency planning, including reliability, resilience, Total Resource Cost Test, and Utility Cost Test. It references changes to Section 79H(2) of Chapter 380 in October 2022 and includes information about the Energy Futures Group, Inc.

creeningproject.org/resources/quantifying-impacts/ Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 10 of 68 EfficiencyOne Benefit-Cost Anal...

AI summary EfficiencyOne (E1) is preparing its 2027-2031 Demand Side Management (DSM) Plan and expects to file it with the Nova Scotia Energy Board (NSEB) in early 2026. E1 is required to work with the DSM Advisory Group (DSMAG) to develop a benefit-cost analysis framework for its DSM Plan, and has engaged Energy Futures Group, Inc. (EFG) to facilitate stakeholder workshops and write a report.

stakeholder workshops and to write a report with recommendations on a benefit cost analysis framework for which E1 would be seeking NSEB approval to use in assessing the 2027- 2031 DSM plan. Consistent with comments on the structure for a...

AI summary EfficiencyOne (E1) is developing a benefit-cost analysis (BCA) framework for its 2027-2031 DSM Plan, informed by stakeholder workshops and a review of the National Standard Practice Manual. The report outlines EFG’s recommendations for a Nova Scotia-specific BCA test, based on stakeholder feedback and policy review.

73. EfficiencyOne 2023-2025 DSM Plan Application. Board Decision. September 6, 2022, page 26, line 73. 7 https://www.nationalenergyscreeningproject.org/national-standard-practice-manual/ Energy Futures Group, Inc PO Box 587, Hinesburg, VT...

AI summary The document references the EfficiencyOne 2023-2025 DSM Plan Application and includes a link to a national standard practice manual. It also mentions the submission of an EfficiencyOne Benefit-Cost Analysis Test Application.

Table 1: Summary of EFG Recommendation on Categories for Inclusion in Nova Scotia Jurisdictional Benefit Cost Test Include in “Nova Scotia Impact Type Sub-Category Impacts 8 Test” 9 Notes Reflect updated electric system Utility Electric Al...

AI summary The table outlines the EFG's recommendation on categories for inclusion in the Jurisdictional Benefit Cost Test in Nova Scotia. It specifies which impact types and sub-categories should be included in the test, such as utility system electric and gas costs, non-utility system greenhouse gas emissions, and host customer costs.

Page 12 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 13 The EFG team’s recommendation on the categories to include are consistent with economic theory 10 and with the NSPM guidance that a jur...

AI summary The EFG team recommends including both utility system impacts (USIs) and non-utility system impacts (NUSIs) in the BCA framework, aligning with economic theory and NSPM guidance. The analysis focuses on electric utility system impacts and their applicability to distributed energy resources (DERs), as detailed in Table 2 and Table 3.

ibution Distribution O&M       Distribution Voltage NM NM NM NM NM NM 10 See for example, Handbook of Public Economics, Vol. 2, 1987, Chapter 14: The Theory of cost-benefit analysis, Jean Dreze, Nicholas Stern. Available at:https://w...

AI summary The document outlines a Benefit-Cost Analysis (BCA) test application for EfficiencyOne, focusing on the impacts of Distributed Energy Resources (DERs) such as energy efficiency, demand response, and distributed generation. It references a handbook on public economics and includes a list of DER types and their applicability in Nova Scotia.

inclusion in the NS UBCA test Not included/or partially included in 2023-2025 test DER types not included in the 2023-2025 DSM plan Consultant Team Recommendations Based on our research and discussions and feedback received during seven DS...

AI summary The document discusses the need for a new Nova Scotia test for benefit-cost analysis to evaluate E1’s 2027-2031 plan, including recommendations from the Energy Futures Group (EFG) on the impact categories to be included in the test, such as electric utility system impacts, greenhouse gas impacts, and criteria air pollutant impacts.

o help identify a portfolio of demand side resources with positive net benefits, when considering the cost and benefit categories aligned with Nova Scotia’s policy priorities and objectives. A jurisdictional benefit cost test does not dire...

AI summary The text discusses the use of a jurisdictional benefit-cost analysis (BCA) to identify cost-effective demand side management (DSM) resources aligned with Nova Scotia's policy goals. It clarifies that while a BCA test helps evaluate net benefits, it does not determine funding sources or amounts. An example is provided using cold climate heat pumps and a 2% social discount rate.

energyfuturesgroup.com 21 Figure 1: Illustrative Example of Recommended Nova Scotia Test As illustrated, the major drivers for the differences between these cases are the value of the saved other fuel, and the valuation of the avoided carb...

AI summary The text presents an illustrative example of a benefit-cost analysis test for Nova Scotia, highlighting the differences in value between cases involving fuel oil and natural gas, as well as the benefits of replacing electric resistance heat with heat pumps. The analysis considers the value of saved fuel, avoided carbon emissions, and the resulting net benefits.

energyfuturesgroup.com 22 Table 6: Illustrative Example Present Value Benefits, Costs and Ratios Benefit PV of Costs PV of Benefits Cost Ratio HP- Fuel Oil $31.66 $57.10 1.80 HP - Fossil Gas $31.66 $14.31 0.45 HP - Electric Resistance $9.9...

AI summary This section presents a benefit-cost analysis of different heating options, including fuel oil, fossil gas, and electric resistance, with cost ratios indicating the economic viability of each. It references the application of the new Nova Scotia test to evaluate EfficiencyOne’s proposed DSM plan for 2027-2031.

energyfuturesgroup.com 23 II. Introduction 1. Background EfficiencyOne (E1) is in the process of developing the next demand-side management (DSM) plan for the period of 2027-2031. As part of the five-year DSM Plan, E1 is reviewing its exis...

AI summary EfficiencyOne (E1) is developing a new demand-side management (DSM) plan for 2027-2031, including updating the Benefit-Cost Analysis (BCA) test and avoided cost methodologies. E1 is working with the DSMAG and NS Power to ensure updated electric system impacts are incorporated into the BCA framework, following best practices from the National Standard Practice Manual (NSPM) for distributed energy resources (DERs).

hat can be used to assess a broad set of DERs including energy efficiency, demand response, distributed generation, distributed storage, and electrification for buildings and transportation. For the 2023-2025 DSM Plan, the cost benefit tes...

AI summary The text discusses the application of a benefit-cost analysis (BCA) test for assessing distributed energy resources (DERs), including energy efficiency and demand response. It references the Total Resource Cost (TRC) test used in the 2023-2025 DSM Plan, noting that it was a variation of the TRC test and excluded certain impacts. The Energy Futures Group (EFG) is mentioned in the context of providing recommendations.

Page 23 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 24 achieve a benefit-cost ratio of 1.0 or higher to be considered cost-effective. Looking forward, it is anticipated plan level screening...

AI summary EfficiencyOne (E1) discusses the benefit-cost analysis (BCA) test application for the 2023-2025 Demand Side Management (DSM) Plan. E1 argues that the Test of Reasonableness (TRC) applied is conservative and unbalanced, violating the symmetry principle of the Nova Scotia Power (NSPM). E1 also raised concerns about understated avoided costs and the need for an optimal BCA methodology.

Review Board (NSUARB) to work with the Demand Side Management Advisory Group (DSMAG) “to assess and develop an optimal DSM cost-effectiveness testing [benefit-cost analysis] methodology.” 16 Through a competitive RFP process, E1 hired Ener...

AI summary The NSUARB is working with the DSMAG to develop a new benefit-cost analysis (BCA) methodology for demand-side management (DSM) programs. E1 hired Energy Futures Group, Inc. to support this effort, which involved stakeholder engagement and a review of the current BCA test. There was a lack of consensus on the impacts included in the current test, leading to a recommendation for clearer documentation in the new BCA framework.

oard Decision. September 6, 2022, page 26, line 73. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 24 of 68 EfficiencyOne Benefit-Cost Ana...

AI summary This document outlines the proposed new Nova Scotia test(s) for screening the 2027-2031 E1 Plan Application, aiming to maintain the BCA test(s) in an 'evergreen' manner that aligns with Nova Scotia policy objectives. It discusses the consultant team's recommendations for the test, its usage, and methodologies for estimating benefits and costs.

dation for the Nova Scotia test, how the test will be used, and the methodologies for estimating benefits and costs. E1 identified several goals of updating the BCA framework. These include: • Nova Scotia’s BCA framework is updated to refl...

AI summary This document outlines the goals of updating Nova Scotia’s Benefit-Cost Analysis (BCA) framework to align with policy objectives and include all anticipated DSM programs. It emphasizes stakeholder input, the need for finalized frameworks by 2025, and the use of the updated test in E1’s 2027-2031 DSM Plan. The report also discusses the engagement of a consultant to support DSMAG working groups.

chnical support to and facilitate DSMAG working group discussions. Energy Futures Group (EFG) was selected through this process. Among other things, the Consultant was charged with drafting 17 Note, while this report focuses on a test for...

AI summary This document discusses the development of a uniform benefit-cost analysis (BCA) test for distributed energy resources (DERs) in Nova Scotia, informed by discussions with the Nova Scotia Power (NSPM) and the Demand Side Management Advisory Group (DSMAG). Energy Futures Group (EFG) was selected to draft the report.

27 Figure 2: Fundamental NSPM Benefit-Cost Analysis Principles 18 The NSPM also recommends a five-step process to develop a primary, jurisdiction-specific benefit-cost test for DERs. These steps are summarized in Figure 3. The focus of EFG...

AI summary The document outlines the NSPM's five-step process for developing a jurisdiction-specific benefit-cost test for DERs, with the EFG working with the DSMAG to recommend a primary BCA test based on these principles and methods.

28 Figure 3: NSPM Process to Defining a Jurisdiction's Primary Cost-Effectiveness Test The proposed Nova Scotia BCA test in this report was developed in a process that followed the first three of these five steps; steps 4 and 5 of the NSPM...

AI summary The document outlines the process used to develop a Benefit-Cost Analysis (BCA) test in Nova Scotia, including policy goals, applicable USIs, and non-USIs. The process involved workshops led by E1 and EFG, with participation from various organizations.

• Efficiency One (E1) • Energy Futures Group (EFG) • Synapse Energy Economics, on behalf of Counsel to NSUARB • Consumer Advocate • Nova Scotia Power • Small Business Advocate (SBA) • Industrial Group (IE) • Ecology Action Center (EAC) • Kwi...

AI summary The document outlines participants in a working group discussion on developing a Benefit-Cost Analysis (BCA) framework for Nova Scotia's energy policies. The group reviewed Nova Scotia energy policies and their applicability to DER types, including generation, transmission, distribution, and general/other. They also evaluated the inclusion of USIs and NUSIs in the 2023-2025 DSM Plan BCA test for EE and DR.

79H (2) The Board shall determine the cost-effective demand-side management at the portfolio level that would be the aggregate amount of demand-side management programs. 79L (4) The Board shall approve an application pursuant to this Secti...

AI summary The text discusses the Public Utilities Act's DSM section and its support for including various impacts in a BCA test. It also mentions the consideration of other Nova Scotia energy policies beyond the Energy Reform Act and Public Utilities Act, as identified by E1 and other stakeholders.

Page 31 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 32 Table 7 indicate how many stakeholder organizations indicated each policy (in the rows) has relevance when considering inclusion of the...

AI summary Table 7 presents a review of Nova Scotia policies and their relevance to various impact categories in the BCA framework, as assessed by stakeholder organizations. It categorizes impacts into utility system, non-utility system, and other areas.

nmental, public health, economic development/job, host customer – both for low/moderate income (LMI) households and for non-LMI customers, and diversity, equity, and inclusion (DEI) impacts. Energy Futures Group, Inc PO Box 587, Hinesburg,...

AI summary The text discusses the inclusion of various impact categories in the Benefit-Cost Analysis (BCA) test for Nova Scotia Power (NSPM). Some categories, such as jobs and economic development, are recommended for separate analysis, while others like resilience and public health are considered embedded in other categories to avoid double counting.

s that are not applicable to some DERs. In addition, even when categories of USI impacts are conceptually applicable to a DER, they may not be material enough to routinely include in a test. 1. Definitions and Examples USIs are elements of...

AI summary This text discusses the concept of utility system impacts (USIs) in the context of distributed energy resources (DERs), noting that not all USI categories are applicable to all DERs. It also references a benefit-cost analysis test application by EfficiencyOne and mentions the Energy Futures Group.

y Actions to comply with federal, state, and regional policies. Example Other Requirements would be FERC Order 2222 21 In Nova Scotia, E1 serves as a third-party administrator for DSM programs. The electric system USI’s in this report refe...

AI summary The document discusses actions to comply with federal, state, and regional policies, referencing FERC Order 2222. It outlines EfficiencyOne's role as a third-party administrator for DSM programs in Nova Scotia and mentions the DSMAG working group's focus on accounting for utility system impacts in a new BCA test.

indicating which of the utility system impacts in Table 8 were included in the BCA test that E1 used to screen the 2023-2025 DSM portfolio. Appendix B presents the results of this exercise. The results indicated there was not always a comm...

AI summary The text discusses the need for clarity and consensus on how to treat utility system impacts (USIs) in the Benefit-Cost Analysis (BCA) framework, particularly in the context of the 2023-2025 DSM portfolio. It highlights gaps in understanding around transmission and distribution loss factors and ancillary services valuation, and emphasizes the importance of stakeholder engagement and documentation.

oided costs. The working group further discussed why some impacts have not been included or fully incorporated in the BCA to date for EE and DR and options for including them moving forward: • Environmental compliance- Assuming Nova Scotia...

AI summary The working group discussed why some environmental compliance and utility direct investment impacts have not been fully included in the Benefit-Cost Analysis (BCA) for energy efficiency (EE) and demand response (DR) programs. It noted that environmental compliance costs may be embedded in avoided costs and that utility investments in distributed energy resources (DERs) could increase as technologies evolve.

ing support can also support building comfort and services during recovery. It is also possible for some DR assets to have cold-start capabilities and provide resilience value. 2. Nova Scotia Electricity Utility System Impacts BCA Proposal...

AI summary The text discusses the inclusion of Utility System Impacts (USIs) in the Benefit-Cost Analysis (BCA) test for Distributed Energy Resources (DER) in Nova Scotia. It emphasizes the importance of considering system impacts on generation, transmission, and distribution to ensure accurate BCA results.

energyfuturesgroup.com 37 shaded cells indicate an impact that was not included or only partially included in the 2023- 2025 DSM Plan BCA test. Table 9: Generation, Transmission and Distribution USIs Impact Type Impact EE DR DG DS EV BE En...

AI summary The table outlines the impact of various energy efficiency (EE), demand response (DR), distributed generation (DG), demand-side management (DS), electric vehicles (EV), and building efficiency (BE) initiatives on generation, transmission, and distribution utility system impacts (USIs). Shaded cells indicate partial or no inclusion in the 2023-2025 DSM Plan BCA test.

p.com 38 Table 10: General Electric USIs As part of the DSM plan development, the DSMAG is also reviewing updates to the electric system avoided costs through a separate engagement led by Nova Scotia Power. E1 anticipates using updated avo...

AI summary The document discusses the review of electric system avoided costs by the DSMAG and the use of updated avoided costs in the new test. It also mentions the inclusion of non-utility system impacts in the BCA test, including customer-specific benefits and policy-related impacts.

Page 38 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 39 comfort, and health) to societal impacts such as economic output, energy security and reduced environmental and economic damages from G...

AI summary The document discusses the inclusion of non-utility system impacts in a new Nova Scotia Benefit-Cost Analysis (BCA) test, emphasizing the importance of considering broader policy goals such as economic output, energy security, and environmental impacts under the Energy Reform Act (ERA).

lusion in the NS UBCA test Not included/or partially included in 2023-2025 test DER types not included in the 2023-2025 DSM plan While, in theory, all the categories in Table 11 are worthy of inclusion, the consultant team recommends a sub...

AI summary The consultant team recommends a subset of categories for inclusion in the BCA test for E1’s 2027-2031 DSM plan, acknowledging overlaps and the need to avoid double counting. They also recommend including other fuels, host customer costs and non-energy benefits, greenhouse gases, and criteria air pollutants as non-utility system impacts in the new Nova Scotia test.

lutants be included as non-utility system impacts in the new Nova Scotia test. The recommended treatment of other fuels, host customer, and societal impacts are discussed sequentially below. 2. Other Fuels Other fuels that can be saved by...

AI summary The document discusses the inclusion of other fuels such as pipeline gas, fuel oil, and propane in the new Nova Scotia test as non-utility system impacts. It notes that impacts are based on commodity prices rather than gas utility system impacts, and recommends including these in the new BCA test.

NSUARB directed the other fuel impacts be removed. The consultant team recommends other fuel impacts, including gas commodity costs, be considered in the new primary Nova Scotia BCA test. Energy Futures Group, Inc PO Box 587, Hinesburg, VT...

AI summary The NSUARB directed the removal of other fuel impacts, but the consultant team recommends considering gas commodity costs in the new primary Nova Scotia BCA test. The document is part of an EfficiencyOne Benefit-Cost Analysis Test Application.

demand created by BE, and implications on reliability, etc.) gas system infrastructure and operations. Key  Impacts that are both applicable and material NA Impacts that are not applicable to a given DER or in NS market NM Not material, o...

AI summary The document discusses host customer impacts related to distributed energy resources (DERs), distinguishing between energy and non-energy impacts. It notes that energy impacts are already accounted for elsewhere and focuses on non-energy benefits and costs, such as measure costs and incentives, which should be considered in a jurisdictional test. This is part of a benefit-cost analysis for a demand-side management (DSM) plan.

NA Many EE investments in businesses improve productivity + Economic well-being  NM     Energy bill savings reducing stress of disconnections, foreclosures, etc. +/- Comfort   NA NA  NA Most positive for shell measures, DR may have...

AI summary The text discusses the non-energy benefits of energy efficiency (EE) investments in businesses, including economic well-being, comfort, amenity, health and safety, empowerment, and pride. It also references Appendix F from the Database of Screening Practices, which highlights how over 18 jurisdictions consider non-energy host customer benefits in screening tests. E1 and the DSMAG have prior experience with reviewing host customer impacts in BCA testing.

eeningproject.org/state-database-dsp/ Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 42 of 68 EfficiencyOne Benefit-Cost Analysis Test App...

AI summary This section discusses a Benefit-Cost Analysis (BCA) test application by EfficiencyOne, focusing on non-energy benefits (NEBs) derived from Massachusetts and adjusted for Nova Scotia conditions. The analysis was reviewed by the Demand Side Management Advisory Group (DSMAG), with consideration of alternative methods such as percent adders for measure categories.

numerous occasions, and there was some discussion of using percent adders for different measure categories as an alternative to the adjusted measure- based values derived from Massachusetts. During the regulatory review of E1’s NEBs Applic...

AI summary The NSUARB ruled it lacks jurisdiction to consider non-energy impacts in cost-effectiveness testing. E1 included host customer costs and savings in its 2023-2025 DSM Plan, but the NSUARB directed their removal. Despite this, the BCA test in the plan still included some host customer costs.

23-2025 Plan 27 specifically (in August 2022) directed E1 to remove these impacts from the Compliance filing.28 However, the 2023-2025 DSM Plan BCA test did include host customer costs for 25 Efficiency One, In the Matter of the Public Uti...

AI summary The 2023-2025 DSM Plan BCA test included host customer costs for measures installed through E1 initiatives, despite the Public Utilities Act not allowing the Board to consider non-energy benefits (NEB) in the BCA test at the time of filing. The NSPM’s symmetry principle suggests that if host customer costs are counted, host customer benefits should also be considered.

ility impacts, in comparison to market rate activities. The values in Table 14 are also considered by EFG to be broadly consistent with the level of valuation adopted by other jurisdictions. The proxy values in Table 14 recommend different...

AI summary The document discusses non-energy benefits (NEB) proxy values for different customer segments and measure types, noting that higher values are recommended for income-qualified or disadvantaged communities. These values are considered consistent with those used in other jurisdictions.

to economic constraints may not have been able to make as many demand side energy investments in the past. Table 14: Consultant Team Host Customer NEB Proxy Adder Recommendations If, over time, more research is done on the customer valuati...

AI summary The text discusses the limitations of data on non-energy impacts (NEBs) in Nova Scotia and the need for a generalized approach in the Benefit-Cost Analysis (BCA) framework. It highlights that the proposed proxy adder values for NEBs are modest compared to other benefit and cost categories, and suggests that these approximations may be acceptable due to resource constraints.

as levelized $ per kWh, are presented in Table 16. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 47 of 68 EfficiencyOne Benefit-Cost Anal...

AI summary The document compares non-energy impact (NEI) benefits from energy efficiency programs in Massachusetts with proxy values recommended for Nova Scotia. The NEI benefits in Massachusetts range from 2.6 to 34 cents per kWh, while the recommended proxy values for Nova Scotia range from 4.2 to 9.5 cents per kWh. The consultant team considers the proxy approach as conservative and appropriate.

ropriate balance between complexity required to estimate the NEI’s separately for each individual measure, and the past default of not counting host customer NEI benefits in the BCA test. 32 Derived from 2023 Electric Statewide Summary Rep...

AI summary The text discusses the balance between estimating non-energy impacts (NEI) separately for each measure and past practices of not counting host customer benefits in the BCA test. It also references a table on societal impacts for different types of distributed energy resources (DER).

NA NA   NA NA stations, police, water treatment facilities, etc.) Impact of changes in GHG emissions on Greenhouse Gas Emissions  NM  NM   society and the environment Impact of changes in other emissions or Other Environmental   ...

AI summary The text discusses the recommendation to include quantification of economic and environmental impacts from GHG and other air pollutants in the BCA test for the 2027-2031 DSM plan application. It notes that the E1 portfolio and support for DERs provide additional societal benefits beyond these categories.

ent-climate-change/services/climate-change/science-research-data/social- cost-ghg.html 35 Appendix C provides the updated social costs of carbon dioxide, methane and nitrous oxide. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461...

AI summary The text references the updated social costs of greenhouse gases and discusses the methodology used by the US Environmental Protection Agency (EPA) for calculating benefits-per-kilowatt-hour (BPK) of air quality-related public health benefits from energy efficiency and renewable energy investments, specifically using New England regional values in a Benefit-Cost Analysis (BCA) test.

36 The consultant team recommends using the New England regional values developed by the EPA in this analysis for valuation per kWh of the reduction of other air pollutants in the BCA test. The EPA calculates BPK for different regions of t...

AI summary The consultant team recommends using New England regional values from the EPA for calculating the benefit per kWh of air pollutant reductions in the BCA test. These values range from 0.34 to 0.77 cents per kWh for energy efficiency and DERs, and are considered the low end of the range due to differences in fossil fuel mix across regions.

sider modifying these values to more accurately reflect specific Nova Scotia conditions and dynamics contributing to the valuation of impacts for criteria air pollutants if deemed desirable. During the discussion of quantifying criteria ai...

AI summary The document discusses the modification of criteria air pollutant values to better reflect Nova Scotia conditions. It raises concerns that absolute emissions caps may not reduce pollutants with increased DER deployment, but recommends adopting New England values for the 2027-2031 DSM plan. A benefit-cost analysis suggests using 0.55 cents per kWh for the BCA test in Nova Scotia.

mental policy objectives. We recommend a value of 0.55 cents per kWh be adopted for the Nova Scotia BCA test, based on a simple average of the US EPA benefit per kWh method for New England. We note that the BPK method does not include calc...

AI summary The document recommends a BCA test value of 0.55 cents per kWh for Nova Scotia, based on a simple average of the US EPA benefit per kWh method for New England. It notes that the BPK method does not account for offset emissions from avoided on-site combustion, particularly for heat pumps, and suggests the need for more detailed data and analysis.

energyfuturesgroup.com 54 VI. Example Quantification of Impacts for Nova Scotia Test 1. Introduction The consultant team recommends the new Nova Scotia test include electric utility system impacts, other fuel impacts, host customer impacts...

AI summary This section introduces the recommended approach for quantifying impacts in the new Nova Scotia test, including electric utility system impacts, other fuel impacts, host customer impacts, and GHG and air pollution emission impacts. It emphasizes that these examples are illustrative and may be updated based on stakeholder input and future analysis.

and impacts between DERs are more likely for certain costs and benefits. Interactive effects are not addressed in this report but are important areas for future analysis and consideration. 2. Residential Heat Pump Example Two cases for a c...

AI summary The text discusses the interactive effects of DERs and presents a residential heat pump example to illustrate the application of the new BCA test. It includes assumptions about system efficiency, fuel prices, and carbon pricing, with references to external data sources.

Page 54 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 55 The consultant team recommends a real societal discount rate of 2% be used for the primary BCA test. This recommendation is based on th...

AI summary The document discusses a Benefit-Cost Analysis (BCA) test recommending a 2% real societal discount rate for evaluating the DSM plan's impact on reducing greenhouse gases. It provides an example of 1,000 residential heat pumps replacing heating oil, highlighting the discounted value of saved fuel oil and the exclusion of carbon price for heating oil until March 2027.

rice inclusion for heating oil through March 2027. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 55 of 68 EfficiencyOne Benefit-Cost Anal...

AI summary The document includes a table titled 'Residential Heat Pumps – Fuel Oil Example' which examines the impact of other fuel, specifically heating oil, in the context of a benefit-cost analysis test application submitted by EfficiencyOne.

13 0.80 $ 2,679,751 2.0% 12 2037 $ 0.53 $ 2.05 $ 1.53 2,186,513 0.79 $ 2,634,238 2.0% 13 2038 $ 0.54 $ 2.07 $ 1.53 2,186,513 0.77 $ 2,589,529 2.0% 14 2039 $ 0.55 $ 2.08 $ 1.54 2,186,513 0.76 $ 2,545,608 2.0% 15 2040 $ 0.56 $ 2.10 $ 1.54 2,...

AI summary The text discusses the offsetting effects of fuel oil savings and increased electric system costs, captured under utility system impacts in the BCA framework. It references Table 19, which outlines the financial implications of energy generation and system capacity costs, and notes the net impact of $21.5 million.

LA, ME, MD, MA, NV, NH, NY, OH, OR, PA, PR, RI, VT, WA. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 67 of 68 EfficiencyOne Benefit-Cost...

AI summary This document is an appendix to an EfficiencyOne Benefit-Cost Analysis Test Application, submitted by Energy Futures Group, Inc. It includes contact information for the company and the date filed, May 16, 2025. The content appears to be part of a regulatory proceeding.

1 Request IR-05: 2 3 Reference: Appendix 8, page 17: "EFG recommends treating gas impacts through the 4 commodity costs is appropriate due to the relatively small size of the gas system and the 5 anticipated level of "DSM portfolio impacts...

AI summary The text discusses the anticipated level of DSM portfolio impacts on the gas system, noting that gas savings from DSM programs are expected to be significantly less than for electricity and other fuels due to the limited service territory of the gas system and program design choices. This is supported by the EFG Report's illustrative example.

- 2 Fuel Impact Nat Gas' worksheet. 3 2.0% 15 2040 $ 10.39 $ 15.71 $ 5.33 84,470 0.74 $ 334,282 $ 6,196,318 1 Request IR-07: 2 3 Reference: General 4 5 (a) How does the benefit-cost test capture the cost of additional pressure on meeting t...

AI summary The document discusses the benefit-cost analysis of strategic electrification, including how it captures the costs of increased electric utility peak demand and infrastructure upgrades. It also asks whether E1 has coordinated with the electric utility's planning department and whether hybrid peaking or dual fuel opportunities were evaluated.

M12282 – EfficiencyOne (E1) Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans 1 Request IR-08: 2 3 Reference: Appendix B, Table 5 4 5 (a) Please explain what is meant by "S...

AI summary The document includes a request for clarification on the methodology used in a Benefit-Cost Analysis (BCA) for evaluating Demand Side Management (DSM) plans. Questions pertain to the social cost of carbon, direct measure costs, and the reliability impact of measures that increase peak load on the electric system.

(f) Yes, please refer to parts (d) and (e) of this IR response. 1 Request IR-09: 2 3 Reference: Appendix B, Textbox 1, Item 8 "EFG also recommends the use of the benefit per 4 kilowatt hour estimates for local non-greenhouse gas air pollut...

AI summary The document references a benefit-cost analysis framework and discusses the use of US EPA estimates for non-greenhouse gas air pollutants in Nova Scotia. It also addresses the appropriateness of NEB proxy adders and potential risks from strategic electrification. Responses direct readers to other documents for detailed explanations.

M12282 – EfficiencyOne (E1) Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans

AI summary EfficiencyOne (E1) seeks approval for a new Benefit-Cost Analysis (BCA) test to evaluate Demand Side Management (DSM) plans in Nova Scotia. The application aims to establish a revised methodology for assessing DSM initiatives under regulatory oversight.

regulator, and stakeholders, to gain insights and knowledge about the cost effectiveness of the DSM Plan. E1 understands the results may be used to inform, guide discussion, and support recommendations as opposed to using them as a binding...

AI summary E1 explains that the PAC test results are for informational purposes and not for determining funding levels or approving the DSM Plan. The Public Utilities Act mandates cost-effective demand-side management, and E1 must determine the appropriate investment level through the DSM Plan development process, considering factors like the Integrated Resource Plan and historical performance.

E1 Responses to Industrial Group (IG) Information Requests NON-CONFIDENTIAL - 1 framework for evaluation. Secondary tests may be used to provide additional insights, and 2 to help understand implications from different perspectives (e.g.,...

AI summary E1 responds to information requests regarding demand-side management (DSM) tracking and reporting. E1 outlines the use of quarterly and annual progress reports to track DSM performance and costs, and proposes a periodic review of the BCA test through the DSMAG. A referenced matter, M12282, is mentioned in the response.

(b) Confirmed. Please refer to EFG's Report[1](#page-23-0) 1 , Summary Table 1, page 12. 2 3 (c) Yes, with the above noted exception that the proposed Nova Scotia Jurisdictional Test 4 (NSJT) test will not address green jobs creation and s...

AI summary The document addresses the Nova Scotia Jurisdictional Test (NSJT) and its limitations in addressing green jobs creation and economic growth. EfficiencyOne (E1) argues that the Energy and Regulatory Boards Act supports considering sustainability and innovation objectives, which indirectly influence the benefit-cost analysis (BCA) test. The Energy Board is not explicitly mandated to assess job market or economic growth impacts.

2 Energy Reform Act, April 5, 2024, Schedule A: Energy and Regulatory Boards Act. 1 stewardship and social responsibility are integrated and recognized as being 2 interconnected." 3 4 (e) The following IR response has been provided by Ener...

AI summary The document discusses the Energy Reform Act, April 5, 2024, Schedule A: Energy and Regulatory Boards Act, and references the Nova Scotia benefit cost analysis (BCA) test, which considers both increases and decreases in fuel and electricity use. Energy Futures Group (EFG) confirms that utility system impacts are included in the analysis, with details provided in Section IV of the EFG Report starting on page 33.

(c) Please refer to part (b) of this IR response. M12282, E1 BCA Test Application, May 16, 2025, Appendix A, Attachment 2: National Standard Practice Manual, pages 264-265 of 302. 1 Request IR-13: 2 3 References: E-1, Appendix B; and Evide...

AI summary The document requests an explanation of why only American jurisdictions were reviewed in the E1 BCA Test Application and asks for analysis on DSM cost-effectiveness metrics used in Canadian jurisdictions, including benefit-cost analysis tests and whether electrification, solar-PV, and storage are evaluated together with energy efficiency and demand-side management plans.

Date Filed: July 4, 2025 E1 (IG) IR-13 Page 2 of 2 M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, S...

AI summary This document discusses the request for approval of a new Benefit-Cost Analysis (BCA) framework, including the use of a 2% social discount rate and the inclusion of proxy adders for non-energy benefits. It outlines the mathematical representation of the BCA test, which includes utility system impacts, host customer impacts, and societal impacts.

6 Request IR-16: Please indicate if, or how, the proposed BCA test can help inform the appropriate level of incentives or subsidies for participation in efficiency initiatives and provide an example. Response IR-16: One of the factors that...

AI summary The response to Request IR-16 explains how the proposed BCA test will replace the current TRC test to assess the cost-effectiveness of efficiency measures. It highlights that the BCA considers both customer costs and incentive costs, with the ratio calculated by dividing total benefits by total costs. An example from Energy Futures Group is referenced.

Date Filed: July 4, 2025 E1 (IG) IR-16 Page 1 of 2 M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, p...

AI summary The text presents a Benefit-Cost Analysis (BCA) framework example, showing how changes in incentive amounts affect host customer measure costs while maintaining a constant benefit-cost ratio of 4.17. Total benefits are listed as $41.26, and total costs are $9.9, with incentives playing a key role in adjusting costs without affecting the ratio.

nd c) proxy host customer non-energy benefits are estimated based on a set of proxy adders that were developed by EFG and reviewed with the Demand Side Management Advisory Group (DSMAG).[3](#page-4-1) Table 7 in the EFG Report[4](#page-4-2...

AI summary The document discusses how non-energy benefits for proxy host customers are estimated using proxy adders developed by EFG and reviewed by the DSMAG. It also references various Nova Scotia policies, regulations, and external guidance to support the inclusion of health impacts, avoided damages from greenhouse gas emissions, and host customer impacts in the BCA. Indirect benefits and costs are excluded from the BCA.

rvices/climate-change/science-research-data/social-cost-ghg.html)[cost-ghg.html](https://www.canada.ca/en/environment-climate-change/services/climate-change/science-research-data/social-cost-ghg.html) See Table 14 of the EFG Report for a l...

AI summary The document references a BCA Test Application and discusses the exclusion of indirect benefits and costs in the BCA. It also outlines EFG's approach to impact category weighting and the inclusion of non-utility benefits in the BCA analysis, aligning with policy and regulatory requirements.

consistent with policy, planning and regulatory requirements as discussed in part (a) of this IR response. Including non-utility benefits in the BCA test has no impact on the "reasonable availability" - of potential measures. E1's portfoli...

AI summary E1 asserts that including non-utility benefits in the BCA test does not affect the reasonable availability of measures and is consistent with policy and regulatory requirements. A separate RBIA is conducted to assess ratepayer impacts. The repeal of section 79L from the Public Utilities Act did not directly impact the BCA framework. E1 emphasizes that performance targets and indicators are part of the DSM Plan development process and will be discussed with the DSMAG.

1 Request IR-03: 2 3 With regards to Table 2 on page 4 of 38 of E1's Evidence: 4 5 (a) Did E1 review any Canadian jurisdictions with similar policy objectives as Nova Scotia to 6 assess how the current TRC test aligns with standard for cos...

AI summary E1 was asked to review Canadian jurisdictions with similar policy objectives to Nova Scotia for cost-effectiveness testing alignment. E1 responded that their research did not include such a review, as a Nova Scotia-specific BCA must reflect the province's own legislative, regulatory, and policy context.

- Scotia in past demand side management (DSM) applications with the new recommended - BCA test. - i) Please refer to part (a) of this IR response. - ii) Please refer to part (a) of this IR response. (b) Policy objectives and legislation fo...

AI summary The text references a BCA test application and discusses policy objectives related to greenhouse gas emissions reduction and energy affordability and equity in four states similar to Nova Scotia. It also references a document (M12282) and page numbers from an evidence submission.

Ibid, page 4 of 38. Ibid, page 4 of 38. 1 Request IR-04: 2 3 Page 4 of 38 discusses the shortfalls of the TRC test as ignoring the symmetrical benefits 4 corresponding to a cost, arguing that such an approach "unjustly favour or disadvanta...

AI summary The document discusses the shortfalls of the Total Resource Cost (TRC) test, noting that it ignores symmetrical benefits corresponding to costs, which may unjustly favor or disadvantage certain resources. It also addresses the Benefit-Cost Analysis (BCA) test, explaining that all measures in the BCA have costs and benefits, though some benefits may not be measured or included.

- 2 system benefit that is not measured and is considered not material. 1 Request IR-05: 5 (a) Treasury Board of Canada Secretariat Guidance (TBCS): Include all relevant economic, 6 environmental, and social impacts 7 BCA: includes utility...

AI summary The document outlines the considerations for a Benefit-Cost Analysis (BCA) in relation to Demand Side Management (DSM) programs, emphasizing the inclusion of economic, environmental, and social impacts, full lifecycle analysis, and market adjustments. It notes that Nova Scotia does not participate in an organized wholesale electricity market, affecting the inclusion of certain metrics.

e currently measuring Host Customer "Asset Value" impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure, program or portfolio level.)

AI summary The text asks whether the current Benefit-Cost Analysis (BCA) test measures Host Customer 'Asset Value' impacts, and seeks clarification on the states involved and the level (measure, program, portfolio) at which the test is applied.

d at the portfolio level in New York. - iii) The data requested for inquiries (iii) through (xviii) are set out in the database as depicted in the Impacts Summary graphic below taken from the website: [https://public.tableau.com/app/profil...

AI summary The text references a database of state efficiency screening practices and suggests that information from other jurisdictions is not relevant to the proposed Nova Scotia specific BCA test. It emphasizes the need to develop a test aligned with Nova Scotia's policy priorities rather than relying on external practices.

Date Filed: July 4, 2025 E1 (NSEB) IR-07 Page 9 of 9 1 Request IR-08: 2 3 With respect to the NSPM for Benefit-Cost Analysis of Distributed Energy Resource: 4 5 (a) Please identify any Canadian jurisdictions that have adopted the NSPM as t...

AI summary The document discusses a request for information on the adoption of the National Standard Practice Manual (NSPM) for Benefit-Cost Analysis (BCA) in Canadian jurisdictions, and the response by Energy Futures Group (EFG) stating no jurisdictions have adopted it. It also references feedback from the Demand Side Management Advisory Group (DSMAG) regarding the final draft EFG report, emphasizing stakeholder engagement and confidentiality.

Ibid. 1 Request IR-10: 2 3 Table 4: NSPM BCA Guiding Principles 4 5 (a) Principle 5 identifies that the analysis should be forward looking and compared against a 6 scenario without the Distributed Energy Resources (DER). Please explain why...

AI summary This document discusses the application of a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans. It addresses the principle of using a scenario without Distributed Energy Resources (DER) as the basis for comparison in BCA analysis and confirms that all utility system impacts included in the TRC test are identified in Table 6 of E1's Evidence.

- Page 29 of 38 of E1's Evidence states: "As explained in the NSPM, best practices suggest that - all impacts relating to a jurisdiction's policy goals and objectives should be included in a - jurisdiction's BCA test." - (a) Is E1 or its c...

AI summary E1's evidence references the NSPM's guidance on including all policy impacts in a BCA test. The response from EFG confirms no alternative practices exclude such impacts. The Nova Scotia Energy Board retains discretion to approve DSM portfolios not meeting the BCA threshold based on broader planning objectives and public interest, as mandated by the Public Utilities Act.

Request IR-13: Page 30 of 38 of E1's Evidence states: "The impact of changes in pipeline gas consumption are based on commodity prices, and do not reflect gas utility system impacts. However, presuming gas commodity prices are the largest...

AI summary The response to IR-13 clarifies that the impact of changes in pipeline gas consumption in the BCA test is based on gas commodity costs, which are considered to represent the majority of gas utility system impacts. The response also notes that estimating impacts related to fixed base energy charges or transportation costs is not currently feasible due to a lack of available data.

The proxies in Table 14 recommend different values depending on the measure type and the customer segment. For example, for residential customers, building shell measures are deemed most likely to result in improved comfort, durability, an...

AI summary The proxies in Table 14 vary based on measure type and customer segment, with higher values for income-qualified or disadvantaged communities. This reflects the recognition that non-energy benefits may be greater for these groups due to past limitations in energy investments. The analysis is drawn from an E1 BCA Test Application and an EFG Report.

dix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 42 of 68. Ibid., page 45 of 68. - i) The EFG report contains citations for comparative information...

AI summary The EFG report discusses the use of proxy values for non-energy impacts in a jurisdictional benefit-cost analysis (BCA) framework for Nova Scotia. It acknowledges that while detailed survey research could provide more accurate estimates, it would be too resource-intensive. Instead, the proxy method is recommended as a practical and cost-efficient approach, with the evergreen process allowing for future refinement of these values.

- measures because they often have lower operations and maintenance than a standard measure. (c) Unit of output per unit of input can be related to labor and non-labor inputs in an office or non-office environment. Efficient measures (for...

AI summary The text discusses how energy efficiency measures can improve comfort through better building performance and controls, and how comfort is considered a non-energy benefit in benefit-cost analysis. It references the EFG Report and a specific BCA Test Application (M12282) that includes a 10% proxy adder benefit for heat pumps.

y 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 42 and page 45 of 68. Ibid., page 19 of 68. that includes the comfort and other no...

AI summary The document discusses the inclusion of non-energy benefits in a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia, specifically highlighting a 10% proxy adder for beneficial electrification, such as heat pumps. It defines terms like 'amenity,' 'empowerment,' and 'pride' as components of these non-energy benefits.

- (c) Public health benefits are related to a reduction in mortality and morbidity rates and associated health care and economic costs associated with each. Energy efficiency reduces the need for electric generation, and associated combust...

AI summary The text discusses public health benefits from energy efficiency and their integration into the BCA test, as well as energy security impacts and their exclusion from the new BCA test. It notes that energy efficiency reduces fossil fuel combustion and that energy security improvements from distributed energy resources are not included in the BCA test.

1 Request IR-19: 2 3 Please provide supporting empirical evidence demonstrating causation for the following 4 Societal Impacts: 5 6 (a) energy efficiency investments and changes in medical outcomes and costs. 7 8 Response IR-19: 9 10 The f...

AI summary The document requests empirical evidence linking energy efficiency investments to medical outcomes and costs and asks for the source of the carbon cost used in the BCA. EFG responds by citing the Interim Updated Guidance from the Government of Canada and refers to EfficiencyOne's previous responses.

(c) In a benefit cost test for demand side management, the social discount rate is used to convert future costs and benefits into their present-day values. This allows for a comparison of costs and benefits that occur at different points i...

AI summary This section discusses the use of a 2% real social discount rate in benefit-cost tests for demand side management, emphasizing its alignment with Nova Scotia's sustainability and prosperity goals. It notes that this rate is lower than a utility weighted average cost of capital and places greater value on future impacts. Figure G-1 from the National Standard Practice Manual illustrates how different discount rates affect DER benefits.

[3](#page-48-0) M12282, E1 BCA Test Application, May 16, 2025, Appendix A, Attachment 2: National Standard Practice Manual, page 276 of 302. i) EFG did not conduct a review of discount rates used in cost effectiveness testing in Canadian j...

AI summary The document references a BCA Test Application and discusses the lack of a review of discount rates used in cost effectiveness testing in Canadian jurisdictions. It highlights the importance of developing a jurisdiction-specific BCA test that aligns with Nova Scotia's policy goals and objectives, and references the Database of State Screening Practices for American discount rates.

3 1 Request IR-21: 2 3 Table 10: Impact Categories for BCA Test identifies that Impacts Measured for Gas is embedded 4 in Other Fuels, Resilience is embedded in Host Customer, and that Public Health is embedded 5 in another GHG Emissions....

AI summary The document discusses the inclusion of impact categories in a Benefit-Cost Analysis (BCA) test for gas systems and the need for additional data to quantify non-commodity gas system impacts. Energy Futures Group (EFG) confirms the inclusion of these measures and explains that infrastructure and operations data are required to estimate non-commodity impacts.

Request IR-23: Reference: Appendix A, Mr. Hill's Evidence Page 8 of 18 of Mr. Hill's evidence notes that criteria air pollutant non-utility impacts for the proposed BCA test are based on modelling of estimated health impacts for the New En...

AI summary The response to Request IR-23 explains that health impacts in Nova Scotia could differ from those in New England due to factors like differences in electric generation mix, ambient air quality, weather patterns, and population health baselines. The EFG Report suggests that using New England per kWh values is conservative, considering Nova Scotia still has some coal generation.

- Halifax Regional Municipality. 1 Request IR-25: 2 3 Reference: Appendix A, Mr. Hill's Evidence 4 5 Table 3 on Page 12 of 18 of Mr. Hill's Evidence: Data Sources and Application in Developing 6 Recommended Nova Scotia Test: 7 8 (a) For th...

AI summary The response to Request IR-25 discusses assumptions made by Energy Futures Group (EFG) regarding program administration and incentive costs, as well as the removal of carbon costs for fuel under 'Other Fuels' to avoid double counting. EFG used a 40% market rate incentive and installed measure costs of $8,000 for heat pumps in 2026. Carbon costs for fuels were excluded from 'Other Fuels' and accounted for under 'Societal' impacts using the social cost of carbon.

Date Filed: July 4, 2025 E1 (NSEB) IR-25 Page 4 of 4 1 Request IR-26: 2 3 Reference: Appendix B EFG Report 4 5 Please provide the proposed BCA in excel format with cells intact and worksheets unprotected. 6 Additionally, provide references...

AI summary The document outlines requests and responses related to the Benefit-Cost Analysis (BCA) framework for evaluating Demand Side Management (DSM) plans in Nova Scotia. It includes a request for an Excel version of the BCA and references for each measure, as well as a response providing an illustrative workbook and clarification on host customer costs and benefits.

Date Filed: July 4, 2025 E1 (NSEB) IR-27 Page 2 of 2 1 Request IR-28: 2 3 Reference: Appendix B EFG Report 4 5 Page 8, under Not Material explains that some outcomes that don't produce a large enough 6 effect are excluded from the BCA. Ple...

AI summary The response to Request IR-28 identifies several impacts excluded from the BCA due to insufficient effect size, including renewable portfolio standard compliance, ancillary services for electric vehicles, and distribution voltage impacts for DER. These impacts are considered unlikely to significantly affect cost-effectiveness screening results.

- 4 Other environmental and public health for distributed storage. 1 Request IR-29: 2 3 Reference: Appendix B EFG Report 4 5 With regards to Table 2 on page 13 of 68 of the EFG Report: 6 7 (a) Please describe any initiatives that E1 curren...

AI summary The response to Request IR-29 outlines that E1 is exploring solar-PV for its 2027-2031 DSM Plan but has no current or planned initiatives for distributed storage (DS) incentives. E1 currently supports existing batteries through its demand response program, not for new installations. This response highlights the distinction between existing and new battery initiatives.

M12282 – EfficiencyOne (E1) Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans - 1 this calculation. E1 is interested in working with NS Power, the Demand Side Management -...

AI summary EfficiencyOne (E1) is seeking approval for a new Benefit-Cost Analysis (BCA) test to evaluate Demand Side Management (DSM) plans. The application involves collaboration with NS Power, the Demand Side Management Advisory Group (DSMAG), and potentially the Nova Scotia Independent Energy System in the future.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL being unbalanced and biased by including host customer costs but not host customer benefits as noted in Synapse Energy Economics Inc.'s Evidence.[1](#pag...

AI summary E1 responds to Nova Scotia Energy Board (NSEB) information requests regarding the Benefit-Cost Analysis (BCA) test for DSM plans. E1 proposes an 'evergreen' periodic review process through the DSMAG to ensure the BCA test remains current and aligned with policy objectives. The 2027-2031 DSM Plan is expected to implement the new BCA test, with results by measure, program component, and resource.

- 3 Fulfillment of any directives provided by the NSEB outlined in their decision on E1's 4 BCA Application. 1 Request IR-36: 5 Table 6: Illustrative Example Present Value Benefits, Costs and Ratios, provides the present 6 value of the hea...

AI summary The text discusses the time horizon for discounting costs and benefits in a benefit-cost analysis (BCA) related to heat pump replacements. The analysis spans 15 years, from 2026 to 2040, and applies to measures within a demand-side management (DSM) plan with varying lifetimes.

M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 14 of 68. 1 Request IR-39: 5 Table 9 identifies...

AI summary The response to Request IR-39 explains that E1 considers the effects of demand-side management (DSM) on transmission and distribution systems significant enough to include in the benefit-cost analysis (BCA). This is because distributed energy resources (DERs), such as efficiency measures and electric vehicles, can impact the capacity of these systems, and excluding these impacts would be a mistake.

- (h) Please refer to part (a) of this IR response. 1 Request IR-42: 2 3 Reference: Appendix B EFG Report 4 5 Table 17: Societal Impacts lists Energy Security which is described as changes in energy 6 independence. Please elaborate on this...

AI summary The response to IR-42 discusses Energy Security as part of societal impacts, noting that Energy Futures Group (EFG) does not recommend quantifying it in the new jurisdictional cost effectiveness test. EfficiencyOne (E1)'s activities and programs are highlighted as improving energy security by reducing reliance on imported fossil fuels and promoting local renewables.

Request IR-46: Reference: Appendix B EFG Report Page 58 notes that the cost of carbon is based on December 2022 updates from Environment Canada. Given that Canada has effectively abolished the federal carbon tax system in April 2025. Does...

AI summary The response to Request IR-46 clarifies that the social cost of carbon is based on December 2022 data and is not affected by the abolition of the federal carbon tax in 2025. EfficiencyOne (E1) will continue to use updated carbon pricing values in its Benefit-Cost Analysis (BCA) framework for Demand Side Management (DSM) Plan Applications.

Request IR-01: Refer to Exhibit E-1 EfficiencyOne's Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans, (the "Application") filed May 16, 2025, E1 Evidence, page 34 of 38, T...

AI summary The document details a regulatory request (IR-01) for EfficiencyOne's (E1) application to approve a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans. E1's response refers to Energy Futures Group's (EFG) workbook and report, which provide formulas, data sources, and examples for calculating non-utility impact categories. Key references include EFG's report (Appendix B) and specific tables from E1's evidence.

1 Request IR-07: 2 3 Refer to Exhibit E-1, the Application, Table 2, page 4 of 38. For each listed state: 4 5 (a) Please provide the specific state's stated policy objectives, legislation, or publicly 6 adopted goals that align with Nova S...

AI summary The response to Request IR-07 indicates that Energy Futures Group (EFG) did not conduct a detailed comparison of cost-effectiveness testing between Nova Scotia and other jurisdictions. Instead, EFG focused on developing a Nova Scotia-specific benefit cost analysis (BCA) aligned with local policy objectives. The information in Table 2 was provided for context but was not central to the BCA development process.

Request IR-08: Refer to Exhibit E-1, the Application, page 18 of 38, line 5. Regarding the creation of green jobs and stimulating economic growth, please provide the results of econometric modeling that EOne has performed or commissioned t...

AI summary The response to Request IR-08 indicates that EfficiencyOne has not conducted econometric modeling to assess the economic and job impacts of the proposed BCA Test. The Energy Futures Group (EFG) Report is referenced, suggesting that such impacts should be analyzed separately.

of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 12 & 33 of 68. recommended for inclusion in the proposed BCA. [1](#page-11-0) Request IR-09: Refer to Exhibit E-1, the...

AI summary The response to Request IR-09 discusses how the current Total Resource Cost (TRC) test in Nova Scotia does not adhere to the National Standard Practice Manual (NSPM) in several key principles, including the treatment of DERs, alignment with policy goals, symmetry, and inclusion of material impacts such as host customer costs.

but not host customer benefits. [1](#page-13-0) Please refer to Table 4 of Appendix A (reproduced below)[2](#page-13-1) and the associated discussion. Cost Effectiveness Test Impact Category New Nova Scotia Test Total Resource Cost Test (N...

AI summary The document discusses the Nova Scotia proposed Benefit Cost Analysis (BCA) test, which aligns with the National Standard Performance Manual (NSPM) and includes new impact categories such as other fuels, criteria air pollutants, and host customer non-energy benefits. The test was developed with input from the Demand Side Management Advisory Group (DSMAG) and reflects legislative changes, including the Energy Reform Act and amendments to the Public Utilities Act.

Request IR-10: Refer to Exhibit E-1, the Application, page 23 of 38, lines 25-26. (a) Please provide the criteria used to categorize each impact category as reliable. (b) Please note for each category's impact how it was measured for Nova...

AI summary The response to Request IR-10 explains that Energy Futures Group (EFG) did not classify data sources as reliable or unreliable but considers referenced data reliable. Reliable data sources include NS Power, government data, and the U.S. Energy Information Administration. The impact categories are based on data from NS Power and EfficiencyOne, with societal impacts informed by updated social cost of carbon guidance.

E1 Responses to Small Business Advocate (SBA) Information Requests NON-CONFIDENTIAL 1 from the Government of Canada, and host customer impacts are based on proxy adder 2 methods. Other environmental impacts (other air pollutants) are based...

AI summary This document provides responses from EfficiencyOne to information requests from the Small Business Advocate, focusing on environmental impact assessments. The methods used are based on proxy adder methods and regional values from the U.S. Environmental Protection Agency. Additional details are referenced in Appendix B of the EFG Report.

Request IR-11: Regarding Exhibit E-1, the Application, page 26 of 38, table 5, please define in detail and provide examples for Host Benefits, Resilience, and Public Health. Response IR-11: The following IR response has been provided by En...

AI summary The response to Request IR-11 defines Host Benefits, Resilience, and Public Health in the context of a Benefit Cost Analysis (BCA) test. Host Benefits are detailed in a report, Resilience is considered part of utility system impacts, and Public Health benefits are included in greenhouse gas and air pollutant impact categories.

Date Filed: July 4, 2025 E1 (SBA) IR-11 Page 1 of 1 M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group,...

AI summary The document contains a request from the Small Business Advocate (SBA) for definitions and examples of how energy efficiency measures improve comfort and health, and how these benefits are monetized in the BCA Test. The response refers to EfficiencyOne's (E1) previous responses to related information requests.

Date Filed: July 4, 2025 E1 (SBA) IR-12 Page 2 of 2 1 Request IR-13: 2 3 Refer to Exhibit E-1, the Application, pages 32-33 of 38. 4 5 (a) Please provide detailed definitions and practical examples of: 6 i) Tax Impacts (specifically explai...

AI summary The document requests detailed definitions and examples of tax impacts, productivity, economic well-being, comfort, and amenity, as well as explanations on how energy efficiency affects resilience and reliability. The response provided by Energy Futures Group explains that tax incentives lower measure costs and that tax impacts are treated as transfer payments in regulatory BCA tests.

Request IR-15: Referring to Exhibit E-1, the Report, Page 45 of 68, Table 14, please explain how the percentages in columns 2 and 3 are created – what are the data points that are used to create the percentage? (a) Please explain how the c...

AI summary The response to Request IR-15 explains that the percentages in Table 14 of the EFG Report are based on expert opinion and stakeholder discussions, and are consistent with the NSPM's principles for handling hard-to-quantify impacts. The use of reliable data where available is emphasized, though some impacts may lack current studies.

Date Filed: July 4, 2025 E1 (SBA) IR-15 Page 1 of 2 M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group,...

AI summary The text discusses the use of proxy adders in benefit cost analysis, stating that their use is appropriate when reliable data is unavailable. It also references a request for working spreadsheets and workpapers used to derive tables in a report, with a response directing to EfficiencyOne's response to NSEB IR-26.

Request IR-17: - Please list the programs and potential funding level that are expected to pass the new BCA Test - that would not have passed the current cost-benefit testing. Response IR-17: EfficiencyOne (E1) expects the new benefit cost...

AI summary EfficiencyOne (E1) expects the new Benefit Cost Analysis (BCA) to be used in the 2027-2031 DSM Plan, replacing the current Total Resource Cost (TRC) test. The new BCA will allow for the evaluation of non-energy benefits, such as those for low-income and equity, and may improve the results of energy efficiency programs compared to the TRC.

- (b) Yes, with specific considerations for water system impacts that are not addressed in the current application. - (c) Capital budgeting for the Province and other public/private actors can be informed by the recommended jurisdictional...

AI summary The response confirms approval with specific considerations for water system impacts and suggests that a jurisdictional benefit cost test can inform capital budgeting but should be treated as a separate analysis considering various factors.

Date Filed: July 4, 2025 E1 (Synapse) IR-02 Page 2 of 2 2 Ibid., Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 19 of 68. 1 Request IR-03: 2...

AI summary The document discusses a request for supporting analysis and workpapers related to the BCA Test for heat pumps. E1 clarifies that the example provided was illustrative and not based on a specific program design, and that they did not perform a separate TRC test for the heat pump example.

Refer to pages 8 and 9 of the Evidence of David Hill, regarding the statements "The numbers in the cells of this table indicate how many of the DSMAG organizations indicated each policy (in the rows) was relevant to each impact category (i...

AI summary The response explains that policy relevance indicates support for inclusion in a BCA test by aligning with Nova Scotia's policy goals and objectives, as per the NSPM. EFG and DSMAG reviewed policies to determine relevant impact categories for the BCA test.

tives. EFG conducted the review and homework assignment with the Demand Side Management Advisory Group (DSMAG) to gain insights into the relationship between Nova Scotia's policies and possible impact M12282, E1 BCA Test Application, May 1...

AI summary EFG conducted a review with DSMAG to understand how Nova Scotia's policies affect energy resources. The BCA Test Application references the NSPM BCA Principles, emphasizing the need to align with policy goals when evaluating energy investments.

9 Table 2 - Constr aine d System A \voi ded T&D ( Costs Avoided T&D Costs 1 nsmission /kW-yr tribution /kW-yr Total $/kW-yr 2023 $ 82.99 $ 89.20 $ 172.19 2024 $ 84.65 $ 90.98 $ 175.64 2025 $ 86.35 $ 92.80 $ 179.15 2026 $ 88.07 $ 94.66 $ 18...

AI summary The document presents a table showing projected avoided transmission and distribution costs from 2023 to 2050. It recommends using updated benefit cost analysis (BCA) test values for the DSM portfolio evaluation.

(b) For the illustrative example shown in Figure 1 of David Hill's Evidence, EFG assumed an $8,000 measure cost with a 40% incentive (equal to $3,200) and $2,000 total of program non-incentive administration and support costs. These are me...

AI summary The text references an illustrative example from David Hill's Evidence, where EFG assumed an $8,000 measure cost with a 40% incentive and $2,000 in program non-incentive administration and support costs. It also cites a document filed on May 16, 2025, as part of a BCA Test Application.

E1 Responses to Synapse Energy Economics (Synapse) Information Requests NON-CONFIDENTIAL - 1 reflect actual EfficiencyOne (E1) program design or delivery costs, which would be included - 2 as inputs in the application of the BCA test for a...

AI summary This document outlines EfficiencyOne's (E1) responses to Synapse Energy Economics' information requests, specifically addressing program design and delivery costs and their inclusion in the Benefit Cost Analysis (BCA) test for a Demand Side Management (DSM) Plan.

3 1 Request IR-06: 2 3 Refer to Figure 1 and Figure 2 on pages 15 and 16 of the Evidence of David Hill. Please provide 4 Figure 1 and Figure 2 and all supporting analysis and workpapers in Microsoft Excel format with 5 all cells unlocked,...

AI summary The text outlines requests and responses from a regulatory proceeding, including requests for documents, instructions given to the DSMAG, and clarification on the inclusion of utility system impacts in the Nova Scotia Test. Energy Futures Group (EFG) provides responses referencing EfficiencyOne and the National Standard Practice Manual (NSPM).

1 Request IR-12: 2 3 Please provide Table 5 on page 19 of the EFG Report in Microsoft Excel format with all 4 supporting analysis and workpapers with formulas intact. 5 6 Response IR-12: 7 8 Please refer to EfficiencyOne's (E1) response to...

AI summary The text includes requests for specific tables and explanations related to the EFG Report, with responses directing to prior submissions and clarifying the exclusion of energy security from the Nova Scotia Test due to insufficient stakeholder and policy support.

PRE-FILED TESTIMONY OF PATRICK BOWMAN IN REGARD TO EFFICIENCY ONE ("E1") BENEFIT-COST ANALYSIS TEST ("BCA") Submitted to: The Nova Scotia Energy Board on behalf of The Industrial Group Prepared by:

AI summary Patrick Bowman's pre-filed testimony addresses the Benefit-Cost Analysis (BCA) test for Efficiency One (E1), submitted to the Nova Scotia Energy Board on behalf of The Industrial Group. The document outlines concerns or perspectives related to the BCA process.

Bowman Economic Consulting Inc. 161 Rue Hebert Winnipeg, MB R2H 0A5 TABLE OF CONTENTS .,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 2 INTRODUCTION 3 3 TERMINOLOGY 3 BACKGROUND AND CONTEXT E1 PROPOSAL EVALUATION OF E1'S PROPOSED BCA OTHER BCA CON...

AI summary The document outlines the structure of a report by Bowman Economic Consulting Inc., including an introduction, terminology, background, E1 proposal, evaluation of E1's proposed Benefit-Cost Analysis (BCA), other BCA considerations, and a summary.

TERMINOLOGY - In assessing DSM (both energy efficiency and strategic electrification), it is necessary to assess cost- - effectiveness, and to utilize a metric to compare benefits and costs. Broadly, this process is termed - Benefit-Cost A...

AI summary The document outlines the use of Benefit-Cost Analysis (BCA) in evaluating Demand Side Management (DSM), with Efficiency One (E1) proposing a Nova Scotia-specific Jurisdiction-Specific Test (JST) termed the Proposed BCA. This approach includes fixed items in benefits and costs, resembling the Societal Cost Test (SCT). BCA inputs are structured at varying levels from Measures/Activities to Programs/Portfolios.

4 For conversion of fuel oil heating to heat pumps (beneficial electrification): Proposed BCA (societal perspective) PAC (utility and its customers perspective, including revenue) Benefits = NPV of avoided fuel oil purchase, Benefits: NPV...

AI summary The document outlines a Benefit-Cost Analysis (BCA) and Public Acceptability Criteria (PAC) for converting fuel oil heating to heat pumps. It compares benefits such as avoided fuel oil purchases and reduced GHG emissions against costs like increased electric generation and installation expenses.

- 6 As is clear from the above examples, a large range of input values in the Proposed BCA are derived from - 7 considerations that are widely delinked from NSPI customers (e.g., health impacts). The PAC by - comparison uses values that ar...

AI summary The document discusses the use of the Public Acceptability Criteria (PAC) as a primary screening tool for Demand Side Management (DSM) activities, noting that it considers utility economics and customer impacts. It addresses concerns that using PAC might exclude societal benefits or reduce cost-effectiveness, clarifying that PAC can still allow for consideration of broader factors like GHG emissions and that it has been more favorable than other tests in past DSM plans.

Should E1's proposal that BCA be conducted only at the Portfolio level be adopted? - No. - Previous sections of this submission highlighted that the Board cannot fulfill its mandate if screening - information or tests are only applied at t...

AI summary The proposal to conduct BCA only at the Portfolio level is rejected, as it would hinder the Board's mandate by failing to identify problematic measures and prevent analysis of customer class cross-subsidization. Measure-level and customer class-level BCA are necessary for effective DSM program evaluation.

What recommendations do you have? - Based on the above considerations, I provide the following conclusions and recommendations for the Board: - 1) The current primary TRC test is limited in its ability to singularly inform the Board about...

AI summary The text outlines recommendations for the Board regarding the use of benefit-cost analysis (BCA) tests in evaluating demand-side management (DSM) activities. It suggests using the PAC test as the primary energy efficiency test, incorporating the E1 BCA test for broader considerations, and rejecting the E1 Proposed BCA test as the primary test. It also emphasizes the need for cost-effective measures and proper consideration of avoided utility costs and GHG emissions.

- A. The purpose of my evidence is to review EfficiencyOne's (E1) proposal for a new - benefit-cost analysis (BCA) test for evaluating demand side management (DSM) plans, - referred to as the Nova Scotia Test.

AI summary The purpose of the evidence is to review EfficiencyOne's proposal for a new benefit-cost analysis (BCA) test for evaluating demand side management (DSM) plans, referred to as the Nova Scotia Test.

es 6-12. 7 Rebuttal Evidence of E1 in M10473, June 10, 2022, page 13, lines 12-14. Id ., at page 13, lines 14-17. Evidence of Courtney Lane In its Decision on the 2023–2025 DSM Plan, the Board directed EI "to work with the DSMAG before the...

AI summary E1 complied with the Board's directive to develop an optimal DSM cost-effectiveness test by filing an application for a new BCA test in May 2025, informed by the DSMAG. The process involved seven meetings with an independent consultant, Energy Futures Group, using the NSPM to develop a BCA framework with five steps.

Evidence of E1 in M12282, May 16, 2025, pages 19-20. 12 Evidence of E1 in M12282, May 16, 2025, Table 3, page 20, line 12. 1 Step 2: Identifying and including the full range of utility system impacts to include in 2 the BCA test. 3 Step 3:...

AI summary The text discusses the steps involved in developing a Benefit-Cost Analysis (BCA) test, including identifying utility system impacts, deciding on non-utility impacts, ensuring consistent treatment of benefits and costs, and establishing documentation. It also references a report by EFG on a jurisdictional BCA framework for Nova Scotia's DSM Plan and mentions the NSPM, a five-step process used in developing DERs.

8 Overview of Proposed Nova Scotia Test - 9 Q. Please summarize the new BCA Test proposed by E1. - 10 A. [Table 1](#page-12-1) below provides an overview of the impact categories, impact type, and impacts

AI summary The document introduces a new Benefit-Cost Analysis (BCA) Test proposed by E1, which aims to evaluate the impacts of various initiatives. A table is referenced to provide an overview of the impact categories, impact type, and associated impacts.

1 Q. What is the justification for including the new non-utility impacts? - 2 A. As part of the DSMAG process, EFG asked working group members to complete a - 3 homework assignment where they considered applicable policies and legislation...

AI summary The justification for including new non-utility impacts is discussed in the context of the DSMAG process, where EFG asked working group members to consider applicable policies and legislation and their relation to BCA impact categories, as summarized in Table 3.

1 I further recommend that the Board direct E1 to launch a process for updating the NEB 2 proxies in 2029 for use in the next DSM Plan. 3 4 Q. Should the Board choose not to adopt the use of host customer NEBs, is there an alternative appr...

AI summary The text discusses the recommendation to update the Non-Energy Benefits (NEB) proxies in 2029 for the next DSM Plan. It also explores the impact of excluding host customer costs and benefits from Benefit-Cost Analysis (BCA) for DERs such as solar PV and EVs, highlighting the need for a comprehensive cost-effectiveness test that includes host customer impacts.

costs. - The BCA test results for the illustrative examples for hybrid heating compare favourably with E1's "Electric Heat Pump – Fuel Oil" and "Electric Heat Pump – Fossil Gas" illustrative examples. [The Economics of Electrification in N...

AI summary The BCA test results for hybrid heating show favorable comparisons to E1's electric heat pump examples using fuel oil and fossil gas. This analysis is part of Nova Scotia Power's report on the economics of electrification, highlighting hybrid heating's benefits.

1 Table 2: Illustrative Example - Hybrid System Replacing Fuel Oil Furnaces Nova Scotia Test ($Million), 2% Social Discount Rate, Using 2023-2025 Avoided Costs: Example based on 1,000 Hybrid Systems Replacing Fuel Oil Furnaces, Program Yea...

AI summary Table 2 presents a Benefit-Cost Analysis (BCA) of a hybrid system replacing fuel oil furnaces, showing net benefits with a benefit-cost ratio of 2.21 for E1 costs and 2.27 for E3 costs. The analysis includes energy generation, capacity, environmental impacts, financial incentives, and other factors such as avoided heating oil costs and health impacts from greenhouse gas emissions.

- Posterity Group recommends that E1 specifically recognize the benefits of hybrid heating to - reduce peak load impacts as part of the 2027-2031 DSM Plan. The benefits of hybrid heating - are recognized in Nova Scotia by Nova Scotia Power...

AI summary Posterity Group recommends that E1 include hybrid heating benefits in the 2027-2031 DSM Plan, citing recognition by Nova Scotia Power, E3, and other jurisdictions. Quantitative examples show hybrid heating has significant net benefits under the BCA test compared to other heating systems.

1 BEFORE THE NOVA SCOTIA ENERGY BOARD 2 3 4 IN THE MATTER OF The Public Utilities Act, R.S.N.S. 1989, c.380 as amended 5 - and - 6 IN THE MATTER OF an Application by EfficiencyOne 7 for Approval of a New Benefit-Cost Analysis Test 8 for Ev...

AI summary This document is a regulatory proceeding before the Nova Scotia Energy Board, concerning an application by EfficiencyOne for approval of a new benefit-cost analysis test for evaluating demand side management (DSM) plans. Melissa Whitten, on behalf of the Small Business Advocate, provides direct evidence in the matter.

- A. The purpose of my evidence today is to outline my concerns with the conclusion reached by EfficiencyOne (E1) that their proposed new Benefit-Cost Analysis (BCA) test is 1 appropriate to be used to evaluate the cost effectiveness of E1...

AI summary The speaker outlines concerns with EfficiencyOne's proposed new Benefit-Cost Analysis (BCA) test for evaluating the cost-effectiveness of their Demand Side Management (DSM) plans. Two main concerns are raised regarding the inclusion of non-energy benefits and the ability to quantify them.

- Relying on benefits in a benefits-cost analysis that cannot be quantified nor independently measured and verified could introduce bias into the test results. M10431(December 14, 20220 , Closing Submission of Small Business Advocate page...

AI summary The text raises concerns about the use of non-energy benefits in a benefits-cost analysis (BCA) for a Demand Side Management (DSM) Plan, arguing that unquantifiable benefits could introduce bias. It recommends that the BCA test not be approved until non-energy benefits like comfort, amenity, empowerment, and pride are independently verified.

In the Application, E1 explains that the amendment to the PUA that included strategic electrification to help reduce overall greenhouse gas emissions and electricity costs requires expanding the scope of the BCA test to include non-utility...

AI summary E1 argues that the amendment to the PUA requires expanding the BCA test to include non-utility impacts such as fuel savings, GHG emissions, and host customer benefits. It cites the ERBA and MAEA to support its interpretation of sustainability factors and sustainable development, while noting some host customer benefits will be represented by proxy.

Table 1: Host Customer Impacts Host Customer Impact Description/Meeting Notes Inclusion in new BCA Economic well-being Energy bill savings reducing stress of disconnections, foreclosures, etc. create direct and induced economic benefits. ✓...

AI summary The table outlines host customer impacts such as economic well-being, comfort, amenity, health and safety, empowerment, and pride, with inclusion in a new benefit-cost analysis (BCA). The document also references exhibits and raises a question about how EfficiencyOne (E1) proposes to quantify non-energy benefits using proxy values.

- A. As stated in the Application, E1 will quantify host customer non energy benefits "using - proxy adders applied as a percentage of net energy benefits or of measure costs (for - electrification) depending on the impact category, target...

AI summary The discussion focuses on concerns raised about E1's and EFG's approach to quantifying non-energy benefits in the BCA. The response highlights that some benefits, like health and safety, may be quantifiable, but others like 'amenity' and 'pride' lack clear valuation sources. Concerns were previously raised during stakeholder sessions.

- non-energy benefits like empowerment and pride. While our concerns were M12282, Exhibit E-1, Application, page 5 at paragraph 24. 1 acknowledged, I do not feel that they were addressed in the Application. EFG included the 2 following in...

AI summary The stakeholder process revealed a lack of clarity regarding the current cost effectiveness test, with working group members unable to reach consensus on several impacts. Appendix B summarizes the review of the BCA test and its scope.

1 are not restricted to utility-related impacts alone" citing that "sustainable development and 2 15 sustainable prosperity invite consideration of … host customer impacts". and even this 3 reference does not explain how E1 and EFG can ext...

AI summary The text discusses concerns regarding the inclusion of non-utility benefits such as 'amenity', 'empowerment', and 'pride' in the Benefit-Cost Analysis (BCA) test. It emphasizes the need for transparency and the importance of using an industry-standard Evaluation, Measurement, and Verification (EM&V) process to address these concerns.

M12282, Exhibit E-1, Application, Evidence, Section 2.1 Current Methodology, page 3 of 38, lines 23-24 and page 4 of 38, lines 1-2. M12282, Exhibit E-1 Application, Evidence, Section 7.5 Guiding Principles, Table 4: NSPM BCA Guiding Princi...

AI summary The review of the Application highlights deficiencies in the BCA test's reliance on proxy values for non-energy benefits, citing a lack of quantifiable data. This could introduce bias into the BCA results, potentially leading to suboptimal decisions regarding the DSM Plan's composition and cost. The reviewer recommends obtaining independent third-party evidence to verify these non-energy benefits.

TERMINOLOGY - In assessing DSM (both energy efficiency and strategic electrification), it is necessary to assess cost- - effectiveness, and to utilize a metric to compare benefits and costs. Broadly, this process is termed - Benefit-Cost A...

AI summary The document outlines the use of Benefit-Cost Analysis (BCA) in evaluating Demand Side Management (DSM) initiatives, emphasizing the Jurisdiction-Specific Test (JST) as a regulatory framework. E1 proposes a Nova Scotia-specific BCA, termed the 'Proposed BCA,' which incorporates fixed items in benefit and cost calculations. This approach is compared to the Societal Cost Test (SCT) and involves hierarchical categorization of DSM measures into programs and portfolios.

Is the E1 commentary a fair criticism of the TRC as previously applied in Nova Scotia? - Yes, from a principled perspective. In general, BCA should include all measurable and meaningful benefits - and costs at the proposed assessment scale...

AI summary The E1 commentary is considered a fair criticism of the TRC in Nova Scotia for excluding non-energy benefits. However, prior TRC application was restricted by M08888, which limited the Board’s jurisdiction. The new Energy and Regulatory Boards Act may permit non-energy considerations, though legal interpretation is pending. Technical challenges remain in revising the TRC test if jurisdiction expands.

1 For conversion of electric resistance heating to heat pumps (energy efficiency): Proposed BCA (societal perspective) PAC (utility and its customers perspective) Benefits = NPV of avoided electric generation and capacity costs, avoided tr...

AI summary The document outlines a Benefit-Cost Analysis (BCA) and Public Acceptability Criterion (PAC) for converting electric resistance heating to heat pumps. It considers benefits such as avoided generation and transmission costs, health impacts, and GHG reductions, while also accounting for installation and program administration costs.

4 For conversion of fuel oil heating to heat pumps (beneficial electrification): Proposed BCA (societal perspective) PAC (utility and its customers perspective, including revenue) Benefits = NPV of avoided fuel oil purchase, avoided GHG gl...

AI summary The document presents a Benefit-Cost Analysis (BCA) and Public Acceptability Criterion (PAC) for converting fuel oil heating to heat pumps. Benefits include avoided fuel costs and GHG emissions, while costs involve infrastructure upgrades and program administration. From the utility's perspective, benefits include added revenue, while costs remain similar.

What recommendations do you have? Based on the above considerations, I provide the following conclusions and recommendations for the Board: - 1) The current primary TRC test is limited in its ability to singularly inform the Board about es...

AI summary The text provides recommendations for the Board regarding the use of benefit-cost analysis (BCA) tests in evaluating DSM activities. It suggests using the PAC test as the primary energy efficiency test, rejecting the E1 BCA test as a primary test, and incorporating multiple tests for balanced evaluation. It also highlights the importance of using NSPI WACC as the discount rate and ensuring accurate GHG emission calculations.

11 For conversion of electric resistance heating to heat pumps (energy efficiency): Proposed BCA (societal perspective) TRC including Non-Energy Benefits (utility and its customers + participant perspective) PAC (utility and its customers...

AI summary The text presents a Benefit-Cost Analysis (BCA) and Total Resource Cost (TRC) for converting electric resistance heating to heat pumps, considering societal, utility, and participant perspectives. It outlines benefits such as avoided fuel oil purchases and GHG costs, and costs including added generation, transmission, and installation expenses.

2. BOWMAN EVIDENCE

AI summary The document section titled '2. BOWMAN EVIDENCE' introduces evidence submitted by Bowman in a Nova Scotia regulatory proceeding. Key terms like NSP, BCA, and DSM are referenced, but no detailed arguments or claims are present in the provided text.

4. GREEN ENERGY EVIDENCE

AI summary The section titled 'GREEN ENERGY EVIDENCE' introduces the context of a regulatory proceeding in Nova Scotia, focusing on green energy-related submissions. Key acronyms and entities involved in the proceeding are pre-defined for reference.

Daymark - In the alternative to the recommendation for further analysis on NEBs, Ms. Whitten suggests that the - Board "make the value assigned to the Unquantified Non-Energy Benefits Nil until the work outlined above - can be completed an...

AI summary Ms. Whitten recommends that the Board set the value of Unquantified Non-Energy Benefits (NEBs) to Nil until further analysis is completed and approved. This suggestion is part of a regulatory proceeding involving a Benefit-Cost Analysis (BCA) framework for Nova Scotia, with references to evidence and appendices from Matter M12282.

E1 Response The approach E1 is proposing in the 'evergreen' process for calculating the emissions intensity of DSM savings for the purposes of benefit cost analyses is the Difference in Carbon Emissions (DICE) method. This approach conside...

AI summary E1 proposes using the Difference in Carbon Emissions (DICE) method for calculating the emissions intensity of DSM savings in benefit-cost analyses, aligning with NSPM guidance and IRP assumptions. E1 clarifies that an illustrative example of gas-to-electric conversions by Eastward Energy does not reflect actual results and would require justification if included in future DSM plans.

7.4 LOST VALUE OF THE NATURAL GAS SYSTEM RELIABILITY

AI summary This section addresses the lost value associated with the reliability of the natural gas system in Nova Scotia. Key acronyms and entities involved in the regulatory proceeding are outlined, though detailed analysis or arguments are not provided in the excerpted text.

- On May 16, 2025, EfficiencyOne ("E1") submitted an Application for Approval of a New Benefit-Cost - Analysis ("BCA") Test for Evaluating Demand Side Management ("DSM") Plans before the Nova Scotia - Energy Board (the "Board") in Matter 1...

AI summary EfficiencyOne submitted an application for a new BCA test for DSM plans before the Nova Scotia Energy Board. The application was supported by a report from Energy Futures Group. Multiple intervenors and consultants submitted evidence, and EFG responded to concerns raised in their rebuttal evidence.

EFG Response - To make the value assigned to the unquantified NEBs nil would result in bias the result which Ms. Whitten - is seeking to avoid. E1 notes that completely excluding known, but hard-to-quantify benefits would default - such be...

AI summary EFG argues against setting unquantified non-energy benefits (NEBs) to zero in benefit-cost analysis (BCA), stating it would bias results. They suggest using conservative proxy values instead, as proposed by E1, to avoid distorting BCA outcomes.

4.2 2% DISCOUNT RATE

AI summary This section discusses the application of a 2% discount rate in the Benefit-Cost Analysis (BCA) for regulatory proceedings in Nova Scotia. The analysis involves considerations by Nova Scotia Power (NSP) and the Nova Scotia Utility and Review Board (NSUARB), focusing on the implications of this rate for energy and non-energy benefits.

- 2 Nova Scotia introduced several pieces of legislation that impact on the way in which - 3 EfficiencyOne must develop and implement its DSM plan. The details of those legislative changes - 4 are set out in detail in the Application, and...

AI summary EfficiencyOne is required to develop and implement a DSM plan under new legislation, which includes considering energy efficiency and sustainability goals. The SBA supports the inclusion of new benefits in the BCA test but has concerns about unquantified non-energy benefits. The SBA will explore these issues during the hearing.

M12282 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT -and - IN THE MATTER OF: AN APPLICATION by EFFICIENCYONE for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans OPENING STATEM...

AI summary The Consumer Advocate supports a new Benefit-Cost Analysis (BCA) Test for evaluating Demand Side Management (DSM) Plans proposed by EfficiencyOne, but recommends that the new test be vetted with stakeholders and that internalized and externalized costs of carbon be treated separately. The Board will need to address several issues, including the appropriateness of the test and the justification for proxy values used.

36 1 Nova Scotia Power Incorporated (Re) , 2009 NSUARB 116 (CanLII), [ ](https://canlii.ca/t/25bsh). 1 2 3 4 The Industrial Group would also reiterate to the Board (and E1) that E1's references throughout its evidence to the Proposed E1 BC...

AI summary The Industrial Group clarifies that references to the Proposed E1 BCA and non-energy benefits in E1's evidence do not imply consensus or endorsement by the DSMAG or the Industrial Group. The statement is part of an opening submission by Nancy G. Rubin and Brianne Rudderham on September 11, 2025.

- Ontario, PEI, Saskatchewan, Newfoundland and Labrador, and Yukon. This PAC test also has the 1 M12282 - EfficiencyOne 2 Application for a Benefit-Cost Test 3 Opening Statement of Patrick Bowman 4 5 6 EfficiencyOne ("E1") is proposing to...

AI summary EfficiencyOne is proposing a new primary test for conducting Benefit-Cost Analysis (BCA), addressing concerns with the previous Total Resource Cost (TRC) Test, which was unbalanced by not fully accounting for customer cost savings. EfficiencyOne's chosen approach is considered inferior.

EfficiencyOne Opening Statement M12282 Filed with the NOVA SCOTIA ENERGY BOARD September 11, 2025 Opening Statement by Stephen MacDonald President and Chief Executive Officer, EfficiencyOne Thank you for the opportunity to present Efficien...

AI summary EfficiencyOne proposes replacing the Total Resource Cost (TRC) test with a Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) Plans, citing legislative changes and the need for a broader cost-effectiveness framework. The application seeks regulatory approval and an 'evergreen' review process for future DSM Plans.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended – and – IN THE MATTER OF: NSEB Matter No. M12282 – EfficiencyOne – New Benefits Cost Analysis Test for Evaluating Demand Side Management (DSM...

AI summary The Nova Scotia Energy Board is addressing a proceeding under the Public Utilities Act, RSNS 1989, c.380, concerning EfficiencyOne's proposed New Benefits Cost Analysis Test for evaluating Demand Side Management (DSM) Plans. The matter (M12282) focuses on assessing the cost-effectiveness of DSM initiatives.

Appendix "A" - a) The proposed benefit cost analysis ("BCA") test framework, as set out in the Application, is a suitable DSM cost-effectiveness testing methodology for Nova Scotia, subject to the clarifications and alterations set out in...

AI summary The text discusses the proposed benefit cost analysis (BCA) test framework for Nova Scotia's demand-side management (DSM) programs, noting that it is suitable subject to clarifications and alterations. It also outlines that the Nova Scotia BCA would include non-energy benefits impacts as described in the E1 Application.

d) The following proxy values will be used to quantify the remaining host customer NEB's listed above in Table 1 in performing BCA testing of the 2027 – 2031 DSM Plan.

AI summary The text outlines the use of proxy values to quantify non-energy benefits (NEB) for host customers in the context of BCA testing for the 2027–2031 DSM Plan.

- f) As an integral component of the Evergreen process for systematically reviewing and refining the BCA framework and impact quantification in preparation for the 2032–2036 DSM Plan, E1 will undertake comprehensive literature reviews, jur...

AI summary E1 will conduct comprehensive research and analysis as part of the Evergreen process to refine the BCA framework and quantify non-energy impacts for the 2032–2036 DSM Plan. This includes literature reviews, jurisdictional analysis, customer surveys, and stakeholder engagement with the DSMAG.

Figure 2: Proposed BCA With Host Customer Costs and Benefits Removed – Illustrative Results Using the E1 proposed BCA test with host customer impacts removed, the benefit cost ratio for replacement of electric resistance systems is 7.93, t...

AI summary Figure 2 presents the proposed BCA test with host customer impacts removed, showing benefit cost ratios for replacing electric resistance, fuel oil, and natural gas systems. The removal of host customer impacts increases the benefit cost ratios due to higher host customer costs compared to non-energy benefits.

- 4 Removed) and the PAC Test Heat Pump Replacing Fuel Oil Natural Gas Electric Resistance Proposed BCA Test Total Costs ($31.66) ($31.66) ($9.90) Total Benefits $57.10 $14.30 $ 41.26 Proposed BCA Test Ratio 1.80 0.45 4.17 Proposed BCA Tes...

AI summary The document presents a comparison of the Proposed BCA Test and the PAC Test, evaluating the costs and benefits of replacing different heating fuels with heat pumps. The Proposed BCA Test includes host customer impacts, while the PAC Test focuses only on utility system impacts. The BCA Test ratios vary significantly depending on the fuel type being replaced.

[201] In its response, E1 stated: The approach E1 is proposing in the 'evergreen' process for calculating the emissions intensity of DSM savings for the purposes of benefit cost analyses is the Difference in Carbon Emissions (DICE) method....

AI summary E1 proposes using the Difference in Carbon Emissions (DICE) method for calculating emissions intensity in DSM savings, aligning with NSPM and IRP for long-term planning. They argue this is more accurate than using marginal generator emissions, especially for significant load changes. In BCA, they use average emissions rates for illustrative examples.

4.6.1 Findings [204] The Board considers the issue regarding average versus marginal generation emission rates to be worthy of further consideration. During crossexamination, E1's witnesses stated that, for expediency, average emission rat...

AI summary The Board emphasizes using long-run marginal emission rates over average rates in E1's BCA modeling, citing the need for refined assumptions. E1 used average data from NS Power but acknowledges the need for improvement.

James R. Gogan Direct +1 (902) 563 5920 [email protected] 292 Charlotte Street Suite 300 Sydney NS Canada B1P 1C7 Tel +1 (902) 563 1000 Fax +1 (902) 563 1113 Our File: 254441 May 16, 2025 Nova Scotia Energy Board 3rd Floor, Sum...

AI summary EfficiencyOne is seeking regulatory approval for a new Benefit Cost Analysis Test to evaluate Demand Side Management (DSM) Plans. This follows a previous request for approval of its 2023-2025 DSM Plan and a review of cost-effectiveness testing methodologies. The Board directed EfficiencyOne to work with the DSM Advisory Group to determine the optimal testing methodology for Nova Scotia.

Request IR-3: - Refer to E1's Evidence at page 35, Table 11: Test Case Application of BCA Test (Heat Pumps). - a. Please provide all supporting analysis and workpapers in Microsoft Excel format with all cells unlocked, and formulas intact....

AI summary The request asks E1 to provide supporting analysis and workpapers in Excel format for their BCA test case on heat pumps, and inquires if they used the TRC Test methodology. It references E1's Evidence at page 35, Table 11, and seeks clarification on whether a BCA was conducted using the TRC Test.

Request IR-4: Refer to pages 8 and 9 of the Evidence of David Hill, regarding the statements "The numbers in the cells of this table indicate how many of the DSMAG organizations indicated each policy (in the rows) was relevant to each impa...

AI summary The text requests clarification on why policy relevance, as indicated in a table from David Hill's evidence, implies support for including specific impact categories in the BCA test. It references DSMAG and EFG interpretations of policy and legislative support for factors like GHG emissions, resilience, and DEI impacts.

- iv. How many states in the database are currently measuring Societal "Other Environmental" (excluding GHG emissions) impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure,...

AI summary The text outlines a series of questions seeking data on how many states measure specific societal and non-utility impacts (e.g., public health, economic development, energy security) within their Benefit-Cost Analysis (BCA) tests, including the scope (measure, program, portfolio level) of these assessments.

Request IR-13: - Page 30 of 38 of E1's Evidence states: "The impact of changes in pipeline gas consumption are based on commodity prices, and do not reflect gas utility system impacts. However, presuming gas commodity prices are the larges...

AI summary E1's Evidence in Request IR-13 questions whether avoided gas costs in DSM include base energy and transportation charges, not just commodity prices. The BCA test is based on commodity prices as an approximation. The request is for confirmation if avoided costs include those other charges.

Request IR-20: - a) Please cite the source for the cost of carbon used in the BCA. - b) Please explain how the proxy for the host customer was selected and measured. - i. Please describe how the proxy is estimated and applied in the BCA. -...

AI summary Request IR-20 seeks clarification on the BCA's carbon cost source, proxy selection methodology, discount rate justification, and use of Canadian vs. American rates in NSPM. Questions focus on transparency, methodology, and regional applicability of economic assumptions.

Request IR-28: - Page 8, under Not Material explains that some outcomes that don't produce a large enough effect - are excluded from the BCA. Please identify and briefly describe the outcomes/impacts identified - by E1/EFG/DSMAG that have...

AI summary Request IR-28 asks to identify outcomes excluded from the BCA by E1/EFG/DSMAG due to insufficient impact. The query focuses on excluded impacts not producing a large enough effect in the analysis.

Request IR-40: - Table 9 identifies the impacts included in the BCA. Please explain the reasons that E1 considers - the effects from DSM on Transmission and Distribution are significant enough to be included.

AI summary Request IR-40 asks E1 to justify including DSM's impacts on transmission and distribution in the BCA. The inquiry focuses on why these effects are deemed significant enough to be part of the analysis, highlighting the importance of transmission and distribution considerations in DER evaluations.

Request IR-6: - Please provide a list of each potential benefit being proposed to be included in the new BCA test - and note for each benefit whether the BCA Test will be assuming that the numerical value of the - benefit is the same throu...

AI summary Request IR-6 seeks a list of benefits for the new BCA test, including whether benefits are assumed constant over time. It questions how the test will address scenarios like NSPI’s decarbonized supply mix, which would render carbon savings zero.

- b) Please note for each category's impact how it was measured for Nova Scotia, as 1 2 compared with adopting something used in other provinces or in a US State. 3 Request IR-11: 4 5 Regarding Exhibit E-1, the Application, page 26 of 38,...

AI summary The text outlines various requests for information related to the impact measurement of categories in Nova Scotia, including definitions and examples for terms such as 'Host Benefits', 'Resilience', 'Public Health', 'improved comfort', and 'health'. It also requests explanations on how certain benefits are monetized for the BCA Test and how terms like 'resiliency' and 'reliability' are defined and contrasted.

- 28 (b) Please compare the new BCA test against the current TRC test for the 29 three examples provided in section 11 of E1's Evidence. 1 2 (i) In the calculation provided, do the "non-energy impacts" outweigh the "energy-related" impacts...

AI summary The text requests a comparison between the new BCA test and the current TRC test using three examples from section 11 of E1's Evidence. It also asks how E1 proposes to track, price, and report non-energy benefits and non-utility system impacts from its DSM plans. The legislation mandates the Energy Board to consider environmental impacts, energy efficiency, and other fuel impacts, including sustainable development and economic benefits.

- 26 Reference: E-1, Evidence, pages 20-22. - 27 Preamble: E1 indicates that the new BCA test is grounded in the National Standard - 28 Practice Manual ("NSPML") eight principles: - 1 (a) NSPM Principle #1 is outlined in Table 4 as: " DERs...

AI summary The text references a new BCA test grounded in the National Standard Practice Manual (NSPML) and outlines principles for evaluating DERs. It requests a comparison of E1's BCA test with NSPI's assessment methods, confirmation of the NSPM's role in guiding BCA tests, and analysis of how E1 plans to handle lost revenues and rate impacts in its filings.

21 Request IR-10: - 22 References: E-1, Evidence, page 26, Table 5; and pages 34-35, Table 9 and 10. - 23 Preamble: E1 has included a number of non-utility system impacts in relation to the 24 new proposed BCA Test, including a "Societal"...

AI summary Request IR-10 seeks clarification on the legislative basis for including 'public health' in the Benefit-Cost Analysis (BCA) Test. E1 argues that public health impacts, such as medical cost changes, are embedded in the BCA, citing Tables 9 and 10. The NSUARB is asked to justify its authority to consider public health in utility regulation.

17 Request IR-14: - 18 Reference: E-1, Appendix B. - 19 Does the requested approval of a new BCA include the following as approved values, or are they 20 inputs that would be considered at each future DSM Plan review: - 21 (a) use of a 2%...

AI summary The document questions whether the approval of a new BCA includes specific values (2% social discount rate and NEB proxy adders) as fixed approvals or if they are inputs for future DSM Plan reviews, referencing E-1, Appendix B.

2 Request IR-16: - 3 Please indicate if, or how, the proposed BCA test can help inform the appropriate level of - 4 incentives or subsidies for participation in efficiency initiatives and provide an example.

AI summary Request IR-16 asks how the proposed Benefit-Cost Analysis (BCA) test can inform the appropriate level of incentives or subsidies for participation in efficiency initiatives, seeking an example.

xplicitly embedded in the proposed test but were excluded under the previous TRC framework. Ultimately, the Board should be guided by NSPM Principle 2's directive to prioritize Nova Scotia legislative policy alignment over alternate jurisd...

AI summary The document emphasizes aligning the Proposed BCA test with Nova Scotia's legislative policies over alternate jurisdiction examples, citing NSPM Principle 2 and statutory interpretation principles. It references the modern approach to statutory interpretation, including Elmer Driedger's formulation and Nova Scotia's Interpretation Act, to ensure alignment with local energy, environmental, and economic objectives.

impacts. Without being able to measure and quantify other fuel impacts as part of its analysis of the cost- effectiveness of its strategic electrification programs, E1 would not be able to properly carry out its strategic electrification m...

AI summary E1 argues that strategic electrification programs require a Benefit-Cost Analysis (BCA) that includes both electric utility costs and non-utility benefits (e.g., GHG savings) to properly assess cost-effectiveness. Excluding these factors would hinder proper evaluation, as utility impacts are costs while non-utility impacts are benefits in the BCA equation.

5589de9d7ff8b2&searchUrlHash=AAAAAQBfbm90IGhhdmUgdGhlIGp1cmlzZGljdGlvbiB0byB0YWtlIGludG8gYWNjb3VudCBub24tZW5lcmd5IGltcGFjdHMgaW4gY29zdC1lZmZlY3RpdmVuZXNzIHRlc3RpbmcAAAAAAQ) 2020 NSUARB 56, at para 38. electricity costs for customers. The B...

AI summary The text discusses E1's acknowledgment that strategic electrification must reduce electricity costs and GHG emissions, but the Proposed BCA does not test for cost reductions. E1 clarifies the BCA's purpose is to assess whether benefits outweigh costs for DSM activities, not specifically for electricity cost reduction. The Board is urged to consider cost reductions for ratepayers.

2. THE BOARD SHOULD NOT TAKE INTO CONSIDERATION NON-ENERGY AND BROAD SOCIETAL IMPACTS In the alternative, if the Board determines it has the jurisdiction to incorporate non-energy and broad societal impacts into the cost-effectiveness test...

AI summary The Industrial Group argues that the Board should not consider non-energy and broad societal impacts in evaluating Demand-Side Management (DSM). They claim this would expand Benefit-Cost Analysis (BCA) beyond ratepayer-focused tests, introducing unquantifiable factors. E1's proposed BCA includes non-energy benefits and carbon costs, which the Small Business Advocate's consultant opposes, aligning with the Program Administrator Cost (PAC) test instead.

Avoided Cost Series NS Power submits that the current avoided cost series is primarily intended to inform analysis of traditional energy efficiency measures that reduce both energy and peak demand, or contribute to demand response. In the...

AI summary NS Power proposes updating the avoided cost series for DSM and Demand Response to reflect new programming, including strategic electrification. They emphasize the need for tailored cost curves and collaboration with E1 and DSMAG. The BCA test focuses on demand-side resources, not supply-side.

APPENDIX A Category PAC (Program Administrator Cost) Current TRC (Total Resource Cost) NS Power Recommendatio ns E1's Proposed BCA (Nova Scotia Jurisdictional Test) Perspective Utility-centric Utility (costs and benefits) + Participant 9co...

AI summary The table compares different approaches to calculating Program Administrator Cost (PAC) and Total Resource Cost (TRC) under various perspectives and benefit-cost analysis (BCA) frameworks. It highlights differences in included benefits, costs, and non-energy benefits (NEBs) across utility-centric, participant-focused, and societal perspectives.

nergy Reform (2024) Act, SNS 2024, April 2024, Part I: Energy and Regulatory Boards Act (Schedule A), s 6(2). Ibid , Part II: More Access to Energy Act (Schedule B), s 2. NS Power contends that the DSM provisions within the PUA supersede t...

AI summary NS Power argues that DSM provisions in the PUA override other energy legislation, while E1 claims statutory harmony exists. E1 asserts the Proposed BCA aligns with modern statutory interpretation, integrating sustainability goals and portfolio-level cost-effective DSM evaluations as outlined in section 2.1.

4.1.1 Introduction [69] The Public Utilities Act requires NS Power to engage E1 to undertake "costeffective demand-side management". The Board must approve these agreements and "determine the cost-effective demand-side management that must...

AI summary The NSUARB must determine the cost-effectiveness test for demand-side management under the Public Utilities Act, with parties disagreeing on whether non-energy impacts should be considered. Post-2020 jurisdictional changes and the 2024 Energy Reform Act split NSUARB into two boards, expanding the Energy Board's consideration scope. E1 argues the Board now has jurisdiction to include non-energy impacts, while some intervenors oppose this. The Board will assess statutory interpretation and decide on BCA approval if jurisdiction is confirmed.

Impact Category Sub-Category BCA Test TRC Test Utility System Electric Generation Transmission Distribution General All All Gas Only Commodity Costs Not Included Non-Utility System Other Fuels All Not Included Host Customer All (costs and...

AI summary The document outlines the impact categories and subcategories for the BCA and TRC tests, highlighting which aspects are included or excluded. It also mentions Mr. Bowman's recommendation to use the PAC test, modified to include increased utility revenue as a benefit, to align with other Canadian jurisdictions and reduce electricity costs as per the Public Utilities Act.