Topic:"Best Interests Of Customers" in M12282

set out in the National Standard Practice Manual (“NSPM”) for Distributed Energy Resources (“DER”); 3 b) Nova Scotia’s policy goals and objectives, as articulated in legislation; c) input from the DSMAG during workshops; and d) Nova Scotia...

AI summary The document outlines the proposed Best Interest of Customers (BCA) test design, incorporating non-utility system impacts like greenhouse gas emissions and air pollutants, aligned with Nova Scotia's sustainability goals. Inputs included the DSMAG's workshop feedback, policy objectives, and E1's DSM Plan performance data.

in the “Other Fuels” category. Resilience is embedded in “Host Customer” category. Public Health impacts embedded in “GHG Emissions” and “Other Environmental” categories. 22. The electric utility system impacts are the same impact categori...

AI summary The text outlines impact categories under the TRC test and new non-utility system impacts, including commodity costs of other fuels, host customer benefits, resilience, GHG emissions, and public health effects. E1 proposes an 'evergreen' periodic review of the BCA test via DSMAG to ensure alignment with current data and policy objectives.

re reflective of accurate and current data, and of any changes to Nova Scotia policy objectives. This ‘evergreen’ review would be conducted in advance of the development of a new DSM Plan. 24. The utility system impacts and other fuel impa...

AI summary E1 proposes replacing the TRC test with the BCA test (1.0 ratio threshold) for assessing DSM Plans, emphasizing accurate data, evergreen reviews, and quantifying impacts via avoided costs, social cost of carbon, and societal benefits using a 2% discount rate. The BCA test is argued to align with ratepayer interests and regulatory priorities.

Group, entitled “Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia”, dated May 13, 2025, to be used in assessing the cost effectiveness of future DSM Plans. 28. In support of this Application, E1 relies on the...

AI summary EfficiencyOne (E1) submits an application for a Jurisdictional Benefit-Cost Analysis (BCA) framework to assess future Demand Side Management (DSM) Plans. E1 cites supporting evidence from Energy Futures Group and asserts the requested order aligns with ratepayer interests. The application emphasizes cost-effectiveness and regulatory compliance.

...............................................9 5.1 Portfolio Level Evaluation............................................................................................................ 9 5.2 Jurisdiction to Consider Non-Energy Impacts ....

AI summary The document outlines sections addressing portfolio-level evaluation, jurisdiction to consider non-energy impacts, legislative changes to the Public Utilities Act and Energy Reform Act, and E1's efforts to develop a new Best Interest of Customers (BCA) test. It includes directives for cost-effectiveness testing and updates to Nova Scotia's policy objectives.

............................................... 18 7.4 Steps Informing EFG Report ...................................................................................................... 20 DATE FILED: May 16, 2025 i EfficiencyOne Benefit-Co...

AI summary The document outlines the design objectives and guiding principles for a Benefit-Cost Analysis (BCA) test application by EfficiencyOne. It emphasizes adherence to Nova Scotia policy objectives, NSPM guidelines, and DSMAG processes, focusing on best practices, transparency, and evergreen evaluation frameworks for energy efficiency initiatives.

......................................... 25 9.2 NSPM Guidelines ....................................................................................................................... 25 9.3 DSMAG Input ......................................

AI summary The document outlines a regulatory analysis comparing the current TRC test with a proposed BCA test, emphasizing non-utility system impacts like societal and host customer effects. It includes DSMAG input, NSPM guidelines, and test case runs on heat pumps, reflecting a shift toward broader impact assessments in energy efficiency programs.

...................................... 35 12. Conclusion ..........................................................................................................................................38 LIST OF TABLES Table 1: Impact Categories...

AI summary EfficiencyOne is applying a Benefit-Cost Analysis (BCA) Test, referencing the National Standard Practice Manual (NSPM) steps and principles for BCA development, as well as the Total Resource Cost (TRC) Test and cost-effectiveness testing in other jurisdictions.

1 engagement process with the Demand Side Management Advisory Group (“DSMAG”) to inform the 2 development of a new cost-effectiveness test for Nova Scotia. 3 4 In December 2023, E1 and EFG initiated engagement with the DSMAG to develop an...

AI summary E1 and EFG engaged the DSMAG to develop a new cost-effectiveness test (BCA) for Nova Scotia's DSM, aligning with updated policy objectives and provincial legislation. The BCA includes non-utility impacts like societal and host customer benefits, differing from the current TRC test. E1 argues this approach reflects best practices and legislative changes.

of the energy 23 sector and the corresponding impacts for consideration in relation to DSM planning, the proposed BCA 24 test including the impact categories and the valuation of same, should be reviewed on an evergreen basis 25 through th...

AI summary E1 seeks approval of a new Best Interest of Customers (BCA) test for evaluating Demand Side Management (DSM) Plans, arguing it better serves ratepayers. The proposal includes an evergreen review process by the DSMAG to assess impact categories before future DSM Plan filings.

1 as discussed below). The recent legislative amendments to the PUA now include strategic electrification 2 within the definition of demand-side management, for which the proposed BCA test allows consideration. 3 The best practice is to us...

AI summary The document discusses legislative amendments to the PUA, incorporating strategic electrification into demand-side management (DSM) and advocating for the Best Interest of Customers (BCA) test over the Total Resource Cost (TRC) framework. E1, as the franchise holder, must seek regulatory approval for its DSM Plan, with the Energy Board required to assess portfolio-level cost-effectiveness. Historical emphasis on DSM cost-effectiveness is highlighted via the 2010 NSUARB case.

Page 5 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence

AI summary EfficiencyOne (E1) submits a Benefit-Cost Analysis (BCA) test application under the Public Utilities Act (PUA) and Energy Reform (2024) Act (ERA) to evaluate the cost-effectiveness of its demand-side management (DSM) programs. The application seeks regulatory approval to align DSM benefits with customer interests and compliance standards.

gst 24 stakeholders, and was signed by E1, NS Power, the CA, the SBA, the MEUs, the AEC and 25 the EAC. 26 27 The NSUARB has endorsed the Balanced Plan approach in past DSM plans, 7 and has recognized that the 28 PUA contains language that...

AI summary The NSUARB has endorsed the Balanced Plan approach in past DSM plans, citing the PUA's provision granting the Board discretion in assessing DSM plans. The Board considers factors like customer best interests, affordability, and other matters when evaluating supply agreements, as outlined in EfficiencyOne (E1) (Re), 2022 NSUARB 137 [M10473].

Page 8 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 4.3 2027-2031 FIVE-YEAR DSM PLAN 2 The March 26, 2025 amendment to the PUA also prescribes the term of the next DSM Plan as five years, 3 commencing January 1, 20...

AI summary EfficiencyOne (E1) seeks approval of a new Best Interest of Customers (BCA) test to inform its 2027-2031 Demand Side Management (DSM) Plan, aligning with the Public Utilities Act (PUA) amendment requiring a five-year DSM Plan term starting January 1, 2027. E1 plans to file the DSM Plan application in early 2026, contingent on BCA test approval.

• Example: Instant Savings; Affordable Single-Family Homes; Small Business Energy Solutions; Residential Demand Response • A specific technology, action or practice that reduces energy consumption Measure of shift energy uses. • Example: M...

AI summary The document discusses the application of the Best Interest of Customers (BCA) test under the Public Utilities Act (PUA) for the development of future Demand Side Management (DSM) Plans. EfficiencyOne (E1) commits to providing data at the measure, program component, and portfolio levels to ensure cost-effectiveness and adherence to the Balanced Plan approach.

Page 11 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 occurred, and outlines how, in E1’s submission, these legislative changes now direct the Energy Board to 2 consider non-energy impacts as part of its evaluation...

AI summary EfficiencyOne (E1) is proposing a new Best Interest of Customers (BCA) test for demand-side management (DSM) cost-effectiveness, developed in collaboration with the DSMAG as directed by the NSUARB in its 2022 Decision on the 2023-2025 DSM Plan. The EFG Report outlines the proposed test and its development process.

G in accordance with the NSUARB’s directive as noted above. In 14 addition to the EFG Report, sections 7 to 13 herein describe how the proposed new BCA test was assessed 15 and developed by E1. 16 17 6. CHANGES TO NOVA SCOTIA POLICY OBJECT...

AI summary The document discusses changes to the Public Utilities Act in Nova Scotia, specifically the amendment replacing the definition of 'electricity efficiency and conservation activities' with 'demand-side management'. This change impacts the NSUARB's jurisdiction over non-energy impacts.

ctrification programs, which can 27 be influenced by the commodity costs of displaced fuels 19 Environmental Goals and Climate Change Reduction Act, SNS 2021, c 20, section 7(b) DATE FILED: May 16, 2025 Page 16 of 38 EfficiencyOne Benefit-...

AI summary The text discusses the importance of including non-utility impacts, such as fuel savings and GHG emissions, in the cost-effectiveness analysis of strategic electrification programs under the BCA. The amendment to the PUA in 2022 expanded the definition of demand-side management to include strategic electrification.

rimary costs and the non-utility impacts (other fuel savings and GHG 13 emissions savings) become the primary benefits. Without their inclusion the testing cannot be conducted 14 appropriately. 15 16 6.4 LEGISLATIVE MANDATE TO CONSIDER HOS...

AI summary The text discusses the legislative mandate under the Energy and Regulatory Boards Act, which requires the Energy Board to consider sustainability-focused factors, including impacts on future generations, environmental stewardship, and social responsibility, in its regulatory decision-making.

Page 17 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 • environmental impacts of DSM programs generally, including how these programs contribute to 2 reducing greenhouse gas emissions and other pollutants; 3 • encou...

AI summary The text discusses the environmental and social benefits of DSM programs, including reducing greenhouse gas emissions, promoting energy efficiency, and creating green jobs. It also outlines E1's efforts to develop a new BCA test through a competitive RFP process by retaining EFG as a consultant.

Page 18 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 • E1 2 • Synapse Energy Economics, on behalf of Board Counsel 3 • Consumer Advocate 4 • Nova Scotia Power Inc. 5 • Small Business Advocate 6 • Industrial Group 7...

AI summary The text outlines the entities involved in the EfficiencyOne Benefit-Cost Analysis Test Application and details the meetings of the DSMAG from December 2023 to January 2023, discussing the development of a BCA framework and reviewing homework assignments related to the 2023-2025 DSM Plan.

tribution, and general/other). EFG 20 also reviewed the homework results. The group identified areas of agreement, differing opinions 21 materiality of impacts, and dissenting views. 22 • Session 3 - March 4, 2024: the DSMAG reviewed the d...

AI summary The DSMAG participated in multiple sessions reviewing the BCA framework report and impact quantification methodologies, focusing on 'other fuel' and GHG emissions impacts, as well as non-energy impacts. Feedback was provided on draft and revised reports, with a focus on quantifying key impacts.

6, 2025 Page 19 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 • Session 6 - July 15, 2024: the DSMAG reviewed and discussed societal impacts beyond 2 greenhouse gases, host customer impacts, and societal non-energy...

AI summary The document outlines the steps taken by EfficiencyOne and EFG in developing the new BCA test, following the NSPM procedure. It highlights the DSMAG's involvement in reviewing societal impacts and providing feedback on the EFG report.

Step 1: • Determine whether to include host customer impacts, low-income impacts, other fuel and water impacts, and/or societal impacts. STEP 4 Ensure that Benefits and Costs are Properly Addressed Ensure that the impacts identified in Steps...

AI summary This section outlines the process for addressing benefits and costs symmetrically and comprehensively, ensuring transparency in documentation, and referencing the eight guiding principles from the NSPM as part of the BCA process.

ut its mandate, EFG followed the eight guiding principles set out under the NSPM, which are 3 listed in Table 4, below. 4 5 Table 4: NSPM BCA Guiding Principles Principle 1 Treat DERs as a Utility System Resource DERs are one of many energ...

AI summary The document outlines the eight guiding principles from the NSPM for the BCA, emphasizing the treatment of DERs as utility resources, alignment with policy goals, symmetry in cost-benefit analysis, inclusion of material impacts, and forward-looking long-term analyses.

erm, and incremental to what would have occurred absent the DER. This helps ensure that the resource in question is properly compared with alternatives. Principle 6 Avoid Double-Counting Impacts Cost-effectiveness analyses present a risk of...

AI summary The document outlines principles for conducting benefit-cost analyses (BCAs) in regulatory proceedings, emphasizing transparency, avoiding double-counting, and separating BCAs from rate impact analyses. It also describes the design objectives for a new BCA test, including extensive stakeholder engagement and ensuring transparency.

lance between 5 the materiality of impacts, and the importance of transparency in measuring all relevant impacts. 6 7 Each of these design objectives is discussed more fully in this section. 8 9 8.1 EXTENSIVE DSMAG PROCESS 10 E1 recognizes...

AI summary E1 is developing a new Best Interest of Customers (BCA) test by following a structured DSMAG consultation process and aligning with the NSPM guidelines. This process ensures the test is comprehensive, technology-neutral, and consistent with Nova Scotia legislation and policy goals.

thin the BCA consistent with design principles. 24 Energy Futures Group, Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia, May 13, 2025, Figure 2, page 27 DATE FILED: May 16, 2025 Page 22 of 38 EfficiencyOne...

AI summary The BCA test ensures symmetry in evaluating benefits and costs of DSM activities, emphasizing relevance and transparency. It distinguishes between the definition and application of the test, including relevant impacts regardless of their magnitude, while documenting immaterial impacts.

ufficient magnitude to affect the result of a BCA. Impact 17 determined to be immaterial should be documented, but not necessarily included in the 18 application of the BCA test. 19 20 In developing the new BCA test, E1 and EFG followed th...

AI summary The document discusses the development of a new Best Interest of Customers (BCA) test by E1 and EFG, which includes all relevant non-utility impact categories to ensure proper assessment of E1’s performance and effective implementation of DSM Plans in the best interests of ratepayers. The approach is based on guidance from the NSPM and considers policy objectives under legislation.

Page 23 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 categories are expected to carry significant weight in the cost-effectiveness determination, does nothing 2 to diminish their relevance, and therefore the approp...

AI summary EfficiencyOne (E1) supports the adoption of an evergreening process for the Best Interest of Customers (BCA) test, ensuring it remains current with policy goals, utility costs, and customer behavior. The process will involve the Demand Side Management Advisory Group (DSMAG) and be implemented ahead of the 2027-2031 DSM Plan filing, with Energy Board approval sought for any changes.

e incorporated as part of the next DSM Plan. For the upcoming 2027-2031 28 DSM Plan, the application will be filed early 2026, with the expectation that it will be subject to a new BCA 29 test. DATE FILED: May 16, 2025 Page 24 of 38 Effici...

AI summary This section outlines the inputs used by EFG in developing a new BCA test for the upcoming DSM Plan. Key inputs include Nova Scotia legislation, NSPM guidelines, and feedback from the DSMAG.

valuable feedback and discussion 21 with the DSMAG members through recurring DSMAG meetings, which covered every aspect of the 22 proposed BCA test methodology (discussed in section 7.3 above). 23 24 10. COMPONENTS OF NEW BCA TEST 25 This...

AI summary The document outlines the key differences between the current TRC Test and the proposed new BCA Test, emphasizing the inclusion of non-utility system impacts, particularly the commodity costs of gas in the 'Other Fuels' category under the BCA Test.

Page 26 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 10.2 UTILITY SYSTEM IMPACTS 2 Utility System Impacts, or “USIs”, are elements of electricity or gas systems required to deliver service to 3 utility customers. U...

AI summary The document discusses Utility System Impacts (USIs) under the new BCA test, which include generation, transmission, and distribution. These impacts are categorized and include energy generation, with examples such as the production or procurement of energy on behalf of customers. This category is included in the new BCA proposed by EfficiencyOne.

 on behalf of customers, can include calculation of line losses Capacity The generation capacity (kW) required to  meet the forecasted system peak load Environmental Actions to comply with environmental Generation Compliance regulations...

AI summary The text discusses various aspects of utility system impacts, including capacity requirements, environmental compliance, renewable portfolio standards, and ancillary services. It outlines how these factors are considered in the context of DERs and the BCA process.

2025 Page 28 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence Impact Type Utility System Impact Description and Examples Inclusion in New BCA Reliability Maintaining generation, transmission, and distribution system to w...

AI summary The document outlines the inclusion of reliability, resilience, and compliance with regulatory requirements in the new BCA (Best Interest of Customers) framework. These impact types are emphasized for their importance in maintaining system stability and adherence to policies such as FERC Order No. 2222.

 Requirements Federal Energy Regulatory Commission (FERC) Order No. 2222 1 2 3 10.3 NON-UTILITY SYSTEM IMPACTS 4 As explained in the NSPM, best practices suggest that all impacts relating to a jurisdiction’s policy goals 5 and objectives...

AI summary The document outlines the inclusion of non-utility system impacts (N-USIs) in the Best Interest of Customers (BCA) test, emphasizing the need to consider efficiency and distributed energy resources (DERs). It references legislative changes, particularly the More Access to Energy Act, and recommendations from the EfficiencyOne Group (EFG) and the Demand Side Management Advisory Group (DSMAG).

le 7: Other Fuel Impacts Other Fuel Description and Examples Inclusion in Discussion Notes Impacts new BCA Primarily electrification or efficiency displacing fossil fuels. Fuel and related O&M Commodity  Distributed Storage can be used costs...

AI summary The document discusses other fuel impacts, including the displacement of fossil fuels by electrification and efficiency, compliance costs for environmental regulations, and the market price effects of other fuels. These impacts are considered in the new BCA framework, with some factors deemed not material.

y increased Effects fuels resulting from large enough to EV usage in NS. Cross fuel DRIPE DATE FILED: May 16, 2025 Page 30 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence Other Fuel Description and Examples Inclusion in...

AI summary The text discusses the inclusion of other fuel impacts in the Best Interest of Customers (BCA) analysis, particularly focusing on changes in consumption levels and the effects of gas DER on the electric system. It notes that cross-fuel impacts may be non-material for most customers but could be significant for large industrial users.

Other Utility If electric DER, impact on Not material, or Further analysis required to System Impacts gas system (e.g., T&D, large enough to determine potential decline in storage, reliability, etc.) merit routine gas consumption and deman...

AI summary The text discusses host customer impacts related to distributed energy resources (DER), emphasizing that non-energy impacts should be included in the Best Interest of Customers (BCA) test. It references the Energy Reform Act, the 2022 NSUARB Decision, and practices in other jurisdictions to support this inclusion. A proxy adder method is used to quantify these impacts.

ethod used in other jurisdictions 15 rather than quantifying a value stream for each separate impact. Table 8 presents the other fuel impact 16 categories, their description and indicates whether they are included in the new BCA proposed b...

AI summary The text discusses the inclusion of various host customer impacts in the new BCA proposed by E1, such as DER measure costs, transaction costs, interconnection fees, and risk. These impacts are relevant to different types of DER and are outlined in Table 8.

ost impacts Some efficiency measures also reduce water  consumption O&M costs EE and EV typically decrease. DR, DG and DS  may increase, BE may increase or decrease Productivity Many EE investments in businesses improve  productivity DATE...

AI summary The document discusses the economic, comfort, amenity, and health benefits of efficiency and demand response programs. It highlights how energy efficiency measures can reduce energy bills, improve comfort, and enhance health and safety. It also notes potential trade-offs, such as range anxiety from electric vehicles.

hour (BPK) of air quality-related public health benefits of investments in energy efficiency 19 and renewable energy as detailed by EFG. Table 9 presents the societal impacts, their description and DATE FILED: May 16, 2025 Page 33 of 38 Ef...

AI summary The text discusses the societal impacts of energy efficiency and renewable energy investments, including resilience, greenhouse gas emissions, environmental impacts, economic development, and public health. It references Table 9, which outlines these impacts and their inclusion in the new Best Interest of Customers (BCA) framework.

& Net changes in GDP and/or jobs No Jobs Public Health Changes in medical outcomes and costs  Energy Security Changes in energy independence No 5 EFG recommends this should be addressed outside of BCA framework by separate study 6 7 In su...

AI summary EFG recommends including specific impact categories in the BCA test, such as public health, energy security, and societal resilience, while noting that some categories like net changes in GDP and jobs should be addressed outside the BCA framework. Table 10 outlines the recommended impact categories and sub-categories for inclusion.

y Impacts Measured Public Health Commodity costs are embedded in the “Other Fuels” category. Resilience is embedded in “Host Customer” category. Public Health impacts embedded in “GHG Emissions” and “Other Environmental” categories. 1 2 E1...

AI summary This section presents test case results for the Best Interest of Customers (BCA) framework, focusing on the impact of replacing different fuel types with heat pumps. The test cases include utility system impacts, host customer impacts, and cost-benefit analyses for 1,000 heat pump installations.

tal Net Benefits $31.36 $25.4 ($17.4) Benefit Cost Ratio 4.17 1.80 0.45 1 DATE FILED: May 16, 2025 Page 36 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 Figure 2 presents the same data as the table, but in a visual fo...

AI summary The text presents a benefit-cost analysis of electrification scenarios, including heat pumps replacing electric resistance, fuel oil, and natural gas. It highlights the impact on utility systems and host customers, showing varying costs and benefits depending on the scenario.

Page 37 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 12. CONCLUSION 2 In accordance with the NSUARB’s direction, E1 has developed an optimal cost-effectiveness test tailored 3 to Nova Scotia. In the development of...

AI summary EfficiencyOne (E1) has developed a new Best Interest of Customers (BCA) test for evaluating Demand Side Management (DSM) Plans in Nova Scotia, following guidance from the Nova Scotia Utility and Regulatory Board (NSUARB). The test was designed with input from the DSMAG and aligns with provincial policy objectives and the NSPM. E1 argues the BCA test is in the best interest of ratepayers and requests approval from the Energy Board.

of David Hill, Energy Futures Group, Inc. EfficiencyOne Benefit-Cost Analysis Test Application Appendix A NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT, RSNS 1989, C 380, AS AMENDED IN THE MATTER OF: EFFICIENCYONE APP...

AI summary This document outlines the application by EfficiencyOne for the approval of a new Nova Scotia Benefit-Cost Analysis (BCA) test for evaluating Demand-Side Management (DSM) plans, prepared by David G. Hill of Energy Futures Group, Inc. It includes sections on qualifications, development of the BCA test using the National Standard Practice Manual, alignment with legislative frameworks, and data sources.

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.

est with 7 Legislative Framework 8 Q: What steps did EFG take to ensure the recommended Nova Scotia BCA test is aligned with and 9 reflects Nova Scotia policy and legislative priorities? 10 A: Conducting an inventory of Nova Scotia’s relev...

AI summary EFG ensured alignment of the Nova Scotia BCA test with policy and legislative priorities by reviewing relevant legislation, including the Public Utilities Act and Energy Reform Act. Amendments to the Energy and Regulatory Boards Act and More Access to Energy Act expanded the scope of impacts considered in regulatory decisions to include sustainable development and prosperity.

Page 11 of 18 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A 1 4. Data Sources and Their Application in Developing the 2 Recommended BCA Framework 3 Q: What data sources and collection were used by EFG during the work with...

AI summary EFG used data from Canadian and U.S. sources, including E1 and Nova Scotia Power, in developing the recommended Nova Scotia benefit-cost analysis test framework. The National Energy Screening Project's National Standard Practice Manual was referenced for methodological guidance. Data usage is detailed in Table 3, with updates expected for the 2027-2031 DSM portfolio screening.

Non-Energy energy benefits or measure costs (for NEBs and presented and refined Benefits beneficial electrification) proposed NEB proxies with the group. 1 2 5. Comparison of Recommended Nova Scotia Test to Prior Test 3 Q: How does the Nova Sco...

AI summary The Nova Scotia BCA Test recommended by EFG differs from the TRC test used for E1’s 2023-2025 DSM Plan. The TRC test excluded other fuel impacts and non-utility benefits, while the new test includes a broader range of impact categories as outlined in Table 4.

ctric resistance heat, fuel oil, natural gas, show benefits above the horizontal axis 2 and costs below. 3 Figure 1: Illustrative Results Using Recommended New Nova Scotia Test 4 5 6 Under the recommended new Nova Scotia BCA Test, the bene...

AI summary The document compares the benefit-cost ratios of replacing different heating systems under the new Nova Scotia BCA Test and the prior TRC Test. Under the new test, electric resistance heating replacement is highly cost-effective, while natural gas replacement is not. The prior test showed similar results for electric resistance but failed to capture benefits from other fuel impacts and host customer benefits, leading to lower ratios for fuel oil and natural gas replacements.

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.

cipants included organizational representation from: 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 28 of 68 EfficiencyOne Benefit-Cost An...

AI summary The document is an appendix to a Benefit-Cost Analysis Test Application submitted by EfficiencyOne. It includes contact information for Energy Futures Group, Inc., and references the test application filed on May 16, 2025.

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

AI summary The text describes a working group's activities related to the Benefit-Cost Analysis (BCA) test, including discussions on areas of agreement, methodology for quantifying impacts, and review of the BCA framework report. The Energy Futures Group, Inc. is identified as a participant.

- $ 341 0.74 $ 1,055,571 Total $ 13,898,925 The social cost of carbon is based on December 2022 updates from Environment Canada.42 The social cost of CO2 is used in the example, but if estimates of avoided CH4 and N20 emissions are availab...

AI summary The text discusses the social cost of carbon based on Environment Canada's 2022 updates and its application in a benefit-cost analysis (BCA) test. It also mentions the value of reducing air pollutants like PM, SO2, and NOx using EPA estimates and highlights the impact of heat pumps on electric generation and associated costs or benefits.

1 Request IR-01: 2 3 Reference: E-1, Application, page 5, para 26 (pdf page 6 of 450). 4 5 E1 submits that the proposed BCA test is appropriate, reasonable, is in the 6 best interest of ratepayers, and should replace the existing TRC test...

AI summary The document discusses E1's proposed BCA test as a replacement for the existing TRC test for evaluating DSM plans. E1 argues the BCA test is in the best interest of ratepayers and more balanced than the TRC test, which is criticized for being biased due to its inclusion of host customer costs but not participant benefits.

Recent legislative changes and evolving energy priorities—especially related to electrification and decarbonization—have further prompted a re-evaluation of this framework. The Nova Scotia Utility and Review Board (now Nova Scotia Energy B...

AI summary Recent legislative changes and energy priorities have prompted a re-evaluation of the cost-effectiveness framework for demand-side management (DSM). The Nova Scotia Energy Board has directed E1 to work with the DSMAG to develop a jurisdiction-specific BCA test to better evaluate DSM investments and align with Nova Scotia's evolving energy and environmental goals.

Request IR-03: (a) Approximately how much additional work does E1 anticipate will be required to accomplish its new BCA test compared to the existing TRC for both forecasting and reporting results? (b) Please provide detail of the work pro...

AI summary EfficiencyOne (E1) anticipates some incremental work to implement a new BCA test compared to the existing TRC test, focusing on quantifying new impact streams. The BCA test is intended to be a more accurate and practical tool for assessing the cost-effectiveness of DSM plans. E1 has initiated this work with the DSMAG and believes the BCA balances analytical rigor with practical feasibility.

ds the BCA analysis in real-world data while respecting practical considerations, ensuring the analysis generates meaningful insights without over-investing beyond the point of diminishing returns. 6 7 (b) To implement the proposed BCA tes...

AI summary The text discusses the implementation of a BCA test by E1, requiring quantification of all included impacts as outlined in a table. The focus is on ensuring the analysis is practical and generates meaningful insights without over-investment.

ased on policy priorities and objectives established under legislation. Applying this lens to non-utility impacts, in E1's submission, supports the inclusion of the impact categories proposed under - (a) Please identify all the indirect be...

AI summary The text requests the identification and explanation of indirect benefits and costs in the BCA, including how they are quantified and supported by empirical evidence under relevant legislation. It also asks for an explanation of why including these is considered a best practice in BCA design for DSM.

- v) If indirect costs and benefits are removed from the proposed BCA, would the ratio of 1.0 or greater remain as the threshold? 1 (b) Please provide the list of the proposed weights to be assigned to each utility impact used 2 in develop...

AI summary The text requests clarification on the proposed BCA test, including the weights assigned to utility and non-utility impacts, whether a sensitivity analysis was conducted, and how non-utility benefits align with policy objectives in the Public Utilities Act. It also asks about the impact of repealing specific sections on the BCA and whether performance requirements will be proposed for non-utility benefits.

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.

- 2 system benefit that is not measured and is considered not material. 1 Request IR-05: 2 3 Please describe how the BCA as proposed by E1 aligns with the Treasury Board of Canada 4 Secretariat Canada's Cost-Benefit Analysis Guide for Regu...

AI summary The document outlines a request for information on how the proposed BCA by EfficiencyOne aligns with Canadian federal cost-benefit analysis guidelines. The response indicates that E1's framework is consistent with the principles of transparency, comprehensiveness, and evidence-based decision-making as outlined in the 2019 and 2018 federal guidelines.

- 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.

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.

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.

E1 Responses to Small Business Advocate (SBA) Information Requests NON-CONFIDENTIAL Request IR-04: - Refer to Exhibit E-1, the Report, page 20 of 68. Describe the safeguards built into the BCA Test - methodology to prevent the double count...

AI summary EfficiencyOne (E1) responds to Small Business Advocate (SBA) information requests regarding the BCA Test methodology. Key points include safeguards to prevent double-counting of benefits like avoided GHG and fuel costs, additional test runs for the BCA Test, and handling of long-term benefits such as decarbonization of the grid.

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.

- 2) Whether the inclusion of host customer benefits and/or host customer costs in the proposed BCA test used to determine the cost effectiveness of future DSM plans is consistent with the legislative support cited in the Application.

AI summary The document raises a question about whether the inclusion of host customer benefits and costs in the BCA test for evaluating future DSM plans aligns with the legislative support cited in the Application.

III. OBSERVATIONS AND RECOMMENDATIONS - Q. Please summarize your observations regarding the Application. - A. After reviewing the Application I have the following observations: - The proposed BCA test framework relies on proxy values for c...

AI summary The reviewer observes that the proposed BCA test framework depends on proxy values for non-energy benefits due to insufficient information from E1 to quantify them directly.

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.

o Empowerment - 2. Present this independent third party evidence to the members of the DSMAG in a stakeholder proceeding that allows for information requests to be include on the record and determine through DSMAG consensus whether and how...

AI summary The testimony outlines steps to amend the BCA test through a stakeholder proceeding involving the DSMAG and includes an update to the Application before filing the 2027-2031 DSM Plan Application. An alternative is to set Unquantified Non-Energy Benefits to Nil until approval by the Board.

1 customers qua customer interests (e.g., price, reliability, availability, etc.) which appears to be 2 consistent with the Board's earlier determinations as well.4 This does not appear to prohibit the 3 Board taking into account any numbe...

AI summary The text discusses the Board's consideration of customer interests, including price, reliability, and availability, in line with earlier determinations. It emphasizes that the Board must prioritize the best interests of NSPI customers while adhering to the Energy and Regulatory Boards Act and other legislation promoting competition, innovation, and sustainable development.

- 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 Criterion (PAC) as a primary screening tool for Demand Side Management (DSM) activities, emphasizing its relevance to utility economics and customer impact. It addresses concerns that using PAC might exclude societal benefits and sustainability considerations, clarifying that PAC can still accommodate these factors through additional information. The PAC is shown to be more favorable than the Total Resource Cost (TRC) in the 2023-2025 DSM plan.

Response to Information Requests Request IR-1: Reference: Exhibit E-13, page 5-6. Ms. Whitten indicates that "a well-crafted DSM plan can be successful in reducing or delaying an increase in peak demand that then should translate into cust...

AI summary The text discusses Ms. Whitten's testimony regarding the benefits of a well-crafted DSM plan, emphasizing customer bill savings and the need for the BCA test to avoid increased costs for customers without corresponding benefits. It raises questions about the meaning of 'benefits' and whether Ms. Whitten supports DSM costs being incurred for broader societal benefits rather than just utility and customer bill benefits.

- Reference: Exhibit E-13, page 8. - Ms. Whitten indicates: "I recommend that E1's proposed BCA test not be approved until - E1 has completed a thorough assessment of the proposed non-energy benefits presented - in this Application. In add...

AI summary Ms. Whitten recommends delaying approval of E1's proposed BCA test until non-energy benefits such as comfort, amenity, empowerment, and pride are thoroughly assessed and quantified. The summary questions whether these benefits should be included in the BCA if they are not aligned with customer bill savings and whether the PAC test would address these concerns.

- On pages 13-15, Mr. Bowman discussed why a focus on the program administrator test as - the primary test would be preferred to the "Proposed BCA". Please explain why a focus on - the program administrator test as the primary test would b...

AI summary The text references a discussion by Mr. Bowman on why the program administrator test should be prioritized over the 'Proposed BCA' and the total resource cost test, which includes non-energy benefits as outlined in 'Option 1'.

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

AI summary The Small Business Advocate (SBA) provides an opening statement regarding EfficiencyOne's application for a new benefit-cost analysis (BCA) test for evaluating demand-side management (DSM) plans. The SBA represents Small General, General, and Small Industrial Classes of ratepayers and has been involved in discussions with EfficiencyOne and the DSMAG over the past 20 months.

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.

9 COUNSEL OPENING STATEMENT 10 ON BEHALF OF THE INDUSTRIAL GROUP 11 As required by the Public Utilities Act , NSPI is required to undertake cost-effective, reasonably - 12 available, demand side management (" DSM ") by entering into a purc...

AI summary The Industrial Group argues against the Proposed E1 BCA test, which incorporates non-energy benefits and societal impacts, and instead recommends the Program Administrator Cost (PAC) test as the primary measure of cost-effectiveness for demand side management (DSM) programs. They emphasize alignment with Canadian regulatory practices and the best interests of customers.

- 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.

- 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, Table 10....

AI summary The document references Exhibit E-1, which includes EfficiencyOne's application for approval of a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans. It outlines requirements for providing detailed formulas, data sources, and examples for calculating benefits and costs, including avoided fuel prices and social cost of carbon values.

1 2025 M12282 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 5 6 IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit Cost Analysis Test for Evaluating Demand Side Management Plans 7 8...

AI summary The Nova Scotia Energy Board has issued information requests to EfficiencyOne regarding its proposed BCA test for evaluating Demand Side Management (DSM) plans. The requests seek clarification on how the BCA test is in the best interest of ratepayers, whether it would reduce the impact on electricity rates, and if it would promote broader diversity in DSM programs and participation.

- 8 (d) Does E1s assertion that its proposed BCA test is in the "best interest of 9 ratepayers" indicate that the new cost effectiveness test will continue to 10 determine whether its Plan is affordable and result in the lowest long-term 1...

AI summary The question challenges E1s' assertion that its proposed BCA test is in the best interest of ratepayers, asking whether the new cost effectiveness test will ensure affordability and the lowest long-term cost of electricity.

21 And References: E-1, Evidence, Section 4.2 – 2026 DSM Plan Extension, page 8; and 22 Section 11, pages 35 – 36 - 23 (a) To compare the new BCA test with the existing approved TRC test, for the 24 entirety of the 2026 DSM Plan, at the po...

AI summary The text requests a comparison between the new BCA test and the existing TRC test for the 2026 DSM Plan, asking whether non-energy impacts outweigh energy-related impacts. This relates to the evaluation of the DSM Plan Extension and involves considerations of cost-effectiveness and regulatory processes.

- 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 outlines several requests to compare the new BCA test with the current TRC test, focusing on non-energy impacts, relative weights, and additional work required. It also references the National Standard Practice Manual and asks about the principle of symmetry in the BCA test.

1 2025 M12282 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit- 5 Cost Analysis Test for Evaluating Demand Side Management 6 Plans 7 8...

AI summary The document is an information request related to EfficiencyOne's application for a new benefit-cost analysis test for evaluating demand side management (DSM) plans under the Public Utilities Act. The request focuses on clarifying the term 'benefits' in the context of potential customer cost increases and bill savings.

- 8 (c) Is the above cited excerpt suggestive that Ms. Whitten is more conceptually 9 aligned with a BCA such as the PAC test rather than the test proposed by 10 E1 (i.e., a test focused on utility and customer bill benefits, rather than 1...

AI summary The text discusses Ms. Whitten's recommendation to delay approval of E1's proposed BCA test until non-energy benefits are thoroughly assessed and quantified, and whether these benefits should be included in the BCA if they are not aligned with customer bill savings. It also asks whether the PAC test would address these concerns.

MATTER #: M12282 DATE: UND# DESCRIPTION REQUESTED OF BY DATE DUE September 22, 2025 To provide the results using the Program Administrator Costs (PAC) test method and exclude the Host Customer Benefits from the new BCA to the analysis of t...

AI summary The document outlines a request for results using the Program Administrator Costs (PAC) test method, excluding Host Customer Benefits from the new BCA analysis, as part of Matter M12282. EfficiencyOne Board Counsel is the party requesting this information by October 1, 2025.

What the Proposed BCA does also include, however, are new non-utility system impact categories and a symmetrical approach of applying both benefits and costs to each non-utility system impact category. More specifically, the Proposed BCA a...

AI summary The Proposed BCA introduces new non-utility system impact categories and applies both benefits and costs to each, including host customer and societal impacts. The CA, SBA, and ECEL support the Proposed BCA with amendments outlined in the PCA. No specific concerns were raised regarding the 'Other Fuels' or 'Societal' categories.

NATURAL GAS TO ELECTRIC CONVERSIONS In its Rebuttal Evidence E1 stated that: "In the actual event that conversion of gas heating systems to electric heat pumps results, under that application of the proposed BCA yielded a negative benefit...

AI summary EfficiencyOne (E1) argues that converting natural gas heating systems to electric heat pumps would result in a negative benefit of $17.4 million and a benefit-cost ratio of 0.45, requiring justification under existing Board directives. Eastward challenges this, arguing such a measure should not be considered valid strategic electrification and urges the Board to provide guidance on the level of justification required for such a low benefit-cost ratio.

NOVA SCOTIA ENERGY BOARD 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 Managem...

AI summary East Coast Environmental Law submits a closing statement supporting EfficiencyOne's proposed new Benefit-Cost Analysis test for evaluating DSM plans, emphasizing the inclusion of avoided social costs of carbon and the Board's responsibility under the Energy and Regulatory Boards Act to consider non-energy impacts in cost-effectiveness testing.

16 17 Please accept these as the closing submissions on behalf of the Consumer Advocate regarding the 18 Application filed by EfficiencyOne ("E1") for approval of a New Benefit-Cost Analysis ("BCA") 19 Test for Evaluating Demand Side Manag...

AI summary The Consumer Advocate submits closing remarks on behalf of EfficiencyOne's application for approval of a new benefit-cost analysis test for evaluating demand side management plans.

23 C. Submissions 24 25 As noted above, the Consumer Advocate has executed a Partial Consensus Agreement with E1 26 and other Parties regarding the new proposed BCA Test. The Consumer Advocate supports the 27 adoption of the terms of the A...

AI summary The Consumer Advocate supports the adoption of a new BCA Test as outlined in a Partial Consensus Agreement with E1 and other parties. The discussion highlights the need to assess whether recent legislative amendments in 2024 allow for the inclusion of non-energy impacts in cost-effectiveness testing, following a previous decision in EfficiencyOne (Re) , 2020 NSUARB 56.