Topic:"Cost Effectiveness" in M12249

1. INTRODUCTION Over the last two and a half years, EfficiencyOne (E1) has been successful in implementing its 2023-2025 Demand-Side Management ("DSM") Plan. The important work entrusted to E1 pursuant to the DSM Plan has achieved measurab...

AI summary EfficiencyOne (E1) has successfully implemented its 2023-2025 Demand-Side Management (DSM) Plan, achieving significant energy and demand savings. E1 seeks Energy Board approval for a 2026 DSM extension and amendments to the DSM Purchase Agreement, aligning with new legislative changes and the Energy Board's expanded mandate focused on sustainability and emissions reduction.

1.2 GUIDING PRINCIPLES In developing the 2026 DSM Extension, E1 followed the same guiding principles as those which informed the 2023-2025 DSM Plan development: transparency, accessibility and equity. In terms of transparency, E1 is commit...

AI summary E1's 2026 DSM Extension adheres to transparency, accessibility, and equity principles. It maintains performance targets from the 2023-2025 DSM Plan, collaborates with the DSMAG, and allocates 20.2% of investments to low-income and equity communities through specific programs. Legislative changes creating a dedicated Energy Board and a proposed Benefit Cost Analysis Framework also influence the plan.

1.3 DESIGN OBJECTIVES E1's overarching objectives in developing the 2026 DSM Extension were as follows: - a) program continuity with the 2023-2025 DSM Plan; - b) achievability of performance targets; - c) continued cost-effectiveness; and...

AI summary E1's 2026 DSM Extension objectives include program continuity, achievable targets, cost-effectiveness, and balance. It maintains 50/50 residential-BNI investment splits but reduced low-income equity investment to 15-20% (from 17-22%) due to updated census data showing fewer low-income Nova Scotians.

1.7 EXISTING BOARD APPROVED COST-EFFECTIVENESS TEST - E1 has applied the current NSUARB-approved cost-effectiveness test to the 2026 DSM Extension as the - 2023-2025 DSM Plan the Total Resource Cost (TRC). This test compares inputs (costs...

AI summary The NSUARB-approved Total Resource Cost (TRC) test was applied to the 2026 DSM Extension, yielding a cost-effectiveness ratio of 1.6, exceeding the 1.0 threshold under the Public Utilities Act (PUA). E1 plans to propose a new benefit-cost analysis framework for the 2027-2031 DSM Plan to the Energy Board in Q2 2025.

2.4 APPLICATION FOR NEW COST-EFFECTIVENESS TEST E1 is always seeking to maximize value for ratepayers in its DSM planning. As a vital input for DSM planning, how this value is measured is of critical importance. In Q2 of 2025, E1 will be f...

AI summary E1 seeks approval for a new benefit-cost analysis test to enhance DSM planning, ensuring value for ratepayers. The test, to be filed in Q2 2025 with the Energy Board, will inform future DSM activities and the 2027-2031 DSM Plan. Timely resolution is emphasized for logistical planning benefits.

3.2 UPDATES TO AVOIDED COST CALCULATION In its decision approving the 2023-2025 DSM Plan, the NSUARB (as it then was) made note of the fact that updates to NS Power Integrated Resource Planning process will have an impact on the avoided co...

AI summary The NSUARB directed E1 to update avoided cost calculations for DSM plans using the latest IRP data, noting climate goals are not fully addressed in current IRP versions. E1 incorporated 2022 IRP results, embedding carbon costs into energy avoided costs for the 2026 DSM Extension. The DSMAG will address climate-related updates for future plans, while the More Access to Energy Act mandates IESO's IRP process.

Avoided costs of both energy and capacity were based on NS Power's Evergreen IRP and avoided costs of transmission and distribution were provided by NS Power, both provided to the DSMAG on August 23, 2024. Avoided costs of carbon are embed...

AI summary The text discusses avoided costs of energy, capacity, transmission, and distribution based on NS Power's Evergreen IRP, and how they are used in cost-effectiveness calculations for energy efficiency (EE) and demand response (DR) programs. It also highlights the collaboration required between E1 and NS Power for DR benefits and the use of various metrics like TRC and PAC for evaluating program performance.

5. ONGOING COMPLIANCE WITH BOARD DIRECTIVES As always, E1 remains committed to complying with all Board directives. - Several directives from the 2023-2025 DSM Plan Decision relate to, and contemplate, the next complete - DSM Plan filing (...

AI summary E1 commits to complying with Board directives from the 2023-2025 DSM Plan Decision, proposing that certain directives be addressed in the 2027-2031 DSM Plan application, including providing individual justification for cost-ineffective measures and including payback information. Other directives are already being incorporated.

7. CONCLUSION - The 2026 DSM Extension Application is a filing brought about through recently enacted legislative - amendments to the Public Utilities Act which; - (1) extends the demand-side management purchase agreement approved by the B...

AI summary The 2026 DSM Extension Application seeks to extend the existing DSM Plan until 2026 under new PUA amendments, proposing energy and demand savings targets. The extension aligns with legislative intent, maintains program continuity, and meets cost-effectiveness criteria with a TRC of 1.6. E1 requests Board approval for the extension.

2.5 MODELLING APPROACH - For the 2026 DSM Extension, E1 utilized the same modelling process and software tools as in the approved - 2023-2025 Plan. Modelling supports quantitative development by providing the following: - detailed cost eff...

AI summary E1 used the same modelling approach and software tools as in the approved 2023-2025 Plan for the 2026 DSM Extension. The modelling supports quantitative analysis through cost-effectiveness impacts, energy/demand impacts, DSM participation estimations, and investment projections.

1 2.5.2 D EM AN D RESPON SE M OD EL - 2 As with the energy efficiency model, E1 worked with Guidehouse to complete demand response modelling - 3 using Guidehouse's DRSim™ model. This modelling approach was consistent with the approach used...

AI summary E1 collaborated with Guidehouse to develop a demand response model using DRSim™, aligning with their 2023-2025 DSM Plan. The model uses bottom-up analysis with primary and secondary data, segmenting customers, defining DR options, and estimating cost-effectiveness.

2.5.5 D SM AG EN GAGEMEN T The DSMAG is a forum to provide strategic or directional advice on current or emerging DSM issues including development of future DSM applications and plans. In developing the 2026 DSM Extension, E1 engaged the D...

AI summary The DSMAG provided strategic advice on DSM issues, engaging stakeholders for the 2026 DSM Extension. Engagement was limited due to February 2025 legislative amendments requiring a one-year extension to the 2023-2025 Plan. E1 led a comprehensive process for the 2026-2030 Plan, including stakeholder feedback and BCA development, with continued engagement planned for the 2027-2031 Plan.

3.4 PROGRAMS SAVINGS, INVESTMENT & PARTICIPATION - Programs for the 2026 DSM Extension remain largely the same as the approved 2023-2025 Plan, with - some changes and enhancements noted below[. Table 5](#page-56-0) provides investment budg...

AI summary The 2026 DSM Extension programs largely mirror the approved 2023-2025 Plan with some updates. Table 5 details investment budgets and savings targets by program component, focusing on demand-side management and efficiency initiatives.

- 3 Cost-effectiveness results are provided for two cost effectiveness tests the Total Resource Cost (TRC), - 4 Program Administrator Cost (PAC). The TRC test compares the costs incurred to design and deliver - 5 programs and customers' co...

AI summary The document discusses cost-effectiveness tests used in Nova Scotia, including the Total Resource Cost (TRC) and Program Administrator Cost (PAC) tests. E1 plans to develop a new jurisdiction-specific BCA test for the 2027-2031 DSM Plan, following directives from the NSUARB and collaboration with the DSM Advisory Group.

Appendix A Attachment 1: DSMAG Electricity System Avoided Costs Summary Document

AI summary Attachment 1 of Appendix A presents the DSMAG Electricity System Avoided Costs Summary Document, focusing on cost calculations related to demand-side management initiatives. The document is part of a regulatory proceeding involving Nova Scotia utility regulations and cost recovery mechanisms.

1. ISSUE - The purpose of the avoided costs discussion with the Demand Side Management Advisory Group (DSMAG) - was to achieve the following deliverable as described in the DSMAG Terms of Reference: - " Developing a methodology and process...

AI summary The document discusses the need to update avoided costs methodology for DSM planning, noting unresolved issues from NS Power's 2024 work using the 2022 IRP Update. E1 uses these costs for the 2026 DSM Extension but emphasizes resolving remaining issues to ensure updated costs are incorporated into the 2027-2031 DSM Plan.

2. BACKGROUND - On September 28, 2023 the initial session on avoided costs was held with the DSMAG. Since that session - the following activities have occurred: - Sept 28, 2023: DSMAG Session NS Power reviewed their methodology for calcula...

AI summary The document outlines a timeline of activities related to NS Power's avoided costs methodology discussions with the DSMAG from September 2023 to April 2025. Key events include presentations, comment submissions from entities like DNRR, Synapse, and E1, and iterative feedback sessions. The process involves refining avoided cost calculations for transmission, distribution, energy, and capacity.

10 3. AVOIDED COSTS USED BY E1 FOR 2026 DSM EXTENSION

AI summary The document discusses avoided costs utilized by E1 for the 2026 DSM extension, focusing on demand-side management strategies and their financial implications.

18 Cost Effectiveness Screening : - 19 A. For modelling of the 2026 DSM Extension, the Total Resource Cost (TRC) test, and Program 20 Administrator Cost (PAC) test, have been provided. - 21 B. Cost effectiveness testing has been performed...

AI summary The 2026 DSM Extension uses TRC and PAC tests for cost effectiveness screening. Energy efficiency and demand response programs underwent testing, with E1 noting some avoided cost streams are non-material to models.

AVOIDED COSTS USED IN 2026 DSM EXTENSION MODELS

AI summary The document discusses the use of avoided costs in 2026 Demand-Side Management (DSM) extension models, focusing on regulatory considerations in Nova Scotia. Key entities include Nova Scotia Utility and Review Board (NSUARB), Nova Scotia Power (NSP), and related programs like DSM Cost Recovery Rider (DCRR).

1. AVOIDED COSTS OF ENERGY

AI summary The section heading indicates a focus on avoided costs of energy, but no detailed content is provided in the given text.

3. AVOIDED COSTS OF TRANSMISSION & DISTRIBUTION (T&D)

AI summary The section discusses avoided costs related to transmission and distribution, focusing on regulatory considerations and stakeholder analyses. Key entities include Nova Scotia Utility and Review Board (NSUARB) and Demand-Side Management (DSM) programs, with emphasis on cost recovery mechanisms and benefit-cost ratios.

A. Energy Efficiency ProCESS Model - E1 understands from NS Power that the avoided costs of carbon (electric utility compliance costs) are - embedded in the avoided costs of energy that NS Power calculated for the Evergreen IRP No Atlantic...

AI summary E1 used avoided energy costs (including embedded carbon costs) from NS Power for the 2026 DSM Extension, without modeling separate carbon costs. Avoided energy costs were not included in demand response cost-effectiveness testing. The same RBIA approach as energy efficiency programs was applied for the 2026 DSM Extension.

forward until 2041, when the modelled impacts of 2026 measures expire. These results offer a frame of reference for considering the appropriate balance of these impacts across electricity customers. The 2026 DSM Extension RBIA compares the...

AI summary The 2026 DSM Extension RBIA compares scenarios with and without DSM, analyzing rate and bill impacts on non-participants. It isolates DSM effects from utility factors, focusing on affordability and long-term trends. Key outputs include non-participant bill impacts and cost-effectiveness testing to assess overall customer benefits.

2. INTRODUCTION The forward-looking RBIA is an analysis of the rate and bill impacts associated with the proposed DSM investment only. The forward-looking rate and bill impact analysis associated with a DSM Plan or Extension Application co...

AI summary The document discusses forward-looking and historical Rate and Bill Impact Analysis (RBIA) for Demand-Side Management (DSM) investments. It outlines E1's proposed elimination of historical RBIA filings except during DSM Plan Application years, with the NSUARB accepting this approach. The next historical RBIA is scheduled for the 2027-2031 DSM Resource Plan Application.

3.2 OVERALL BILL IMPACTS Generally speaking, ratepayers that participate in DSM programs directly benefit by reducing their electricity consumption and thereby lowering their electricity bills. Together, the level of reduced consumption (o...

AI summary DSM programs reduce electricity bills for participants by 0.1-8.8% (2026-2041), while non-participants see minimal increases (+0.1-0.4%). Total customer savings range from -1.1 to -0.1%. Net savings for Nova Scotia ratepayers are $74 million due to reduced revenue requirements from DSM programs implemented in 2026.

ot been modelled. Users can also adjust the Avoided Cost Scenario relative to the DSM Benchmark avoided cost assumptions in tab 'COSS Outputs 1". Users have the option to select cost scenarios of 75%, The savings presented in the NS Power...

AI summary The NS Power rate model allows adjusting the Avoided Cost Scenario relative to the DSM Benchmark. Savings in the 'Total-Savings(Added)' tab depend on selected DSM resources in the 'E1 Data Inputs' tab. If all DSM resources are selected, no savings are shown, but avoided costs from unselected resources are added to NS Power's revenue requirement.

5. AVOIDED COSTS - Avoided costs are calculated at the system level using evaluated DSM savings and avoided cost - rates in four categories: generation, transmission, distribution, and energy. Avoided costs used - for the 2026 Extension an...

AI summary Avoided costs are calculated system-wide using DSM savings and rates across generation, transmission, distribution, and energy categories. Data for the 2026 Extension and RBIA are detailed in Appendix A, Attachment 1.

"Total-Savings" tab The "Total-Savings" tab provides a sum of annual class savings in energy and demand usage at the generator's gate and customer's meter. In addition, class demand savings at the high side of the bulk power substation are...

AI summary The 'Total-Savings' tab calculates annual energy and demand savings at the generator's gate, customer's meter, and bulk power substation. It details methods for determining avoided fuel, generation, transmission, and distribution costs, distinguishing between FAM-related and non-FAM-related calculations.

Schedule B (Page 1 of 2)

AI summary Schedule B of a Nova Scotia regulatory proceeding outlines a document involving energy efficiency, demand response, and cost recovery mechanisms. Key entities include Nova Scotia Power, EfficiencyOne, and regulatory bodies like the NSUARB. Topics focus on DSM programs, benefit/cost ratios, and compliance with the Public Utilities Act.

ar resource plans, but these are usually only relevant for the next few years; then they are replaced by another 20 or 30-year plan. So, the operative part a resource plan is typically only 3-5 years. long term, otherwise we may make the w...

AI summary The document emphasizes the need for long-term resource planning, modifying least-cost strategies to account for climate change, reversing economic discounting methods, and the importance of resilience and disaster preparedness in energy systems. It references Efficiency Nova Scotia's 2021 whitepaper and cites footnotes for further reading.

A. Appliance Retirement Program (ARet) The Appliance Retirement (ARet) program is one of two program components of the Residential Efficient Product Rebates program. Appliance Retirement advances the retirement of old, inefficient full siz...

AI summary The Appliance Retirement (ARet) program retires inefficient appliances (refrigerators, freezers, air conditioners) via rebates and free removal, retiring 77,696 units since 2012. Participants must own working appliances over 10 years old; certain appliances require co-retirement with full-sized units. ARCA Canada Inc. handles collection and recycling. Rebates range from $10–$50 per appliance. Efficiency Nova Scotia adjusted criteria post-2016 to boost participation and cost-effectiveness.

Recommendations SVR2024-Demand Response – 13 . In the next evaluation, include an analysis of the relative importance or lack of importance to the possible capacity shortfall problem to Nova Scotia Power, the roles of the load research sho...

AI summary The document recommends evaluating Demand Response (DR) programs' impact on Nova Scotia Power's capacity shortfall, clarifying their practical benefits beyond learning experiences, and justifying their business case. It critiques DR programs for minimal kW demand reduction and calls for analysis of whole-home vs. device-level approaches in residential DR. A citation to Econoler's report is included.

4. BNI Demand Reduction Programs SVR2024-Demand Response – 13 . In the next evaluation, include an analysis of the relative importance or lack of importance to the possible capacity shortfall problem to Nova Scotia Power, the roles of the...

AI summary The text requests an evaluation of BNI Demand Response programs, emphasizing the need to analyze their impact on Nova Scotia Power's capacity shortfall, clarify their practical benefits, and justify their business case. It criticizes the programs' weak demand reduction effects and calls for a comparison of whole-home vs. device-level approaches in residential analysis.

Practice Manual, For Benefit-Cost Analysis of Distributed Energy Resources, 2020. Uniform Methods Project Uniform Methods Project Refrigerator Recycling Evaluation Protocol. See: [http://www.nrel.gov/docs/fy17osti/68563.pdf.](http://www.nr...

AI summary The document references Uniform Methods Project (UMP) protocols for evaluating distributed energy resources, including refrigerator recycling, residential lighting, and behavior. Protocols were prepared by organizations like The Cadmus Group and Apex Analytics, with contributions from individuals such as Doug Bruchs and Scott Dimetrosky. These resources support benefit-cost analysis in energy efficiency initiatives.

1 Request IR-01: 2 3 Please file the 2026 DSMAG Extension PowerPoint presentation from April 22, 2025. 4 5 Response IR-01: 6 7 Please refer to EfficiencyOne's response to part (b) of Synapse IR-04. Date Filed: June 25, 2025 E1 (IG) IR-01 P...

AI summary The document outlines three requests (IR-01 to IR-03) and responses related to EfficiencyOne's (E1) 2026 DSMAG Extension. Key issues include lower performance targets compared to the 2023-2025 DSM Plan, justification for higher investment with lower targets, and clarification on negative demand response benefit numbers. E1 confirms the understanding and refers to prior responses for detailed justifications.

(e.g., solar-PV and strategic Nova Scotia Legislature - Bill 228 - [Public Utilities Act (amended) -](https://nslegislature.ca/legc/bills/64th_1st/3rd_read/b228.htm) RA electrification) and additionalsupport for development of a five-year...

AI summary Legislative amendments extended the Board-approved DSM Plan to 2026, requiring E1 to file 2026 performance targets. Incremental costs arose from developing the 2026 DSM Extension and the new 2027-2031 DSM Plan. The NSUARB directed E1 to develop a cost-effectiveness methodology, leading to unexpected costs not included in the original 2023-2025 Plan. Flow-through costs from regulators, advocates, and consultants increased due to legislative changes and BCA development.

ants, Consumer Advocate and their consultants, and the Small Business Advocate and their consultants have also increased as a result of both the legislative changes and the development of the new BCA. Bill 6 - An Act Respecting Agriculture...

AI summary E1 forecasts a $1.8M increase in costs for DSM Plan development and BCA activities due to legislative changes and process complexities, requiring cost offsets within NSUARB-approved investment levels. References include Bill 6, the Public Utilities Act, and NSUARB Decision M10473.

Date Filed: June 25, 2025 E1 (IG) IR-10 Page 2 of 2 1 Request IR-11: 2 3 Reference: Page 23, Table 5: 2026 Program Savings and Investment. 4 5 (a) Please confirm that the residential energy efficiency programs cumulatively do not pass 6 th...

AI summary The document outlines a request and response regarding the total resource cost (TRC) test for residential energy efficiency and demand response programs. It confirms that residential programs have a cumulative TRC ratio of 0.9 and demand response programs have a ratio of 0.7. The response explains that individual program-level TRC tests are not required due to legislative requirements under the Public Utilities Act, and that the overall DSM portfolio meets the TRC threshold at 1.6.

1 Request IR-12: 2 3 Reference: Page 24 4 5 (a) Please confirm that the two directives (e) and (f) were two recommendations of the 6 Industrial Group in matter M10473. 7 8 (b) Please confirm that there is nothing explicit in these directiv...

AI summary Request IR-12 asks EfficiencyOne (E1) to confirm directives from the Nova Scotia Utility and Review Board, clarify compliance with multi-year plans, and provide details on cost-effectiveness testing and payback periods for measures in the DSM Plan. E1 responds that directives align with Industrial Group recommendations and that the 2026 DSM Extension is a continuation of the 2023-2025 plan.

Date Filed: June 25, 2025 E1 (IG) IR-12 Page 2 of 4 M10473, E1 2023-2025 Demand Side Management (DSM) Resource Plan, Board Decision, page 65, Directives (e) and (f), November 8, 2022 M10473 M10473, E1 2023-2025 Demand Side Management (DSM)...

AI summary The document references E1's 2023-2025 DSM Plan and discusses updates in the 2026 DSM Extension model, noting changes in naming conventions, data sources, assumptions, and methodologies. It emphasizes that the new model is a separate exercise and that prior cost effectiveness test results are not directly comparable to current results.

(c) Please see part (b) of this IR response. 1 Request IR-22: 14 i) For the Societal Cost Test values, please explain what societal costs and benefits 15 have been included. 16 17 Response IR-23: 18 19 (a) The 2026 Extension Demand Respons...

AI summary The response to a request for explanation on societal cost test values indicates that the DRSim software does not support the specific output required for '19b. BC Ratios Cost categories' and 'BCA by Cost Category' tabs with rate class information. However, the software does include traditional cost-effectiveness tests, and EfficiencyOne has validated these for use in Nova Scotia.

4 5 The requested cost-effectiveness results are not performed within the excel workbook 6 referenced; rather they are performed by Guidehouse's proprietary DRSim model and the 7 excel workbook contains the results of that analysis. While...

AI summary The requested cost-effectiveness results are generated using Guidehouse's proprietary DRSim model rather than the referenced Excel workbook. E1 has provided general formulas for the TRC and PAC tests in demand response and confirmed that results are available in Appendix A, Attachment 4.

1. BACKGROUND In 2024, NS Power led the development of electric utility avoided costs using the 2022 Evergreen Integrated Resource Plan (IRP) Update. While E1 has used the avoided costs resulting from this development work as provided on A...

AI summary NS Power developed electric utility avoided costs using the 2022 Evergreen IRP Update. E1 utilized these costs but highlights unresolved issues that must be addressed to incorporate updated avoided costs into the 2027-2031 DSM Plan. Resolving these issues is critical for future DSM planning.

3. ANNUAL NEW WIND MODELLING CONSTRAINT E1 reviewed the annual amount of new wind resources built in each year by scenario, as shown in Figure 1. Apart from planned wind projects expected to be online by 2026, E1 understands an annual new...

AI summary E1 reviewed annual new wind build rates under different scenarios, noting a 200 MW/yr cap in most scenarios except No DSM, which allows 400 MW/yr. This difference likely caused a dip in avoided costs from 2029-2035. E1 emphasizes applying consistent constraints across all scenarios to ensure meaningful avoided cost results.

5. COMPARISON OF 2021 TO 2024 AVOIDED COSTS 2 2022 Evergreen IRP Updated Assumptions – Revised January 2023. Slide 12. January 26, 2023. E1 assessed the differences in avoided costs between the previous 2021 avoided costs (developed from t...

AI summary E1 compared NS Power's 2021 and 2024 avoided costs, noting that 2024 includes an embedded carbon cost absent in 2021. Annual avoided costs, not levelized values, were used for DSM Plan modeling. Figures 3 and 4 illustrate comparisons, with adjustments for CPI and carbon inclusion.

Discussion of 2021 and 2024 avoided cost results: Energy and carbon combined ( Figure 3 ) : - When assessing the 2026-2045 period, average avoided costs have decreased 11% compared to 2021 and decreased 15% compared to the 2021 CPI adjuste...

AI summary The document discusses avoided costs for energy and carbon from 2021 and 2024 analyses, noting an 11% decrease in average avoided costs by 2026-2045 compared to 2021 and a 15% decrease compared to 2021 CPI-adjusted costs. Energy avoided costs show fluctuations, peaking in 2028 and dipping in 2031. The text requests NS Power to provide estimates of the embedded avoided cost of carbon and explain calculations.

6. EMBEDDED AVOIDED COST OF CARBON WITHIN AVOIDED COST OF ENERGY At the direction of the Nova Scotia Utility and Review Board (NSUARB), in 2024 E1 initiated a process led by Energy Futures Group (EFG) to assess and develop an optimal DSM c...

AI summary E1, under NSUARB direction, is developing a DSM methodology with EFG, aiming to file a BCA application in 2025. The BCA test includes GHG emissions' societal impacts, requiring subtraction of embedded carbon costs from avoided energy costs. NS Power's OBPS carbon tax is referenced as reflecting marginal carbon costs, influencing the embedded carbon price calculation.

7. MARGINAL LINE LOSSES As part of E1's BCA work completed with EFG in 2024 it was identified that for the purposes of costeffectiveness testing it is appropriate to use marginal rather than average line losses. The concept of marginal lin...

AI summary The document discusses the debate over using marginal vs. average line losses in Nova Scotia's regulatory proceeding. E1, EFG, and Synapse advocate for marginal line losses as best practice, while NS Power expresses concerns about aggregating them over time series. NS Power is conducting a line loss study to address these issues, but E1 remains concerned about NS Power's reluctance to engage on this methodology.

Observations: - There are some years where the on-peak winter avoided cost of energy is lower than the offpeak winter avoided costs (2031, 2032, 2034, 2035, 2036, 2037, 2041, 2042, 2047). The difference is as much as $43/MWh (2036). - Ther...

AI summary The text highlights years where on-peak winter avoided energy costs are lower than off-peak winter costs and non-winter periods, with a maximum difference of $43/MWh in 2036. Such discrepancies occur in multiple years, including 2029, 2031, and others, indicating irregularities in cost patterns across seasons and times.

9. ADDITIONAL SYSTEM IMPACTS OF DSM As part of its May 13, 2024 comments E1 requested information on additional system impacts that had either (a) been identified through E1's BCA workshops or (b) been identified as additional use cases fo...

AI summary E1 requested quantification of system impacts (credit, risk, reliability) and additional demand response use cases. NS Power cited the Smart Grid project but used 2021 DSM avoided costs as a proxy, which E1 deems insufficient. E1 seeks specific references and characterization of new use cases for program design.

10.RESPONSE TO SYNAPSE'S COMMENTS FROM JULY 22, 2024 As part of its July 22, 2024 comments, Synapse made the following comment: "The Smart Grid Nova Scotia pilot involved installation and implementation of utility-controlled, behindthe-met...

AI summary Synapse highlighted the Smart Grid Nova Scotia pilot's high costs relative to benefits, urging E1 to consider control differences and incentive alignment with SGNS. E1 clarified that avoided costs apply only to applicable demand response programs, emphasizing control strategies and DRMS implementation for flexibility.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL 1 • Updates to measure characterizations and cost assumptions for the Affordable Multi 2 Family Housing and Home Energy Assessment program components in...

AI summary E1 notes that updates to residential energy efficiency programs, including Affordable Multi-Family Housing and Home Energy Assessment, have reduced TRC results for 2026. The removal of Appliance Retirement and Green Heat programs, which had higher TRC results in prior plans, further contributed to this reduction. Some measures show reduced energy savings or increased costs.

15 Demand Response Programs 13 a 13.5% increase in incremental cost. 16 In comparing the 2023-2025 DSM Plan Total Resource Cost (TRC) cost results of Demand 17 Response (DR) to the 2026 DSM Extension TRC results, (E1) makes the following o...

AI summary EfficiencyOne (E1) notes a 56% decline in unitary savings and methodological changes in the 2026 DSM Extension compared to the 2023-2025 plan, including a one-year DR activity period and adjusted CET timespan. The application for approval is referenced as M12249.

M12249 – EfficiencyOne (E1) Application for Approval of the 2026 DSM Extension 1 o As DR programs scale-up, fixed costs will be spread over more capacity 2 (benefits). Some variable costs will also come down as programs scale-up and 3 cont...

AI summary EfficiencyOne (E1) argues that as demand response (DR) programs scale up, fixed and variable costs will decrease, and additional use-cases may emerge. E1 also plans to explore program improvements with peers and consider Nova Scotia-specific impacts. However, E1 did not comply with certain Board directives in its current filing, including providing individual justification for measures failing the cost effectiveness test.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL 1 indicating that the measure provides net benefits to the utility system and 2 ratepayers. o Energy audit measures have a TRC ratio of 0 due to a lack o...

AI summary E1 argues that energy audit measures, despite a TRC ratio of 0, drive customer awareness and support program participation. Instant Savings measures with TRC ratio 1.0 are justified by customer satisfaction, market needs, and PAC Test results exceeding 1.0, indicating net benefits to the utility system and ratepayers. New measures are evaluated for long-term impacts under the 2026 DSM Plan.

1 Request IR-03: 2 3 (a) Is the Benefit Cost Ratio for the Application evaluated at the total DSM Plan level only? 4 5 (b) How many of the constituent programs, within the DSM Plan, have a Benefit Cost Ratio 6 of 1.0 or lower? 7 8 (c) What...

AI summary The response to Request IR-03 discusses the evaluation of the Benefit Cost Ratio for the DSM Plan, noting that two DSM programs have a TRC lower than 1.0. It also identifies specific programs with TRC below 1.0, their customer focus, and their percentage of the total DSM Plan investment.

2026 DSM Extension Application to the Date Filed: June 25, 2025 REDACTED Synapse IR-04, Attachment 1, Page 3 of 19 Energy Board - Developed as a continuation year of the 2023-2025 DSM Plan per the legislation and not a stand-alone DSM Plan...

AI summary The 2026 DSM Plan extension application aligns with the 2023-2025 plan, using updated assumptions and existing NSUARB-approved TRC tests. E1 proposes a streamlined regulatory process and seeks approval for adjusted performance targets. No new resources like solar-PV will be introduced.

Support for Residential Customers – Efficient Products Rebates

AI summary The document discusses Nova Scotia Power's (NSP) Efficient Products Rebates program, administered by EfficiencyOne (E1), aimed at supporting residential customers through energy-efficient product incentives. The Demand Side Management Advisory Group (DSMAG) recommended the program, which must pass the Total Resource Cost Test (TRC) and Program Administrator Cost Test (PAC) for approval.

Appliance Retirement • E1 ended Appliance Retirement on January 8, 2025. This was influenced by several considerations. Delivery costs were rising, and savings were declining as eligible units being retired were newer and more efficient. T...

AI summary E1 terminated the Appliance Retirement program on January 8, 2025, citing rising delivery costs, declining savings from retiring newer efficient units, and limited service providers in Canada.

Support for Residential Customers – Existing Residential (con't)

AI summary The document section continues discussing support for existing residential customers, involving EfficiencyOne, Nova Scotia Power, and the Demand Side Management Advisory Group. Key considerations include the Total Resource Cost Test and Program Administrator Cost Test.

E1 Responses to Synapse Energy Economics (Synapse) Information Requests NON-CONFIDENTIAL 1 (c) The avoided costs used to calculate the Lifetime Benefits (TRC and PAC), TRC ratios and PAC 2 ratios for 2026 in the 2026 DSM Extension were dev...

AI summary EfficiencyOne (E1) outlines that Nova Scotia Power (NSP) provided avoided cost data for TRC and PAC calculations to the DSMAG in 2024 and 2021, using the 2022 and 2020 IRP updates respectively. Updated transmission/distribution avoided costs were shared in 2024, developed outside the 2022 IRP modelling. References to matter numbers M12249 and M10473 are included.

Table 2: Efficient Products Installation – Lighting Efficient Product Installation - Lighting 2023 Actuals 2024 Actuals 2025 Forecast 2026 Extension Investment ($M) $0.9 $0.9 $0.7 N/A Lifetime Benefits ($M) a $ 1.85 $ 0.67 $ 0.27 N/A Light...

AI summary Table 2 outlines the Efficient Products Installation – Lighting program's investment, benefits, and energy savings for the years 2023 to 2026. It also notes that EfficiencyOne cannot retroactively perform cost-effectiveness testing due to a lack of verified customer and utility avoided costs.

M12249 – EfficiencyOne (E1) Application for Approval of the 2026 DSM Extension

AI summary EfficiencyOne (E1) seeks approval for the 2026 DSM extension, subject to Total Resource Cost (TRC) and Program Administrator Cost (PAC) tests, with Nova Scotia Power (NSP) and the Demand Side Management Advisory Group (DSMAG) involved. The Nova Scotia Utility and Regulatory Board (NSUARB) will evaluate the application.

(c) The phase out of LED lighting in the residential sector due to the LED baseline shift in 2025 only impacts Instant Savings and Efficient Product installation program components. & lt;sup>b EfficiencyOne (E1) is not able to retroactivel...

AI summary The phase out of LED lighting in the residential sector due to the LED baseline shift in 2025 only affects Instant Savings and Efficient Product installation programs. EfficiencyOne (E1) cannot retroactively perform cost-effectiveness testing due to a lack of verified customer and utility avoided costs.

Table 1: Breakout of 2026 Residential Low-income and Equity Subtotal - 40010 21 21 24 04 10 41 0 0 20 20 11001 G = 9 G. 1 C / C 2026 Investment ($ million) Lifetime Benefits ($ million) First Year Energy Savings (GWh) Lifetime Energy Savin...

AI summary The table provides a detailed breakdown of the 2026 residential low-income and equity programs, including investments, lifetime benefits, energy savings, and cost tests. The data highlights the financial and energy efficiency impacts of various initiatives aimed at supporting low-income households and promoting equity.

b EfficiencyOne (E1) is not able tot retroactively perform cost-effectiveness testing. E1 does not have verified customer costs or verified utility avoided costs, both of which are required to retroactively perform cost-effectiveness scree...

AI summary EfficiencyOne (E1) is unable to perform retroactive cost-effectiveness testing due to a lack of verified customer costs and utility avoided costs. The 2026 DSM Extension application is referenced, and lifetime ratepayer benefits are calculated based on avoided costs from the 2023-2025 DSM Plan.

EfficiencyOne (E1) Responses to Industrial Group (IG) Information Requests NON-CONFIDENTIAL with associated electrical and non-electrical savings is provided in the 2024 Existing Residential Evaluation Report[1](#page-2-0) 2 . 3 (b) The ap...

AI summary EfficiencyOne (E1) responds to Industrial Group (IG) information requests, stating their evaluation approach does not rely on cost-effectiveness tests. They reference the 2024 Existing Residential Evaluation Report and clarify that cost-effectiveness testing aims to assess program value, not distinguish electricity ratepayer portions from other funding sources.

tor stalled over a whole summer and into the fall, failing to make good on the guarantee. We reported the issue to the DSM administrator, and Efficiency Nova Scotia followed up with the contractor and 1 the heat pumps were replaced within...

AI summary A contractor's delay in replacing heat pumps led to Efficiency Nova Scotia (E1) intervening to resolve the issue. E1 emphasizes using annual verification reports to evaluate program effectiveness, flagging underperforming initiatives for redesign or cancellation. Responses to information requests clarify E1's limited role in developing a new Benefits Costs Analysis (BCA) test and propose enhancing program evaluation processes.

Response IR-2-a: - We are not recommending the evaluation consultant flag any of the programs for closing. We are - recommending the flagging of any exceptionally weak program that appears not to be returning - practical value at the custo...

AI summary The response outlines a framework for evaluating demand-side management programs, stating that only exceptionally weak programs with insufficient energy savings or demand reduction should be flagged for closure. Programs below a reasonable performance threshold should be improved or cancelled to enhance productivity relative to investment.

- Advocate in assessing the impacts of utility energy efficiency plans and delivery 1 strategies on customers. I have also evaluated DSM program efforts in New 2 Brunswick, New Mexico, Prince Edward's Island, Ontario, Vermont, Hawaii, 3 Ne...

AI summary The witness has extensive experience evaluating demand-side management (DSM) programs across multiple jurisdictions and has provided testimony before various regulatory bodies. They are now providing evidence on behalf of Counsel to the Nova Scotia Energy Board regarding the 2026 DSM Extension, concluding that the cost-effectiveness of energy efficiency is declining due to reduced savings and benefits relative to costs.

Q. Please summarize the 2026 DSM Extension. - A. The 2026 DSM Extension is a DSM Plan for 2026. It is essentially a continuation of the 2023-2025 DSM Plan. The 2026 DSM Extension focuses on energy efficiency and demand response programs. E...

AI summary The 2026 DSM Extension continues the 2023-2025 DSM Plan with a focus on energy efficiency and demand response. E1 applied the NSEB-approved TRC and PAC tests for cost-effectiveness. Some changes include updated avoided cost assumptions, phasing out residential lighting measures, and terminating certain program components.

The design objectives for investment in low-income and equity efforts decreased to 15% to 20% of total energy efficiency portfolio investment from 17% to 22% in the 2023-2025 Plan. 2 A. Yes. I have a concern about the current construction...

AI summary The design objectives for low-income and equity investments in energy efficiency have decreased from 17% to 22% in the 2023-2025 Plan to 15% to 20% in the 2026 DSM Extension. Concerns were raised regarding the imbalance in the TRC test and lack of responsiveness from E1 in providing data for cost-effectiveness analysis.

A. Footnote b on the 2023 Actuals and 2024 Actuals tabs of E1's response to Synapse IR-08 states, "EfficiencyOne (E1) is unable to retroactively perform cost-effectiveness testing. E1 does not have verified customer costs or verified utili...

AI summary Footnote b in E1's response to Synapse IR-08 explains that EfficiencyOne cannot retroactively perform cost-effectiveness testing due to a lack of verified customer costs and utility avoided costs.

Q. Is E1's rationale for not providing a complete set of actual cost-effectiveness results for 2023 and 2024 reasonable? No. DSM program administrators in many other jurisdictions provide retroactive cost-effectiveness calculations. For ex...

AI summary The rationale provided by E1 for not providing a complete set of actual cost-effectiveness results for 2023 and 2024 is deemed unreasonable. Other jurisdictions, such as Ontario, Massachusetts, and Rhode Island, provide retroactive cost-effectiveness calculations in their annual reports, which include actual benefit-cost ratios. These calculations account for actual quantities and savings adjustments, and hold certain variables constant to isolate DSM program effectiveness.

Energy Efficiency Program Cost-Effectiveness

AI summary The document discusses the cost-effectiveness of energy efficiency programs in Nova Scotia, involving organizations like NSPI and EEC. Key acronyms include DSM, E1, PAC, TRC, and NSPI. The analysis focuses on regulatory proceedings related to demand-side management and program administration costs.

A. The decrease in benefits is due to lower savings and lower avoided costs.[12](#page-9-1) 19 12 In response to NSEB IR-14, E1 provided a comparison of the avoided costs used in the calculation of benefits and cost-effectiveness for the 2...

AI summary The decrease in benefits is attributed to lower savings and avoided costs. E1 states that the energy efficiency portfolio remains cost-effective in 2026, with benefit-cost ratios of 2.4 (PAC) and 1.6 (TRC).

Q. Do you have any concerns that these energy efficiency program components are not cost-effective in the 2026 DSM Extension? A. No. These two program components that are not cost-effective using the PAC serve low-income customers and prog...

AI summary The respondent does not have concerns about the cost-effectiveness of the 2026 DSM Extension's energy efficiency programs. They note that low-income programs are not typically cost-effective using PAC due to higher incentives, but similar ratios were approved in the 2023-2025 Plan by NSEB. Cost-effectiveness is evaluated at the portfolio level.

Demand Response Program Cost-Effectiveness 2 Q. Have costs, available capacity, participation, and benefits associated with 3 demand response changed from 2023 to 2026? Yes. [Table 5](#page-16-0) below provides the most up-to-date data on...

AI summary E1's demand response program saw a more than three-fold increase in investment from 2023 to 2026, with participation growing significantly, driven by reengaging existing participants, resulting in improved cost-effectiveness as capacity and benefits outpaced costs.

Q. Is the demand response portion of the 2026 DSM Extension cost-effective? 14 A. No. As proposed, demand response is not cost-effective in 2026 with a PAC of 0.5 and a TRC of 0.7.

AI summary The demand response portion of the 2026 DSM Extension is not cost-effective, with a Program Administrator Cost (PAC) of 0.5 and a Total Resource Cost (TRC) of 0.7, as stated in the response.

Q. Was the demand response portfolio cost-effective in prior years? 17 A. In its response to Synapse IR-08, E1 provided 2023 and 2024 actual lifetime 18 benefits and 2025 forecasted lifetime benefits for the demand response portfolio 19 as...

AI summary E1 provided 2023-2025 data on demand response portfolio benefits and calculated Program Administrator Costs (PACs), concluding the portfolio was not cost-effective from a PAC perspective in prior years.

Q. Why isn't the demand response portion of the 2026 DSM Extension cost-effective? 3 Table 6, below, shows the cost effectiveness of the demand response program in A. 4 total, by program component, and by demand response option within each...

AI summary The demand response portion of the 2026 DSM Extension is not cost-effective overall. The Residential program component is not cost-effective from any perspective, while the BNI program component is not cost-effective from a PAC perspective but is cost-effective from a TRC perspective, with only C&I Curtailment being cost-effective under TRC.

Q. Are there any other factors affecting cost-effectiveness over time? 20 A. Yes. Table 7, below, shows the proportion of investment in the Residential and BNI program components from 2023 to 2026. In 2026, there is a greater emphasis on R...

AI summary The response indicates that changes in investment allocation between the Residential and BNI demand response program components will impact the cost-effectiveness of the portfolio. The BNI demand response program is noted as being more cost-effective than the Residential program component.

11 Q. Is demand response cost-effective in any other jurisdictions? A. Yes. I examine demand response programs in Rhode Island as the utility there is implementing similar offerings. Earlier this year, Rhode Island Energy proposed Connecte...

AI summary Demand response is cost-effective in Rhode Island, where programs like Bring Your Own Thermostat and Daily Dispatch show cost-effectiveness from a PAC perspective. Rhode Island Energy's 2024-2026 proposal details avoided electric bill costs, supported by tables in their System Reliability Procurement Investment Proposal.

1 within each sector, and most programs and pathways are cost-effective from a 2 14 PAC perspective. 3 4 Q. Do you have any concerns with the fact that E1's demand response offerings are not cost-effective? 5 A. Yes. The PAC for the propos...

AI summary The discussion focuses on the cost-effectiveness of E1's proposed 2026 demand response program, with concerns raised about its Program Administrator Cost (PAC) being 0.5, indicating that system benefits are only half of system costs. The response also compares Nova Scotia's efforts to other jurisdictions, noting that Nova Scotia's 2026 demand response offering is lower than some Canadian and U.S. utilities.

4. CONCLUSIONS - Q. Please describe your conclusions regarding the 2026 DSM Extension. - A. My conclusions are as follows: Canadian and leading U.S. jurisdictions. • Investment, first-year energy savings, and lifetime benefits reached thei...

AI summary The 2026 DSM Extension remains cost-effective despite declining energy savings and benefits. However, demand response is not cost-effective in 2026. NSPI has not responded to E1's questions regarding avoided costs.

PROFESSIONAL EXPERIENCE Synapse Energy Economics, Inc. , Cambridge, MA. Principal Associate , April 2023 – Present; Senior Associate , June 2013 – April 2023; Associate, July 2008 – June 2013; Research Associate , January 2007 – July 2008....

AI summary The document outlines 18 years of professional experience in demand-side management (DSM) analysis, including work with jurisdictions across the US and Canada. Key activities include evaluating utility energy efficiency plans, assessing DSM program effectiveness, and conducting cost-effectiveness and rate impact analyses. The individual has provided testimony in New Brunswick, Rhode Island, and New Mexico, and supported the Rhode Island Division of Ratepayer Advocate since 2012.

Efficiency and Building Electrification Portfolios Through 2025: A Brief on the New York Public Service Commission's Recent Order. Synapse Energy Economics for the Natural Resources Defense Council. Kallay, J., A. Hopkins, J. Frost, A. Nap...

AI summary The document lists various energy efficiency and building electrification studies, comments, and reports by Synapse Energy Economics and partners. Key entities include Nova Scotia Utility and Review Board, Natural Resources Defense Council, and Bloom Energy. Topics cover energy efficiency initiatives, low-income energy burden, fuel cell cost-effectiveness, and rate model enhancements. Cross-references include New York Public Service Commission Case 18-M-0084.

Q. ARE YOU CONCERNED ABOUT THIS SHARP INCREASE IN RESIDENTIAL SAVINGS ACQUISTION COSTS? Yes. The primary goal of the portfolio is to acquire energy savings, with the main constraint coming from the budget available to do so. As costs to ac...

AI summary The respondent confirms concern over rising residential savings acquisition costs, which reduce savings and net benefits under the current Total Resource Cost (TRC) test, yielding a 0.9 benefit-cost ratio (BCR). This indicates negative net benefits, though an ongoing proceeding (Matter No. 12282) may revise the benefit-cost test.

8 Q. SHOULD EFFICIENCYONE DISCONTINUE ANY OF THESE PROGRAMS? - 9 A. No, not at this time. There are many uncertainties surrounding the future direction of the - 10 EfficiencyOne portfolio including new policy directives from the new Nova S...

AI summary EfficiencyOne will not discontinue its programs due to uncertainties including new policy directives from the Nova Scotia Energy Board, updated benefit-cost tests, reevaluated savings, and new program areas like solar and storage. A plan extension allows continued service while policy questions are resolved and further planning occurs.

1 Q. DO THE SAVINGS FOUND FOR THE EFFICIENCY INSIGHTS PROGRAM 2 HAVE VALUE AT THE SYSTEM LEVEL? - 3 A. Yes, and EfficiencyOne specifically calculates that value as part of its cost benefit 4 analysis. This is done by taking the load shape...

AI summary The Efficiency Insights Program's savings are valued at the system level through EfficiencyOne's cost-benefit analysis, which considers avoided capacity, generation costs, and emissions. This approach goes beyond what was implied in the 2024 Savings Verification Report.

Economic and Policy Analysis Small Business Utility Advocate - California (June 2020 – Present) - Provided testimony and analysis on cost recovery for wildfire management and grid hardening efforts for Southern California Edison (Docket No...

AI summary The individual served as the Small Business Utility Advocate in California, providing testimony and analysis on various energy-related topics including cost recovery for wildfire management, grid hardening, program budgets, non-energy benefits, phase-out of gas incentives, cost-effectiveness tests, and clean energy financing. They also worked on program design, underserved customer definitions, and participation rates in energy efficiency programs.

Program Management and Benefit Cost Analysis Expert Public Service Enterprise Group (PSE&G) – New Jersey. (Oct 2021 – Apr 2023, Feb 2024 - present) - Consulted on tracking, forecasting and management of PSE&G's internally run commercial En...

AI summary The expert provided program management and benefit-cost analysis services for PSE&G's energy efficiency programs in New Jersey, including tracking system development, economic test calculations, and training material creation. Work spanned 2021–2023 and 2024, involving collaboration with ANB Enterprises and implementation across seven utilities.

Analytic and Technical Support for DSM Tracking Systems PECO Energy Company – Pennsylvania (September 2016 – December 2017) Commonwealth Edison Company – Illinois (August 2017 – August 2018) Companywide (September 2020 – December 2023) - S...

AI summary The text details work on DSM tracking systems from 2016-2023, including roles at PECO Energy and Commonwealth Edison, development of dashboards, automation of reporting, cost effectiveness modules, and audit tools for programs like ComEd's Carbon Free School Assessment Program.

Technical Assistance for Energy Efficiency Programs Focus on Energy - Wisconsin (June 2011 – August 2013) - Developed and customized cost-effectiveness calculators for Wisconsin's Focus on Energy portfolio of energy efficiency programs; -...

AI summary Focus on Energy in Wisconsin (2011–2013) developed cost-effectiveness calculators, trained staff, and conducted QA/QC on 14 energy efficiency programs with $160M in spending over two years.

Chicagoland Energy Efficiency Portfolio People's Gas - Chicago, Illinois (September 2008 – January 2013) - Providing ongoing regulatory support; - Provided cost-benefit analysis of various program scenarios and aided in the analysis of con...

AI summary People's Gas provided regulatory support, conducted cost-benefit analyses for energy efficiency programs, evaluated contractor bids, and developed customized Excel tools for portfolio and cost-effectiveness analysis from 2008 to 2013 in Chicago, Illinois.

Incentive Calculations for the Project Cost-effectiveness Analysis Tool (CAT) Efficiency Vermont – Burlington, Vermont (November 2008 – June 2010) - Aided in the design of a new approach to calculating incentives for custom energy efficien...

AI summary Efficiency Vermont contributed to designing a new method for calculating incentives for custom energy efficiency projects, focusing on financing and achieving a desired rate of return. They modified the CAT's Excel VBA-based cash-flow projection engine to support this approach during 2008–2010.

Testimony and Proceeding Participation Forum On Behalf Of Docket/Matter Date Issues Addressed Massachusetts Department of Public Utilities Massachusetts Office of the Attorney General D.P.U. 24-140 through D.P.U. 24-149 - 2025-2027 Three-Y...

AI summary This section lists various regulatory proceedings and testimonies from different states, focusing on energy efficiency plans, rate cases, and wildfire mitigation costs. Key issues addressed include policy design, incentive structures, cost-effectiveness, and plan development.

1 1. INTRODUCTION - 2 EfficiencyOne's ("E1") Application for Approval of the 2026 DSM Extension for Demand-Side Management - 3 Activities ("DSM") between E1 and Nova Scotia Power Inc. ("NS Power"), and for Approval of the - 4 Amendment to...

AI summary EfficiencyOne (E1) seeks approval to extend its Demand-Side Management (DSM) services until 2026, aligning with the Nova Scotia Energy Board's (NSEB) new mandate and pending Benefit Cost Analysis (BCA) test (Matter M12282). The application includes an amendment to the DSM Purchase Agreement with Nova Scotia Power Inc. (NS Power). E1 concurs with intervenor findings but addresses limited divergences and relies on Econoler's report for the Peach Report (Matter M12186).

E1 Response - E1 acknowledges the current TRC test as described, and notes Synapse's observation. Evaluating all costs - but only a subset of benefits leads to an imbalanced test that does not reflect participant benefits. E1 seeks - to ad...

AI summary E1 acknowledges the current TRC test but argues it is imbalanced by considering only a subset of benefits. E1 proposes a new BCA test in its pending Application (M12282) to assess DSM Plans by incorporating both utility and non-utility system impacts.

Synapse - Synapse states: - Q. Do you have any concerns that these energy efficiency program components are not cost-effective in the 2026 DSM Extension? A. No. These two program components that are not cost-effective using the PAC serve l...

AI summary Synapse responds to concerns about the cost-effectiveness of energy efficiency program components in the 2026 DSM Extension, stating that these components, which serve low-income customers, are not typically cost-effective due to the need for higher incentives.

1 cost-effectiveness ratios in the 2023-2025 Plan and received approval from the NSEB. Lastly, 2 cost effectiveness is assessed at the portfolio level.3 3 4 E1 Response 5 E1 asserts that program components which serve low-income and equity...

AI summary The document discusses the cost-effectiveness ratios in the 2023-2025 Plan, which were approved by the NSEB. It highlights E1's concern that low-income and equity program components may fall below cost-effectiveness thresholds due to the need for higher incentives. Synapse recommends that NSPI respond to E1's questions regarding August 2024 avoided costs and that the NSEB direct NSPI and E1 to update the 2027-2031 DSM Plan accordingly.

E1 Response E1 supports and accepts Synapse's recommendation that the Board direct NS Power to respond to E1's questions and recommendations on the August 2024 avoided cost updates. The avoided cost input is a significant impact stream con...

AI summary E1 supports Synapse's recommendation for NS Power to address avoided cost updates and suggests establishing a deadline for disclosure to align with E1's 'evergreen' process for BCA impacts in the 2027-2031 DSM Plan. Avoided cost input is critical for DSM resource cost-effectiveness tests.

E1 Response In its response to Synapse IR-08, E1 provided excel spreadsheets showing actual lifetime benefits for energy efficiency, demand response, as well as these two components combined, for the requested years, and explained the limi...

AI summary E1 responded to Synapse's request for actual retroactive benefit-cost data, explaining limitations due to lack of verified customer and utility costs. Synapse recommended including PAC and TRC results in annual reporting, while E1 agreed to report PAC but not TRC due to complexity and cost. E1 proposed reporting PAC results in the 2025 Annual Progress Report.

2.5 COST-EFFECTIVENESS OF DEMAND RESPONSE

AI summary This section discusses the cost-effectiveness of demand response programs, evaluating their economic benefits relative to traditional supply-side solutions. Key considerations include comparative analysis frameworks and regulatory implications for Nova Scotia's energy sector.

E1 Response E1 acknowledges the potential for further development within the demand response program. This is a key focus area in E1's discussions with stakeholders in relation to the 2027-2031 DSM Plan, and there are Ibid., page 18, lines...

AI summary E1 acknowledges opportunities to expand demand response programs under the 2027-2031 DSM Plan but contests Synapse's use of advanced jurisdictions as comparators. E1 refuses to commit to a PAC threshold of 1.0 due to legislative constraints, ongoing cost-benefit analysis reviews, and projected cost improvements. Discontinuing the program would hinder grid-constrained initiatives and undermine progress.

2.6 BENCHMARKING STUDY

AI summary The document section titled '2.6 BENCHMARKING STUDY' outlines a regulatory proceeding involving a benchmarking study. Key entities include Nova Scotia Power Inc. (NSP) and the Nova Scotia Energy Board (NSEB), with acronyms such as BCA and TRC referenced. The study likely evaluates efficiency metrics and resource costs.

Synapse Synapse states: NSPI should provide E1 with sufficient detail about location of the constrained system as of the August 2024 avoided cost update to facilitate this targeting (if NSPI has not already provided this information). E1 s...

AI summary Synapse requests NSPI to provide detailed location data on constrained systems by August 2024 to enable E1 to develop energy efficiency and demand response strategies for the 2027-2031 DSM Plan. E1 must also incorporate benefits from constrained systems into the plan's benefit-cost analysis.

Q. Are you concerned about this sharp increase in residential savings acquisition costs? A. Yes. The primary goal of the portfolio is to acquire energy savings, with the main constraint coming from the budget available to do so. As costs t...

AI summary The respondent is concerned about the sharp increase in residential savings acquisition costs, which has led to a decline in acquired savings despite stable or slightly increased budgets. They emphasize the need for a thorough review of residential energy efficiency programs to ensure cost-effective savings for ratepayers.

Appendix A

AI summary Appendix A of the Nova Scotia regulatory proceeding document outlines key acronyms and entities involved in the proceeding, including Nova Scotia Power Inc., the Nova Scotia Energy Board, and methodologies like Benefit Cost Analysis and Total Resource Cost.

ture of RCTs is random assignment, not sample size, large samples increase precision and chance to detect a real effect if it exists, which is often why RCTs are ideally conducted with larger samples. Econoler does not agree that the proto...

AI summary Econoler argues that statistical significance, not practical effect size, is sufficient for evaluating residential behavior programs, as effect perception occurs in metering data rather than at the household level. They reject the Verifier's comparison to medical studies, emphasizing aggregated results matter. The Peach Report recommends including a business case justification for program funding in evaluation protocols.

Econoler Response: Econoler does not agree that due to the effect size at the household level, a savings claim for the program does not make sense. - Behaviour change initiatives are designed to make small, simple changes in how individual...

AI summary Econoler argues that residential behavior programs should claim energy savings if measurable, even with small per-household effects. The program achieved 6.270 GWh savings (0.34%-0.62% annual household consumption), consistent with other jurisdictions. Savings are comparable to E1's LED lamp program (0.113 kWh/day).

Avoided costs of both energy and capacity were based on NS Power's Evergreen IRP and avoided costs of transmission and distribution were provided by NS Power, both provided to the DSMAG on August 23, 2024. Avoided costs of carbon are embed...

AI summary The document discusses avoided costs related to energy, capacity, and carbon, referencing NS Power's Evergreen IRP and the 2026 DSM Extension. It outlines cost-effectiveness ratios, investment requirements for demand response (DR), and lifetime benefits calculations for energy efficiency (EE) and DR programs. It also mentions participation by low-income and equity customers in various programs.

out of lighting as a low-cost opportunity (Instant Savings and Efficient Product Installation), and the expected decrease in participation in Home Energy Assessment. [Exhibit E-1, Appendix A, p. 19] [27] E1's application highlights the fol...

AI summary E1's 2026 DSM Extension application evaluates cost-effectiveness using TRC and PAC tests. While the overall portfolio passes both tests, low-income programs like Affordable Multi-Family Homes and Mi'kmaw Home Energy Efficiency fail TRC due to lower cost-effectiveness. The application highlights challenges in maintaining participation in Home Energy Assessment programs.

4.1 Industrial Group [28] The Industrial Group argues that although the specific investment amount for the 2026 DSM extension has been prescribed by the legislation, the Board must still consider whether the proposed 2026 DSM Plan is in th...

AI summary The Industrial Group argues that the Board must evaluate the 2026 DSM Plan's cost-effectiveness, reasonableness, and spending allocation to ensure ratepayer interests. Recommendations include engaging DSMAG, rejecting exclusions of savings from specific programs, addressing cybersecurity breach impacts, and coordinating data collection between E1 and NSPI. The Group also urges E1 to manage budgeted spending by customer class and address tariff amendment requirements.

4.3 Small Business Advocate - [36] The Small Business Advocate is generally supportive of E1's application to extend the DSM Plan. However, she identified concerns she felt should be held in abeyance and brought forward in the 2027-2031 DS...

AI summary The Small Business Advocate supports extending EOne's DSM Plan but raises two concerns: (1) Synapse's cost-effectiveness claims for Demand Response programs may expand the application's scope beyond the Board's portfolio-level cost-benefit analysis mandate; (2) Econoler's response to the Peach Report's valuation concepts (Practical Value to Utility System and Households) lacks participant value consideration. Both issues are deferred to future filings.

5.4.1 Findings [65] The Board agrees that concerns about E1's demand response programs are better addressed in its consultations and upcoming application for approval of its fiveyear DSM Plan. That said, the Board notes that E1 should be f...

AI summary The Board agrees that E1's demand response program concerns should be addressed in its DSM Plan application, noting potential overlap with NS Power's Critical Peak Pricing Program and targeting constrained areas. The Board declines requiring E1's programs to have a PAC of at least 1.0, allowing lower PAC programs if justified under the Energy and Regulatory Boards Act.

5.10 Evaluation and Reporting [85] In the 2026 DSM Extension, E1 proposes to follow the same measurement and evaluation activities as approved in the 2023-2025 DSM Plan. This includes an annual impact evaluation for each program. E1 also p...

AI summary E1 proposes to follow existing DSM evaluation methods, but Synapse requests PAC and TRC calculations for 2023-2026. E1 lacks verified data for retroactive analysis and suggests limiting reporting to PACs, which would not require third-party support. Synapse emphasizes the value of actual results in other jurisdictions for cost-effectiveness transparency.

5.10.1 Findings [89] Since the Board did not approve E1's proposed benefit-cost analysis test in its recent decision and directed E1 to use the PAC test (2025 NSEB 18), the Board finds it is appropriate to limit the requested reporting to...

AI summary The Board directed E1 to use the PAC test for cost-effectiveness analysis instead of its proposed method, citing prior decisions (2025 NSEB 18). E1 must report PAC results for 2023–2025 and future years in annual progress reports. Additional reporting may be required if PAC data fails to assess cost-effectiveness trends or administrator performance.

Request IR-15: - On page 21 of 25 in E1's Evidence, E1 stated that the unit cost of energy savings will increase - over time due to factors such as diminishing returns, increased complexity, and market maturity. - Indeed, the 2023-2025 Pla...

AI summary E1's evidence indicates that the unit cost of energy savings will rise from $0.39/kWh to $0.49/kWh between 2023-2025 and the 2026 plan extension, a 25% increase. The request questions E1's measures to control costs and address affordability concerns.

Request IR-16: - Regarding the Total Resource Cost (TRC) test, in Table 9 on page 40 of 149 in Appendix A of the - 2023-2025 DSM application (M10473), the TRC for Residential EE Programs is presented as 1.4 Document: 321929 Date Filed: Jun...

AI summary The NSEB requests an explanation for the decline in Total Resource Cost (TRC) values for Residential EE and DR programs from 2023-2025 (1.4/1.1) to 2026 (0.9/0.7), with most components now below TRC 1.0. This discrepancy between application tables (M10473 and M12249) raises concerns about the TRC deterioration.

Request IR-17: - On page 24 of 25 in E1's Evidence, E1 determined that "Several directives from the 2023-2025 - DSM Plan Decision relate to, and contemplate, the next complete DSM Plan filing (as opposed to - the current Extension applicat...

AI summary E1 did not comply with Board directives in the current DSM Plan Extension application, citing that directives relate to the next DSM Plan filing. The Board requests justification for measures failing the TRC test, as required by Decision M10473.

mbers joined by their consultants); and • On April 22, 2025, E1 hosted a DSMAG Technical Briefing for the 2026 DSM Extension." a. Please provide the dates of the one-on-one meetings and a list of the stakeholders who participated each meet...

AI summary The document requests details on DSMAG meetings and materials from a technical briefing. It references the NSUARB's directive to update avoided cost calculations for DSM planning, incorporating 2022 IRP data and climate goals. E1 integrated updated avoided costs, including embedded carbon costs, for the 2026 DSM Extension, though separate carbon inputs were not provided.

- Cost Test (TRC), and Program Administrator Cost Test (PAC) for lighting measures in the 1 Efficiency Product Installation program component over time. Please include 2023 4 Program Total. Please provide an updated version of Table 5 incl...

AI summary The text refers to the Cost Test (TRC) and Program Administrator Cost Test (PAC) for lighting measures, and requests updated information on program components, including lifetime benefits and cost-effectiveness testing results. It also mentions the 2026 Plan Extension and the need for specific justification for measures failing cost-effectiveness testing.

Request IR-3: Request IR-4: - a) Is the Benefit Cost Ratio for the Application evaluated at the total DSM Plan level only? - b) How many of the constituent programs, within the DSM Plan, have a Benefit Cost Ratio of 1.0 or lower? - c) What...

AI summary Request IR-4 seeks clarification on the Benefit Cost Ratio (BCR) evaluation for the DSM Plan, including how many constituent programs have a BCR ≤1.0, their cost percentage, and whether they target residential or BNI customers.

- 26 incremental costs, and incentives). For each change, please explain the rationale. 1 Request IR-11: 2 Reference: Page 23, Table 5: 2026 Program Savings and Investment. 3 4 (a) Please confirm that the residential energy efficiency prog...

AI summary The text requests confirmation and explanation regarding the total resource cost (TRC) test for residential energy efficiency and demand response programs, as well as compliance with directives from a prior matter. It also inquires about cost-effectiveness testing and proposed incentive levels.

26 consideration and how it has been accounted for. If not, why not. 1 (e) Please provide a list of measures in the 2023-2025 DSM Plan which failed 2 cost-effectiveness testing (provide the TRC for each) and indicate whether 3 each of thes...

AI summary The text requests information on the 2023-2025 DSM Plan, including failed measures, cost-effectiveness testing, and proposed changes for the 2026 DSM Plan. It also asks for details on measures with a payback period of three years or less and their incentive levels in the 2026 Plan. Additionally, it requests population of a table with 2025 Q1 and Q2 results and forecasts.

10 Request IR-15:

AI summary The document outlines Request IR-15, a regulatory proceeding in Nova Scotia involving Demand-Side Management (DSM) initiatives. Key acronyms include DSMAG (Demand-Side Management Agreement) and TRC (Total Resource Cost), which are central to the discussion of resource planning and cost methodologies.

20 Request IR-16:

AI summary Request IR-16 is part of a Nova Scotia regulatory proceeding. Key acronyms include DSM (Demand-Side Management), DSMAG (Demand-Side Management Agreement), and TRC (Total Resource Cost). The document outlines procedural elements related to energy management and cost analysis.

1 2025 M12249 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended 4 IN THE MATTER OF: An Application by EfficiencyOne for approval of the 2026 DSM 5 Extension for Demand-Side Management Act...

AI summary EfficiencyOne seeks approval for a 2026 DSM extension and amendment to a 2023-2025 Purchase Agreement with Nova Scotia Power Inc. The document includes information requests from H. Gil Peach, PhD., regarding savings verification processes, involvement in the Benefits Cost Analysis (BCA) test, and utilization of verification reports in BCA development.

BA respectfully submits that the following areas of concern should be held in abeyance in this Application and be brought forward in the next DSM plan application, for the 5-year period of 2027-2031. - 1. In the EOne reply evidence startin...

AI summary The SBA argues that two issues related to Demand Response program cost-effectiveness and valuation methodologies should be deferred to the next DSM plan application. It contends that Synapse's cost-benefit analysis at the portfolio level conflicts with the Board's order, and that Econoler's response to the Peach Report fails to address participant value considerations outside the current application's scope.

only 2 types of value being assessed, the SBA respectfully submits that there is no consideration of the value that participants either received or expected to receive when they chose to participate. The SBA respectfully suggests and recom...

AI summary The SBA argues that the current value assessment only considers two types of value, ignoring participants' received or expected benefits. It recommends deferring program decisions, funding, and cost-benefit analyses to a future Five-Year Plan application. The submission is dated September 18, 2025, by Melissa P. MacAdam, Small Business Advocate.

Cost-Effectiveness Testing E1 states that it has applied the current Board-approved cost-effectiveness test to the 2026 DSM Plan i.e., the Total Resource Cost (" TRC ") test. This test compares the cost of program design and delivery with...

AI summary E1 applied the Board-approved Total Resource Cost (TRC) test to the 2026 DSM Plan, comparing program costs with NSPI's avoided costs (energy, capacity, transmission, distribution, and carbon). The Program Administrator Cost (PAC) test is presented as an informational comparator. References to exhibits and footnotes are included.

Updates to Avoided Cost Calculation E1 incorporated the IRP results from the 2022 IRP Evergreen Process into its avoided cost calculation for the 2026 DSM Extension. These avoided costs were provided by NSPI in August 2024. E1 flagged that...

AI summary E1 integrated 2022 IRP Evergreen Process results into its 2026 DSM Extension avoided cost calculation, using data provided by NSPI in August 2024. E1 noted that carbon costs are now embedded within energy avoided costs, but NSPI did not supply them as a separate input.

Anticipated Results E1 anticipates lower energy savings and lower demand savings in 2025 and 2026 compared to those achieved in 2023 and 2024, despite the notable increase in the budget. It attributes this to the following factors: - E1 ha...

AI summary E1 anticipates lower energy and demand savings in 2025-2026 despite increased budgets, citing expired LED rebates, exhausted Canada Greener Homes Grant funding, and lower demand response adoption. 2025 targets 128.7 GWh at $62M, while 2026 targets 116 GWh at $63.75M, with rising unit costs ($0.49/kWh in 2026 vs. $0.39/kWh in 2023). Residential and BNI energy savings contributions shift from 35%/65% to 51%/49%.

General The Industrial Group submits that while this application has been filed as a one-year "extension plan", it lacks the full consultative approach generally employed by E1 and E1 did not fulfill all the standardized filing requirement...

AI summary The Industrial Group criticizes E1's extension plan for lacking consultative approach and failing to comply with NSUARB directives on cost-effectiveness testing and data disclosure. E1's 'balanced plan' spending (51% residential, 49% BNI) contrasts with unbalanced energy savings (35% residential, 65% BNI). The Industrial Group supports E1's adoption of updated census data for equity spending but calls for DSMAG review of E1's planning framework.

Cost Effectiveness Testing E1 states that at the portfolio level, cumulatively the programs exceed the threshold ratio of 1.0, with a ratio of 1.6. E1 asserts that this thereby satisfies the statutory requirement of "cost effective" under...

AI summary E1 argues that a portfolio-level cost-effectiveness ratio of 1.6 satisfies the PUA 's 'cost effective' requirement. The Industrial Group disputes this, asserting the PUA allows granular cost-effectiveness testing beyond the portfolio level to assess DSM plans' alignment with customer interests and NSPI's obligations. The Consumer Advocate's consultant emphasizes the need for detailed cost-effectiveness criteria, target markets, and evaluation methods in DSM planning.

DEMAND RESPONSE As is evident from the Application (Table 5), the residential demand response program fails both the TRC and PAC tests by a wide margin: 0.3, for both. The BNI demand response program component passes the TRC with a ratio o...

AI summary The residential and BNI demand response (DR) programs fail TRC and PAC tests, with E1's efforts criticized for lack of transparency and formal pilot reports. The Industrial Group urges E1 to improve program effectiveness, commit to cost-effective DR, and coordinate with NSPI for data. Synapse recommends locational DSM in grid-constrained areas, which E1 claims lacks necessary data.

nt to explain and report; E1 must also manage its spending to avoid such material rate impacts and provide advance notice so that customer classes directly affected may object or support such changes. Where the reduction of costs to ratepa...

AI summary The document emphasizes that E1 must manage spending to avoid significant rate impacts and provide advance notice for customer class objections. The NSUARB prioritizes cost-effectiveness and reducing ratepayer costs, opposing unfettered cost-shifting between customer classes. Amendments to the DSM rider are proposed to address these issues.

Conclusion The Industrial Group recommends that the Board: - 1. Take into consideration the cost-effectiveness results provided in relation to the program and/or measure level, in addition to the portfolio level, considering the requiremen...

AI summary The Industrial Group recommends the NSUARB consider cost-effectiveness at program and portfolio levels, engage DSMAG pre-2027-2031 plan filing, reject Mr. Peach's savings exclusion, mandate E1's comprehensive DR analysis, coordinate with NSPI on overlapping programs, and manage budgeted spending. E1 must address cybersecurity breach impacts and clarify Supply Agreement amendments.

2. SMALL BUSINESS ADVOCATE - 2 The Submission filed by the Small Business Advocate recommends that stakeholder concerns raised in the - 3 2026 DSM Extension that relate to the upcoming 2027-2031 DSM Plan and its associated regulatory - 4 p...

AI summary The Small Business Advocate recommends deferring stakeholder concerns related to the 2026 DSM Extension to the next DSM Plan application (2027-2031), focusing on demand response programs' cost-effectiveness and value concepts from the Peach Report. E1 supports this recommendation.

The legislative amendment set out in s. 79J(3) of the Public Utilities Act, directs E1 to submit 2026 targets for the one-year extension of the existing DSM Plan. (3) The franchise holder shall submit its targets for the one-year extension...

AI summary The legislative amendment to the Public Utilities Act requires E1 to submit 2026 targets for the one-year extension of the existing DSM Plan. E1 argues that detailed program design and test methodology issues should be addressed in the upcoming 2027-2031 DSM Plan process. The Industrial Group, however, suggests a broader review of the extension application, including cost-effectiveness and spending management. E1 asserts that the current application provides sufficient information for approval.

4.3 COST-EFFECTIVENESS TEST E1 applies the legislatively prescribed cost-effectiveness test at the portfolio level. The Industrial Group takes the position that the level of inquiry for cost-effectiveness should not be at the portfolio lev...

AI summary E1 applies the legislatively mandated portfolio-level cost-effectiveness test for its DSM plan under the Public Utilities Act. The Industrial Group argues that cost-effectiveness should not be evaluated at the portfolio level. E1 maintains that meeting the portfolio-level cost-effectiveness (1.0 or higher) is a prerequisite for submitting a DSM plan to the Board, though it acknowledges the Board can consider granular data.

Avoided costs of both energy and capacity were based on NS Power's Evergreen IRP and avoided costs of transmission and distribution were provided by NS Power, both provided to the DSMAG on August 23, 2024. Avoided costs of carbon are embed...

AI summary The document discusses avoided costs related to energy, capacity, and carbon, referencing NS Power's Evergreen IRP and E1's approach to calculating these costs. It also outlines cost-effectiveness ratios and provides details about DR and EE programs, including investment requirements, program lifetimes, and participation by low-income and equity customers.

out of lighting as a low-cost opportunity (Instant Savings and Efficient Product Installation), and the expected decrease in participation in Home Energy Assessment. [Exhibit E-1, Appendix A, p. 19] [27] E1's application highlights the fol...

AI summary E1's 2026 DSM Extension application discusses the cost-effectiveness of energy efficiency and demand response programs. While the overall portfolio passes TRC and PAC tests, low-income programs like Affordable Multi-Family Homes and Mi'kmaw Home Energy Efficiency fail TRC due to lower cost savings. This highlights challenges in balancing equity-focused initiatives with broader cost-effectiveness metrics.

4.0 POSITION OF THE INTERVENORS

AI summary The section outlines the positions of intervenors in the regulatory proceeding. Key arguments focus on Demand-Side Management (DSM), Total Resource Cost (TRC), and Program Administrator Cost (PAC), with emphasis on rate design and cost methodologies. NS Power's role and program cost structures are central to the discussion.

4.2 Consumer Advocate [31] Green Energy Economics Group (Green Energy), the Consumer Advocate's Consultant, recommended the 2026 DSM extension be granted with the following modifications: • To ensure the same sector budget allocation is us...

AI summary The Consumer Advocate recommends granting the 2026 DSM extension with adjustments, including reallocating funds to the residential sector and ensuring proper cost-effectiveness and low-income participation in programs. Green Energy Economics Group supports these recommendations and advises against discontinuing savings verification for the Efficiency Insights program.

4.3 Small Business Advocate - [36] The Small Business Advocate is generally supportive of E1's application to extend the DSM Plan. However, she identified concerns she felt should be held in abeyance and brought forward in the 2027-2031 DS...

AI summary The Small Business Advocate supports extending the DSM Plan but raises concerns about cost-effectiveness of Demand Response programs and valuation methods. She argues that Synapse's evidence may expand the application's scope beyond current matters and that Econoler's response to the Peach Report overlooks participant benefits. These issues should be addressed in future filings.

5.4.1 Findings [65] The Board agrees that concerns about E1's demand response programs are better addressed in its consultations and upcoming application for approval of its fiveyear DSM Plan. That said, the Board notes that E1 should be f...

AI summary The Board directs E1 to address concerns about its demand response programs in its upcoming DSM Plan application, including potential overlap with NS Power's Critical Peak Pricing Program. It rejects a PAC threshold of 1.0 for demand response programs, citing portfolio-level cost-effectiveness evaluations under the Energy and Regulatory Boards Act.

5.10 Evaluation and Reporting [85] In the 2026 DSM Extension, E1 proposes to follow the same measurement and evaluation activities as approved in the 2023-2025 DSM Plan. This includes an annual impact evaluation for each program. E1 also p...

AI summary E1 proposes continuing existing DSM evaluation practices, while Synapse urges reporting actual PACs and TRCs for 2023-2026. E1 cites data limitations but later agrees to PAC reporting without third-party support, while TRC calculations would require additional resources and be delayed. The dispute centers on cost-effectiveness transparency and methodological complexity.

5.10.1 Findings [89] Since the Board did not approve E1's proposed benefit-cost analysis test in its recent decision and directed E1 to use the PAC test (2025 NSEB 18), the Board finds it is appropriate to limit the requested reporting to...

AI summary The Board directed E1 to use the PAC test for cost-effectiveness analysis instead of its proposed method, requiring PAC test results for 2023-2025 and future annual reports. This avoids consultant costs and ensures sufficient data for evaluating program administrator performance.