Topic:"Best Interests Of Customers" in M12780

2. BACKGROUND AND OVERVIEW: ROUND 2 MODEL RESULTS E1 circulated its Round 1 model assumptions and results to the Demand-Side Management Advisory Group (DSMAG) on October 27, 2025. E1 received written comments from DSMAG members regarding t...

AI summary E1 updated its Round 2 model results for the DSM Plan, incorporating new avoided costs from NS Power and guidance from the NSEB. Strategic electrification was excluded due to its failure to reduce customer electricity costs. The Residential Behaviour program was removed, and the Residential DR program was modified based on feedback from the NSEB and DSMAG.

Standardized Filing Framework the proposed cost-effective demand-side management at the portfolio level that would be the aggregate amount of demand-side management programs." 28 In the Board's Decision dated December 10, 2025 in matter M1...

AI summary The Board directed E1 to use the Program Administrator Cost (PAC) test as the primary method for evaluating the cost-effectiveness of its Demand Side Management (DSM) plan for 2027, using NS Power's WACC as the discount rate. E1 is also required to provide individual justifications for any measures failing cost-effectiveness tests in future applications.

4.3.2 COST-EFFECTIVENESS TESTING E1 will apply the NSEB-approved cost-effectiveness test. Pursuant to Section 79H (2) of the Public Utilities Act , the NSEB, in evaluating a franchise holder's application, "shall evaluate the proposed cost...

AI summary E1 is required to apply the NSEB-approved cost-effectiveness test for its DSM plan, using the PAC test and NS Power's WACC as the discount rate. The Board also directed the use of a modified PAC for assessing strategic electrification, which must reduce both GHG emissions and electricity costs. E1 will provide cost-effectiveness results at multiple levels, including individual measures that fail testing.

2. Another challenge is the exclusion of other energy benefits from the scope of the test due to legislative requirement. The National Standard Practices Manual (NSPM) explains that electrification may add costs to the electric grid and ca...

AI summary The exclusion of non-electric system benefits from the BCA test creates challenges in evaluating strategic electrification. The NSPM highlights that electrification may add costs to the electric grid unless non-electric benefits like fuel savings are included. While the Board's modified PAC aligns with statutory requirements, it does not fully capture the broader benefits of electrification.

1 appears that E1 either assessed the BCA of strategic electrification by itself, or E1 2 looked at the change in the portfolio-level BCA (including energy efficiency, 3 demand response, PV) when strategic electrification is added.28 4 How...

AI summary The text discusses E1's assessment of the benefit-cost analysis (BCA) of strategic electrification and how it was interpreted in light of the NSEB's Decision in Matter M12282. The Board required E1 to use the PAC test and consider increased revenues from strategic electrification, which must reduce both GHG emissions and electricity costs for customers. The Public Utilities Act defines strategic electrification and outlines its requirements.

PAC test. (b) Please explain in detail how these benefits are excluded from consideration by the modified PAC test. Response IR-2: This IR response has been provided by The Brattle Group. (a-b) As explained in Section V.B.2 of the Brattle...

AI summary The response from The Brattle Group explains that the modified PAC test excludes benefits from reduced consumption of other fuels and avoided emissions, as it focuses only on electric system energy benefits. This exclusion may undermine the comprehensive benefits of strategic electrification programs, though the Board's decision to use the modified PAC test is based on statutory requirements.

M12780 - In the Matter of EfficiencyOne's (E1) 2027–2031 Demand Side Management (DSM) Resource Plan Application 1 Lane at Synapse, or conferred or consulted with Ms. Lane in any way? If 2 so, please describe the nature of those discussions...

AI summary The response addresses whether the respondent conferred with Courtney Lane from Synapse regarding the BCA test and DSM Plan. The respondent confirms discussions with Ms. Lane, but clarifies that they did not intend to offer legal opinions and that they did not propose changing the cost-effectiveness framework established in M12282.

EfficiencyOne's demand-side management responsibilities and the differing interpretations of applicable statutory language, the work of interpreting and opining on the changes introduced by the Energy Reform (2024) Act , SNS 2024, c 2, wil...

AI summary EfficiencyOne's application for a new benefit-cost analysis test for demand-side management plans is being considered by the Nova Scotia Energy Board. The Board must interpret amendments to the Public Utilities Act and apply its new sustainability mandate under the Energy and Regulatory Boards Act. East Coast Environmental Law is participating in the matter to observe how the Board implements its sustainability responsibilities.

- (5) Address any matters deemed appropriate by the Board (s. 79L(4) & (5)); and - (6) Be in the best interests of NS Power customers (s. 79L(4)). As detailed in the sections that follow, E1 submits that each requirement above has been met...

AI summary E1 submits that the Preferred Plan meets all regulatory requirements, including being in the best interests of NS Power customers. The plan is cost-effective with a benefit-cost ratio of 2.4, includes programs within the DSM definition, and aligns with past Board directives and technical requirements.

4.2 AFFORDABILITY WITHIN THE PUBLIC UTILITIES ACT - E1 submits affordability is a central consideration for DSM plans under the PUA . The Board's responsibility - in considering this DSM Plan Application is defined by ss. 79A–79W of the PU...

AI summary The text discusses affordability considerations under the Public Utilities Act (PUA) in relation to Demand Side Management (DSM) plans. It highlights key sections of the PUA, including cost-effectiveness tests, the franchise holder's role, and rate stability provisions. The focus is on ensuring that DSM plans are cost-effective and in the best interests of customers.

9 4.7 E1'S POSITION ON A HIGHER INVESTMENT LEVEL As explained in Section [4.1](#page-15-1) above, E1 evaluated multiple investment scenarios and agrees the IRP identifies a higher level as optimal over the long term. These submissions defe...

AI summary E1 supports a higher investment level in the Integrated Resource Plan (IRP) as optimal over the long term and agrees that the Board can direct such a level under section 79L(4) of the Public Utilities Act if it is in customers' best interests. E1 will implement any approved higher investment level through appropriate ramp-up considerations and structured mechanisms like the Annual Adjustment Process and Mid-term Check-in.

4.8 CONCLUSION Affordability was a central design principle of this Preferred Plan, and it is a principle the PUA , this Board (in Matter M12282), and parties to this proceeding recognize as legitimate. The question for the Board under s....

AI summary Affordability is a central principle of the Preferred Plan, recognized by the PUA, the Board (in Matter M12282), and parties to the proceeding. The Board must determine whether the plan is in customers' best interests and satisfies s. 79I of the PUA, considering both near-term affordability and long-term savings.

10.3.2 BEST INTERESTS OF RATEPAYERS Once it is determined that a DSM resource falls within E1's legislated mandate under the PUA, the question before the Board is whether inclusion of that DSM resource, as set out in the DSM Plan, is in th...

AI summary The document discusses the approval of a solar-PV program under the Public Utilities Act, emphasizing its cost-effectiveness and benefits to equity-seeking customers. E1 argues that the program, as presented in the Preferred Plan, aligns with the best interests of ratepayers.

10.4 CONCLUSION As a threshold matter, E1 has the legislated mandate to carry out solar-PV activities as part of DSM, pursuant to section 79A(b) of the PUA . Falling within the definition of DSM does not, on its own, entitle the program to...

AI summary E1 argues that the solar-PV program should be included in the DSM Plan as it meets the requirements of the PUA and ERBA, is cost-effective, and aligns with equity-seeking group provisions and balanced plan principles.

15. CONCLUSION AND REQUESTED ORDER The 2027–2031 Preferred DSM Plan having been submitted for approval before the Board is an appropriate and effective plan for providing Nova Scotia with the DSM services outlined in the PUA. The Preferred...

AI summary E1 submits its 2027–2031 Preferred DSM Plan for approval, emphasizing its alignment with the PUA, cost-effectiveness, affordability, and benefits to Nova Scotia ratepayers. The plan includes specific energy and financial targets, and E1 requests approval or interim approval if a decision is delayed.

Historical Context for DSM Planning The Board's prior DSM decisions provide important context for the current application in evaluating the importance of short-term impacts and the alignment with IRP targets. When the multi-year DSM provis...

AI summary The document provides historical context for Demand Side Management (DSM) planning, referencing the Board's 2015 decision on the 2016-2018 DSM Plan. It highlights the importance of affordability in DSM-related decisions and the Board's emphasis on aligning with the best interests of customers despite short-term affordability concerns.

1. AFFORDABILITY The CA, AEC, ECEL, and EAC each submit, in various forms, that the Preferred Plan's capped investment level of $63.75 million annually is unnecessarily conservative and that the Board should direct E1 toward the IRP-aligne...

AI summary The CA, AEC, ECEL, and EAC argue that the Preferred Plan's investment level is too low and should align with the IRP savings target. However, the IG contends that focusing only on residential affordability ignores the impact on other customer classes, particularly large industrial users, who would bear the cost of increased BNI programming required to meet the higher savings target. The IG emphasizes the need for a comprehensive affordability analysis considering all customer classes.