Topic:"Cost Effectiveness" in M03669

5.2 Changes to DSM Screening ENSC is proposing that the TRC test for the 2012 DSM Plan be applied at the program level, not at the measure level as was previously required. ENSC is seeking the flexibility to consider factors in addition to...

AI summary ENSC proposes changing the DSM screening process by applying the TRC test at the program level rather than the measure level and considering additional factors beyond TRC. The TRC and PAC tests have historically shown strong benefit-cost ratios for DSM programs in 2012, with TRC and PAC values exceeding 1.0.

TOTAL RESOURCE COST (TRC) SCREENING REQUIREMENTS Current electricity DSM targets were derived from Nova Scotia Power's Integrated Resource Planning (IRP) process. Through this process, a level of incremental annual energy savings, roughly...

AI summary The Total Resource Cost (TRC) screening requirements in Nova Scotia's Demand Side Management (DSM) plan are based on the Integrated Resource Planning (IRP) process. The TRC approach compares the full cost of energy efficiency to the equivalent long-run cost of offset supply, ensuring that only cost-effective measures are promoted. However, the requirement that the TRC must be greater than 1 raises concerns about undue constraints and unintended consequences.

advantages. 10 Ultimately, should a single test be required to screen the DSM plan or its components, we would urge that it take into consideration the shortcomings highlighted above. RISK The requirement for individual measures to pass th...

AI summary The document criticizes the use of the Total Resource Cost (TRC) as a screening mechanism for Demand Side Management (DSM) plans, arguing that it is unduly restrictive and may lead to unintended consequences, such as discouraging the adoption of cost-effective technologies. It recommends moving away from measure-level TRC requirements to plan-level cost-effectiveness evaluations and exploring alternatives to the TRC.

buildings' performance and, as such, may generate spillover savings that cannot easily be attributed. Residential Existing Houses: In this program, solar hot water heaters are being promoted, despite a TRC of 0.4. ENSC has chosen to promot...

AI summary The text discusses ENSC's promotion of certain energy efficiency measures, such as solar hot water heaters, ENERGY STAR® freezers, and screw-in CFLs, despite their Total Resource Cost (TRC) failing to meet the threshold. ENSC justifies these decisions based on long-term strategic benefits, spillover effects, and customer value. References are made to other regulatory requests and decisions for further context.

Request IR-29: Regarding Appendix C, the Dunsky report, at p. 16, please explain why the Utility Cost (or Program Administrator) Test is superior to the TRC in providing a threshold for determining cost-effectiveness and/or a ranking of in...

AI summary The response clarifies that Dunsky's report does not claim the Program Administrator Cost (PAC) test is superior to the TRC test but highlights PAC as an alternative addressing TRC's failure to account for non-energy benefits (NEBs). TRC may prioritize costly measures due to undervaluing NEBs, while PAC focuses on public spending and implicitly considers NEBs, adopting a business-oriented approach to maximize savings per ratepayer dollar.

uded to demonstrate the importance of implementing the program as a randomized trial, it appears that in this particular case, the ATE could have been estimated even in the absence of a control group. The third specification in Table 7.3 r...

AI summary The text discusses the estimation of Average Treatment Effects (ATE) in a randomized trial, highlighting a discrepancy between ATEs calculated using logged and non-logged specifications. The difference is statistically and substantively significant, affecting cost-effectiveness estimates.

5 Cost Effectiveness and Profiling Regardless of the mechanism that drives the variation in treatment effects across households with different baseline usage, the heterogeneity in treatment effects as a function of an observable characteri...

AI summary The text discusses cost effectiveness and profiling in the context of energy efficiency programs. It emphasizes targeting the most responsive households for maximum gains and outlines a decision-making framework for utilities aiming to minimize compliance costs with energy efficiency regulations.

ATE of the Quarterly reports is much more than 1/3 the ATE of the monthly reports, and depending on Positive Energy's ratio of fixed to variable costs, Quarterly reports could be more cost-effective. & lt;sup>17 Note that this example is n...

AI summary The text discusses the cost-effectiveness of Positive Energy's program, noting that quarterly reports may be more cost-effective than monthly ones depending on cost structure. It also highlights that the program's impact is strongest for high-consumption households and suggests targeting based on expected treatment effects to improve cost-effectiveness.

$7.6 \quad \hbox{Profiling and Cost Effectiveness}$ Assignment Mechanism All I II III ATE -0.0191 -0.0343 -0.0346 -0.0347 (0.0053) (0.0035) (0.0035) (0.0036) Electricity Bill Savings (dollars/household-year) 20.34 36.56 36.85 36.99 (5.60)...

AI summary This section presents a table analyzing the cost effectiveness of different assignment mechanisms (All, I, II, III) in terms of ATE, electricity bill savings, and cost effectiveness in cents per kWh saved. The data shows varying levels of savings and cost effectiveness across mechanisms.

Target - Eligible retrofit projects save 20,000+ kWh/year - Can aggregate multiple sites, where cost effectiveness is improved and incentives from other C&I programs do not apply

AI summary Eligible retrofit projects are highlighted for their energy savings of over 20,000 kWh per year. These projects can aggregate multiple sites, improving cost effectiveness and avoiding incentives from other C&I programs.

British Columbia: Energy Conservation Assistance Program Program Name Energy Conservation Assistance Program Follow-up assessments ensure work was carried out properly and effectively. Successes In 2004, EMA budgeted US$16 million, engaged...

AI summary The Energy Conservation Assistance Program (EMA) in British Columbia achieved significant energy savings and participant engagement between 2001 and 2004, with a cost-effectiveness of 0.63. However, income and household size caps may limit participation, and landlord consent is required. The program is funded through a public goods charge (SBC) levied on customers.

c) Regulators throughout North America have commonly evolved their application of tests based on the scope of savings that were deemed beneficial at the time. For example, many regions new to DSM have had a tendency to begin by applying th...

AI summary This text discusses the evolution of cost-effectiveness tests used in demand-side management (DSM) across North America, highlighting the shift from the Rate Incremental Method (RIM) to the Total Resource Cost (TRC) and variations thereof. It references a 2008 study showing the use of TRC and other tests by different DSM administrators, including utility and non-utility organizations.

ABSTRACT For the past two decades, the Total Resource Cost Test (TRC) has been regulators' principal test for assessing energy efficiency program cost-effectiveness and approving utility funding. However, the TRC as commonly applied today...

AI summary The Total Resource Cost Test (TRC) has been the primary method for assessing energy efficiency program cost-effectiveness, but it has significant limitations, including the exclusion of non-energy benefits and inconsistent treatment of supply alternatives. The document argues that the TRC is impractical to improve and suggests emphasizing the program administrator cost test instead.

Introduction Utility regulators and other policy-makers typically require that initiatives to promote energy efficiency and other demand-side investments are shown to be "cost-effective" before they are approved. In 1983, the California Pu...

AI summary This introduction discusses the evolution of cost-effectiveness screening for energy efficiency programs, referencing the California Standard Practice Manual (CSPM) and its five tests. It highlights the need to re-examine current methods, particularly the Total Resource Cost (TRC) test, due to changes in efficiency programs and growing climate concerns.

The Five Cost-Effectiveness Tests The reason the California Standard Practice Manual describes five different costeffectiveness tests is that cost-effectiveness can be viewed and assessed from at least that many different perspectives. All...

AI summary The California Standard Practice Manual outlines five cost-effectiveness tests used to evaluate energy efficiency programs. These tests compare the net present value of benefits and costs over an investment's life. The paper provides a brief description of each test and a summary table of key benefits and costs included in each.

Participant Test The Participant Test measures cost-effectiveness from the perspective of the efficiency program participant . It simply compares the bill savings (using retail rates) that the customer will realize over the life of an effi...

AI summary The Participant Test evaluates the cost-effectiveness of efficiency programs from the customer's perspective by comparing bill savings to the customer's costs, including any financial incentives. Some upgrades involve immediate costs, while others have costs spread over multiple years.

Total Resource Cost Test The TRC Test theoretically measures cost-effectiveness from the combined view point of program participants and non-participants. We say theoretically because in practice the TRC measures secondary fuel, water or o...

AI summary The Total Resource Cost (TRC) Test evaluates cost-effectiveness from the perspective of both program participants and non-participants. It uses avoided costs for resources like fuel and water rather than retail prices, comparing the value of resource savings with the full cost of efficiency measures and non-measure program costs.

Societal Test The Societal Test is a variant on the TRC.3 It is intended to represent a broader societal view of cost-effectiveness. To that end, it is the same as the TRC except that it theoretically adds environmental and other non-energ...

AI summary The Societal Test is a variation of the Total Resource Cost (TRC) method, designed to incorporate broader societal considerations such as environmental and non-energy benefits into cost-effectiveness evaluations. These benefits, including improved comfort and health, are often not fully addressed in practice.

Which Tests are Predominant? We have not conducted a comprehensive assessment of which jurisdictions are currently using which tests. However, based on both our own extensive experience with regulatory practice in a variety of jurisdiction...

AI summary The text discusses which cost-effectiveness tests are predominantly used in various jurisdictions for approving energy efficiency programs. While multiple tests are often considered, most regulators rely primarily on either the Total Resource Cost Test or the Societal Test, with some regions using the UCT or RIM test. The use of these tests varies by location and regulatory approach.

dress those interests. Sometimes that is just by saving money on energy bills, but more often than not reducing waste streams, improving worker productivity or other factors are at least as important. The TRC test as originally conceptuali...

AI summary The TRC test originally considered total costs and benefits, but non-energy benefits became difficult to measure and were rarely used in cost-effectiveness analyses. Massachusetts and Washington, D.C. have made some attempts to include non-energy benefits, but utilities have generally not utilized them in their analyses.

Inconsistency in Treatment of Demand and Supply Options As noted above, supply investments are not subjected to TRC or Societal costeffectiveness screening. For example, when a regulator approves a utility purchased power contract from a c...

AI summary The text discusses the inconsistency in how demand and supply options are treated in regulatory decisions. Supply investments are not subjected to TRC or societal cost-effectiveness screening, unlike energy efficiency programs. This creates an uneven regulatory standard where only the cost to the utility system is considered, not the broader societal or investment costs.

Why TRC Failings Matter The asymmetrical inclusion of participant costs while failing to include most participant non-energy benefits in cost-effectiveness screening fundamentally biases regulatory decisions against efficiency investments....

AI summary The exclusion of non-energy benefits from cost-effectiveness screening in TRC evaluations biases regulatory decisions against efficiency investments. Studies show these non-energy benefits can significantly outweigh energy savings, leading to reduced savings from efficiency programs.

Possible Solutions Conceptually, we see three potential solutions to this problem: - 1. Adjust the TRC so that only the "energy portion" of measure costs are included in the test; - 2. Fix the TRC and Societal Tests by quantifying even in...

AI summary The text outlines three potential solutions to a problem: adjusting the TRC to include only energy costs, fixing TRC and Societal Tests to include non-energy benefits, or changing the test to use PACT. Each option has its supporters and drawbacks.

Using Only the "Energy Portion" of Measure Costs in the TRC If the problem with the TRC is that it compares total costs to only the energy benefits, then one option is to assess how much of the total cost is attributable to energy savings...

AI summary The text discusses using only the 'energy portion' of measure costs in the Total Resource Cost (TRC) calculation to better align costs with energy benefits. This approach would improve the TRC's ability to identify cost-effective energy efficiency programs, such as the Home Performance with ENERGY STAR program, that may currently fail under the existing TRC framework.

Quantifying All Non-Energy Benefits The second option for fixing the TRC is to tackle the benefits side of the equation. Specifically, regulators could theoretically require that all non-energy benefits are estimated and factored into TRC...

AI summary This text discusses the theoretical ideal of including all non-energy benefits in the Total Resource Cost (TRC) screening process, arguing that while it would provide a more balanced assessment of costs and benefits, it is likely too complex, controversial, and expensive to implement in practice. Examples include health and safety benefits from energy efficiency programs, which may be underestimated if not properly quantified.

Conclusions We believe it is clear that the TRC,17 as currently applied, has significant flaws. Because of the asymmetrical application of the TRC test to energy efficiency resources, but not other utility resource options, efficiency reso...

AI summary The document critiques the current Total Resource Cost (TRC) test for systematically disadvantaging energy efficiency programs due to asymmetrical application. It argues that switching to the Payback Analysis Criteria (PACT) is the best solution to ensure cost-effective energy efficiency, especially as objectives for energy savings expand. Non-energy benefits are also highlighted as critical to consider for a more accurate assessment of program cost-effectiveness.

References - Amann, Jennifer. 2006. " Valuation of Non-Energy Benefits to Determine Cost-Effectiveness of Whole-House Retrofit Programs: A Literature Review ", ACEEE Report Number A061. - [CPUC/CEC] California Public Utilities Commission a...

AI summary The references section lists various academic and industry publications related to the evaluation of demand-side management (DSM) programs, cost-effectiveness analysis, and energy efficiency initiatives. These sources include studies on non-energy benefits, economic analysis, and program evaluation techniques.

a) The electrical load forecast used for the 2009 IRP update is provided below. Cumulative 10 11 c) For each proposed measure in the 2012 Plan that does not meet the TRC test, please 12 provide an explanation of the "strategic or long-term...

AI summary The text discusses the use of the Total Resource Cost (TRC) test in the 2012 Plan, noting that most regions do not require a positive TRC at the measure level. It references a 2008 survey showing that while some regions use TRC as a formal requirement, others apply it at the program or plan level with exceptions.

Q. Does the reporting of savings from outside 2012 DSM Programs raise any concerns? - Previous DSM plans relied exclusively on customer-funded, incentive-based DSM programs to - meet IRP targets. In 2012, ENSC is recording incremental ener...

AI summary The reporting of savings from outside 2012 DSM programs is discussed, referencing the 2009 IRP Update Report which allows inclusion of non-program savings. Concerns include lack of criteria for verifying such savings, potential erosion from industrial efficiency projects, and ensuring ENSC's spending is justified. Savings from non-program sources may reduce new generation needs and aid environmental targets.

Q. What about spending on development and research, fuel substitution, and renewable - heating? - In response to IR-6 from the Consumer Advocate, ENSC indicated that opportunities exist in - both the residential and non-residential sectors...

AI summary ENSC acknowledges opportunities for development and research in residential and non-residential sectors regarding fuel substitution and renewable heating. However, no quantification of potential savings or expenditure allocation by rate class was provided, raising concerns about transparency and cost-effectiveness.

- A. Yes. As previously noted, the 2012 Plan incorporates NTG ratios at the program level, - with the exception of the New Houses Program. Lacking better data this might be an - appropriate approach. However, moving forward ENSC should con...

AI summary ENSC's 2012 Plan uses program-level NTG ratios except for the New Houses Program. The response supports moving toward measure-level or measure-category-level NTG ratios for key measures, acknowledging barriers like cost and market saturation. It also notes limitations of the TRC test, which overlooks non-energy benefits in existing and new home programs, potentially skewing cost-effectiveness assessments.

PROFESSIONAL SUMMARY Glenn Reed has more than 25 years of expertise in demand-side management (DSM) program planning and evaluation; energy-efficiency policy development and implementation; building codes and appliance standards developmen...

AI summary Glenn Reed has over 25 years of experience in demand-side management (DSM) program planning, energy-efficiency policy, building codes, and appliance standards. He has worked with Massachusetts, Connecticut, Rhode Island, and other states, providing technical assistance and overseeing program design. He also developed training modules and held roles at various energy organizations.

- Rhode Island Energy Efficiency Resource Management Council. Senior Advisor providing ongoing technical and programmatic advice to, and oversight of, Rhode Island's residential efficient products (lighting, appliances and consumer electro...

AI summary The text outlines roles of various entities in energy efficiency programs, including technical oversight, cost-effectiveness assessments, and program design for residential, commercial, and transportation sectors. Entities collaborate with utilities and governments to evaluate savings potential and develop long-term strategies.

5 Three other points should be noted: 7 was done, however. It shows that in moving from the ENSC proposed plan to the 8 alternative plans, investment levels and savings are increased across all programs 9 except the New Houses program. 10...

AI summary The text highlights that investment levels and savings increased across all programs except the New Houses program when comparing the ENSC proposed plan to alternative plans. Average costs across three plans are within 6% of each other, with the lowest cost plan offering 10% more savings than the 2011 plan. All plans show TRC (Total Resource Cost) of ~2.0 and PAC (Program Assessment Criteria) of ~3.0.

13 NSUARB-NSPI-P-884(2), Paragraph 36. 1 • PAC = Present Worth of costs avoided by the DSM measure (or program) 26 level is consistent with experience across North America, as documented in 27 ENSC (NPB) IR-3(a). 28 c) As noted earlier, EN...

AI summary The text discusses the application of the Total Resource Cost (TRC) and Program Assessment Criteria (PAC) in Demand Side Management (DSM) programs. It notes that ENSC's use of avoided costs in TRC is conservative, and there is emerging research on the shortcomings of TRC. A performance-based approach to DSM is suggested, as recommended by Dr. Wheeler.

2. SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS - Q. Please summarize your primary recommendations regarding the pace at which efficiency programs are ramped up over time. - A. I offer the following recommendations with regard to program ram...

AI summary The primary recommendations focus on ensuring ENSC implements cost-effective energy efficiency resources, conducts thorough assessments for future DSM Plans, and includes three-year savings projections. Rate impact analysis should consider all costs and benefits, prioritize high participation, and avoid limiting DSM budgets without justification.

unded energy conservation and demand management initiatives outside of the ratepayer-funded DSM programs offered by NSPI and now ENSC, some of which is appropriately reflected in ENSC's 2012 DSM Plan. However, in order to ensure that DSM s...

AI summary NPB opposes increasing DSM spending in ENSC's 2012 Plan, citing concerns about cost-effectiveness, short-term rate impacts, and lack of experience with higher investment levels. ENSC's evaluation of past spending (2008-2010) showed cost-effectiveness, but NPB argues further increases are premature. NPB trusts ENSC's balance in the plan and rejects external consultants' recommendations for higher spending.

In 2007 - Analysis and counsel to the Vermont Energy Investment Corporation regarding potential costs and savings of a second refrigerator early retirement program for northeastern U.S. states. - Critical assessments of an array of energy...

AI summary In 2007, activities included advising Vermont Energy Investment Corporation on refrigerator retirement programs, assessing Ontario Power Authority energy plans, training Efficiency New Brunswick staff on energy efficiency concepts, and consulting Hydro-Québec on low-income program strategies. These efforts focused on energy efficiency, cost-effectiveness, and best practices.

4.2.4 Economic DSM Potential Results As discussed previously, economic potential is the amount oftechnical DSM potential that is "costeffective" as defined by the TRC test. However, economic potential does not consider market barriers, suc...

AI summary Economic DSM potential, determined by the TRC test, is a theoretical measure that ignores market and economic barriers. It highlights impractical implementation through forced installations and discusses limitations in demand response programs due to customer participation issues.

gy demand and usage of alternative sources of energy. However, going green is not inexpensive. Well-intentioned efforts to promote DSM must be subject to critical analysis and planning to ensure that expenditures are justifiable and projec...

AI summary The document discusses the transition of Demand Side Management (DSM) to Efficiency Nova Scotia Corporation (ENS) and emphasizes the need for critical analysis and planning to ensure that DSM efforts are cost-effective and in the public interest. The Board provides guidance to ENS regarding its role in administering DSM in the Province.

[65] In its Closing Submission of May 13, 2011, ENSC stated: With respect to the proposed budget for the 2012 DSM Plan of $43.7M - a modest increase over the 2011 DSM Plan budget of $41.9M - ENSC submits that there is insufficient evidence...

AI summary ENSC argues against increasing the 2012 DSM Plan budget to $53.4M or $58M, stating the existing plan already exceeds 2009 IRP energy savings targets. It contends there is insufficient evidence to justify higher expenditures, citing concerns about front-loading savings, viewing IRP targets as a 'floor', and potential regressive impacts on contractors and future program scaling.

5.1 Total Resource Cost ("TRC") [82] ENSC's application proposes to use the TRC test at the program level and not at the measure level starting in 2012: ENSC is proposing that the TRC test for the 2012 DSM Plan be applied at the program le...

AI summary ENSC proposes applying the Total Resource Cost (TRC) test at the program level rather than the measure level for the 2012 DSM Plan. This would allow consideration of strategic and long-term benefits beyond TRC. While some support this approach, concerns are raised about the TRC test's limitations, particularly in not fully quantifying non-energy benefits.

Request IR-1: - With respect to page 14, Figure 5.1, - a) Please provide the results for the TRC test in terms of costs, benefits and net benefits in cumulative present value dollars, for each program and the total. - b) Please provide the...

AI summary The petitioner is requesting detailed results of the TRC and PAC tests, including costs, benefits, and net benefits in cumulative present value dollars for each program and the total, as well as the worksheets and calculations used to determine these results.

Introduction and Background Electric energy efficiency has been seen as one of the most promising and cost-effective strategies for addressing numerous problems associated with conventional power generation including climate change disrupt...

AI summary The document highlights energy efficiency as a cost-effective strategy for addressing climate change and reducing emissions. It notes growing interest in scaling energy efficiency programs across buildings and industry, while acknowledging concerns about resource demands. The analysis aims to provide empirical data on achievable savings and costs for policymakers and program administrators.

supply curve for saved energy" is theoretically appealing. It reflects a logical order of prioritization of opportunities. Why would someone implement a high cost measure but not a lower cost measure? There is no question that CSC analysis...

AI summary The Conservation Supply Curve (CSC) is a useful tool for comparing energy efficiency measures but has limitations. It excludes advanced technologies and implies a bias against demand-side resources in long-term modeling. Program costs may differ from technology-based CSE due to factors like administration and verification expenses.

Guidelines for the Monitoring, Evaluation, Reporting, Verification, and Certification of Energy-Efficiency Projects for Climate Change Mitigation, March 1999L Lawrence Berkeley National Laboratory. 4 For example, we used the 12 year averag...

AI summary The text discusses methods for estimating energy savings in utility programs, emphasizing that absolute savings must be contextualized relative to sales volume. It highlights how program efficiency and scale can reduce per-unit costs, using examples from SMUD and other utilities. Statistical analysis (e.g., trend lines, R-square values) is used to evaluate long-term savings and cost trends.

Conclusion There is growing interest in increasing the scale and impacts of electric energy efficiency programs in the United States. The experience of the utilities or other administrators that have achieved the greatest levels ofsavings...

AI summary The analysis highlights that U.S. utilities achieving high energy efficiency savings (≥1% of sales) show decreasing per-unit program costs as scale increases. This contradicts theoretical expectations and suggests economies of scale in comprehensive programs. Further research directions include expanding data, analyzing sector-specific impacts, and evaluating administrative cost shares.

rovide the basis on which ENSC concludes that "80th of these changes are incremental to the electrical load forecast in the 2009 IRP Update". Request IR-1 0 With respect to page 17, lines 23 - 25, a) Please provide examples of measures whi...

AI summary The document contains a series of regulatory requests (IR-5 to IR-14) seeking clarifications on ENSC's methodology for calculating avoided costs, free ridership, program evaluations, and alignment with prior DSM plans. Requests focus on data derivation, consistency with past methodologies, and justification for program design assumptions.

NON-CONFIDENTIAL _________________________________________________________________________________________________________ Request IR-13: Please provide additional detail and any working papers on how the energy and demand savings from cod...

AI summary The document contains six regulatory requests (IR-13 to IR-18) directed at ENSC, seeking details on energy savings calculations, TRC measures, net-to-gross ratios, free ridership evaluation methods, cost-accessibility trade-offs, and budgeting criteria. Requests focus on transparency in program design, evaluation methodologies, and alignment with regulatory standards.

Request IR-26: - With regard to market transformation efforts, what if any rules of thumb or other analytic - tools are usable to decide whether a loss-leader investment in the short term will produce a - positive net present value of effi...

AI summary The inquiry seeks analytic tools or rules of thumb to assess if short-term loss-leader investments in efficiency yield positive net present value over the long term, focusing on market transformation strategies.

Consumer Advocate Information Requests to ENSC NON-CONFIDENTIAL 1 Request IR-27: 2 3 Please provide a copy of or an operational link to a complete copy of the DOE study referenced in footnote 8 of the Dunsky report, Appendix C, on p. 15. 4...

AI summary The document outlines several information requests from the Consumer Advocate to Efficiency Nova Scotia Corporation (ENSC) regarding studies and methodologies referenced in the Dunsky report, including the DOE study, NEBs, Utility Cost Test versus TRC, and Pareto optimality in DSM measures.

Summary - 1. The Ecology Action Centre (EAC) supports the move towards a performance based approach at Efficiency NS and the efforts to provide more versatile energy efficiency programs for Low-Income rate-payers in the 2012 DSM plan. As w...

AI summary The Ecology Action Centre (EAC) supports a performance-based approach for Efficiency NS, emphasizing low-income program versatility and outreach education. DSM is highlighted as critical for reducing electricity demand and meeting renewable/emissions goals. EAC argues that rate increases are driven by NSPI's depreciation, capital costs, and coal fuel prices, not DSM, which has a marginal impact (<2% of proposed 9% residential increases).

Rate Impacts 1. There is no formal process to properly assess the rate and bill impacts of DSM in Nova Scotia. However as the analysis provided by Mel Whalen and Tim Woolf suggests, and as the IRP identified, DSM is the most cost-effective...

AI summary The text highlights the absence of a formal process to assess DSM rate impacts in Nova Scotia, despite DSM being identified as the most cost-effective resource. Experts like Mel Whalen and Tim Woolf emphasize the need for detailed, long-term analysis of rate impacts on both participants and non-participants, challenging the use of rate impacts to limit energy efficiency budgets.

these other factors that I and Efficiency's raised - - and we get some of these arguments around this point, I think there's a balance there. And I think we've got a fair balance for the 2012 plan. 16 NPB agrees with the comments made by M...

AI summary NPB argues against increasing ENSC's 2012 DSM budget, citing rapid spending growth, limited verified savings from prior spending, and ENSC's early operational phase. ENSC's 2012 plan is expected to meet IRP targets, but NPB emphasizes prudence in maintaining current spending levels. Mr. Crandlemire acknowledges aggressive 2012 targets and commitment to achieving them.

ss to the DSM programming will bear a disproportionate impact of this increase, as they will not see corresponding bill reductions on account of lower usage from the DSM funded energy/demand programs. Obviously, there are expected to be ad...

AI summary The text highlights concerns that DSM program participants may face disproportionate rate increases without corresponding bill reductions. It acknowledges long-term benefits of DSM spending, such as infrastructure cost avoidance, but emphasizes the need to balance short-term rate impacts with long-term cost-effectiveness, as noted in Mr. Woolf's testimony.

22-26. 7 Exhibit [E-1], Evidence of Efficiency Nova Scotia Corporation as DSM Administrator, Page 11, Figure 4.1. would result in an increased 2012 DSM Plan budget to $53.4M or $58M:8 1 - 2 (a) There is sufficient uncertainty in achieving...

AI summary The 2012 DSM Plan is defended as balancing energy savings and expenditures, with arguments that aggressive 2013+ targets create uncertainty and that IRP savings should be a 'floor,' not a 'ceiling.' ENSC acknowledges stakeholder concerns but emphasizes cost-effectiveness, noting that increasing DSM budgets would lead to higher over-achievement of IRP targets.

Reply Submission In the past, Nova Scotian stakeholders have agreed that DSM is the better ratepayer option to pursue, not only because it offered the least cost procurement option, when compared to supply options, but also because stakeho...

AI summary The document argues that Demand Side Management (DSM) is a cost-effective strategy for Nova Scotia's electricity system, emphasizing its role in reducing fuel and capacity costs. It highlights overachievement of Integrated Resource Plan (IRP) targets, urging increased DSM budgets to capitalize on efficiency opportunities. The Efficiency Nova Scotia Corporation (ENSC) acknowledges potential for more savings with higher funding, while risks of inaction include lost momentum and public trust.

the absence of an appropriate framework to properly evaluate and develop equitable savings goals and targets for ENSC programs, the EAC is concerned that this sets a poor example for future DSM plans. ENSC has correctly identified and char...

AI summary EAC expresses concern that ENSC lacks a framework for equitable DSM savings goals, risking regressive outcomes. While agreeing with ENSC's emphasis on cost-effective measures, EAC argues ENSC may overlook long-term system cost minimization, prioritizing short-term rate impacts over Nova Scotia's least-cost procurement objectives under the IRP.

Conclusion Given the context of new global energy and climate realities, the unsustainable structure of the Nova Scotia electricity market and system and the work and the success that has been achieved to date with respect to DSM in Nova S...

AI summary The conclusion advocates maintaining and increasing DSM program savings targets to 2011 levels, citing equity, cost-effectiveness, and environmental benefits. It emphasizes aligning with the IRP compass for rate-payer protection and reducing coal-burning at NSPI. The Board is urged to support DSM as the optimal strategy for the Nova Scotian electricity system.

gy demand and usage of alternative sources of energy. However, going green is not inexpensive. Well-intentioned efforts to promote DSM must be subject to critical analysis and planning to ensure that expenditures are justifiable and projec...

AI summary The document discusses the transition of DSM administration to Efficiency Nova Scotia Corporation (ENS) and emphasizes the need for critical analysis and planning to ensure that DSM initiatives are cost-effective and in the public interest. The Board provides guidance to ENS regarding its role in DSM and outlines criteria for evaluating the proposed DSM Plan.

5.1 Total Resource Cost ("TRC") [82] ENSC's application proposes to use the TRC test at the program level and not at the measure level starting in 2012: ENSC is proposing that the TRC test for the 2012 DSM Plan be applied at the program le...

AI summary ENSC proposes applying the Total Resource Cost (TRC) test at the program level for the 2012 DSM Plan instead of the measure level, allowing for consideration of strategic and long-term benefits. While supported by the CA and the Province, concerns were raised about the TRC test's limitations in capturing non-energy benefits.

9.0 SUMMARY OF BOARD FINDINGS [153] The Board accepts the 2010 DSM Plan evaluation and verification, with the qualification made in the SVS for a 10% reduction for the Efficient Products-Direct Install program. [154] The Board understands...

AI summary The Board accepts the 2010 DSM Plan evaluation, approves the 2012 DSM investment, and sets conditions for ENSC, including quarterly meetings and a free ridership study. It also approves changes to the TRC test and allows exploration of a PBM. The Board reserves jurisdiction to rule on costs if EAC and ENSC cannot agree.