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Topic:"Cost Effectiveness" in M06733

Matter: E-ENS-R-15 - EfficiencyOne Application for approval of a Supply Agreement for Electricity Efficiency and Conservation Activities between Efficiency One and Nova Scotia Power Inc.- NSPI - 2016-2019 DSM Plan IN THE MATTER OF AN APPLICATION for Approval of a Supply Agreement for electricity efficiency and conservation activities between EfficiencyOne and Nova Scotia Power Incorporated, the establishment of a final agreement between the parties, and approval of a 2016-2018 Demand Side Management Resource Plan
163 passages 32 documents

Cost Effectiveness across all matters →

E-1EfficiencyOne Application - Revised Application see Exhibit E-43 54 passages
Efficient Product Rebates p. p. 18
Efficient Product Rebates The Efficient Product Rebates (BNI) program, marketed as the Business Energy Rebates (BER) service, includes both mail-in and point-of-purchase incentives. The service achieved total energy savings of 24.6 GWh in...

AI summary The Efficient Product Rebates (BNI) program, marketed as Business Energy Rebates (BER), achieved 24.6 GWh energy savings in 2014 (below its 27.0 GWh target). Mail-in rebates contributed 11.1 GWh, while Instant Rebates provided 13.5 GWh. Custom Incentive lighting projects were transferred to BER in 2014 to enhance service delivery and cost-effectiveness by standardizing processes for retrofits.

4.1 Development of 2016-2018 DSM Program Targets and Investment p. p. 31
4.1 Development of 2016-2018 DSM Program Targets and Investment The 2016-2018 DSM Resource Plan has been developed based on ENS's growing experience and history in delivering successful DSM programs and services to Nova Scotians. As part o...

AI summary ENS developed the 2016-2018 DSM Resource Plan using Navigant Consulting's EL-RAM model, aligning with cost-effective targets and investment levels. The Plan's 405.9 GWh energy savings and 62.5 MW demand savings aim to balance affordability with long-term energy needs, referencing NS Power's 2014 IRP and updated assumptions. ENS emphasizes reduced rate pressures and capacity additions compared to prior scenarios.

4.1.2 Balance of Long-Term and Short-Term Considerations p. pp. 37-42
oss of a competitive market for DSM implementation contractors is a risk if DSM activity levels are reduced below a • Steep rate increases in the future: When higher levels of DSM are required in the - level that sustains having multiple d...

AI summary Reducing DSM activity risks losing competitive market advantages, increasing future costs, and reducing energy savings for Nova Scotians. ENS argues maintaining DSM capacity is cost-efficient, while NS Power highlights risks of underperformance requiring additional investments. Program reductions may lead to higher fixed costs and lower bill savings.

4.1.3 Affordability p. pp. 42-43
4.1.3 Affordability The Province of Nova Scotia issued an Electricity Review Report on February 18, 2015, which states that a "large part of Nova Scotia's electricity future relates to increasing energy efficiency. One of the best ways to...

AI summary The Province of Nova Scotia's 2015 Electricity Review Report emphasizes energy efficiency and affordability. ENS's 2016-2018 DSM plan reduces short-term costs compared to the Mid-DSM Scenario while preserving long-term benefits, balancing affordability and efficiency.

4.1.4 Cost Efficiency Opportunities p. pp. 44-45
4.1.4 Cost Efficiency Opportunities The 2016-2018 DSM Resource Plan is cost effective, per legislative and UARB requirements for DSM. Results from Navigant's EL-RAM show that all programs are cost-effective in each year of the Plan, using...

AI summary The 2016-2018 DSM Resource Plan is deemed cost-effective using TRC and PAC tests. ENS aims to reduce unit costs through program adjustments like removing the Home Energy Report and reducing Enabling Strategies investment. Navigant's 2015 report is cited for affordability considerations.

4.2 Evaluation p. p. 48
4.2 Evaluation ENS proposes that its evaluation activities include an annual impact evaluation for each program in each of the three years, with some modification to the evaluation methodology and reporting structure, as outlined below. An...

AI summary ENS proposes annual impact evaluations for its programs from 2016-2018, shifting focus to organizational processes and reducing costs via condensed reports and rolling evaluations. This approach aims to track energy and demand savings progress toward DSM targets while maintaining third-party evaluations.

5.1 Cost-Effectiveness Testing p. pp. 62-63
5.1 Cost-Effectiveness Testing The Total Resource Cost (TRC) test has been the primary cost-effectiveness test for demand-side management in Nova Scotia since the commencement of DSM-related activities in the province. In the early years,...

AI summary Nova Scotia's DSM program shifted from measure-level TRC testing to program-level screening in 2011, allowing strategic measures with TRC ratios below one. ENS now seeks UARB approval to replace TRC with PAC as the primary cost-effectiveness test for future DSM plans, citing the 2012 plan and Dunsky analysis.

6. CONCLUSION p. pp. 67-70
6. CONCLUSION The 2016-2018 DSM Resource Plan provides an evidence-based approach that enables Nova Scotians to achieve reasonably-available, cost-effective electricity energy and demand savings. The plan was developed with emphasis on aff...

AI summary The 2016-2018 DSM Resource Plan aims to achieve cost-effective electricity savings in Nova Scotia through affordability-focused strategies. ENS seeks UARB approval for the plan, supply agreements, performance metrics, a shift from TRC to PAC cost-effectiveness testing, and a reserve fund establishment.

& lt;sup>d Reflects ENS's planned participation by low income customers, per the 2015 DSM Resource Settlement Agreement. p. pp. 78-79
& lt;sup>d Reflects ENS's planned participation by low income customers, per the 2015 DSM Resource Settlement Agreement. Figure 1.3 - 2017 DSM Resource Plan Investment and Savings 2017 Investment (S Lifetime Benefits ($ million) a Incremen...

AI summary The 2017 DSM Resource Plan outlines investments and savings for residential and non-residential programs, including efficient product rebates, custom incentives, and education initiatives, with a focus on low-income participation and overall energy savings metrics.

Update on Implementation of 2013 Verification and Evaluation Recommendations p. p. 101
Update on Implementation of 2013 Verification and Evaluation Recommendations B C E F G K 114 Investigate the organization's costs of HR hiring: These costs should be evaluated to identify ways to reduce them. 2013 TPE R4. Not Recommended f...

AI summary The document discusses ENSC's disagreement with a 2013 recommendation to investigate HR hiring costs, stating that recruitment expenditures are a small part of the HR budget and reducing them is not a prudent investment.

Alternative DSM Scenarios p. p. 139
Alternative DSM Scenarios Alternative Scenarios explore the effect of varying levels of DSM investment. DSM Potential Study data ($M and GWh) for the Low, Base, and Mid-DSM Scenarios over 2016-2018 were used to inform the model with respec...

AI summary The analysis evaluates alternative DSM investment scenarios (Low, Base, Mid, and NS Power's 50% Low IRP) to assess energy savings impacts. ENS's proposed Plan is compared against these scenarios, with the Base scenario omitted due to similarity. NS Power's 50% Low Scenario, not vetted by ENS, uses conservative avoided costs. The model assumes 75% of energy savings changes stem from participant numbers, with 25% from adoption depth, capped at 100% participation.

Investing in Demand-side Resources: Considering Affordability p. p. 187
Investing in Demand-side Resources: Considering Affordability

AI summary The document examines the integration of demand-side resources in Nova Scotia's energy strategy, emphasizing affordability. It discusses balancing cost-effective energy efficiency programs with consumer affordability, involving entities like Efficiency Nova Scotia (ENS) and Nova Scotia Power Inc. (NSPI), while considering regulatory frameworks and stakeholder input.

1.2 Summary of Findings p. p. 190
1.2 Summary of Findings - 1. Since 2011, excluding 2015, Nova Scotia has invested in demand-side resources at or above the level (in real terms) proposed by ENS in the 2016-2018 Demand-Side Resource Plan. - 2. Demand-side resource investme...

AI summary Nova Scotia's demand-side resource investments since 2011 (excluding 2015) meet or exceed ENS's 2016-2018 plan. These investments yield over $200M in net benefits, enhance affordability, and reduce Nova Scotia Power's revenue requirements. DSM is highlighted as cost-effective, with the Province's plan emphasizing its role in improving electricity affordability and economic competitiveness.

1.3 Legislative Charge p. pp. 191-193
1.3 Legislative Charge In the Public Utilities Act, the Nova Scotia General Assembly mandated that Nova Scotia Power Inc. (NSPI) "undertake cost-effective energy efficiency and conservation activities that are reasonably available in an ef...

AI summary The Nova Scotia General Assembly mandates Nova Scotia Power Inc. (NSPI) to undertake cost-effective energy efficiency and conservation activities under the Public Utilities Act, emphasizing their ability to reduce customer costs. The directive requires balancing benefits, costs, and rate class interests, with affordability being a key consideration for the Nova Scotia Utility and Review Board.

2.1 Investments in Demand-side Resources p. p. 193
2.1 Investments in Demand-side Resources Demand-side management (DSM) is recognized as a highly cost-effective electricity supply resource.[10](#page-193-3) For Nova Scotians, DSM has reduced customer electricity costs, provided substantia...

AI summary Demand-side management (DSM) is highlighted as a cost-effective electricity resource, reducing customer costs and providing economic and system benefits since 2008. ENS's proposed investments are projected to yield over $200 million in ratepayer benefits. Jurisdictions in Canada and the U.S. recognize DSM's value, with some requiring utilities to procure all cost-effective demand-side resources.

2.2 Demand-Side Management is an Investment, Not a Cost p. pp. 193-194
2.2 Demand-Side Management is an Investment, Not a Cost Since 2008, demand-side resource investments have provided significant benefits to Nova Scotian households and businesses. On behalf of Efficiency Nova Scotia, Navigant's Electricity...

AI summary Since 2008, demand-side management (DSM) investments in Nova Scotia have delivered benefits to households and businesses. Efficiency Nova Scotia, using Navigant's EL-RAM model, assessed cost-effectiveness. The 2016-2018 plan optimized DSM investment for cost-effectiveness and broad participation, with program participants benefiting from lower bills and improved affordability.

2.4.2 Economic Benefit of Demand-side Resource Investments for Nova Scotians p. p. 197
2.4.2 Economic Benefit of Demand-side Resource Investments for Nova Scotians Total economic impact analysis examines the direct, indirect, and induced impacts of a particular activity. The energy efficiency sector provides benefits to the...

AI summary The analysis highlights that demand-side resource investments in Nova Scotia generate economic benefits across direct, indirect, and induced impacts. The energy efficiency sector contributes to the provincial economy through these three categories, emphasizing broader economic advantages.

2.4.2.2 Indirect Benefits p. pp. 197-198
2.4.2.2 Indirect Benefits Indirect economic benefits that occur as a result of direct energy efficiency investments include goods and services purchased by firms engaged in delivery of efficiency products and services. Indirect benefits in...

AI summary Indirect economic benefits from energy efficiency investments include increased business competitiveness and economic activity across sectors like finance and accounting. These benefits arise from firms participating in efficiency programs, leading to broader economic impacts beyond direct energy savings. A 2013 Canmac Economics Ltd. report highlights the energy efficiency industry's role in driving local economic activity through ripple effects.

2.4.2.3 Induced Benefits p. p. 198
2.4.2.3 Induced Benefits The induced benefits effect derives from the change in spending that energy efficiency investments enable. Broader economic benefits for Nova Scotians include increased household income and purchasing power for pro...

AI summary Energy efficiency investments in Nova Scotia generate economic benefits through increased household income, job creation, and reduced costs for businesses and households. These investments lower energy expenses, enabling reinvestment in the local economy and enhancing purchasing power for families and businesses.

2.5.1 Overview p. pp. 198-199
2.5.1 Overview Demand-side resource investments provide additional benefits above and beyond the direct system benefits available to all customers and the electricity bill savings that accrue to Nova Scotian households and businesses that...

AI summary Demand-side investments provide non-energy benefits (NEBs) to participants, utilities, and society, enhancing affordability despite low costs. These benefits, beyond direct savings, are highlighted in Lazar and Colburn's 2013 report on energy efficiency's full value.

2.5.4 Utility Non-energy Benefits p. p. 199
2.5.4 Utility Non-energy Benefits In addition to avoided energy and capacity costs, demand-side resources often are considered a lower risk option compared with many supply-side alternatives. By contrast with major supply infrastructure, d...

AI summary Demand-side resources are highlighted as lower-risk investments compared to supply-side alternatives due to their dispersed nature and reliability. They reduce fuel supply needs for fossil generators, mitigating market price volatility. These benefits are not typically addressed in traditional cost-effectiveness analyses of demand-side resources.

2.5.6 Summary of Non-energy Benefits Issues p. pp. 199-200
2.5.6 Summary of Non-energy Benefits Issues Increasingly, non-energy benefits – especially those that accrue to participants – are viewed as significant benefit streams that the current demand-side resource benefit-cost analysis effectivel...

AI summary Non-energy benefits, particularly those to participants, are overlooked in the current demand-side resource benefit-cost analysis. This neglect is critical as the analysis should reflect total benefits and costs to both participants and non-participants, justifying affordable investments with net financial benefits for ratepayers.

Approach p. p. 201
Approach Few regions have adopted a formal and publically available set of principles to guide their DSM plans. This is partly the result of the complexity of DSM itself which, for reasons we will explain below, does not lend itself well t...

AI summary The document outlines the complexity of Demand Side Management (DSM) and identifies four guiding principles for DSM plans: maximizing energy savings, optimizing net benefits, minimizing risk, and ensuring equitable access. It emphasizes balancing these goals with trade-offs and the need for diverse portfolios and sustained market presence.

Consideration #2: MAXIMIZE NET BENEFITS ET NBENEFITS p. p. 201
Consideration #2: MAXIMIZE NET BENEFITS ET NBENEFITS One of the key drivers for DSM is its cost-effectiveness – the extent to which benefits exceed costs – when compared against supply-side energy resources. As such, most DSM PAs focus sig...

AI summary The document emphasizes that Demand Side Management (DSM) should prioritize maximizing net benefits over minimizing costs alone. It argues that energy savings from different measures (e.g., efficient heating vs. fridges) vary in value due to usage patterns and longevity. For example, savings from building envelopes outlast those from T8 lamps, affecting NSPI's avoided costs.

Energy & Demand • Energy savings • Annual incremental • Annual cumulative • Lifetime • Peak demand savings • Annual incremental • Annual cumulative • Lifetime Costs & Benefits • Total Resource Benefits • Net Benefits • Levelized cost • Total spending Long Term & Depth • Market transformation • Depth of savings Societal Impacts • Jobs • Regional equity • Customer equity • GHG emission reductions p. p. 219
Energy & Demand • Energy savings • Annual incremental • Annual cumulative • Lifetime • Peak demand savings • Annual incremental • Annual cumulative • Lifetime Costs & Benefits • Total Resource Benefits • Net Benefits • Levelized cost • Tot...

AI summary The text outlines metrics for evaluating energy efficiency programs, including energy and peak demand savings (annual incremental, cumulative, and lifetime), cost-benefit analysis (Total Resource Benefits, Net Benefits), market transformation indicators, and societal impacts (jobs, equity, GHG reductions). It explains how savings are calculated over time and emphasizes long-term vision and distributional equity.

Highlights : p. pp. 219-224
Highlights : - Nine of the ten jurisdictions have an energy savings metric and six of them also have a peak demand savings metric. Massachusetts is the only region that has not incorporated an energy savings performance target indicator pe...

AI summary The analysis compares energy efficiency performance metrics across jurisdictions, noting that most use energy and peak demand savings, while others incorporate cost, benefits, or local economic indicators. Massachusetts uses TRB instead of energy savings targets. Vermont, DC, and Oregon have unique approaches, with Oregon avoiding financial incentives. The 29 regions are categorized by complexity of performance evaluation, with 83% using simple metrics.

Costs and Benefits p. p. 232
Costs and Benefits - Several metrics may be used to ensure effective use of program expenditures, the most frequently used being Total Resource Benefits (Hawaii, Massachusetts and Vermont), which focuses on the benefits side of the equatio...

AI summary The text discusses metrics like Total Resource Benefits (TRB) and Net Benefits used in regions such as Hawaii, Massachusetts, and Vermont to evaluate program expenditures. It highlights that TRB focuses on benefits, while Net Benefits considers both costs and benefits. Tracking total expenditure as a Target Performance Indicator (TPI) is also noted in Vermont, DC, and Ontario.

4.2. DISCUSSION & RECOMMENDATIONS p. p. 235
- Levelized Costs : Given our recommendations to report on both spending and lifetime savings, reporting on levelized cost (¢/kWh, i.e. the ratio of the former over the latter) would add no value. - Market Transformation : Although market...

AI summary The document discusses DSM program metrics, emphasizing that levelized cost reporting adds no value, market transformation is hard to measure, and equity concerns are addressed by existing mechanisms. It highlights debates over deep vs. broad savings, geographic and low-income equity, and the exclusion of job creation from ENS' mandate.

DSM SCREENING IN NOVA SCOTIA TOWARD A BALANCED COST-EFFECTIVENESS FRAMEWORK p. pp. 244-245
DSM SCREENING IN NOVA SCOTIA TOWARD A BALANCED COST-EFFECTIVENESS FRAMEWORK PREPARED BY DUNSKY ENERGY CONSULTING Philippe Dunsky, President François Boulanger, Senior Consultant SUBMITTED TO EFFICIENCY NOVA SCOTIA February 23rd, 2015

AI summary A document prepared by Dunsky Energy Consulting and submitted to Efficiency Nova Scotia on February 23, 2015, discusses DSM screening in Nova Scotia toward a balanced cost-effectiveness framework. The report outlines the need for a structured approach to evaluating demand-side management programs, emphasizing cost-effectiveness and regulatory considerations.

EXECUTIVE SUMMARY p. p. 248
ctiveness of demand-side management (DSM) options. More recently, the DSM community has come to question the wisdom of basing key decisions on the TRC. Specifically, four concerns have come to light: - 1. Accuracy: To many, the TRC has bee...

AI summary The text critiques the Total Resource Cost (TRC) methodology in Demand-Side Management (DSM), highlighting four concerns: accuracy of assumptions, systemic bias against DSM, neglect of ratepayer value, and potential policy conflicts with Nova Scotia's 2014 legislation. The TRC's flawed application may skew decisions against DSM, undermining equitable cost-benefit analysis.

STANDARD COST-EFFECTIVENESS TESTS p. pp. 248-253
STANDARD COST-EFFECTIVENESS TESTS The tests provided an analytical framework designed to reflect different perspectives. Among them, three are commonly used today 5 , namely: - The Total Resource Cost (TRC) test is designed as a sort of co...

AI summary The document outlines three standard cost-effectiveness tests: Total Resource Cost (TRC), Modified Total Resource Cost (MTRC), and Societal Cost Test (SCT). TRC is criticized for overlooking participant benefits, leading to MTRC modifications. SCT is a California variant of TRC, with historical changes in the California Standard Practice Manual, including renaming tests and incorporating non-energy benefits.

CHOICE OF TESTS: THE RISE OF THE TRC AND MORE RECENT TRENDS p. p. 253
CHOICE OF TESTS: THE RISE OF THE TRC AND MORE RECENT TRENDS Through the vagaries of time and the shifting importance given to DSM, most states and provinces that gave it consideration have, in the end, landed on the use of the TRC test as...

AI summary The document discusses the evolution of cost-effectiveness testing in demand-side management (DSM), noting the initial dominance of the Total Resource Cost (TRC) test due to abundant low-cost opportunities. However, with diminishing low-hanging fruit and the recognition of non-energy benefits (NEBs), there's a growing shift towards alternative tests. Program administrators are reevaluating TRC's limitations, and many DSM leaders now use other methods.

POLICY DRIVERS p. p. 253
POLICY DRIVERS Nova Scotia's DSM is arguably driven by imperatives outside of the strict regulatory arena as well. We note that in 2012, an equivalency agreement between the Province and the federal government was reached on climate change...

AI summary Nova Scotia's DSM is influenced by 2012 climate change agreements with the federal government, allowing carbon exemptions for power plants in exchange for sectoral reductions. The 2014 Electricity Efficiency and Conservation Plan formalized ENS's role in competing energy savings with supply options, aligning with PAC cost-effectiveness tests. Nova Scotia's approach reflects broader trends in reevaluating DSM strategies.

CONCERNS WITH THE CONVENTIONAL TRC p. p. 253
CONCERNS WITH THE CONVENTIONAL TRC

AI summary The document outlines concerns regarding the conventional Total Resource Cost (TRC) methodology, emphasizing its limitations in accurately reflecting energy efficiency programs and non-energy benefits. Key issues include outdated assumptions and insufficient consideration of modern energy solutions.

INTRODUCTION p. pp. 253-257
INTRODUCTION The Total Resource Cost test is meant to measure cost-effectiveness from the perspective of consumers, writ large, i.e. something akin to a societal perspective. In itself, this is a valid and important perspective. However, a...

AI summary The Total Resource Cost (TRC) test, intended to measure cost-effectiveness from a societal perspective, faces concerns regarding accuracy, bias, ratepayer value, and policy alignment. Jurisdictions have adapted TRC methodologies, highlighting its non-standardized application despite originating from the Standard Practice Manual (SPM). Innovations in cost-effectiveness frameworks are emerging to address these issues.

ISSUE #1: ACCURACY: IS THE TRC CALCULATED CORRECTLY? p. p. 257
ISSUE #1: ACCURACY: IS THE TRC CALCULATED CORRECTLY? The TRC is the most common test currently in use, and compares all direct benefits, expressed through avoided energy and capacity supply costs, to all direct costs, both for the DSM prog...

AI summary The TRC (Total Resource Cost) ratio compares avoided energy and capacity costs to program and participant costs. While the simplified formula is clear, the detailed algorithm in the Standard Practice Manual lacks clarity on key inputs and assumptions. Six components of the TRC calculation may use different methodological approaches, raising concerns about accuracy.

ISSUE #2: BIAS: DOES THE CONVENTIONAL TRC NEGLECT IMPORTANT BENEFITS? p. p. 257
ISSUE #2: BIAS: DOES THE CONVENTIONAL TRC NEGLECT IMPORTANT BENEFITS? Beyond issues of interpretation, many now question whether and to what extent the Total Resource Cost test, as commonly applied , may also contain an inherent bias. The...

AI summary The Total Resource Cost (TRC) test may contain inherent bias by neglecting non-energy benefits (NEBs) that accrue to participants, utilities, and society. While TRC accounts for all costs, it often overlooks NEBs, which are substantial but hard to quantify, leading to their effective undervaluation at zero in cost-effectiveness analyses.

PARTICIPANT NON-ENERGY BENEFITS (NEBS) p. pp. 257-263
PARTICIPANT NON-ENERGY BENEFITS (NEBS) Participant NEBs are increasingly understood to play a significant role in the overall value proposition that consumers derive from many energy efficient technologies or services. To understand the ex...

AI summary Non-energy benefits (NEBs) are critical to the value of energy efficiency programs, emphasized by program marketers, academic research, and market data. NEBs like comfort and health improvements drive consumer adoption, while neglecting them risks underinvestment and higher costs. Tim Woolf highlights that excluding NEBs from TRC tests undermines program effectiveness.

Societal NEBs p. p. 263
Societal NEBs While we have discussed participant and utility NEBs, DSM is also known to generate non-energy benefits for society as a whole, primarily through (1) environmental benefits (to the extent they are not already internalized in...

AI summary The text discusses societal non-energy benefits (NEBs) from demand-side management (DSM), including environmental and macroeconomic benefits. Environmental benefits include reduced emissions, while macroeconomic benefits involve increased GDP and job creation. It critiques the Total Resource Cost (TRC) method for being biased against energy efficiency and not fully capturing societal benefits. The document notes that in Nova Scotia, carbon emissions are already partially internalized due to legislation.

SUMMARY OF NEB ISSUES p. p. 263
SUMMARY OF NEB ISSUES Increasingly, non-energy benefits – especially those that accrue to participants – are viewed as significant benefit streams that the current TRC effectively neglects. This is critical to the extent that the TRC's pur...

AI summary The document critiques the Total Resource Cost (TRC) methodology for neglecting non-energy benefits (NEB), particularly for participants. It notes that some regions modify TRC to include NEB or adopt alternative tests. A study evaluated DSM scenarios with 1.0%-2.5% annual savings, referencing Nova Scotia's 2012 DSM achievement of 1.52% annual sales. The text also mentions deliberate low-rate choices to avoid discounting future generations' interests.

IMPLICATIONS FOR NOVA SCOTIA p. p. 263
IMPLICATIONS FOR NOVA SCOTIA Nova Scotia's current TRC does not account for non-energy benefits, whether they accrue to participants, the utility, or society at large. By failing to account for these benefits, while fully accounting for pa...

AI summary Nova Scotia's current Total Resource Cost (TRC) methodology excludes non-energy benefits (NEB), creating a bias against Demand Side Management (DSM) by fully accounting for participant costs while ignoring societal and utility-level NEB.

ISSUE #3: RATEPAYER VALUE: DOES THE TRC BEST REFLECT A RATEPAYER PERSPECTIVE? p. p. 263
ISSUE #3: RATEPAYER VALUE: DOES THE TRC BEST REFLECT A RATEPAYER PERSPECTIVE? The Total Resource Cost test seeks to find the theoretically optimal investment, irrespective of who – ratepayers (through the program administrator) or particip...

AI summary The TRC test aggregates all costs, including those borne by participants, which may not align with ratepayer interests. Critics argue it fails to reflect program efficiency or stakeholder concerns about who pays. The California Standard Practice Manual highlights that TRC includes participant costs, unlike supply-side options, potentially distorting program decisions and overlooking long-term market transformation.

ISSUE #4: POLICY: WHAT IF THE TRC IS INCONSISTENT WITH PUBLIC POLICY? p. p. 263
ISSUE #4: POLICY: WHAT IF THE TRC IS INCONSISTENT WITH PUBLIC POLICY? Throughout the 1990s, when the TRC first took on prominence as the pre-eminent DSM screen, most program administrators were working against growing but still modest DSM...

AI summary The text discusses the evolution of DSM goals from the 1990s to today, noting increased targets (1.5-3% annual savings) and improved baselines due to factors like consumer awareness and new codes. This combination is increasing costs for DSM administrators, requiring more expensive measures like deep retrofits and solar hot water to meet targets.

THE NESP'S RESOURCE VALUE FRAMEWORK p. p. 263
THE NESP'S RESOURCE VALUE FRAMEWORK One result of the ongoing revision of cost-effectiveness frameworks is the recent publication of the Resource Value Framework, or RVF. Developed by the National Efficiency Screening Project (NESP) 29 , t...

AI summary The National Efficiency Screening Project (NESP) developed the Resource Value Framework (RVF) to evaluate cost-effectiveness screening practices against principles like public interest, symmetry, and transparency. The RVF highlights that Nova Scotia's Total Resource Cost (TRC) method does not align with these principles. The framework emphasizes including hard-to-quantify benefits and aligning with energy policy goals.

NEW NORTHEAST COST-EFFECTIVENESS GUIDELINES p. p. 263
NEW NORTHEAST COST-EFFECTIVENESS GUIDELINES At the time of completing this report, states across the northeast U.S. had agreed to adopt a set of guidelines largely inspired from the RVF framework. Specifically, representatives of the state...

AI summary Northeast U.S. states adopted cost-effectiveness guidelines inspired by the RVF framework, developed under NEEP's EM&V Forum. The guidelines emphasize five principles, including aligning with state policies, accounting for non-energy benefits (NEB), and using the Program Administrator Cost (PAC) test as a foundation. The NEEP EM&V Forum Steering Committee endorsed the guidelines in 2014.

Fig. 7. Overview of Concerns & Implications for Nova Scotia p. p. 263
Fig. 7. Overview of Concerns & Implications for Nova Scotia OUR CONCERNS NESP & NEEP GUIDELINES CONSIDERATIONS FOR NOVA SCOTIA ACCURACY Key assumptions may not reflect deliberate or appropriate choices. Both guidelines insist on need for t...

AI summary The document discusses concerns with the Total Resource Cost (TRC) methodology, including potential bias, lack of transparency, and misalignment with policy goals. It suggests that Nova Scotia should consider alternative frameworks like the Program Administrator Cost (PAC) test for better alignment with best practices and ratepayer value.

1. ACCOUNT FOR PARTICIPANT NON-ENERGY BENEFITS (NEBS) p. p. 263
1. ACCOUNT FOR PARTICIPANT NON-ENERGY BENEFITS (NEBS) The exclusion of participant NEBs is arguably the most important factor in generating bias against DSM. On the other hand, the reason that NEBs have historically been excluded is that t...

AI summary The exclusion of participant non-energy benefits (NEBs) may bias against demand-side management (DSM). NEBs are hard to quantify, leading to varied valuation methods: specific valuations via market research, inferred valuations using cost-saving algorithms, or approximate adders. Each approach has trade-offs, balancing accuracy against over-conservatism or false precision.

Figure 8. Participant NEBs: The Case of B.C. p. p. 263
Figure 8. Participant NEBs: The Case of B.C. In British Columbia, the ambitious DSM goals of BC Hydro and Fortis BC recently began to hit up against the limitations of the TRC. As a result, in December 2011, the province chose to redefine...

AI summary British Columbia redefined its Total Resource Cost (TRC) test to include non-energy benefits (NEBs) from demand-side management (DSM) programs. Three methods were introduced for NEB inclusion, with a 15% cap on portfolio-level impacts. Nova Scotia Power may benefit from reduced utility costs due to lower consumer electricity bills, though these are not quantified as utility NEBs.

3. ACCOUNT FOR ENVIRONMENTAL EXTERNALITIES? p. p. 263
3. ACCOUNT FOR ENVIRONMENTAL EXTERNALITIES? Environmental externalities are the most common DSM non-energy benefit included in costeffectiveness screening. A recent ACEEE study (Kushler, Nowak, & Witte, 2012) reports that 35% of the survey...

AI summary The text discusses the inclusion of environmental externalities in demand-side management (DSM) cost-effectiveness screening, citing a 2012 ACEEE study showing 35% of U.S. jurisdictions include such benefits. It notes that Nova Scotia's regulations may already internalize emissions through existing compliance measures, questioning the need for additional externalities accounting beyond societal perspectives.

OPTION B. MOVE FOCUS TO PAC TEST p. p. 263
OPTION B. MOVE FOCUS TO PAC TEST The other primary option for Nova Scotia is to focus instead on the narrower but more straightforward PAC test. Using the PAC test provides a clear measure of a program's (past or anticipated) performance,...

AI summary Option B advocates shifting to the PAC test for evaluating DSM programs, emphasizing its clarity, symmetry in cost-benefit analysis, and alignment with other jurisdictions like Connecticut and Michigan. It addresses concerns about equity and non-electric energy impacts through policy exceptions and dedicated funding. The PAC test is seen as more accurate and straightforward compared to TRC, with existing familiarity among stakeholders.

PRIMARY RECOMMENDATION p. p. 263
PRIMARY RECOMMENDATION Our review of the issues and options for Nova Scotia concludes with the need to change the current cost-effectiveness framework, to ensure internal consistency and best practices. In the absence of significant change...

AI summary The analysis recommends shifting from the Total Resource Cost (TRC) to the Program Administrator Cost (PAC) test for evaluating Demand Side Management (DSM) in Nova Scotia. This change is advocated for its simplicity, accuracy, relevance to ratepayer interests, and alignment with the 2014 Electricity Efficiency and Conservation Restructuring Act and Nova Scotia Power Inc.'s Integrated Resource Plan (IRP).

NOTES ON APPLICATION p. p. 263
NOTES ON APPLICATION Beyond the choice of tests, the way in which they are applied is also important. Indeed, screening tests can be applied in a number of ways: as information to be balanced with other considerations; as a hard threshold...

AI summary The document discusses the application of cost-effectiveness screening tests for Demand Side Management (DSM) within Nova Scotia Power Inc.'s (NSPI) Integrated Resource Plan (IRP). It argues against applying thresholds at the 'program' level, advocating instead for sector-level screening to avoid artificial delineations and ensure equity. Portfolio-level screening risks cross-subsidization between sectors, while sector-level screening allows flexibility for Efficiency Nova Scotia (ENS) to optimize its portfolio.

CONCLUSIONS & RECOMMENDATIONS p. p. 263
CONCLUSIONS & RECOMMENDATIONS There are several options available to Nova Scotia to improve the value provided by cost-effectiveness screening of DSM initiatives. Some aim at correcting the problems inherent in the TRC; others propose shif...

AI summary The document evaluates cost-effectiveness screening methods for DSM initiatives in Nova Scotia, critiquing the Total Resource Cost (TRC) approach and advocating for the Program Administrator Cost (PAC) framework. It highlights PAC's alignment with Nova Scotia's Electricity Efficiency and Conservation plan, its transparency, and stakeholder familiarity. Concerns with TRC include methodological challenges, misalignment with the Integrated Resource Plan (IRP), and inadequate benefit accounting.

Preamble p. p. 263
- Acadia Center. (2014). Energy Efficiency: Engine of Economic Growth in Canada . - Amann, J. (2006). "Valuation of Non-Energy Benefits to Determine Cost-Effectiveness. ACEEE Report Number A061. - Application of Southern California Edison...

AI summary The text includes a list of references and documents related to energy efficiency, economic analysis, and regulatory practices. These sources span academic research, policy manuals, and regulatory decisions from various jurisdictions, including Nova Scotia and California.

E-22014 Electricity Demand Side Management Plan Evaluation Reports 1 passage
Table 11: General Recommendations on ENSC Program Manuals p. p. 33
Table 11: General Recommendations on ENSC Program Manuals No. Recommendations OV-R1. Consider the core budget allocation in the cost/subsidy ratio and cost-effectiveness tests. Every organization has a so-called core budget that supports i...

AI summary The text discusses recommendations for improving ENSC program manuals by incorporating core budget allocations into cost/subsidy ratios and documenting pilot projects. These changes aim to ensure accurate cost-effectiveness assessments and provide evaluators with comprehensive information from the start of the evaluation process.

E-6Verification Review of Program Year 2014 Evaluation Results 3 passages
B. A Better Analysis p. pp. 13-14
B. A Better Analysis Currently, evaluations are required to produce the level of informational results shown above in Tables 1 & 2 and in Figures 2&3. Impact evaluations are to produce first year energy savings and first year demand reduct...

AI summary The document argues for a more comprehensive evaluation of DSM programs beyond first-year savings, considering long-term benefits. It references Figure 4 from a 2012 guide by the State and Local Energy Efficiency Action Network, highlighting the balance between evaluation cost and benefit.

L. Residential Financing (No Impact Evaluation) p. pp. 48-50
L. Residential Financing (No Impact Evaluation) This is a zero interest buy-down program with sixty-six participants in 2014. Program savings are allocated to other programs (HEA, Solar and Green Heat). The financing enables all necessary...

AI summary A zero-interest residential financing program with 66 participants in 2014 was evaluated as pivotal in enabling energy improvements. Savings were allocated to other programs (HEA, Solar, Green Heat). Process evaluation via interviews confirmed participants would have postponed work without financing. Questions remain about cost-effectiveness and reliance on behavioral savings for resource planning.

X. References p. pp. 58-62
X. References Donaldson, Stewart L., Christina A. Christie & Melvin M. Mark, eds., What Counts as Credible Evidence in Applied Research and Evaluation Practice? Los Angeles, London, New Delhi, Singapore: Sage Publications, 2009. Dunsky Ene...

AI summary The references section lists academic publications, industry reports, and white papers related to energy efficiency, demand-side management, and evaluation methodologies. Key documents include DSM evaluations, cost-effectiveness analyses, and savings estimation methods, with contributions from organizations like Efficiency Nova Scotia Corporation and Dunsky Energy Consulting.

E-7E1 (NSPI) RIR-1 to RIR-47 7 passages
Section 28
e Filed: March 27, 2015 E1 (NSPI) IR-4 Page 2 of 2 2016-2018 Supply Agreement for EECA M06733 (E-ENS-R-15) E1 Responses to NSPI Information Requests NON-CONFIDENTIAL 1 Request IR-5: 2 3 Reference: EfficiencyOne, Evidence – Page 39, Lines 1...

AI summary E1 (EfficiencyOne) responds to NSPI's inquiry about the 2016-2018 DSM Resource Plan's cost-effectiveness, stating that UARB requires a Total Resource Cost test ratio of 1.0 or greater. E1 clarifies that the RIM test is not part of their analysis but notes Navigant's model can calculate RIM ratios.

Section 45
ate Filed: March 27, 2015 E1 (NSPI) IR-6 Page 3 of 3 2016-2018 Supply Agreement for EECA M06733 (E-ENS-R-15) E1 Responses to NSPI Information Requests NON-CONFIDENTIAL 1 Request IR-7: 2 3 Reference: EfficiencyOne, Appendix A – 2016-2018 DS...

AI summary E1 responds to NSPI's information request regarding income verification and participation statistics in residential programs. E1 states it does not collect income levels for most programs, relying instead on independent evaluations to assess program effectiveness and cost efficiency.

Section 49
Filed: March 27, 2015 E1 (NSPI) IR-8 Page 2 of 2 2016-2018 Supply Agreement for EECA M06733 (E-ENS-R-15) E1 Responses to NSPI Information Requests NON-CONFIDENTIAL 1 Request IR-9: 2 3 Reference: EfficiencyOne, Evidence - Page 56, Lines 12-...

AI summary EfficiencyOne (E1) responds to NSPI's information request regarding measures with TRC<1.5 in the 2016-2018 DSM Resource Plan. E1 explains that programs are approved at the program level with a minimum TRC of 1.0, and individual measures with TRC<1.0 may be included if the overall program passes. Strategic benefits of including such measures are discussed in Attachment 1.

Section 78
NON-CONFIDENTIAL 1 a lower investment level, ENS removed the program from the Plan, as, based on a one- 2 year measure life, it has the highest lifetime unit cost in ENS’s portfolio. Removing this 3 program did not affect local industry ca...

AI summary Efficiency Nova Scotia (ENS) removed a program from its DSM Plan due to high lifetime unit costs and lack of data on assumptions for demand response measures. ENS also removed demand response from consideration due to its inability to provide energy savings or avoid capacity costs during the Plan period. Future research and pilot programs are expected.

Section 79
Existing Residential or New 22 Residential programs as applicable (Application, Appendix A, page 23, lines 5-7). Any 23 piloted measures would be subject to cost-effectiveness screening. 24 25 Business Demand Response: The Business Demand...

AI summary The document discusses the removal of the Business Demand Response program due to cost-effectiveness concerns and lower priority from NSPI. It also references the 2016-2018 Supply Agreement for EECA under matter number M06733.

Section 81
NON-CONFIDENTIAL 1 Enabling Strategies: Enabling strategies build demand for, and support the long-term 2 sustainability of, energy savings. When ENS reduced its proposed investment level from 3 the $50 million plan to the current proposed...

AI summary The document discusses Enabling Strategies and their role in supporting long-term energy savings, noting reductions in investment levels by ENS. It also mentions the use of the EL-RAM model to determine program-level investments and highlights considerations for the overall DSM portfolio, including cost-effectiveness, affordability, and industry capacity.

Section 722
March 27, 2015 E1 (NSPI) IR-25 Page 2 of 2 2016-2018 Supply Agreement for EECA M06733 (E-ENS-R-15) E1 Responses to NSPI Information Requests NON-CONFIDENTIAL 1 Request IR-26: 2 3 Reference: EfficiencyOne, Evidence - Page 33, Lines 23-24: 4...

AI summary E1 argues that reducing program capacity now may not be cost-effective if it leads to future rebuilding. E1 refers to its Application Evidence for analysis and discusses a reduced investment plan to address affordability while preserving industry capacity. No further mitigation measures were considered beyond the proposed plan.

E-8Evidence of Nova Scotia Power Inc. 19 passages
April 10, 2015 p. p. 16
April 10, 2015 1 TABLE OF CONTENTS 2 3 1.0 EXECUTIVE SUMMARY 3 4 2.0 INTRODUCTION 7 5 2.1 Transparency and Accountability 9 6 3.0 AFFORDABILITY 14 7 3.1 DSM Spending Levels 15 8 3.2 Lowering the Cost of DSM 24 9 3.3 Affordability from a Sy...

AI summary NS Power supports acquiring affordable and cost-effective demand side management (DSM) to ensure stable electricity prices. However, it believes the E1 DSM Plan is not sufficiently affordable or cost-effective for customers.

& lt;sup>4 Please refer to Figure 4.1 on page 34 herein. p. p. 16
& lt;sup>4 Please refer to Figure 4.1 on page 34 herein. 1  A decision on the allocation and recovery of costs of any approved DSM Plan 2 from NS Power be deferred until an application is made by NS Power. 3 4  E1's request for the estab...

AI summary The text outlines several decisions related to the Demand Side Management (DSM) Plan, including deferring cost allocation until an application is made, rejecting requests for a reserve fund and a change in cost-effectiveness testing methodology, and establishing standardized filings for future DSM applications.

Section 19 p. p. 16
onth). NS Power also questions whether the information is correct since it does not correspond to the Final 8760 profile provided in conjunction with E1's Electric Resource Assessment Model ("ELRAM"). NS Power had requested E1 provide cert...

AI summary NS Power disputes the accuracy of information provided by E1, citing discrepancies with the Final 8760 profile in ELRAM. NS Power requested historical data on customer participation and custom projects to assess the cost-effectiveness of DSM programs, but E1 refused, claiming the data was not relevant and too difficult to consolidate.

20 (a) Selection of Lower Unit Cost Options (Measures and Programs) p. p. 22
20 (a) Selection of Lower Unit Cost Options (Measures and Programs) 21 22 E1's primary DSM planning tool in the development of the E1 DSM Plan was the 23 ELRAM. This is a proprietary spreadsheet-based model developed by Navigant 24 which u...

AI summary NS Power analyzed E1's DSM Plan using ELRAM and found that selecting lower unit cost measures could reduce costs significantly. E1's consultants argue that only choosing the lowest cost measures is not viable, but other Canadian utilities achieve lower unit costs. NS Power urges E1 to explore lower-cost options, noting E1's refusal to prepare such plans for analysis.

7 (c) Eliminate Adoption of Emerging Technologies at High Costs p. pp. 22-27
7 (c) Eliminate Adoption of Emerging Technologies at High Costs 8 9 With continual improvements in appliance efficiency standards and building 10 codes, the market increasingly adopts more efficient technologies and the cost of 11 these te...

AI summary The document argues that emerging technologies, like LED lighting and solar PV, become more affordable over time due to market trends and economies of scale. NS Power contends that subsidizing early adoption in Nova Scotia is costly, as the province's small market cannot influence technology maturation. Waiting until costs decrease through larger market adoption is more economically efficient.

17 3.3 Affordability from a System Planning Perspective p. p. 27
17 3.3 Affordability from a System Planning Perspective 18 19 Through the course of the 2014 IRP, the Company analyzed revenue requirements 20 resulting from a variety of different DSM profiles. NS Power has further considered the 21 affor...

AI summary NS Power analyzed the affordability of DSM profiles via NPV of revenue requirements over time horizons. The $22M annual DSM plan (Contract Period) yields the lowest long-term NPV beyond 2030, while the $25M plan (CRP 1-1) is more affordable in the short term. NS Power argues this balances cost-effectiveness and rate stability.

Figure 3.6: Ranking of CRPs p. pp. 27-32
Figure 3.6: Ranking of CRPs low and low to a mid-investment level. In terms of a revenue requirement analysis, the Low DSM energy and capacity savings for the $22 million expenditure plan again demonstrates superior near term affordability...

AI summary The text discusses the affordability and cost-effectiveness of different Demand Side Management (DSM) expenditure levels in the context of the 2014 Integrated Resource Plan (IRP). It highlights that the 'Low' DSM energy and capacity savings plan offers superior near-term affordability while remaining cost-effective beyond 2030.

5.1 NS Power's Alternative DSM Plan p. p. 32
5.1 NS Power's Alternative DSM Plan E1 did not develop or model any DSM investment scenarios lower than that contained in the proposed E1 DSM Plan. NS Power had requested E1 develop different plan scenarios, including one within an annual...

AI summary NS Power requested E1 (NSPI) to model lower DSM investment scenarios but was declined. E1's analysis lacks quantitative evaluation of lower expenditure options, limiting informed decision-making. NS Power proposes an alternative DSM plan aligned with Canadian benchmarks, emphasizing affordability and cost-effectiveness.

Preamble p. p. 32
3 At present, the Total Resource Cost test ("TRC") is applied for cost-effectiveness testing 4 in Nova Scotia and much of North America. 5 6 When DSM began in Nova Scotia, the Board required individual Measures to pass 7 economic effective...

AI summary The document discusses the evolution of cost-effectiveness testing for Demand Side Management (DSM) in Nova Scotia, including the shift from individual measure testing to program-level and now sector-level testing. NS Power opposes relaxing the threshold, arguing it may lead to suboptimal choices and recommends maintaining the Total Resource Cost (TRC) test.

DATE FILED: April 10, 2015 Page 48 of 51 p. p. 32
DATE FILED: April 10, 2015 Page 48 of 51 1 11.0 ICFI EVIDENCE 2 3 To assist in its analysis of the E1 DSM Plan, NS Power engaged ICFI to carry out a 4 separate review and provide testimony. Attached hereto as Appendix A is a copy of the 5...

AI summary NS Power argues that the proposed E1 DSM Plan is not cost-effective or affordable for Nova Scotians. While recognizing the long-term benefits of DSM, NS Power suggests a reduced investment level during the Contract Period, estimating annual spending of approximately $22 million would achieve energy savings of 100 GWh per year and avoid the need for additional generation capacity until 2032.

13 A. I find that: p. p. 32
13 A. I find that: - 14 The program information provided by EfficiencyOne is insufficient for 15 regulatory approval and contract development, and I recommend that 16 EfficiencyOne be directed to provide additional information; - 17 The re...

AI summary The findings indicate that EfficiencyOne's program data lacks sufficiency, cost justification, and breadth. The board recommends enhanced data submission, broader program evaluation, alternative DSM portfolio analysis, improved reporting standards, and expanded performance targets. These issues require corrective action for regulatory approval.

15 Appropriateness of the Proposed DSM Program Portfolio p. p. 32
15 Appropriateness of the Proposed DSM Program Portfolio - 17 Q. HAVE YOU REVIEWED EFFICIENCYONE'S APPLICATION AND 18 PROPOSED PORTFOLIO OF DSM PROGRAMS? - 19 A. Yes, I have reviewed the Application and proposed programs and find 20 three...

AI summary The reviewer identifies three issues with EfficiencyOne's DSM program proposal: incomplete information, potential excessive budgets, and insufficient alternate scenarios. Recommends rejecting the plan and evaluating alternatives.

16 Range of Scenarios Considered p. p. 32
16 Range of Scenarios Considered - 18 Q. WHAT RANGE OF DSM PROGRAM TYPES DID EFFICIENCYONE 19 CONSIDER? - 20 A. According to Company IR-12(b) the only programs considered by 21 EfficiencyOne were the six included in the final proposal, alo...

AI summary EfficiencyOne considered only a limited range of DSM program types and expenditure levels in its proposal, excluding many low-cost programs and not conducting quantitative analysis on demand response programs. The expert testimony suggests that a broader range of programs and expenditures should have been considered for a more cost-effective and balanced portfolio.

1 Q. COULD YOU PLEASE ILLUSTRATE THE CONSIDERATION OF p. p. 32
1 Q. COULD YOU PLEASE ILLUSTRATE THE CONSIDERATION OF 2 ALTERNATE PROGRAM ASSUMPTIONS AND EXPENDITURE 3 LEVELS? 4 A. Yes. In order to illustrate the potential impact of considering alternate 5 policy and program assumptions, ICF and NSP de...

AI summary The witness explains that ICF and NSP developed alternate scenarios using EfficiencyOne's ELRAM model to assess the impact of different program assumptions, including the exclusion of non-cost-effective measures. The witness argues that including a large number of non-cost-effective measures is not justified.

Attachment A Page 2 of 6 2016-2018 DSM NS Power Evidence Appendix A Page 45 of 100 p. p. 32
Attachment A Page 2 of 6 2016-2018 DSM NS Power Evidence Appendix A Page 45 of 100 Developed DSM program filings (including DSM potential, detailed program designs, regulatory filing and benchmarking documents, and full implementation serv...

AI summary The text details Mr. Pickles' work on demand-side management (DSM) programs for multiple utilities, including regulatory filings, energy efficiency initiatives, and financing programs. Projects span program design, cost-effectiveness analysis, and evaluations for utilities like Exelon, Delmarva Power, and Maui Electric, with a focus on compliance, implementation, and regulatory engagement.

Summary of Insights p. p. 101
Summary of Insights - The ENSC portfolio ranks highest on the list of jurisdictions reviewed for DSM spend per capita and per customer. - ENSC has the highest first year cost per kWh of energy savings of the jurisdictions reviewed. - Withi...

AI summary ENSC leads Canada in DSM energy savings and per capita spend but has high first-year costs per kWh. Nova Scotia plans the highest electrical DSM investment relative to energy sales. Despite industrial sector's cost-effectiveness, ENSC lacks targeted programs. ENSC's diverse DSM portfolio includes costly elements, and performance variances may impact system planning.

4 Results of the Research p. p. 101
4 Results of the Research The following exhibits present a consolidated view of the research findings: - Exhibit 1: DSM Program Administrator Actual and Planned $DSM/capita and $DSM/customer - Exhibit 2: 2015 First Year Cost Comparison ($/...

AI summary The research findings show that Nova Scotia's DSM program expenditure per capita and per customer in 2015 was higher than other jurisdictions reviewed. Exhibits provide data on DSM program administrator costs, energy savings, and cost-effectiveness. Nova Scotia's DSM portfolio is discussed in detail in Section 5 of the research.

History of Results p. pp. 116-117
istrator's 2011 Demand Side Management Programs, March, 2012 27 Costs are expressed in Canadian Dollars. 28 Market Trends for the Supply & Demand of Electricity in Nova Scotia, 29 Econoler for Efficiency Nova Scotia Corporation, 2012 DSM E...

AI summary The text details historical references to Nova Scotia's Demand Side Management (DSM) programs, including evaluations, cost recovery reports, and regulatory applications. Key entities include Efficiency Nova Scotia Corporation (ENSC), Nova Scotia Power Incorporated (NSPI), and the Nova Scotia Utilities and Review Board (URB). The focus is on DSM program evaluations, cost analysis, and regulatory submissions from 2011 to 2015.

Section 156 p. pp. 118-120
The ENSC portfolio ranks highest on the list of jurisdictions reviewed for DSM spend per capita and per customer and also appears to have the highest DSM expenditure relative to savings. Exhibit 15 shows the verified cost per kilowattͲhour...

AI summary The ENSC portfolio has the highest DSM spend per capita and per customer, with Exhibit 15 showing verified cost per kilowatt-hour of ENSC's programs over the past three years. More detailed cost effectiveness tests are required to evaluate individual measures and programs within the portfolio.

E-11NSPI (CA) RIRs to IR-1 to IR-41 - Redacted 4 passages
Request IR-1: p. p. 11
Request IR-1: 2 1 3 Reference: 2016-2018 DSM Plan NS Power Evidence Appendix B 4 - 5 NSPI has proposed a DSM spending of approximately $22 per year for the years 2016- - 6 2018. How was an annual DSM budget of $22 million determined to be...

AI summary NS Power justifies a $22 million annual DSM budget for 2016-2018 by aligning with the 2014 IRP and Public Utilities Act, using ELRAM scenarios, and citing consistency with Canadian jurisdictions' per-customer spending.

12 Response IR-11: p. p. 11
12 Response IR-11: 13 14 (a) Yes. NS Power compared the average monthly residential household bill as a percentage 15 of gross income per household. 16 17 18 19 Marginal electricity costs, avoided costs and domestic generation were not exp...

AI summary NSPI responded to IR-11 by comparing residential electricity bills to household income. They noted marginal costs and domestic generation were not analyzed, citing Multeese IR-5. The 2016-2018 DSM Plan (NSUARB M06733) is referenced, with no applicability for part (b).

NON-CONFIDENTIAL p. pp. 11-95
NON-CONFIDENTIAL 1 savings – provided the right amount of DSM for the system. Contracting additional DSM to 2 avoid capacity additions beyond 2032 is costly and uncertain. 3 4 Spending in other jurisdictions 5 6 Once the Company determined...

AI summary The document analyzes Nova Scotia Power Inc.'s (NSPI) Demand Side Management (DSM) strategies, noting that Nova Scotians spend more than the national average on DSM. It highlights the cost and uncertainty of expanding DSM beyond 2032, advocates for efficiency to ensure affordability, and references alternative DSM options achievable for ~$22 million. A 2016-2018 DSM Plan (NSUARB M06733) is cited.

Illustrative Model of One-time DSM investment p. pp. 76-79
Illustrative Model of One-time DSM investment DSM Investment Savings After tax WACC discount rate -40 $M 135 Gwh 1 Year DSM Investment made at end of 2015 0 2015 1 2 2016 2017 3 2018 4 2019 2 5 6 2020 2021 7 2022 8 9 2023 2024 10 2025 11 2...

AI summary The document presents a financial model evaluating a one-time Demand Side Management (DSM) investment by Nova Scotia Power Inc. (NSPI), showing energy and capacity savings, present value (PV) calculations, and economic balance over 12 years. Key metrics indicate breakeven in 2022 for energy-related savings and positive economic balance by 2022 for combined energy-capacity savings.

E-12NSPI (EAC) RIRs to IR-1 to IR-8 1 passage
NON-CONFIDENTIAL
NON-CONFIDENTIAL 1 Request IR-2: 2 3 The benefits of most efficiency measures last well beyond one year; why would those 4 savings not be included as benefits to the system for their life? 5 6 Response IR-2: 7 8 DSM cost-effectiveness test...

AI summary The request questions why the benefits of efficiency measures, which last beyond one year, are not considered over their full lifespan. The response explains that DSM cost-effectiveness tests, such as TRC and PAC, account for long-term savings by using NPV of costs and benefits over time.

E-13NSPI (E1) RIRs to IR-1 to IR-50 - Redacted 2 passages
2016-2018 DSM Plan (NSUARB M06733) NSPI Responses to EfficiencyOne Information Requests p. pp. 17-34
2016-2018 DSM Plan (NSUARB M06733) NSPI Responses to EfficiencyOne Information Requests 1 Request IR-17: 1 Request IR-19: 2 3 Reference: NS Power's Evidence, Section 7.0, Page 43 4 5 (a) Does NS Power believe that cost-effectiveness tests...

AI summary NS Power responds to questions about cost-effectiveness tests in the DSM Plan, acknowledging the importance of balancing costs and benefits but defending the TRC test as more balanced than PAC, which ignores participant contributions.

NON-CONFIDENTIAL p. p. 34
NON-CONFIDENTIAL 1 Request IR-29: 2 3 Reference: Appendix A, Page 59 of 100, Exhibit 3 (Program Cost Effectiveness) 4 5 (a) Please provide the rationale for excluding BC Hydro's individual programs from 6 Mr. Pickles' benchmarking exercise...

AI summary The document contains a request and response regarding the exclusion of certain programs from a benchmarking exercise and the inclusion of all programs in a portfolio analysis. The response explains that data was aggregated and that the requested analysis has not been performed.

E-14NSPI (IG) RIRs to IR-1 to IR-4 1 passage
NON-CONFIDENTIAL
NON-CONFIDENTIAL 1 Request IR-4: 2 3 Reference: NSPI Evidence (p. 43, line 6) 4 5 (a) Please provide further explanation of NSPI's position on E1's proposed changes to 6 cost-effectiveness testing. 7 8 (b) What is the impact of testing at...

AI summary NSPI is requested to explain its position on E1's proposed changes to cost-effectiveness testing, the impact of testing at different levels (sector, program, measure), the PAC test's stringency, and how the Board should compare TRC, PAC, and RIM test outcomes for DSM programs. NSPI refers to Peach IR-24 for details.

E-15NSPI (Multeese) RIRs to IR-1 to IR-19 - Redacted 1 passage
NON-CONFIDENTIAL p. p. 9
NON-CONFIDENTIAL 1 Response IR-10: 2 3 (a) Confirmed. 4 5 (b) The Company analyzed the franchise holder's 2016-2018 ELRAM and determined that 6 DSM energy and capacity savings costs could be significantly reduced such that the 7 "Low" DSM...

AI summary The Company confirmed its analysis of the franchise holder's ELRAM data, indicating that DSM energy and capacity savings costs could be reduced, allowing the 'Low' DSM levels from the Navigant study to be achievable at a lower cost. The 'low' scenario was chosen for its balance of cost effectiveness and affordability, and the Company requested alternate DSM plans but did not receive them.

E-16NSPI (NSUARB) RIRs to IR-1 to IR-15 1 passage
1 NS Power 2014 Integrated Resource Plan Final Report, NSUARB M05522, October 15, 2014, page 62. p. p. 4
1 NS Power 2014 Integrated Resource Plan Final Report, NSUARB M05522, October 15, 2014, page 62. 1 The analysis of partial revenue requirements analyzes fuel and purchased power as well 2 as the associated variable O&M. It assumes other OM...

AI summary The analysis of partial revenue requirements considers fuel, purchased power, and variable O&M costs, assuming other OM&G costs are common across plans. The proposed DSM savings and spend profile is deemed to provide the best balance between short-term affordability and long-term cost effectiveness, with the economic crossover point for higher DSM options not occurring until 2034.

E-17NSPI (Peach) RIRs to IR-1 to IR-24 2 passages
4 NS Power DSM Evidence, pages 9-10, April 10, 2015.
4 NS Power DSM Evidence, pages 9-10, April 10, 2015. 1 Request IR-19: 2 3 NSPI notes that it is concerned with the "description and understanding" of the scope of 4 DSM services and suggests that other jurisdictions commonly require variou...

AI summary NSPI is concerned with the scope of DSM services and suggests that other jurisdictions require detailed information. E1, despite being a new organization, has been running DSM programs and achieving targets. NS Power argues that more detailed information is needed to ensure cost-effective and affordable DSM programs as required by legislation.

1 Request IR-21:
NON-CONFIDENTIAL 1 Request IR-21: 23 not the mandate of NS Power or the UARB under the legislation. Such goals would have 24 significant cost and affordability implications which would need to be vetted publicly 25 before approval and adop...

AI summary NSPI opposes E1's request to change the cost-effectiveness testing method from TRC to PACT/UCT and does not support moving testing to the sector level. NSPI also raises questions about the appropriate discount rate for the test, given the varying practices across jurisdictions.

62745Board Decision 9 passages
2.0 BACKGROUND p. p. 0
une 30, 2016. This will allow sufficient time to deal with any such matters prior to the submission of the next DSM Plan. [25] For reasons that are explained later in this Decision, however, the Board does not approve the Quantum Agreement...

AI summary The Board does not approve the Quantum Agreement due to insufficient DSM spending in the public interest, despite support from multiple groups. It approves some aspects like the DSM Expenditure Justification Criteria and the Small Business Energy Study, though NSPI objects to the latter due to cost. The DOE supports equity principles and other sections of the agreements.

3.5.3 Affordability p. p. 0
an, as amended by the Board, meets the test of affordability. [79] The Industrial Group begins the discussion on affordability in its posthearing submission with the following very salient statement: The Industrial Group wishes to make it...

AI summary The discussion on affordability emphasizes balancing short-term costs with long-term risks. The Industrial Group opposes prioritizing immediate affordability over long-term risks, while the DOE clarifies affordability refers to upfront costs. NSPI and SBA align with short-term customer perspectives (up to five years). The PUA amendments focus on short-term rate impacts, but the Board must prioritize customer best interests.

3.5.4 Relationship of the Proposed 201 6-18 DSM Plan to the 2014 Integrated Resource Plan p. p. 0
3.5.4 Relationship of the Proposed 201 6-18 DSM Plan to the 2014 Integrated Resource Plan [94] During a 10-month period in 2014, NSPI developed a new IRP in collaboration with Board Staff and consultants, and in consultation with intereste...

AI summary NSPI's 2014 Integrated Resource Plan (IRP) emphasized demand-side management (DSM) to achieve cost-effective energy savings. The proposed 2016-18 DSM Plan aligns with the IRP's 'mid-DSM' scenario, which projects higher savings (519 GWh over 3 years) compared to prior DSM plans (397 GWh). The IRP process aims to balance supply-side and demand-side resources for long-term ratepayer savings.

3.5.5 Cost Effectiveness Screening p. p. 0
3.5.5 Cost Effectiveness Screening [99] Although the Board has not approved the Quantum Agreement, Section 7 contains a provision which states as follows: Through collaboration within the DSM Advisory Group the parties agree to work to ach...

AI summary The Board has not approved the Quantum Agreement but allows the DSM Advisory Group to develop a consensus methodology for cost-effectiveness screening. The existing TRC methodology remains in place, with the Board cautioning that abandoning it requires a compelling case.

3.5.6 Avoided Cost Analysis p. p. 0
3.5.6 Avoided Cost Analysis [101] Synapse, in its evidence, indicated that rate impact analysis should account for all factors that impact rates either positively or negatively, which would include avoided costs that might exert downward p...

AI summary The text discusses avoided cost analysis in Nova Scotia's regulatory context, emphasizing Synapse's view on rate impact analysis, E1's recognition of DSM benefits, NSPI's interest in locational avoided costs, and the Board's encouragement of collaboration. Key considerations include environmental compliance, transmission deferral, and stakeholder coordination.

4.0 LETTERS OF COMMENT AND PUBLIC SPEAKERS p. p. 0
4.0 LETTERS OF COMMENT AND PUBLIC SPEAKERS [129] The Board received 37 letters of comment from various persons, who wrote individually or on behalf of organizations. With only two exceptions, all were supportive of El and maintaining the a...

AI summary The Board received 37 letters supporting El's DSM plan, emphasizing environmental, economic, and low-income benefits. Most advocated maintaining or increasing efficiency spending. A critique of Dr. Peach's evidence was an exception. Public speakers, including industry stakeholders and students, emphasized DSM's benefits and risks of reduced programs.

5.0 SUMMARY OF BOARD FINDINGS p. p. 0
aving considered the history of underspending on DSM programming, the history of overachieving savings and demand targets, and as an inducement to bring greater rigor to the calculation of incentives. [142] The Board considers that the tar...

AI summary The Board approves the El DSM Plan within approved spending, acknowledges affordability under PUA s.79L, but warns against short-term focus. It rejects the Quantum Agreement but approves aspects like DSM Expenditure Justification Criteria. The Consensus Agreement is approved with referrals to the DSM Advisory Group, and TRC remains for cost effectiveness.

7) COST-EFFEcTIVENESS TESTING p. p. 0
7) COST-EFFEcTIVENESS TESTING a) Through collaboration withIn the DSM Advisory Group, the parties agree to work to achieve consensus as to the methodology and assumptions of the cost-effectiveness screening test to be applied to future DSM...

AI summary The parties agree to collaborate with the DSM Advisory Group to develop a consensus on the methodology and assumptions for cost-effectiveness screening tests for future DSM Resource Plans.

9) PRINCIPLES OF EQUITY p. p. 0
9) PRINCIPLES OF EQUITY a) ALL ratepayers are entitled to an equitable opportunity to partIcipate in DSM programs. Lowincome tenants and homeowners as well as marginally viable commercial and industrial customers are some of the most diffi...

AI summary The section emphasizes that all ratepayers, including low-income and marginally viable customers, must have equitable access to DSM programs. It highlights the need for services that address barriers faced by these groups and for cost-effectiveness screening to consider additional costs.

63307Board Order 2 passages
Section 98 p. p. 44
a Lifetime benefits are expressed as the net present value ofthe avoided costs, including energy and capacity, over the life ofthe program measures. , b TRC is a benefit/cost ratio comparing lifetime benefits to the sum ofENS's and partici...

AI summary The text discusses lifetime benefits, TRC and PAC ratios, and provides references to figures that detail program-level investment and savings for specific years. These metrics are used to evaluate the cost-effectiveness of energy efficiency programs.

1) ESTABLISHMENT OF A STANDARDIZED FILING FOR FUTURE APPLICATIONS TO APPROVE A DSM SUPPLY AGREEMENT p. p. 73
1) ESTABLISHMENT OF A STANDARDIZED FILING FOR FUTURE APPLICATIONS TO APPROVE A DSM SUPPLY AGREEMENT - a) The Parties agree to the establishment of a standardized filing for future applications, the substance of which will be vetted through...

AI summary Parties agree to establish a standardized filing for future DSM supply agreement applications, including templates and data points like energy savings, cost-effectiveness analysis, and rate impact assessments. The DSM Advisory Group will vet the filing, and EfficiencyOne may add relevant information.

62375Closing Submission - Affordable Energy Coalition 3 passages
a. Principles of Equity – Clause 9 p. p. 7
a. Principles of Equity – Clause 9 Clause 9 of the Settlement Agreement reads: "All ratepayers are entitled to an equitable opportunity to participate in DSM programs. Low income tenants and homeowners as well as marginally viable commerci...

AI summary Clause 9 of the Settlement Agreement emphasizes equitable access to Demand Side Management (DSM) programs for low-income and marginalized customers, requiring cost-effectiveness screening to account for their unique challenges. It addresses affordability, cost-effectiveness screening, evaluation, and compliance with the 2014 Electricity Efficiency and Conservation Restructuring Act. This 3-year contract under the 2014 Act will establish principles influencing regulatory decisions.

Issue 5a – Affordability and Issue 5-c – Cost effectiveness screening: p. p. 7
Issue 5a – Affordability and Issue 5-c – Cost effectiveness screening: Four expert witnesses in this year's hearing for the 2016-18 Electrical Efficiency Supply Agreement argued that equity of access must be recognized as an important elem...

AI summary Expert witnesses and the Affordable Energy Coalition argue that equity of access must be central to affordability and cost-effectiveness screening, emphasizing the challenges of serving low-income households. They urge the DSM Advisory Group to incorporate Clause 9 of the Settlement Agreement to prevent exclusion of hard-to-serve customers. Clause 7 mandates collaborative methodology development for cost-effectiveness screening.

Page 31: p. p. 7
Page 31: - 17 Please summarize your points regarding the affordability of the E1 DSM Plan and 18 the NSPI alternative DSM plan. - 19 A. NSPI's discussion of affordability is incomplete, because it focuses only on the short - 20 term rate i...

AI summary The response argues that NSPI's affordability analysis of its DSM plan is incomplete, focusing only on short-term rate impacts while ignoring bill impacts and long-term effects. A complete analysis shows E1's DSM Plan has lower net costs and similar long-term rates, making it more affordable. Affordability is important but not the sole factor in evaluating DSM plans.

62377Closing Submission - Small Business Advocate 1 passage
Cost-Effectiveness Testing p. p. 0
Cost-Effectiveness Testing In the evidence filed as well as testimony at the hearing, there was significant discussion of cost effectiveness testing and the difference between the Program Administrator Cost (PAC) test versus the Total Reso...

AI summary The document discusses the use of the Total Resource Cost (TRC) test as the current screening method for demand-side management (DSM) in Nova Scotia. It highlights the Monetary Consensus agreement to address cost-effectiveness testing in future DSM plans, with NS Power supporting this approach. The SBA advocates for the DSM Advisory Group to evaluate screening tests, with the Board as a fallback if consensus fails.

62378Closing Statement - Nova Scotia Department of Energy 3 passages
The Public Utilities Act Focus on Affordability p. p. 3
dustrial and institutional customers with greater flexibility and control over demand side investments funded by the programs at their facilities; and (I) programs for public education regarding energy efficiency and demand management; pro...

AI summary The document outlines requirements for Nova Scotia Power Incorporated's Demand Side Management (DSM) plan under the Public Utilities Act (PUA), including funding mechanisms, performance incentives, budgeting, and economic benefits. It specifies spending limits, reconciliation methods, and the role of the advisory council in approving expenditures. The plan emphasizes reducing peak load, energy costs, and promoting consumer benefits.

The Inherent Flexibility of DSM p. p. 12
ript, June 19, 2015, pp.917-918 and p.969. & lt;sup>52 Exhibit E-8, Nova Scotia Power Incorporated Direct Evidence, pp.15-16; Transcript, June 19, 2015, p.985. GWH/year. 53 - b. E1 has noted that it requires the flexibility to make mid-cou...

AI summary The text discusses the flexibility of Demand Side Management (DSM) in adapting to market changes and technological advancements. It highlights Efficiency One's (E1) ability to adjust mid-course and Nova Scotia Power Incorporated's (NSPI) acknowledgment of DSM's flexibility. Arguments include potential cost-effective capacity savings, demand response options, and concerns about overstated customer benefits if budgets are reduced.

Consensus Settlement Agreement and Terms of Consensus Agreement p. pp. 16-17
Consensus Settlement Agreement and Terms of Consensus Agreement 47. The Province supports some aspects of the terms of Consensus Agreement but does not agree with the DSM investment level and performance targets. The Province notes that in...

AI summary The Province supports aspects of the Consensus Agreement but disagrees with DSM investment levels and performance targets. Other topics for discussion include standardized filing, rate impact analysis, DSM expenditure criteria, and cost-effectiveness testing. The Province supports mid-course adjustments, flexibility for E1, and the Principles of Equity and Performance Targets.

62379Closing Submission - Nova Scotia Power Inc. 6 passages
5.0 RATE PRESSURE p. p. 51
5.0 RATE PRESSURE Electricity rates are a critical consideration in assessing the affordability of DSM expenditures and an issue which the Board must take into account. Indeed, as noted above, the DOE in its comments on the balancing of sh...

AI summary The DOE opposes DSM spending that increases electricity rates, while NS Power argues DSM costs are incremental and not currently in customer rates. NS Power highlights DSM's flexibility and three-year review under the Public Utilities Act. The removal of the DSM rate rider in 2015 and use of fuel charges to address FAM deferrals are also discussed.

1 2 3 been informed by that since some of them are so far outside the range of reasonableness. 37 p. p. 51
1 2 3 been informed by that since some of them are so far outside the range of reasonableness. 37 4 NS Power provides further submissions below with respect to its concerns 5 regarding the incentive levels proposed by E1 in the E1 DSM Plan...

AI summary NS Power argues that the proposed incentive levels in E1's DSM Plan are too high and not cost-effective compared to its own proposal, citing evidence showing similar savings at half the cost and expert testimony affirming the achievability of lower unit costs.

Section 45 p. p. 51
Given that the benefit-to-cost ratio given that benefit-to-cost ratio for the customer, why does EOne consider it necessary to provide a $200 incentive to the customer? That incentive becomes a cost that must be borne by all other customer...

AI summary The proceeding discusses concerns about the cost-effectiveness and justification of a $200 incentive provided by EOne for a DSM measure. NS Power argues that EOne's response to the incentive process was unresponsive and lacks evidence of a documented process or comparison to alternative incentives.

Section 46 p. p. 51
and strategies, which it did not do. It should have compared alternate incentives to E1's proposed amounts. Further, there was no comprehensive comparison to incentives in non-high cost jurisdictions. & lt;sup>51 Exhibit E-54, Opening Stat...

AI summary The document criticizes E1's process for not adequately considering the cost-effectiveness and affordability of incentives for NS Power customers. It highlights the lack of comprehensive comparison to non-high cost jurisdictions and the overemphasis on customer and trade ally input, potentially leading to inflated incentive requests.

& lt;sup>63 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 19, 2015, page 969, Lines 9-20. p. p. 51
& lt;sup>63 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 19, 2015, page 969, Lines 9-20. 1 2 While it is a hypothetical possibility, it is not a reason to incur more cost than necessary now. I have two observat...

AI summary The testimony discusses the impact of increasing DSM spending on rates, emphasizing that higher costs could negatively affect the provincial economy. It also suggests that adding rigor to the DSM incentive process and right-sizing incentives could reduce disparities between participants and non-participants without harming industry capacity significantly.

Response: p. p. 51
Response: Please refer to EfficiencyOne's response to NSPI IR‐10 Attachment 1, filed electronically, for measure‐level incentives modelled in the EL‐RAM, which are provided in column BK. The modelled incentive dollars provided reflect actu...

AI summary The response critiques EfficiencyOne's (E1) use of the ELRAM model for incentive calculations, citing lack of rationale, excessive incentives compared to other jurisdictions, and failure to consider cost-effectiveness or affordability. It highlights flaws in E1's process, including reliance on customer input without quantitative criteria and benchmarking against high-cost states, leading to potentially inappropriate incentive levels.

62380Closing Submission - Efficiency One 8 passages
EFFICIENCYONE CLOSING SUBMISSION p. p. 0
EFFICIENCYONE CLOSING SUBMISSION FILED July 8, 2015

AI summary EfficiencyOne submits its closing arguments in a Nova Scotia regulatory proceeding, advocating for the approval of its energy efficiency programs. The submission emphasizes the programs' cost-effectiveness, consumer benefits, and alignment with provincial energy goals, seeking regulatory endorsement.

Preamble p. pp. 14-51
- 3 "amount that Nova Scotia Power Incorporated will pay to the franchise holder for the supply of - electricity, efficiency and conservation activities"[22](#page-15-0) 4 over the course of the contract. 5 - 6 In conjunction with these in...

AI summary EfficiencyOne proposes a modified 2016-2018 DSM Resource Plan with energy and demand savings targets, developed in line with the Public Utilities Act and based on analyses from NS Power's 2014 IRP. EfficiencyOne asserts that the plan is cost-effective and affordable, despite concerns raised by NS Power about affordability.

Position of Nova Scotia Power p. pp. 17-18
Position of Nova Scotia Power 12 - NS Power indicated in its evidence that the EfficiencyOne DSM Plan (at the original investment - level of $121.5 million for the 3-year contract) was neither cost-effective nor affordable on the - 15 grou...

AI summary Nova Scotia Power argues that the EfficiencyOne DSM Plan's investment level is too high and not cost-effective, citing comparisons with Canadian jurisdictions. EfficiencyOne counters that NS Power's analysis is flawed and based on inaccurate data, with Mr. Dunsky reviewing the analysis and finding issues.

15 [emphasis added] p. p. 35
htened 4 attention to the consideration of affordability was expressly considered in EfficiencyOne's Plan 5 development and was specifically noted by Ms. Vincent during the NS Power cross-examination: When we looked at the concept of affor...

AI summary EfficiencyOne's Plan balanced long-term benefits of higher DSM (per IRP) against short-term rate impacts, repurposed 2014 DSM funds for FAM repayment, and emphasized stable DSM investment to ensure rate stability, as explained by Ms. Vincent during NSP cross-examination.

1 COST-EFFECTIVENESS SCREENING p. pp. 42-45
1 COST-EFFECTIVENESS SCREENING 3 In its Application, EfficiencyOne requested approval to change the primary cost-effectiveness testing methodology from the TRC to the PAC for subsequent DSM Resource Plans.[65](#page-44-1) 4 In support of t...

AI summary EfficiencyOne requested approval to switch from the TRC to the PAC test for DSM Resource Plans, citing benefits like fairness and alignment with the Public Utilities Act. NS Power opposed the change, arguing that PAC lowers the cost-effectiveness standard, potentially leading to suboptimal choices. EfficiencyOne defends the shift as necessary to ensure unbiased screening and align with industry best practices.

Exhibit 33. NS Power Revised Evidence, Page 43, Lines 17-19. 70 Exhibit 1. EfficiencyOne Evidence filed February 27, 2015, Appendix "I", Pages 1 and 2. p. pp. 45-46
Exhibit 33. NS Power Revised Evidence, Page 43, Lines 17-19. 70 Exhibit 1. EfficiencyOne Evidence filed February 27, 2015, Appendix "I", Pages 1 and 2. 1 EfficiencyOne submits that there is no evidence before the Board to demonstrate that...

AI summary EfficiencyOne argues that there is no evidence that shifting from TRC screening to PAC screening would relax standards and requests the Board to refer the issue to the DSM Advisory Group for further consideration. EfficiencyOne also refutes claims that incentives are necessary for all energy-saving measures.

Section 61 p. pp. 46-48
1 opportunities where you do need to incent. One thing I'll say is that there is only way to know and that's through understanding the market[72](#page-48-0) 2 . 4 [emphasis added] 5 3 6 In his opening statement, filed on behalf of the Ind...

AI summary The document discusses a proposed two-part test by Mr. Drazen on behalf of the Industrial Group, requiring EfficiencyOne to demonstrate cost-effectiveness and inversely proportional investment based on the TRC ratio. EfficiencyOne argues there is no evidence of excessive incentives and questions the assumptions behind the algorithmic approach, such as participants understanding bill savings and believing in the benefits of the measures.

[emphasis added] p. pp. 53-54
furtherance of an - 30 undertaking provided at the time of the hearing, EfficiencyOne has filed Undertaking U-4 which 83 Public Utilities Act , ss. 79(I)(6). 1 details EfficiencyOne s assessment of its incentive level and methodology. The...

AI summary EfficiencyOne's incentive methodology, based on historical experience, research, benchmarking, and market monitoring, aligns with industry standards. Evaluation reports and free-ridership considerations ensure cost-effectiveness, as submitted to the Board.

62381Closing Submission - Industrial Group 4 passages
(c) Vague and Unquantified Risks to "Efficiency Industry" p. p. 6
pacity should rise and fall with the level of need for the DSM resource itself, much the same way that the level of capacity to build generation should vary with the amount of generation anticipated. I generally disagree with much of Effic...

AI summary The Consumer Advocate disputes EfficiencyOne's claim that maintaining excessive DSM capacity is necessary, arguing that US jurisdictions have rapidly achieved significant energy savings. The CA emphasizes evaluating the long-term costs of sustaining excess capacity versus future costs of recreating it, noting potential declines in efficiency measure prices and natural technology adoption.

28. And later: p. pp. 6-8
28. And later: Mr. Gogan: Mr. Pickles, you would agree it takes time to build up the infrastructure necessary to deliver a successful DSM portfolio? Is that correct? 18 Transcript, June 16, 2015, cross-examination of Mr. Crandlemire, pp.55...

AI summary Mr. Pickles testified that DSM program timelines vary depending on program type, with some programs able to be implemented quickly while others take longer. He emphasized the need to balance timing with carrying costs, contrasting with Mr. Gogan's challenge on EfficiencyOne's ability to dispatch programs as needed. Reference is made to a 2009 South Carolina Docket where Mr. Pickles faced prior challenges.

(d) Incentives Are Too High p. p. 10
you acknowledge that there are measures in your portfolio that pay for themselves from the customers' perspective without any incentive from EfficiencyOne? On an economic basis. Ms. Vincent: Yes. Ms. Rubin: And some of them would pay for t...

AI summary The document highlights concerns that EfficiencyOne (E1) has not adequately evaluated incentive levels and payback periods for energy efficiency measures. Despite 44 measures with payback periods under 12 months, E1 offers up to 100% cost incentives. While E1 acknowledges customer payback should influence incentives, there is no evidence they tested lower levels. E1's response cites benchmarking other jurisdictions but lacks concrete modeling.

(e) Alternative Proposal p. p. 14
ints overlap with the Drazen proposal. As noted on page 1, he states that only measures with a net TRC benefit cost ratio greater than 1.0 (i.e., the TRC ratio multiplied by the estimated measure net-to-gross ratio) should be included, unl...

AI summary The text discusses alternative proposals for demand-side management (DSM) measures, emphasizing a net TRC benefit cost ratio above 1.0 and simple payback periods. EfficiencyOne (E1) expresses concerns about delays in creating a step-change plan, while Paul Chernick and Mr. Pickles advocate for specific cost-benefit criteria. E1 has not yet presented a finalized implementation plan.

62382Closing Submission - Consumer Advocate 1 passage
THE IMPORTANCE OF DSM TO NOVA SCOTIA p. p. 0
THE IMPORTANCE OF DSM TO NOVA SCOTIA It is the view of the Consumer Advocate that an effective and robust DSM program is an important component in meeting the energy requirements of Nova Scotians. We continue to rely heavily on fossil fuel...

AI summary The Consumer Advocate emphasizes that DSM is crucial for Nova Scotia's energy needs due to reliance on fossil fuels and limited alternative sources. While renewable options like wind and hydro exist, they face cost, supply, or capacity challenges. DSM is highlighted as cost-effective, reducing demand cheaper than generation, though upfront costs concern ratepayers, particularly small businesses.

62386Final Submission - Ecology Action Centre 2 passages
MID-COURSE ADJUSTMENTS p. p. 4
MID-COURSE ADJUSTMENTS The ability to adjust to changing conditions is critical to effective energy efficiency programming. The planning cycle for a three-year agreement generally starts one to two years in advance of the threeyear cycle,...

AI summary The document highlights the importance of mid-course adjustments in energy efficiency programming to adapt to changing economic, technological, and consumer conditions. It argues that overly burdensome correction processes reduce flexibility and increase costs, emphasizing the need to quickly implement programs based on ongoing research for low-income renters.

DISCOUNT RATES p. pp. 4-5
DISCOUNT RATES EAC argues that too much attention has been paid in the current hearings to the issue of "unit cost" as a decision criteria among programs and measures. Cost per megawatt hour is a poor focus because of its lens on first-yea...

AI summary EAC argues that focusing on unit cost (e.g., cost per megawatt hour) in DSM program evaluations is flawed as it prioritizes first-year savings over lifetime benefits. They advocate using net present value with a societal discount rate (e.g., 3% as used by Vermont’s PSB in 2012) rather than utility-specific rates for broader societal cost-effectiveness screening.

62435Letter from counsel for NSPI re Board's letter of July 13 and Mr. Gogan's letter of July 9 1 passage
3. Mr. Pickles' memorandum is not new evidence p. p. 0
3. Mr. Pickles' memorandum is not new evidence In his memorandum, Mr. Pickles sets out his review of U-4 and states whether the documentation provided supports E1's position that its incentive levels are appropriate. Mr. Pickles' comments...

AI summary Mr. Pickles' memorandum is criticized by E1 for making inappropriate jurisdictional comparisons, but the response clarifies that his comments only reference E1's own comparisons to high-cost states. The memorandum is deemed not new evidence, as it does not introduce new facts or statistics but critiques E1's existing documentation. The Board's relaxed evidence rules are highlighted, allowing broad discretion in admitting evidence.

62458Rebuttal Submission - EfficiencyOne 3 passages
PLANNING HORIZONS p. pp. 9-11
sales sets Nova Scotia as a leader in DSM investment, not a "price leader". As Mr. Dunsky's benchmarking analysis demonstrated, Nova Scotia's DSM investment on a unit-cost basis is middle of the pack. 19 NS Power Closing Submission, Page 2...

AI summary The text discusses Nova Scotia's DSM investment compared to other regions, with NS Power and EfficiencyOne debating the reliability of benchmarking analysis. NS Power claims EfficiencyOne's plan is costly, while EfficiencyOne disputes the methodology's validity.

INCENTIVES p. p. 17
Exhibit E-46, EfficiencyOne Rebuttal Evidence, Page 14, Lines 8-16. 30 Transcript, June 16, Page 501, Line 13 to Page 504, Line 12. by E1, in contrast to this statement, the incentives appear to remain constant over the three-year period....

AI summary EfficiencyOne (E1) argues that incentives remain constant over three years, while the Industrial Group criticizes E1 for not analyzing incentive levels and payback periods. The Industrial Group highlights that 44 measures have payback periods under 12 months, with E1 offering up to 100% cost coverage. E1 clarifies its plan includes measure-specific incentives, not all aligned with RAM. The Industrial Group also questions if E1 has self-sustaining measures requiring no incentives.

REASONABLY AVAILABLE ENERGY EFFICIENCY p. p. 22
REASONABLY AVAILABLE ENERGY EFFICIENCY electricity efficiency and conservation activities that are reasonably available in an effort to reduce costs for its customers", not to "undertake all cost-effective electricity efficiency and conser...

AI summary EfficiencyOne's DSM Plan proposes Base-DSM energy savings at Low-DSM investment levels, not all cost-effective measures. The text distinguishes between 'reasonably available' and 'all cost-effective' DSM activities, citing a footnote.

62460Reply Submission - NSPI 1 passage
Section 6
DATE FILED: July 15, 2015 Page 4 of 32 1 CA Closing Submission, July 8, 2015, page 7. 2016-2018 Demand Side Management Resource Plan (M06733), Transcript, June 15, 2015, page 5-15. 1 It is noteworthy that this statement was not questioned...

AI summary The document discusses NS Power's recommendation for a Demand Side Management (DSM) plan that avoids capacity additions until 2032, arguing it is in customers' best interests. It also raises concerns about E1's potential self-interest in obtaining DSM funding, despite affordability concerns, and references a conflict of interest based on E1's incentive process.

62745Board Decision 11 passages
3.5.1 Program Development p. p. 0
he $53 million that was in rates for DSM in 2014 and which amount was subsequently repurposed by Order of the Board for 2015 fuel expenses. It expanded on these points in its post-hearing submission: - It is $69 million, or 38 percent. les...

AI summary The document discusses the repurposing of a $53 million DSM rate allocation from 2014 for 2015 fuel expenses, and how the proposed DSM investment level balances short and long-term affordability. It emphasizes the cost-effectiveness of the Mid-DSM scenario in the IRP and contrasts the proposed plan with NS Power's alternative, which relies heavily on energy savings from the BNI sector.

3.5.2 Incentives p. p. 0
3.5.2 Incentives [66] The Board, in its questioning of El's witnesses, and NSPI and the Industrial Group in their submissions, expressed significant concerns over the manner in which incentives are determined by El. It would appear from th...

AI summary The Board raised concerns about El's incentive design for DSM programs, noting over 60% of the budget is allocated to participants. Experts like Mr. Pickles and Mr. Drazen criticized the lack of justification and reasonableness in incentives, while NSPI argued El's plan lacks quantitative criteria and affordability analysis. Mr. Dunsky's testimony was favored, but concerns about incentive structure were acknowledged.

3.5.3 Affordability p. p. 0
an, as amended by the Board, meets the test of affordability. [79] The Industrial Group begins the discussion on affordability in its posthearing submission with the following very salient statement: The Industrial Group wishes to make it...

AI summary The Industrial Group emphasizes long-term risks over short-term affordability, while the DOE clarifies affordability in the PUA refers to upfront costs. NSPI and SBA focus on short-term customer affordability (up to five years). The DOE highlights that electricity efficiency activities require long-term cost-effectiveness assessments.

3.5.4 Relationship of the Proposed 201 6-18 DSM Plan to the 2014 Integrated Resource Plan p. p. 0
update in 2009. So I believe we filed a quote from the Terms of Reference for the 2009 IRP and it lists basically what we're trying to evaluate in doing the IRP. Bullet number three says: Develop and evaluate alternative plans in order to...

AI summary The 2016-18 DSM Plan aligns with the 2014 IRP's objective to achieve cost savings and emissions reductions. DSM's primary purpose is to support the IRP's goals, including saving customers money and reducing carbon emissions. Past programs like '08-'09 met their targets, demonstrating the effectiveness of DSM initiatives.

3.5.5 Cost Effectiveness Screening p. p. 0
3.5.5 Cost Effectiveness Screening [99] Although the Board has not approved the Quantum Agreement, Section 7 contains a provision which states as follows: Through collaboration within the DSM Advisory Group the parties agree to work to ach...

AI summary The Board has not approved the Quantum Agreement but acknowledges Section 7's provision for collaboration on DSM cost effectiveness screening methodology. The Board supports the process but maintains the existing TRC methodology unless a compelling case is made to abandon it.

3.5.6 Avoided Cost Analysis p. p. 0
3.5.6 Avoided Cost Analysis [101] Synapse, in its evidence, indicated that rate impact analysis should account for all factors that impact rates either positively or negatively, which would include avoided costs that might exert downward p...

AI summary The section discusses avoided cost analysis in regulatory proceedings, emphasizing the inclusion of avoided costs in rate impact analysis. Synapse highlights the need to consider factors like environmental compliance and transmission/distribution savings. E1 notes that locational DSM efforts can reduce capital investments, while NSPI expresses interest in exploring locational avoided costs. The Board encourages collaboration between parties on these issues.

4.0 LETTERS OF COMMENT AND PUBLIC SPEAKERS p. p. 0
4.0 LETTERS OF COMMENT AND PUBLIC SPEAKERS [129] The Board received 37 letters of comment from various persons, who wrote individually or on behalf of organizations. With only two exceptions, all were supportive of El and maintaining the a...

AI summary The Board received 37 letters of comment, mostly supporting El's DSM plan and advocating for increased efficiency spending. Environmental, economic, and low-income benefits were cited. At a public session, 21 speakers, including industry stakeholders and students, emphasized DSM's importance, warning of industry capacity loss if funding decreases. Most supported maintaining energy efficiency initiatives.

5.0 SUMMARY OF BOARD FINDINGS p. p. 0
aving considered the history of underspending on DSM programming, the history of overachieving savings and demand targets, and as an inducement to bring greater rigor to the calculation of incentives. [142] The Board considers that the tar...

AI summary The Board approves the DSM Plan, finding it achievable within approved spending, but rejects the Quantum Agreement. It emphasizes long-term cost considerations over short-term affordability, approves aspects of the Quantum Agreement, and endorses the Consensus Agreement with referrals to the DSM Advisory Group. The TRC cost-effectiveness screening remains in place.

7) COST-EFFEcTIVENESS TESTING p. p. 0
7) COST-EFFEcTIVENESS TESTING a) Through collaboration withIn the DSM Advisory Group, the parties agree to work to achieve consensus as to the methodology and assumptions of the cost-effectiveness screening test to be applied to future DSM...

AI summary Parties agree to collaborate with the DSM Advisory Group to establish methodology and assumptions for cost-effectiveness screening tests for future DSM Resource Plans, aiming for consensus on testing criteria.

9) PRINCIPLES OF EQUITY p. p. 0
9) PRINCIPLES OF EQUITY a) ALL ratepayers are entitled to an equitable opportunity to partIcipate in DSM programs. Lowincome tenants and homeowners as well as marginally viable commercial and industrial customers are some of the most diffi...

AI summary The text emphasizes that all ratepayers, particularly low-income and marginalized customers, must have equitable access to DSM programs. It highlights the need for services that address barriers faced by these groups and requires cost-effectiveness screening to consider additional costs of serving them.

1) ESTABLISHMENT OF A STANDARDIZED FILING FOR FUTURE APPLICAT IONS To APPROVE A DSM SUPPLY AGREEMENT p. p. 0
1) ESTABLISHMENT OF A STANDARDIZED FILING FOR FUTURE APPLICAT IONS To APPROVE A DSM SUPPLY AGREEMENT - a) The Parties agree to the establishment of a standardized filing for future applications, the substance of which will be vetted throug...

AI summary Parties agree to establish a standardized filing for future DSM supply agreement applications, vetted by the DSM Advisory Group. The filing includes program descriptions, energy savings metrics, cost-effectiveness analysis, and bill impact details, with EfficiencyOne allowed to add relevant information.

63105Compliance Filing 1 passage
COLLABORATION WITH NS POWER ON GEOTARGETING OF DSM p. p. 9
COLLABORATION WITH NS POWER ON GEOTARGETING OF DSM The Board encouraged collaboration between EfficiencyOne and NS Power with respect to avoided cost analysis and locational DSM efforts. EfficiencyOne and NS Power are in agreement to colla...

AI summary The UARB encourages collaboration between EfficiencyOne and NS Power on locational DSM efforts and avoided cost analysis. Both parties agree to explore reasonable locational DSM initiatives and develop locational avoided cost methodologies.

63106Supply Agreement 1 passage
1.2 Programs and Services Overview p. p. 47
1.2 Programs and Services Overview 5 7 8 4 The 2016-2018 Residential and Business, Non-profit and Institutional (BNI) programs are expected to include ongoing gradual evolution in order to address the following objectives: 9 10 11 12 13 -...

AI summary The 2016-2018 Residential and BNI programs aim to evolve by addressing market changes, research findings, and ensuring access across ratepayers. ENS plans 'Programs 2.0' to enhance customer experience through streamlined services, flexible support, and IT improvements, with implementation expected in 2016. The initiative seeks to maintain industry capacity stability and balance investments between sectors.

63292Supply Agreement EfficiencyOne and NSPI Form of Agreement Final Executed in Counterparts 1 passage
1. INTRODUCTION p. pp. 43-44
1. INTRODUCTION The 2016-2018 Demand-Side Management (DSM) Resource Plan has been developed based on ENS's growing experience and history in delivering successful DSM programs and services to Nova Scotians. As part of the process, ENS enga...

AI summary The 2016-2018 Demand-Side Management (DSM) Resource Plan outlines ENS's comprehensive suite of programs and services for Nova Scotia electricity users, developed with input from consulting firms. The Plan is not an implementation plan but a tool for planning and cost-effectiveness testing, with flexibility for mid-course adjustments based on market changes and stakeholder agreements.

63307Board Order 2 passages
2.2 Existing Residential p. p. 44
2.2 Existing Residential 19 20 21 22 23 24 25 26 The Existing Residential program is designed to help reduce electricity consumption for space and water heating and lighting. The goal is to promote cost-effective energy efficiency improvem...

AI summary The Existing Residential program aims to reduce electricity consumption for heating, lighting, and water heating in Nova Scotia's housing stock through cost-effective energy efficiency improvements. Services include rebates, financing, and low-cost product installations, with examples of recent initiatives like personal energy planners and property tax-based financing pilots. ENS manages the program, collaborating with contractors and municipalities.

1) ESTABLISHMENT OF A STANDARDIZED FILING FOR FUTURE APPLICATIONS TO APPROVE A DSM SUPPLY AGREEMENT p. p. 73
1) ESTABLISHMENT OF A STANDARDIZED FILING FOR FUTURE APPLICATIONS TO APPROVE A DSM SUPPLY AGREEMENT - a) The Parties agree to the establishment of a standardized filing for future applications, the substance of which will be vetted through...

AI summary Parties agree to establish a standardized filing for future DSM supply agreements, including energy savings metrics, cost-effectiveness analysis, and rate impact details. The DSM Advisory Group will vet the template, modeled on Efficiency Maine. EffidencyOne may add relevant information and provide technical data in its filings.

63791Grant Thornton Report - Financing Demand Side Management 6 passages
Potential financing alternatives and cost p. p. 5
and the requirement for a committed (as opposed to demand) structure from the successful lender(s), we suspect such upfront costs could be in the area of $500,000 - $700,000 (subject to negotiation of required standby fees if the full fina...

AI summary The text discusses potential financing alternatives for a DSM Plan, estimating upfront costs between $500,000 and $700,000, with considerations for standby fees and a 4% implied interest rate for cost-benefit analysis.

Preamble p. p. 11
- specifically, $38.5 million in 2016; $40.3 million in 2017; and $42.6 million in 2018. As well, - EfficiencyOne is proposing a three year contracted deliverable of cumulative energy and peak demand - savings. - Furthermore, EfficiencyOne...

AI summary EfficiencyOne is proposing a three-year DSM plan with cumulative energy and peak demand savings, regular reporting to the UARB and DSM Advisory Group, and a reserve fund to cover financial risks. They also request a change in cost-effectiveness testing methodology from TRC to PAC.

Summary of Quantum Agreement[4](#page-12-2) p. pp. 11-12
Summary of Quantum Agreement[4](#page-12-2) - On June 16, 2015, EfficiencyOne entered into an agreement ("Quantum Agreement") with the - Consumer Advocate, Small Business Advocate, Affordable Energy Coalition, and Ecology Action - Centre....

AI summary EfficiencyOne agreed with advocacy groups to reduce DSM investment from $121.5M to $113.5M (2016-2018), set energy/demand savings targets (405.9 GWh, 62.5 MW), and commit to consensus on cost-effectiveness screening methodology for future DSM plans.

Summary of Consensus Agreement[5](#page-12-3) p. pp. 12-13
- UARB Decision[6](#page-13-1) - On August 12, 2015, the UARB submitted its decision. A summary of the UARB's findings is as - follows: - The UARB did not approve the Quantum Agreement; however, it does approve an aggregate spending of $10...

AI summary The UARB approved an aggregate spending of $102.2 million for the EfficiencyOne DSM Plan, a 10% reduction from the Quantum Agreement. It also approved the Consensus Agreement, referring matters to the DSM Advisory Group and requiring EfficiencyOne to submit recommendations on incentive programs by March 31, 2016.

522 Summary of key observations p. p. 22
pportable and potentially closer to the lower end as opposed to the upper end of the range. This can only be validated through the initiation of a formal financing process, including management presentations, full legal documentation revie...

AI summary The text discusses the need for a formal financing process to validate the DSM Plan's cost range and enforceability, highlighting upfront costs for EfficiencyOne (e.g., legal fees, lender consultant fees) estimated at $500,000–$700,000. It emphasizes evaluating the cost-benefit of these fees against ratepayer savings via a 4% annual interest rate.

Summary of E1's proposed DSM plan 2016-2018 2 p. p. 34
Summary of E1's proposed DSM plan 2016-2018 2 E1's proposed plan calls for an investment of $121.5 million over a three year period – specifically, $38.5 million in 2016; $40.3 million in 2017; and $42.6 million in 2018. As well, E1 is pro...

AI summary E1's proposed DSM plan for 2016-2018 includes a three-year investment of $121.5 million, with regular reporting to the UARB and DSM Advisory Group. E1 is requesting a reserve fund to cover financial risks and a change in cost-effectiveness testing methodology from TRC to PAC.

63792E1 Covering Letter from E1 (Gogan) 1 passage
Section 1 p. p. 0
James R. Gogan Direct Dial: (902) 563-5920 E-Mail: [email protected] File No. 41736-18 November 13, 2015 Nova Scotia Utility & Review Board PO Box 1692, Unit "M" Halifax, Nova Scotia B3J 3S3 Attention: Doreen Friis, Regulatory Affairs...

AI summary EfficiencyOne submitted a Grant Thornton report on financing Demand Side Management (DSM) to the Nova Scotia Utility and Review Board. The Board had previously raised concerns about DSM financing during hearings, including impacts of commercial lending and deferral costs. The Board directed EfficiencyOne to explore cost-effective financing options outside NSPI's rate base following stakeholder input.

Disclaimer: These summaries were generated by AI from the filings they describe. We take care to make them accurate, but errors are possible - and they aren't advice. Only the filings themselves are the record: if you're relying on something here, confirm it against the source documents or the Nova Scotia Energy Board's own record. Full disclaimer →