E-1Notice of Application and Evidence
62 passages
was extended through a legislative amendment to the PUA that does as follows: a) extends the term of the existing 2023-2025 DSM Plan by one additional year, to December 31, 2026; b) extends the existing approved demand-side management purc...
AI summary The PUA was amended to extend the 2023-2025 DSM Plan to 2026, set a $63.75M investment, and require E1 to seek Energy Board approval for 2026 targets. The TRC Test is used to evaluate DSM Plan cost-effectiveness.
s compared to costs. 9. In its 2022 application for approval of the 2023-2025 DSM Plan, E1 sought regulatory approval to conduct a review of cost-effectiveness testing methodologies: 1 E1 submits that a broad review of cost-effectiveness t...
AI summary E1 requested a review of cost-effectiveness testing methodologies for Nova Scotia's DSM Plan due to legislative changes and advancements in demand response. The Nova Scotia Utility and Review Board approved this, directing E1 to collaborate with the DSM Advisory Group before the 2026-2028 DSM Plan application to determine the optimal methodology.
herefore, directs E1 to work with the DSMAG before the 2026-2028 DSM Plan application to assess and develop an optimal DSM cost-effectiveness testing methodology. 11. In accordance with the Board’s direction, E1 worked with the DSMAG to re...
AI summary The document outlines E1's collaboration with the DSMAG to develop a new benefit-cost analysis (BCA) test for Nova Scotia's DSM Plan, including workshops and legislative changes. A 2022 PUA amendment shifted cost-effectiveness testing from program to portfolio level, impacting the BCA's application.
t to the PUA that enacted the following relevant changes: a) Changing the level at which cost-effectiveness testing would apply from the program level to the portfolio level; and b) Adding a definition of “demand-side management” to includ...
AI summary The text outlines legislative changes under the Public Utilities Act (PUA) and the Energy Reform (2024) Act, which expanded cost-effectiveness testing and redefined demand-side management. These changes informed the development of a new BCA test by EFG, influenced by policy goals and the National Standard Practice Manual for DER.
set out in the National Standard Practice Manual (“NSPM”) for Distributed Energy Resources (“DER”); 3 b) Nova Scotia’s policy goals and objectives, as articulated in legislation; c) input from the DSMAG during workshops; and d) Nova Scotia...
AI summary The document outlines the proposed Best Interest of Customers (BCA) test design, incorporating non-utility system impacts like greenhouse gas emissions and air pollutants, aligned with Nova Scotia's sustainability goals. Inputs included the DSMAG's workshop feedback, policy objectives, and E1's DSM Plan performance data.
re reflective of accurate and current data, and of any changes to Nova Scotia policy objectives. This ‘evergreen’ review would be conducted in advance of the development of a new DSM Plan. 24. The utility system impacts and other fuel impa...
AI summary E1 proposes replacing the TRC test with the BCA test (1.0 ratio threshold) for assessing DSM Plans, emphasizing accurate data, evergreen reviews, and quantifying impacts via avoided costs, social cost of carbon, and societal benefits using a 2% discount rate. The BCA test is argued to align with ratepayer interests and regulatory priorities.
Group, entitled “Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia”, dated May 13, 2025, to be used in assessing the cost effectiveness of future DSM Plans. 28. In support of this Application, E1 relies on the...
AI summary EfficiencyOne (E1) submits an application for a Jurisdictional Benefit-Cost Analysis (BCA) framework to assess future Demand Side Management (DSM) Plans. E1 cites supporting evidence from Energy Futures Group and asserts the requested order aligns with ratepayer interests. The application emphasizes cost-effectiveness and regulatory compliance.
6 EVIDENCE May 16, 2025 EfficiencyOne Benefit-Cost Analysis Test Application Evidence TABLE OF CONTENTS 1. Introduction...........................................................................................................................
AI summary The document outlines EfficiencyOne's application for a benefit-cost analysis test, discussing existing cost-effectiveness tests, gaps in the TRC methodology, and evaluations of current and prospective DSM plans (2023-2025, 2026 extension, 2027-2031). It references Board jurisprudence on cost-effectiveness tests and portfolio-level evaluations.
...................................... 35 12. Conclusion ..........................................................................................................................................38 LIST OF TABLES Table 1: Impact Categories...
AI summary EfficiencyOne is applying a Benefit-Cost Analysis (BCA) Test, referencing the National Standard Practice Manual (NSPM) steps and principles for BCA development, as well as the Total Resource Cost (TRC) Test and cost-effectiveness testing in other jurisdictions.
iii EfficiencyOne Benefit-Cost Analysis Test Application Evidence
AI summary EfficiencyOne submits a benefit-cost analysis test application as evidence in a regulatory proceeding, likely under the Public Utilities Act (PUA). The application evaluates the cost-effectiveness of demand-side management initiatives, aligning with Nova Scotia's energy efficiency goals.
1 1. INTRODUCTION 2 The energy landscape in Nova Scotia is in a state of significant change. The ambitious emissions reductions 3 targets under both provincial and federal legislation are fueling a transition to integrating more renewable...
AI summary Nova Scotia's energy sector is undergoing transformation due to provincial and federal emissions targets, with the Energy Reform (2024) Act creating a new Energy Board to regulate sustainable development. The Total Resource Cost (TRC) test is central to evaluating EfficiencyOne's demand-side management (DSM) plans, aligning regulatory assessments with climate policy objectives.
screening test used by E1 is the total resource cost 23 test (“TRC”). The Energy Board, in turn, uses the TRC to inform its assessment of the cost-effectiveness of 24 E1’s DSM Plan, in accordance with the Public Utilities Act. 4 25 26 In i...
AI summary The document discusses EfficiencyOne's (E1) use of the Total Resource Cost (TRC) test to assess demand-side management (DSM) plans under the Public Utilities Act. The Energy Board evaluates E1's DSM Plan using TRC, while the Nova Scotia Utility and Review Board (NSUARB) directed E1 to develop an optimal cost-effectiveness test, leading to hiring Energy Futures Group (EFG) for analysis.
25 Page 1 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence
AI summary EfficiencyOne (E1) submits a benefit-cost analysis test application, seeking regulatory approval for its proposed efficiency initiatives. The application focuses on demonstrating cost-effectiveness and aligning with demand-side management (DSM) objectives under Nova Scotia's energy regulations.
1 engagement process with the Demand Side Management Advisory Group (“DSMAG”) to inform the 2 development of a new cost-effectiveness test for Nova Scotia. 3 4 In December 2023, E1 and EFG initiated engagement with the DSMAG to develop an...
AI summary E1 and EFG engaged the DSMAG to develop a new cost-effectiveness test (BCA) for Nova Scotia's DSM, aligning with updated policy objectives and provincial legislation. The BCA includes non-utility impacts like societal and host customer benefits, differing from the current TRC test. E1 argues this approach reflects best practices and legislative changes.
of the energy 23 sector and the corresponding impacts for consideration in relation to DSM planning, the proposed BCA 24 test including the impact categories and the valuation of same, should be reviewed on an evergreen basis 25 through th...
AI summary E1 seeks approval of a new Best Interest of Customers (BCA) test for evaluating Demand Side Management (DSM) Plans, arguing it better serves ratepayers. The proposal includes an evergreen review process by the DSMAG to assess impact categories before future DSM Plan filings.
Table 1: Impact Categories Under TRC Test Total Resource Cost Impact Category Sub-Category Utility System Electric • Generation • Transmission • Distribution • General 12 The cost-effectiveness assessment of E1’s current 2023-2025 DSM Plan...
AI summary The document outlines the Total Resource Cost (TRC) test applied to EfficiencyOne's DSM Plan, emphasizing avoided costs in generation, transmission, and distribution. It notes NS Power's current methodology for calculating utility avoided costs and the upcoming transition to the Independent Energy System Operator. The TRC test requires a cost-effective ratio of 1.0 or greater, but the current test is criticized for not aligning with recent legislative changes.
Page 3 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 restricted to utility-related impacts alone. As examples, sustainable development and sustainable 2 prosperity invite consideration of societal GHG impacts and ho...
AI summary The text critiques the current TRC test for excluding host customer benefits, violating the NSPM's symmetry principle, and misaligning with industry standards. It argues this creates biased evaluations favoring certain resources and calls for a more balanced cost-effectiveness framework.
ith similar policy objectives in legislation. Examples are provided in Table 2, below. 12 13 Table 2: Examples of Cost-effectiveness Testing in Jurisdictions with Similar Policy Objectives State Test Purpose State-specific cost- Align ener...
AI summary The text argues that Nova Scotia's current Total Resource Cost (TRC) test for evaluating Demand Side Management (DSM) Plans is outdated, as it fails to incorporate environmental and societal considerations mandated by updated policy objectives. Examples from other jurisdictions using alternative cost-effectiveness tests (e.g., New Jersey's state-specific cost-benefit test, California's Societal Cost Test) are cited to support the need for reform.
E1 delivers are designed to influence the amount and timing of electricity usage, 24 ultimately reducing the overall demand for electricity (with the (new) exception of strategic electrification, DATE FILED: May 16, 2025 Page 4 of 38 Effic...
AI summary EfficiencyOne (E1) programs aim to influence electricity usage timing and volume to reduce overall demand, with an exception for strategic electrification. The document, filed on May 16, 2025, outlines a benefit-cost analysis test application related to these initiatives.
1 as discussed below). The recent legislative amendments to the PUA now include strategic electrification 2 within the definition of demand-side management, for which the proposed BCA test allows consideration. 3 The best practice is to us...
AI summary The document discusses legislative amendments to the PUA, incorporating strategic electrification into demand-side management (DSM) and advocating for the Best Interest of Customers (BCA) test over the Total Resource Cost (TRC) framework. E1, as the franchise holder, must seek regulatory approval for its DSM Plan, with the Energy Board required to assess portfolio-level cost-effectiveness. Historical emphasis on DSM cost-effectiveness is highlighted via the 2010 NSUARB case.
jectives of environmental protection, reduction in future energy demand and 23 usage of alternative sources of energy. However, going green is not inexpensive. Well- 24 intentioned efforts to promote DSM must be subject to critical analysi...
AI summary The text emphasizes the need for critical analysis of Demand Side Management (DSM) expenditures to ensure cost-effectiveness and public accountability. It highlights that the cost-effectiveness test applies at the portfolio level, requiring aggregate benefits to exceed costs, with a reference to a prior NSUARB decision on NS Power's 2011 DSM Plan.
1 do so). E1 uses the cost-effectiveness framework to guide the development of its DSM Plan among other 2 factors, including the concept of a balanced portfolio design; equitable allocation of investment and 3 savings between residential a...
AI summary E1's DSM Plan employs a cost-effectiveness framework and balanced portfolio design to ensure equitable access across sectors. While low-income programs may individually fail the TRC test, the overall portfolio passes, enabling broader participation. The NSUARB endorsed the 'Balanced Plan Approach' in its 2022 decision, emphasizing stakeholder collaboration.
1 Overall, the cost-effectiveness test is the primary assessment of a DSM Plan. A benefit-cost ratio threshold 2 of 1.0 or greater of a DSM Plan must always be satisfied at the portfolio level. While measures that do not 3 meet the ratio t...
AI summary The cost-effectiveness test is central to evaluating DSM Plans, requiring a benefit-cost ratio of 1.0 or higher at the portfolio level. While measures failing the TRC test may be included, E1 must justify their inclusion to align with the Balanced Plan Approach. The Board's 2022 Decision emphasizes that measure-level TRC tests could hinder future market development and equitable access, but measures failing TRC should be justified for strategic or long-term benefits.
s provide strategic or long-term 23 benefits. 24 25 [129] Although broadly stated, the Board finds that some of the factors outlined in E1’s 26 response to E1(IG) IR-7(b) provide this justification for the inclusion of the questioned 27 me...
AI summary The Board acknowledges some strategic benefits of E1's measures but downplays arguments about TRC test limitations and non-energy impacts. It emphasizes that future applications must provide individual justifications for measures failing cost-effectiveness tests, while ongoing concerns about the test should be addressed through stakeholder processes.
Page 7 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence
AI summary EfficiencyOne submits a benefit-cost analysis test application as evidence in a regulatory proceeding, seeking approval for a program or initiative. The analysis evaluates the financial and operational impacts of the proposed measure.
1 4. CURRENT AND PROSPECTIVE DSM PLANS 2 4.1 2023-2025 DSM PLAN 3 On September 6, 2022, the NSUARB (as it then was) approved E1’s application for its 2023-2025 DSM Plan 4 (subject to a compliance filing). 5 6 The cost-effectiveness test ap...
AI summary The NSUARB approved E1's 2023-2025 DSM Plan with a compliance filing, directing the development of an optimal cost-effectiveness test. The Board endorsed E1's proposal to review methodologies via the DSMAG ahead of the 2026-2028 Plan. The PUA amendment extended the DSM Plan to 2026 with prescribed investment levels.
er, on March 26, 28 2025, the Nova Scotia government passed an amendment to the PUA that extends the term of the current 29 DSM Plan to December 31, 2026 and prescribes an investment level for the 2026 year of $63,750,000.00. 30 The amendm...
AI summary The Nova Scotia government amended the PUA to extend the 2023-2026 DSM Plan to 2026 with a $63.75M investment target. E1 seeks Energy Board approval for revised performance targets under Board Matter M12249. The TRC test applies to the 2026 DSM year due to its inclusion in the previously TRC-approved 2023-2025 Plan.
Energy Board’s decision in relation to the application for approval of the 17 new BCA test herein, and to ensuring the development of the 2027-2031 DSM Plan is in keeping with the 18 decision. 19 20 5. BOARD JURISPRUDENCE ON COST-EFFECTIVE...
AI summary The Nova Scotia government amended the Public Utilities Act to evaluate cost-effectiveness at the portfolio level for demand-side management (DSM) plans, rather than the program level. This aligns with the Energy Board's decision on the BCA test and the development of the 2027-2031 DSM Plan.
Page 14 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence
AI summary This document is part of a regulatory proceeding related to the EfficiencyOne Benefit-Cost Analysis Test Application, focusing on evidence submission. It involves an analysis of energy efficiency programs and their associated benefits and costs.
st E1 in carrying out this directive. Following a 17 competitive RFP process, E1 retained EFG to act as E1’s consultant in relation to the development of the 18 optimal cost-effectiveness test. 19 20 7.2 EFG SCOPE AND MANDATE 21 EFG’s scop...
AI summary E1 retained EFG to assist in developing a cost-effectiveness test for DSMAG workshops, aligning with Nova Scotia legislation, the NSPM, and using recent local data.
Step 1: • Determine whether to include host customer impacts, low-income impacts, other fuel and water impacts, and/or societal impacts. STEP 4 Ensure that Benefits and Costs are Properly Addressed Ensure that the impacts identified in Steps...
AI summary This section outlines the process for addressing benefits and costs symmetrically and comprehensively, ensuring transparency in documentation, and referencing the eight guiding principles from the NSPM as part of the BCA process.
embers of the Demand Side 11 Management Advisory Group (DSMAG) on a Nova Scotia specific benefit cost framework for screening 12 distributed energy resources, I make the following recommendations: 13 1. E1 adopt the jurisdictionally specif...
AI summary The testimony discusses the adoption of a jurisdictionally specific benefit cost analysis (BCA) framework for screening distributed energy resources in Nova Scotia. The recommendation is for E1 to use the 'Nova Scotia BCA test' as the primary cost-effectiveness test for future DSM plans, including the 2027-2031 plan. The EFG Report provides further detail on the development of this framework.
Non-Energy energy benefits or measure costs (for NEBs and presented and refined Benefits beneficial electrification) proposed NEB proxies with the group. 1 2 5. Comparison of Recommended Nova Scotia Test to Prior Test 3 Q: How does the Nova Sco...
AI summary The Nova Scotia BCA Test recommended by EFG differs from the TRC test used for E1’s 2023-2025 DSM Plan. The TRC test excluded other fuel impacts and non-utility benefits, while the new test includes a broader range of impact categories as outlined in Table 4.
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AI summary The text discusses the analysis of a regulatory proceeding, focusing on the EfficiencyOne Benefit-Cost Analysis (ABC) and its application in evaluating DEF. It references the use of DEF in assessing programs and policies related to energy efficiency and cost-benefit analysis within the context of regulatory oversight.
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AI summary The text discusses regulatory proceedings related to energy efficiency programs, cost recovery mechanisms, and the implementation of energy efficiency initiatives. It references the EfficiencyOne Benefit-Cost Analysis and Nova Scotia Power, emphasizing the importance of cost-effectiveness and program evaluation in the regulatory process.
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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It outlines the application of benefit-cost analysis in regulatory proceedings, including topics such as cost-effectiveness, standard practice, and the evaluation of efficiency programs.
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AI summary The document outlines the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It discusses the application of benefit-cost analysis in the context of energy efficiency programs, including considerations for testing and evaluation methods.
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AI summary The text discusses the regulatory proceedings related to the Board of Fuel Costs (BFC) and the Board of Commissioners (BC), focusing on the implementation of the fuel-cost-adjustment mechanism and the impact of the Public Utilities Act (PQR). It references the need for regulatory oversight and the evaluation of cost-effectiveness and compliance.
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AI summary This section discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the process for evaluating benefit-cost analyses, including considerations for program evaluation, cost-effectiveness, and standard practices in regulatory proceedings.
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AI summary The text discusses the application of a benefit-cost analysis test under the EfficiencyOne program, referencing the National Standard Practice Manual. It outlines the methodology for evaluating the cost-effectiveness of efficiency programs, including the use of standard practice guidelines and the evaluation of demand-side management initiatives.
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AI summary The text discusses the application of a benefit-cost analysis test in the context of efficiency programs, referencing the National Standard Practice Manual. It outlines procedures for evaluating the cost-effectiveness of energy efficiency initiatives and mentions the importance of aligning with regulatory standards.
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AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on base rates, noting a lag of 18 months between actual costs and base rates, which created perverse incentives. It also references the need for regulatory oversight and evaluation of cost-effectiveness in energy programs.
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AI summary This text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines considerations related to benefit-cost analysis, including the evaluation of programs, cost-effectiveness, and the application of national standards for analysis.
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AI summary The document discusses the regulation of energy efficiency programs, including the evaluation of cost-effectiveness, the role of the Board in setting policies, and the implementation of measures such as demand-side management and energy efficiency initiatives. It also touches on the evaluation of program performance and stakeholder engagement.
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AI summary The text discusses the application of a benefit-cost analysis test for EfficiencyOne, referencing regulatory practices and procedures. It touches on topics such as regulatory compliance, cost-effectiveness, and the evaluation of programs and policies.
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AI summary The text discusses the analysis of regulatory proceedings, including the evaluation of programs, policies, and legal frameworks, with a focus on topics such as energy efficiency, affordability, and stakeholder engagement. It also references various regulatory processes and the use of cost-effectiveness and prudence reviews.
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AI summary The text discusses the application of the EfficiencyOne Benefit-Cost Analysis Test, referencing the National Standard Practice Manual. It highlights the importance of assessing the cost-effectiveness of energy efficiency programs and the need for proper evaluation methodologies.
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AI summary The text discusses regulatory proceedings related to utility rates and cost recovery, emphasizing the importance of aligning base rates with actual costs, the role of fuel-cost-adjustment mechanisms, and the evaluation of cost-effectiveness in regulatory decisions. It highlights concerns over potential inefficiencies and the need for proper oversight in rate-setting processes.
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AI summary This text discusses the application of a benefit-cost analysis test under the National Standard Practice Manual for an EfficiencyOne initiative. It outlines the methodology for evaluating efficiency programs, including the consideration of cost-effectiveness, program design, and alignment with regulatory standards.
Utility Gas Emissions emissions System Other Estimated health impacts from Societal Environmental PM, SO2 and NOx air pollutants Embedded in other Public Health E Environmental and GHG Economic Should be addressed outside of Developmen...
AI summary The text discusses the categorization of impacts related to gas emissions, public health, and environmental considerations, emphasizing the need for separate studies outside the BCA framework. It references the structure of these categories and their sub-elements described in the report.
s the new Nova Scotia test include all electric utility system impacts, other fuel impacts, host customer impacts, greenhouse gas impacts, and criteria air pollutant impacts. 2) E1 should screen the cost effectiveness of demand side portfo...
AI summary The new Nova Scotia Jurisdictional Test is proposed to include various system and environmental impacts, and to use updated avoided cost streams for cost-effectiveness screening of demand-side portfolios. The test is expected to evolve, with future responsibility for avoided cost calculations shifting to the Independent Electricity System Operator.
assessed in a separate analysis and that job and that indirect and induced economic impacts not be incorporated into the new jurisdictional test. (See Table 16 and Figure 3). 10) EFG recommends the primary jurisdictional test use a 2% soci...
AI summary EFG recommends using a 2% social discount rate in the primary jurisdictional test for assessing the cost-effectiveness of the E1 portfolio. They also suggest that indirect and induced economic impacts not be included in the test, and that secondary tests like the utility cost test be used for additional perspective, not as a substitute.
energyfuturesgroup.com 20 The results of the illustrative example in Table 5 indicate that the cost effectiveness of the 1,000 heat pump replacements depends upon the type of fuel displaced, and that heat pumps displacing fuel oil or elect...
AI summary The illustrative example in Table 5 shows that replacing 1,000 heat pumps is cost-effective when displacing fuel oil or electric resistance, yielding net benefits of $25 million and $31 million, respectively. However, replacing natural gas with heat pumps results in a net cost increase of $17 million. Electric system costs increase by roughly $26 million in both cases.
Page 23 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 24 achieve a benefit-cost ratio of 1.0 or higher to be considered cost-effective. Looking forward, it is anticipated plan level screening...
AI summary EfficiencyOne (E1) discusses the benefit-cost analysis (BCA) test application for the 2023-2025 Demand Side Management (DSM) Plan. E1 argues that the Test of Reasonableness (TRC) applied is conservative and unbalanced, violating the symmetry principle of the Nova Scotia Power (NSPM). E1 also raised concerns about understated avoided costs and the need for an optimal BCA methodology.
Review Board (NSUARB) to work with the Demand Side Management Advisory Group (DSMAG) “to assess and develop an optimal DSM cost-effectiveness testing [benefit-cost analysis] methodology.” 16 Through a competitive RFP process, E1 hired Ener...
AI summary The NSUARB is working with the DSMAG to develop a new benefit-cost analysis (BCA) methodology for demand-side management (DSM) programs. E1 hired Energy Futures Group, Inc. to support this effort, which involved stakeholder engagement and a review of the current BCA test. There was a lack of consensus on the impacts included in the current test, leading to a recommendation for clearer documentation in the new BCA framework.
cipants included organizational representation from: Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 28 of 68 EfficiencyOne Benefit-Cost An...
AI summary The document is an appendix to a Benefit-Cost Analysis Test Application submitted by EfficiencyOne. It includes contact information for Energy Futures Group, Inc., and references the test application filed on May 16, 2025.
categories such as host customer non-energy benefits or environmental benefits, and therefore they are not recommended for separate accounting to avoid potential double counting of impacts. Working group members also identified additional...
AI summary The document discusses the inclusion of utility system impacts (USIs) in cost-effectiveness tests for DERs, emphasizing the need to compare economic merits of DERs with supply-side alternatives. It highlights potential overlaps in impact categories and notes that not all USI impacts may be relevant or material for every DER.
numerous occasions, and there was some discussion of using percent adders for different measure categories as an alternative to the adjusted measure- based values derived from Massachusetts. During the regulatory review of E1’s NEBs Applic...
AI summary The NSUARB ruled it lacks jurisdiction to consider non-energy impacts in cost-effectiveness testing. E1 included host customer costs and savings in its 2023-2025 DSM Plan, but the NSUARB directed their removal. Despite this, the BCA test in the plan still included some host customer costs.
44 measures installed through E1 initiatives. Following the NSPM’s symmetry principle, if host customer costs are counted, then host customer benefits should also be considered. During the fourth through the sixth DSMAG working group sessi...
AI summary The document discusses the inclusion of non-energy host customer impacts in the cost effectiveness screening of energy efficiency programs, based on the Energy Reform Act (ERA) and discussions from the Demand Side Management Advisory Group (DSMAG). It recommends using proxy adders, differentiated by measure category, DER type, and customer segment, and notes that 18 U.S. jurisdictions incorporate non-energy benefits into such screening.
,234 7,878 2,836 1,398 $308 $ 180 $ - $ 308 0.85 $367,454 2034 84,470 4,234 7,878 2,907 1,327 $313 $ 184 $ - $ 313 0.84 $347,527 2035 84,470 4,234 7,878 2,119 2,115 $317 $ 188 $ - $ 317 0.82 $549,937 2036 84,470 4,234 7,878 2,797 1,437 $32...
AI summary The analysis compares the cost effectiveness of displacing different fuels, showing that displacing heating oil is more cost effective than displacing pipeline gas, with net benefits of over $25 million versus a $20 million increase in net energy costs for pipeline gas, partially offset by GHG benefits.
t on the type of displaced fuel and suggests that measures and program initiatives targeting displacement of heating oil fuel may be more cost effective than displacement of pipeline gas. Energy Futures Group, Inc PO Box 587, Hinesburg, VT...
AI summary The text discusses the cost-effectiveness of measures targeting the displacement of heating oil fuel compared to pipeline gas. It also references an appendix containing a Nova Scotia policies inventory and a working group review of current practices for electric utility system impacts.
63 B. Working Group Review of Current Practice for Electric Utility System Impacts Table B1 is a synthesis of the working group homework assignment and discussions of which electric USIs are currently included in the Nova Scotia screening...
AI summary This section discusses the working group's review of current practices for including electric utility system impacts in the Nova Scotia screening test of energy efficiency and demand response programs. It also outlines the social costs of carbon and greenhouse gas impacts based on Canadian guidance.
E-5E1 (NSEB) RIR 1-46
14 passages
Request IR-01: - Please discuss how the November 9, 2022, Public Utilities Act changes to the level of cost- - effectiveness test from the program level to the portfolio level have changed the analysis - results, citing analysis results, u...
AI summary The November 9, 2022 amendment to the Public Utilities Act changed the cost-effectiveness evaluation level from the program level to the portfolio level. However, this change does not affect how EfficiencyOne performs cost-effectiveness testing or the results, which remain available at multiple levels including the portfolio level.
1 Request IR-03: 2 3 With regards to Table 2 on page 4 of 38 of E1's Evidence: 4 5 (a) Did E1 review any Canadian jurisdictions with similar policy objectives as Nova Scotia to 6 assess how the current TRC test aligns with standard for cos...
AI summary E1 was asked to review Canadian jurisdictions with similar policy objectives to Nova Scotia for cost-effectiveness testing alignment. E1 responded that their research did not include such a review, as a Nova Scotia-specific BCA must reflect the province's own legislative, regulatory, and policy context.
- 2 system benefit that is not measured and is considered not material. 1 Request IR-05: 2 3 Please describe how the BCA as proposed by E1 aligns with the Treasury Board of Canada 4 Secretariat Canada's Cost-Benefit Analysis Guide for Regu...
AI summary The document outlines a request for information on how the proposed BCA by EfficiencyOne aligns with Canadian federal cost-benefit analysis guidelines. The response indicates that E1's framework is consistent with the principles of transparency, comprehensiveness, and evidence-based decision-making as outlined in the 2019 and 2018 federal guidelines.
electrification. Request IR-07: On page 18 of 38 of E1's Evidence, a hyperlink to the "National Energy Screening Project (NESP), National Standard Practice Manual (NSPM) for Benefit-Cost Analysis of Distributed Energy Resource" is provided...
AI summary The request focuses on the National Energy Screening Project (NESP) and its National Standard Practice Manual (NSPM) for Benefit-Cost Analysis (BCA) of distributed energy resources. It asks for details about NESP members, deviations of the proposed BCA test from the NSPM, the use of the MTR handbook, and how many states have adopted the NSPM framework.
ii) How many states in the database are currently using a Societal Cost Test (SCT) for DSM portfolios, programs or measures? (Please identify the related states and whether the test is applied at the measure, program or portfolio level) ii...
AI summary The text lists nine questions about the use of Societal Cost Test (SCT) and measurement of various societal impacts (resilience, environmental, public health, etc.) in Benefit-Cost Analysis (BCA) for Demand-Side Management (DSM) across states in a database. It seeks details on which states apply these tests/impacts and at what level (measure, program, portfolio).
e currently measuring Host Customer "Asset Value" impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure, program or portfolio level.)
AI summary The text asks whether the current Benefit-Cost Analysis (BCA) test measures Host Customer 'Asset Value' impacts, and seeks clarification on the states involved and the level (measure, program, portfolio) at which the test is applied.
x) How many states in the database are currently measuring Host Customer "Water Cost" impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure, program or portfolio level.) xi)...
AI summary The text lists questions inquiring about the number of states measuring various Host Customer impact categories (e.g., Water Cost, O&M Cost) in their BCA tests and the levels at which these tests are applied.
e currently measuring Host Customer "Empowerment" impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure, program or portfolio level.)
AI summary The document questions the current measurement of Host Customer Empowerment impacts within the BCA test, seeking clarification on related states and the level (measure, program, portfolio) at which the test is applied.
xviii) How many states in the database are currently measuring Host Customer "Pride" impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure, program or portfolio level.) (e) P...
AI summary The response discusses the National Energy Screening Project (NESP), its mission to improve cost-effectiveness screening practices for distributed energy resources (DERs), and its products including the National Standard Practice Manual (NSPM) and Methods, Tools, and Resources (MTR) Handbook. It highlights NESP's role in convening stakeholders and providing BCA resources.
Resources Handbook](https://www.nationalenergyscreeningproject.org/resources/quantifying-impacts/) [(MTR Handbook)](https://www.nationalenergyscreeningproject.org/resources/quantifying-impacts/) . NESP is primarily funded by E4TheFuture wi...
AI summary EfficiencyOne proposes a BCA framework aligned with NSPM principles for DSM plans. The framework requires further analysis of utility system impacts, though EFG believes benefits may outweigh costs. Impact quantification will occur during DSM plan development, with the MTR handbook as a technical reference.
M portfolio and plan. The MTR handbook provides a useful technical reference for the steps and resources that will be used in quantifying individual impact categories. (d) [https://www.nationalenergyscreeningproject.org/wp-content/uploads/...
AI summary EfficiencyOne (E1) applies for approval of a new BCA test for DSM plans in Nova Scotia, referencing jurisdictional-specific tests adopted by states like Connecticut and Maine, and the societal cost test used in Arizona and Vermont. The application cites the National Standard Practice Manual (NSPM) and the Database of Screening Practices (DSPs) to support its framework.
E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL 1 propose an optimal cost effectiveness test specifically aligned with Nova Scotia's 2 policy objectives.
AI summary The document proposes an optimal cost-effectiveness test aligned with Nova Scotia's policy objectives, aiming to ensure that energy efficiency initiatives are both economically and environmentally effective.
M12282 – EfficiencyOne (E1) Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans
AI summary EfficiencyOne (E1) seeks approval for a new Benefit-Cost Analysis (BCA) test to evaluate Demand Side Management (DSM) plans under Nova Scotia regulatory proceedings. The application involves assessing DSM initiatives using updated methodologies, with implications for energy policy and regulatory frameworks.
f avoided fuels are counted in the "Other fuels" category, host customer impacts do not include fuel savings benefits for the host (these would be double counted) and focus on the non-energy benefits. Request IR-31: Reference: Appendix B E...
AI summary The response explains that the Planning Reserve Margin (PRM) adjustment reduces Nova Scotia Power's required planning reserve due to demand-side management (DSM). Data sources include NS Power's August 23, 2024, submission and reference to M12249. The adjustment affects E1's cost estimation for avoided capacity.
E-8See new revised evidence submitted under E-14 (Evidence of P. Bowman, on behalf of IG)
19 passages
INTRODUCTION - This Pre-filed Testimony has been prepared by Mr. Patrick Bowman of Bowman Economic Consulting Inc., - retained by the Industrial Group ("IG") of Nova Scotia. This testimony reviews and assesses the 2025 - EfficiencyOne ("E1...
AI summary Mr. Patrick Bowman of Bowman Economic Consulting Inc., retained by Nova Scotia's Industrial Group, prepares pre-filed testimony assessing Efficiency One's 2025 application to implement a new Benefit-Cost Analysis Test for Demand Side Management Plans. The application was filed with the Nova Scotia Energy Board on May 16, 2025. Bowman emphasizes his role as an independent, objective witness with extensive experience in utility regulation and energy efficiency since 1998.
TERMINOLOGY - In assessing DSM (both energy efficiency and strategic electrification), it is necessary to assess cost- - effectiveness, and to utilize a metric to compare benefits and costs. Broadly, this process is termed - Benefit-Cost A...
AI summary The document outlines the use of Benefit-Cost Analysis (BCA) in evaluating Demand Side Management (DSM), with Efficiency One (E1) proposing a Nova Scotia-specific Jurisdiction-Specific Test (JST) termed the Proposed BCA. This approach includes fixed items in benefits and costs, resembling the Societal Cost Test (SCT). BCA inputs are structured at varying levels from Measures/Activities to Programs/Portfolios.
BACKGROUND AND CONTEXT - This evidence relies on the following context for E1, and the broad understanding of the regulation of E1 - and the role of the Board. - E1 is the current franchise holder for development and delivery of DSM plans...
AI summary E1, the current franchise holder for DSM in Nova Scotia, requires Board approval for its DSM activities under the Public Utilities Act sections 79A to 79W. The Act distinguishes between DSM operations and purchase agreements with NSPI but treats both similarly in requiring Board approval. However, the legislation lacks explicit guidance on tests for 'reasonable availability' of DSM, focusing instead on cost-effectiveness.
- directed to conduct a "thorough assessment of the relative merits of both the PAC test and a jurisdiction- - specific test" in order to "determine the optimal cost-effectiveness testing methodology for Nova Scotia." 5
AI summary The document directs a thorough assessment of the PAC test and a jurisdiction-specific test to determine the optimal cost-effectiveness testing methodology for Nova Scotia.
What is E1 proposing as a BCA? - E1 has proposed that its current reliance on the Total Resource Cost ("TRC") screening test for cost- - effectiveness (and to a lesser degree, the Program Administrator Cost ("PAC") test) be replaced by a n...
AI summary E1 proposes replacing the Total Resource Cost (TRC) and Program Administrator Cost (PAC) tests with a new Benefit-Cost Analysis (BCA) tailored to Nova Scotia, incorporating societal impacts. The BCA would apply at the Portfolio level to assess public interest, with a 2% discount rate and proxy adders for non-energy benefits. E1 seeks Board approval for these changes.
EVALUATION OF E1'S PROPOSED BCA
AI summary The document evaluates Efficiency One's proposed Benefit-Cost Analysis (BCA) as part of a regulatory proceeding in Nova Scotia, focusing on energy efficiency programs and their alignment with jurisdiction-specific tests and societal cost considerations.
Why is E1 adopting the new Proposed BCA? - E1 indicates that the previous TRC does not show balance, in that participant costs are included in the - Costs component of the BCA, but the benefits (other than energy savings) received by the p...
AI summary E1 adopts the new Proposed BCA due to the previous TRC's imbalance, where participant costs are included in the Costs component but benefits (excluding energy savings) are omitted from Benefits. Legislative changes are cited as removing prior limitations that led to the unbalanced TRC test.
Is the E1 commentary a fair criticism of the TRC as previously applied in Nova Scotia? - Yes, from a principled perspective. In general, BCA should include all measurable and meaningful benefits - and costs at the proposed assessment scale...
AI summary The E1 commentary criticizes the TRC for excluding non-energy benefits, but the NSUARB previously limited jurisdiction to energy impacts per M08888. The new Energy and Regulatory Boards Act may permit non-energy considerations, though legal interpretation is pending. Technical challenges remain in revising TRC to meet updated requirements.
Scotia? 2020 NSUARB 56 M08888, pdf page 2 of 19. - No. - First, although the legislation indicates that cost-effectiveness shall be measured at the portfolio level, - there is no prohibition against also assessing cost-effectiveness at oth...
AI summary The NSUARB must assess DSM cost-effectiveness at multiple granularity levels, not just portfolio level, to evaluate alternatives and ensure compliance with legislative requirements. E1's proposal fails to address mandatory customer interest assessments, including cost reduction, reliability, and availability, as previously interpreted by the Board.
Is the Proposed E1 BCA the only possible response to the criticism? - No. From the outset, the assessment to be conducted was to consider two alternatives to the TRC – - either relying primarily on PAC, or developing a new Nova Scotia spec...
AI summary The Proposed E1 BCA is not the only response to criticism, as three alternatives exist: relying on PAC, developing a Nova Scotia-specific test, or adjusting TRC to include non-energy benefits. Legislative changes enabled the third approach. References include Public Utilities Act sections and a 2020 NSUARB board order.
1 For conversion of electric resistance heating to heat pumps (energy efficiency): Proposed BCA (societal perspective) PAC (utility and its customers perspective) Benefits = NPV of avoided electric generation and Benefits: NPV of avoided e...
AI summary The document compares the societal benefits of converting electric resistance heating to heat pumps (avoided generation and transmission costs, health benefits, GHG reductions) with the costs (installation and program administration) from the utility and customer perspective. This analysis is part of a regulatory proceeding in Nova Scotia.
OTHER BCA CONSIDERATIONS - E1's Application relies on the National Standard Practice Manual for Benefit-Cost Analysis of - Distributed Energy Resources ("NSPM"), produced by the National Energy Screening Project. - Does E1 appropriately in...
AI summary The NSUARB found E1's BCA methodology inconsistent with the NSPM's principles, particularly Principle 1, which requires treating DERs as utility system resources. E1's approach uses non-standard discount rates and unbalanced plan design, potentially biasing resource investment decisions against residential and business interests.
Why is the E1 proposal on discount rates inconsistent with utility system resources? - In conducting Integrated Resource Planning ("IRP"), utilities typically compare alternative new energy - generation resources using their Weighted Avera...
AI summary The E1 proposal to use a 2% social discount rate for DSM evaluation conflicts with NSPM's requirement for consistent methods, as WACC is standard for utility IRP. Treasury Board guidance cited by E1 applies to regulatory proposals, not infrastructure investments. NSPM mandates equal footing for DSM with other resources using WACC, not lower social rates.
Why is E1's approach of using balanced plan design problematic? - E1 indicates that in addition to cost-effectiveness, its proposals are designed to reflect balance, such as - equitable allocation of investment and savings between resident...
AI summary E1's balanced plan design prioritizes equity and access over cost-effectiveness, conflicting with NSPM Principle 1 and Nova Scotia IRP principles (safety, reliability, least cost, decarbonization, robustness). The NSPM allows balance criteria only with explicit policy, while utility resources are typically evaluated economically, not by equity. Examples like PPA allocation illustrate potential inequities in applying balance without policy mandates.
Should E1's proposal that BCA be conducted only at the Portfolio level be adopted? - No. - Previous sections of this submission highlighted that the Board cannot fulfill its mandate if screening - information or tests are only applied at t...
AI summary The proposal to conduct BCA only at the Portfolio level is rejected, as it would hinder the Board's mandate by failing to identify problematic measures and prevent analysis of customer class cross-subsidization. Measure-level and customer class-level BCA are necessary for effective DSM program evaluation.
Is there any relevance to a Participant Cost Test? - Yes. - E1 should be directed to provide information on the results of the PCT by measure (or comparable - measures, such as customer payback periods), to indicate whether E1 has proposed...
AI summary The Participant Cost Test (PCT) is relevant, requiring E1 to provide PCT results by measure or comparable metrics to ensure proposed incentives are reasonable and cost-effective for Demand Side Management (DSM) participation without being excessive.
Is there any relevance to measurements considering rate impacts, such as a RIM test? - A RIM test should not be applied as a screening test for energy efficiency, as it can derive excessively - narrow metrics and fail to measure proper cos...
AI summary The text argues against using RIM tests as a screening tool for energy efficiency due to their narrow metrics and inadequate cost-effectiveness measurement. However, it recommends that E1 continue reporting rate impacts at multiple granularities to enable the Board's assessment of customer impacts, including non-participants.
Are there other concerns with E1's BCA inputs? - Yes. However, this concern may be more appropriately addressed as part of a specific DSM Plan review, - rather than a BCA review. - E1 has proposed to estimate the benefits of DSM measures u...
AI summary The analysis highlights three concerns with E1's BCA inputs: (1) using inflationary adders instead of evolving baseline conditions for avoided generation costs, (2) misrepresenting GHG emission impacts via average NSPI intensity, and (3) uncertainty about DSM's emission avoidance under fixed emission caps. These issues may require revisiting during DSM plan reviews.
What recommendations do you have? - Based on the above considerations, I provide the following conclusions and recommendations for the Board: - 1) The current primary TRC test is limited in its ability to singularly inform the Board about...
AI summary The text outlines recommendations for the Board regarding the use of benefit-cost analysis (BCA) tests in evaluating demand-side management (DSM) activities. It suggests using the PAC test as the primary energy efficiency test, incorporating the E1 BCA test for broader considerations, and rejecting the E1 Proposed BCA test as the primary test. It also emphasizes the need for cost-effective measures and proper consideration of avoided utility costs and GHG emissions.
E-9Evidence and Resume of Courtney Lane - Synapse
20 passages
BEFORE THE NOVA SCOTIA ENERGY BOARD In the Matter of an Application by EfficiencyOne for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans (NSEB M12282) Evidence of Courtney Lane On Behalf of Counsel...
AI summary EfficiencyOne seeks approval for a new benefit-cost analysis test to evaluate demand side management plans. The proceeding, referenced as NSEB M12282, includes evidence presented by Courtney Lane on behalf of the Nova Scotia Energy Board's counsel.
II. SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS - Q. Please describe your conclusions. - A. My conclusions are: - E1's approach to developing the Nova Scotia Test is reasonable and follows the sound economic guidance from the National Stand...
AI summary The Nova Scotia Test is deemed an improvement over the TRC test for incorporating energy policy goals, other fuels, societal impacts, and non-energy benefits. While proxy values for non-energy benefits are reasonable, E1's justification for specific proxy values is insufficient.
1 be based on a review of literature, proxy values used by other jurisdictions, and 2 should consider differences between jurisdictions. 3 Q. What are your recommendations? 4 A. Based on my conclusions, I offer the following recommendation...
AI summary The text discusses the recommendation to approve the Nova Scotia Test for use in the 2027–2031 DSM Plan, including modifications to NEB proxy adders and a process for updating them in 2029. It also references the current TRC test and its implementation in Nova Scotia, based on the Public Utilities Act.
A. Evidence provided by Synapse on E1's 2023–2025 DSM Plan (M10473) recommended that the Board launch a process to develop a jurisdiction-specific cost-effectiveness test (JST) that reflects Nova Scotia's policy priorities using the NSPM....
AI summary Synapse recommended the Board develop a jurisdiction-specific cost-effectiveness test (JST) for Nova Scotia's DSM Plan, citing issues with the TRC test. E1 rebutted, suggesting a broader review of cost-effectiveness methodologies is needed due to legislative changes and advancements in demand response and electrification.
es 6-12. 7 Rebuttal Evidence of E1 in M10473, June 10, 2022, page 13, lines 12-14. Id ., at page 13, lines 14-17. Evidence of Courtney Lane In its Decision on the 2023–2025 DSM Plan, the Board directed EI "to work with the DSMAG before the...
AI summary E1 complied with the Board's directive to develop an optimal DSM cost-effectiveness test by filing an application for a new BCA test in May 2025, informed by the DSMAG. The process involved seven meetings with an independent consultant, Energy Futures Group, using the NSPM to develop a BCA framework with five steps.
A. The NSPM was developed by the National Energy Screening Project (NESP), an organization working to improve cost-effectiveness screening practices for DERs, [13](#page-9-0) to help guide the development of a jurisdiction's cost-effective...
AI summary The NSPM, developed by the National Energy Screening Project, provides guidance on cost-effectiveness screening for DERs. It introduces the Jurisdictional-Cost Test (JST), which aligns with each jurisdiction's policy goals and allows for modifications over time, addressing issues with traditional tests that are static and may not account for public health or GHG emissions.
Q. Why is it appropriate for Nova Scotia to use the NSPM process? A. The NSPM provides a set of principles and steps to support jurisdictions with the review and modification of an existing cost-effectiveness test or the development of a n...
AI summary Nova Scotia uses the NSPM process to align with the Board's directive to review or develop cost-effectiveness tests. Recent policy changes, such as amendments to the Public Utilities Act expanding demand-side management, necessitate this approach. The NSPM provides structured principles for jurisdictions to evaluate cost-effectiveness, as referenced in Board Decision M10473.
Evidence of Courtney Lane 1 20 programs, and the Energy Reform Act that broadens what the Board should consider 2 when it makes regulatory decisions and establishes the Energy and Regulatory Boards 3 21 Act and the More Access to Energy Ac...
AI summary Courtney Lane discusses the use of the Nova Scotia Policy Model (NSPM) in other jurisdictions, noting that 12 U.S. states and the District of Columbia have adopted it for DER cost-effectiveness tests. She also states that no Canadian provinces have used the NSPM for BCA tests, but sees no reason why they should not. The NSPM is described as objective, policy-neutral, and economically sound.
Q. If an impact is not applicable or not material, should it be excluded from the Nova Scotia Test? A. No, it should not. It is important to distinguish between the definition of the BCA test and the application of the test. All utility sy...
AI summary The Nova Scotia Energy Board (NSEB) asserts that impacts should not be excluded from the Nova Scotia Test even if not applicable or material. The distinction between the BCA test's definition and its application is critical, ensuring all relevant impacts are included for policy goals while allowing exclusion in specific DER cases. This approach supports transparency and consistency in cost-effectiveness evaluations.
Q. How will the Nova Scotia Test be used to determine cost-effectiveness? - A. As was done in the prior DSM Plans, E1 will conduct the BCA at the measure, program - component, program, resource, and portfolio (i.e., Plan) levels and will m...
AI summary The Nova Scotia Test will evaluate DSM Plans' cost-effectiveness at the portfolio (Plan) level, per the November 9, 2022, Public Utilities Act amendment. E1 will conduct BCA analyses at multiple levels, but the Board's evaluation focus has shifted from program to portfolio level.
Q. What is your overall assessment of the proposed Nova Scotia Test? - A. I find that the proposed Nova Scotia Test is an improvement upon the current TRC test. - Unlike the current TRC test, the Nova Scotia Test accounts for both host cus...
AI summary The proposed Nova Scotia Test is considered an improvement over the current TRC test as it accounts for host customer benefits and costs, ensuring proper valuation of DERs and avoiding biased BCA results. It aligns with Nova Scotia's energy policy goals by incorporating non-energy impacts as directed by recent legislation.
Review of Policy Developments Impacting Host Customer NEBs
AI summary The document reviews policy developments affecting Host Customer NEBs, focusing on regulatory frameworks, cost methodologies, and energy management practices in Nova Scotia. Key considerations include DSM, WACC, and GHG regulations, with references to national standards and cost tests.
Q. Did the DSMAG previously investigate NEBs? - A. Yes. As part of the Settlement Agreement in the 2016–2018 DSM Plan, the parties to the settlement agreed to work with the DSMAG "to pursue the nature and quantification of estimates associ...
AI summary The DSMAG investigated non-energy benefits (NEBs) as part of the 2016–2018 DSM Plan, with E1 retaining VEIC to develop NEB values. In 2020, the Board ruled it lacked jurisdiction to consider NEBs in cost-effectiveness testing under the Public Utilities Act.
Nova Scotia Utility Board, Decision in M0888, April 15, 2020, paragraph 49. 1 benefits and an array of environmental benefits with the definition of electricity 2 44 efficiency and conservation activities in the Public Utilities Act. Speci...
AI summary The Nova Scotia Utility Board discusses the reevaluation of cost-effectiveness criteria, incorporating environmental and non-energy benefits, based on recent legislative changes such as the Energy Reform Act and the Environmental Goals and Climate Change Reduction Act. This reevaluation aims to align rate-setting with broader policy goals, including sustainability and market competition.
Evidence of Courtney Lane states that the long-term objective of the Government is to achieve sustainable prosperity, which includes supporting "the well-being and quality of life for all Nova Scotians" and working towards "continues impro...
AI summary Courtney Lane argues the Nova Scotia Energy Board (NSEB) should reconsider its authority to include Non-Energy Benefits (NEBs) in cost-effectiveness screening. E1 proposes quantifying NEBs like asset value, productivity, and health using proxy adders from EFG. The analysis references the Environmental Goals and Climate Change Reduction Act (SNS 2021, c 20) and cites matter M12282.
in Table 4 are already within that range and can be approved without modification. Should E1 want to include the higher NEB values, it should provide justification in its upcoming 2027-2031 DSM Plan. Sutter, M., J. Mitchell-Jackson, S. Sch...
AI summary The document states that values in Table 4 are within an approved range and can be accepted without changes. However, if E1 wishes to use higher NEB values, it must justify this in its 2027-2031 DSM Plan. References to studies on non-energy benefits and cost-benefit analyses are provided.
1 I further recommend that the Board direct E1 to launch a process for updating the NEB 2 proxies in 2029 for use in the next DSM Plan. 3 4 Q. Should the Board choose not to adopt the use of host customer NEBs, is there an alternative appr...
AI summary The text discusses the recommendation to update the Non-Energy Benefits (NEB) proxies in 2029 for the next DSM Plan. It also explores the impact of excluding host customer costs and benefits from Benefit-Cost Analysis (BCA) for DERs such as solar PV and EVs, highlighting the need for a comprehensive cost-effectiveness test that includes host customer impacts.
PROFESSIONAL EXPERIENCE Synapse Energy Economics, Inc. , Cambridge, MA. Senior Principal , August 2024 – Present, Principal Associate , September 2022 – August 2024, Senior Associate, November 2019 – September 2022. Provides consulting and...
AI summary The individual's professional experience spans energy consulting, policy analysis, and regulatory work, focusing on demand-side management, energy efficiency, distributed energy resources, and performance-based regulation. Roles include senior positions at Synapse Energy Economics, National Grid, and advocacy groups, with expertise in benefit-cost assessment, program evaluation, and stakeholder engagement in energy initiatives.
PUBLICATIONS Woolf, T., M. Whited, C. Lane. 2025. Identifying and Accounting for Transfers in Benefit‐Cost Analysis of Distributed Energy Resources . Synapse Energy Economics for the National Energy Screening Project. Fortman, N., J. Micha...
AI summary The document lists publications related to benefit-cost analysis (BCA) of distributed energy resources (DERs), energy efficiency programs, and clean vehicle policies. Key contributors include Synapse Energy Economics, the National Energy Screening Project (NESP), and E4TheFuture. Topics span equity in DERs, rate impacts, and macroeconomic clean energy scenarios.
y for Authority to Implement a Multiyear Rate Plan for Electric Distribution Service in the District of Columbia. On behalf of the District of Columbia Government. January 12, 2024 and April 22, 2024. Maryland Public Service Commission (Ca...
AI summary Testimonies by Courtney Lane in multiple regulatory cases across Maryland, New Hampshire, and the District of Columbia regarding electric vehicle programs, cost recovery, and benefit-cost analysis for utility rate plans. Testimonies were provided on behalf of the Maryland Office of People's Counsel and the Office of Consumer Advocate in cases involving Potomac Electric Power Company, Liberty Utilities, and Baltimore Gas and Electric Company.
E-10-(i)Resume of Francis Wyatt
10 passages
Professional Experience December 2005 – Present Co-Founder, Green Energy Economics Group, Inc ., Cuttingsville, VT. Consultancy specializing in energy-efficiency and renewable resource portfolios investing in electricity and gas savings, c...
AI summary The individual's professional experience spans energy efficiency, renewable resources, and civil engineering. They co-founded Green Energy Economics Group, Inc., developed cost-effectiveness models for demand-side management, and worked on energy-saving analyses. Previous roles include Senior Analyst at Optimal Energy, Inc., and civil engineering positions at Enman Engineering and Nowlan Engineering. Their work includes utility regulatory proceedings and program planning.
Ontario Ontario Energy Board Served on the Stakeholder Advisory Group (SAG): provided expert advice on efficiency program design and potential study analysis. 2023 - 2024. Small Business Utility Alliance Reviewed Enbridge DSM plan and part...
AI summary The Ontario Energy Board served the Stakeholder Advisory Group (SAG) on efficiency program design (2023-2024). The Small Business Utility Alliance reviewed Enbridge's DSM plan, participated in a litigated proceeding (Matter No. EB-2021-0002, 2021-2022), and testified on program design, cost effectiveness, and stakeholder engagement.
Vermont - Reviewed and analyzed program proposals for the Community Energy & Efficiency Development Fund (CEED Fund), including the development of scoring and rebalancing mechanisms and reviewing and revising cost-effectiveness analyses fo...
AI summary Activities include analyzing the Community Energy & Efficiency Development Fund (CEED Fund) proposals, developing cost-effectiveness models for energy efficiency programs, supporting Efficiency Vermont's operations, and assisting Vermont Gas Systems' transition. Work spans 2000–2017, focusing on energy efficiency, reliability gap assessments, and technical tool development for utilities in Vermont.
Pennsylvania Program design, implementation planning, regulatory support, technical reference manual development and portfolio cost-effectiveness tool for Columbia Gas of Pennsylvania. Assisted - with testimony before the Pennsylvania Publ...
AI summary Activities include program design, regulatory support, and testimony preparation for energy companies in Pennsylvania before the PUC. Involves Columbia Gas, Philadelphia Gas Works, UGI Gas, and Peoples Natural Gas, with multiple docket numbers spanning 2006–2022. Focuses on energy efficiency, cost-effectiveness analysis, and portfolio design.
Wisconsin Portfolio and project cost-effectiveness calculator development. Cost-effectiveness analysis, assistance with contractor selection and regulatory support for 3-year energy-efficiency portfolio for Focus on Energy in Wisconsin. Ju...
AI summary A 3-year energy-efficiency portfolio project for Focus on Energy in Wisconsin (2011–2013) involved developing a cost-effectiveness calculator, conducting analyses, supporting contractor selection, and providing regulatory assistance.
Louisiana Empirical costs projections and cost-effectiveness analysis of alternative energy-efficiency resource acquisition scenarios for Entergy New Orleans, prepared for the Alliance for Affordable Energy and submitted as comments to the...
AI summary Empirical cost projections and cost-effectiveness analysis of energy-efficiency resource acquisition scenarios for Entergy New Orleans were prepared by the Alliance for Affordable Energy and submitted to the City Council in April-May 2013 as part of a regulatory proceeding.
District of Columbia Developed multi-measure cost-effectiveness screening tool for the District of Columbia Sustainable Energy Utility, as a subcontractor to Vermont Energy Investment Corporation. November 2011 – 2014.
AI summary A multi-measure cost-effectiveness screening tool was developed for the District of Columbia Sustainable Energy Utility by Vermont Energy Investment Corporation as a subcontractor between November 2011 and 2014.
Illinois Portfolio and project cost-effectiveness calculator development. Cost-effectiveness analysis, assistance with contractor selection and regulatory support for 3-year energy-efficiency portfolio for Peoples Gas in Illinois. Septembe...
AI summary Development of a cost-effectiveness calculator for Peoples Gas Illinois' 3-year energy-efficiency portfolio (2008-2012), including analysis, contractor selection support, and regulatory assistance.
People's Republic of China - Developed portfolio and project economic and financial analysis tools for use in China, and provided remote and in-person training sessions on use. For Natural Resources Defense Council and Institute for Sustai...
AI summary The text details work on energy efficiency projects in China, including economic analysis tools for the Natural Resources Defense Council, efficiency retrofits for Guangdong's Economic and Trade Commission, and prefeasibility studies for an Asian Development Bank loan. Projects involved Jiangsu province, Shanghai municipality, and Efficiency Power Plant assessments.
PRIOR ASSIGNMENTS (RESOURCE INSIGHT) – 1992-1996 - Technical assistance on DSM program development in the Potomac Electric Power Company collaborative, for the Maryland Office of People's Counsel. Work included characterizing new energy-ef...
AI summary The text details technical contributions to DSM program development (1992–1996), including cost-effectiveness analysis, program design, and regulatory support. Key activities involve commercial/industrial energy efficiency measures, IRP reviews, and stakeholder negotiations. Entities include utilities, regulatory bodies, and environmental organizations.
E-14Evidence of P. Bowman, on behalf of IG - Revised (Old evidence filed under E-8)
16 passages
PRE-FILED TESTIMONY OF PATRICK BOWMAN IN REGARD TO EFFICIENCY ONE ("E1") BENEFIT-COST ANALYSIS TEST ("BCA") Submitted to: The Nova Scotia Energy Board on behalf of The Industrial Group Prepared by: Bowman Economic Consulting Inc. 161 Rue H...
AI summary Patrick Bowman of Bowman Economic Consulting Inc. submitted a pre-filed testimony to the Nova Scotia Energy Board on behalf of The Industrial Group regarding the Efficiency One (E1) Benefit-Cost Analysis (BCA) test. The document outlines the submission's context, including the preparer and revision date.
INTRODUCTION - This Pre-filed Testimony has been prepared by Mr. Patrick Bowman of Bowman Economic Consulting Inc., - retained by the Industrial Group ("IG") of Nova Scotia. This testimony reviews and assesses the 2025 - EfficiencyOne ("E1...
AI summary Mr. Patrick Bowman of Bowman Economic Consulting Inc., retained by Nova Scotia's Industrial Group, provides pre-filed testimony assessing Efficiency One's 2025 Application to implement a new Benefit-Cost Analysis Test for Demand Side Management Plans. The Application was filed with the Nova Scotia Energy Board on May 16, 2025. Bowman emphasizes his role as an independent, objective witness with extensive experience in utility regulation and energy efficiency.
TERMINOLOGY - In assessing DSM (both energy efficiency and strategic electrification), it is necessary to assess cost- - effectiveness, and to utilize a metric to compare benefits and costs. Broadly, this process is termed - Benefit-Cost A...
AI summary The document outlines the use of Benefit-Cost Analysis (BCA) in evaluating Demand Side Management (DSM) initiatives, emphasizing the Jurisdiction-Specific Test (JST) as a regulatory framework. E1 proposes a Nova Scotia-specific BCA, termed the 'Proposed BCA,' which incorporates fixed items in benefit and cost calculations. This approach is compared to the Societal Cost Test (SCT) and involves hierarchical categorization of DSM measures into programs and portfolios.
BACKGROUND AND CONTEXT - This evidence relies on the following context for E1, and the broad understanding of the regulation of E1 - and the role of the Board. - E1 is the current franchise holder for development and delivery of DSM plans...
AI summary E1, the current DSM franchise holder in Nova Scotia, requires Board approval for DSM activities under the Public Utilities Act sections 79A to 79M. The Act links DSM operations and purchase agreements with NSPI, requiring Board review. However, legislative guidance on 'reasonable availability' tests is absent, focusing only on cost-effectiveness within availability constraints.
- directed to conduct a "thorough assessment of the relative merits of both the PAC test and a jurisdiction- - specific test" in order to "determine the optimal cost-effectiveness testing methodology for Nova Scotia.["](#page 1-6) 5
AI summary The document directs a thorough assessment of the PAC test and a jurisdiction-specific test to determine the optimal cost-effectiveness testing methodology for Nova Scotia.
What is E1 proposing as a BCA? - E1 has proposed that its current reliance on the Total Resource Cost ("TRC") screening test for cost- - effectiveness (and to a lesser degree, the Program Administrator Cost ("PAC") test) be replaced by a n...
AI summary E1 proposes replacing Nova Scotia's current TRC and PAC tests with a new BCA that evaluates total societal impacts, aligning with policy objectives. The BCA would assess portfolios for public interest and seek approval for a 2% discount rate and proxy adders for non-energy benefits. E1 also requests board direction on these proposals.
EVALUATION OF E1'S PROPOSED BCA
AI summary The evaluation of E1's proposed Benefit-Cost Analysis (BCA) is being reviewed by the NSUARB, considering its alignment with the Societal Cost Test (SCT) and Jurisdiction-Specific Test (JST). Key focus areas include demand-side management (DSM) effectiveness, program administrator costs (PAC), and total resource costs (TRC).
Why is E1 adopting the new Proposed BCA? - E1 indicates that the previous TRC does not show balance, in that participant costs are included in the - Costs component of the BCA, but the benefits (other than energy savings) received by the p...
AI summary E1 is adopting the new Proposed BCA because the previous TRC test does not balance participant costs and benefits, and legislative changes have removed prior limitations. The NSUARB previously imposed an unbalanced TRC test.
Is the E1 commentary a fair criticism of the TRC as previously applied in Nova Scotia? - Yes, from a principled perspective. In general, BCA should include all measurable and meaningful benefits - and costs at the proposed assessment scale...
AI summary The E1 commentary is considered a fair criticism of the TRC in Nova Scotia for excluding non-energy benefits. However, prior TRC application was restricted by M08888, which limited the Board’s jurisdiction. The new Energy and Regulatory Boards Act may permit non-energy considerations, though legal interpretation is pending. Technical challenges remain in revising the TRC test if jurisdiction expands.
Does E1 appear to accurately portray the economic and policy framework for DSM in Nova Scotia? 2020 NSUARB 56 M08888, pdf page 2 of 19. - No. - First, although the legislation indicates that cost-effectiveness shall be measured at the port...
AI summary The document states E1 does not accurately portray the DSM framework in Nova Scotia. The NSUARB must assess cost-effectiveness at granular levels beyond the portfolio level to meet legislative requirements, including evaluating alternative DSM plans. E1's proposal fails to address customer interests, which the Board mandates as central to DSM assessments.
Is the Proposed E1 BCA the only possible response to the criticism? - No. From the outset, the assessment to be conducted was to consider two alternatives to the TRC – - either relying primarily on PAC, or developing a new Nova Scotia spec...
AI summary The Proposed E1 BCA is not the only response to criticism. Alternatives include using PAC, developing a new test, or adjusting TRC to balance non-energy benefits. Legislative changes enabled a third approach. Cited sections of the Public Utilities Act and a 2020 NSUARB order (M08888) are referenced.
OTHER BCA CONSIDERATIONS - E1's Application relies on the National Standard Practice Manual for Benefit-Cost Analysis of - Distributed Energy Resources ("NSPM"), produced by the National Energy Screening Project. - Does E1 appropriately in...
AI summary E1's Benefit-Cost Analysis (BCA) approach is criticized for violating Principle 1 of the National Standard Practice Manual (NSPM) for DERs, which mandates treating DERs as utility system resources and comparing them with other resources using consistent methods. The NSUARB argues E1's BCA uses inconsistent inputs like discount rates and unbalanced plan design.
Why is E1's approach of using balanced plan design problematic? - E1 indicates that in addition to cost-effectiveness, its proposals are designed to reflect balance, such as - equitable allocation of investment and savings between resident...
AI summary E1's balanced plan design approach is criticized for prioritizing equity and access over cost-effectiveness, conflicting with NSPM Principle 1. The NSPM emphasizes cost-effectiveness as the primary DSM test unless explicitly mandated by policy. Nova Scotia's IRP principles (safety, reliability, least cost, decarbonization, robustness) are highlighted as the foundation for resource planning, with balance not typically justified in rate-funded DSM programs.
Should E1's proposal that BCA be conducted only at the Portfolio level be adopted? - No. - Previous sections of this submission highlighted that the Board cannot fulfill its mandate if screening - information or tests are only applied at t...
AI summary The submission argues against E1's proposal to conduct BCA only at the Portfolio level, stating it would prevent identifying outliers and hinder the Board's mandate. It emphasizes the need for customer-class-level analysis to address cross-subsidization and align with NSPM guidelines. Current DSM cost recovery methods also require class-specific cost assessments.
Are there other concerns with E1's BCA inputs? - Yes. However, this concern may be more appropriately addressed as part of a specific DSM Plan review, - rather than a BCA review. - E1 has proposed to estimate the benefits of DSM measures u...
AI summary Concerns exist with E1's BCA inputs, particularly its use of inflation-adjusted long-term avoided generation costs and average GHG intensity metrics. These approaches may not align with utility planning standards or Treasury Board guidelines, as they fail to account for evolving baseline conditions, incremental GHG impacts, and fixed emission caps. The analysis should inform future DSM plan justifications.
SUMMARY
AI summary The document outlines a regulatory proceeding in Nova Scotia involving efficiency programs, cost tests, and stakeholder analyses. Key entities include Nova Scotia Power Inc. (NSPI) and the Nova Scotia Utility and Regulatory Board (NSUARB). The discussion centers on Benefit-Cost Analysis (BCA), Demand Side Management (DSM), and tests like the Societal Cost Test (SCT) and Jurisdiction-Specific Test (JST).
E-24Rebuttal Evidence of E1 including Appendix A - Energy Futures Group Rebuttal Evidence
28 passages
EfficiencyOne IN THE MATTER OF The Public Utilities Act , RSNS 1989, c. 380, as amended -and- IN THE MATTER OF An Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans
AI summary The document pertains to a regulatory proceeding under the Public Utilities Act, RSNS 1989, c. 380, involving an application to approve a new benefit-cost analysis test for evaluating demand side management plans. EfficiencyOne is referenced as the subject of the proceeding.
1 1. INTRODUCTION - On May 16, 2025, EfficiencyOne ("E1") submitted an Application for Approval of a New Benefit-Cost - Analysis ("BCA") Test for Evaluating Demand Side Management ("DSM") Plans before the Nova Scotia - Energy Board (the "B...
AI summary EfficiencyOne submitted a new BCA test for DSM plans to the Nova Scotia Energy Board in Matter 12282. Multiple intervenors, including Synapse and the Industrial Group, provided evidence, with E1 rebutting claims about alternative BCA tests, portfolio-level cost-effectiveness, proxy values for non-energy benefits, and discount rates. The Industrial Group opposed E1's proposed framework, prompting E1's detailed rebuttal.
Bowman Scotia.[1](#page-4-2) He states: The evidence of Patrick Bowman of Bowman Economic Consulting Inc., for the Industrial Group, represents the only intervenor party to take issue with E1's position that cost-effectiveness screening of...
AI summary Patrick Bowman of Bowman Economic Consulting Inc. challenges E1's position that DSM cost-effectiveness should be assessed at the portfolio level, arguing that the legislation allows for granular assessments at program or measure levels. He asserts the Board must evaluate alternative DSM plans at various scales to ensure cost-effectiveness and compliance with statutory mandates, including customer interests and reasonable program availability.
E1 Response - The argument that the Board can, and must, measure cost-effectiveness at the measure level requires - legislative interpretation and is a legal argument. Questions of law are within the power of the Board to - determine. Nota...
AI summary E1 argues that measure-level cost-effectiveness testing for DSM may hinder proactive market development and reduce overall benefits, advocating for portfolio-level evaluation. The Board previously allowed program-level screening but 2022 legislative amendments now mandate portfolio-level assessment. E1 asserts BCA is primarily a portfolio-level tool but will also be used at lower levels for informational purposes.
2.2.2 N S POWER CUSTOMER INTERESTS Unlike the PAC test, which accounts for only the DSM Administrator's costs and NS Power's avoided costs, the BCA test accounts for the DSM Administrator's costs and customer costs while recognizing the ex...
AI summary The BCA test is preferred over PAC and UCT as it includes customer costs and legislative requirements like those from the Energy Reform (2024) Act, ensuring alignment with sustainable development and ratepayer interests.
Bowman Mr. Bowman further submits: E1 should be directed to pursue measures and programs that are cost-effective as the primary criteria, minimizing the other "balanced" criteria in program design to support non-cost-effective measures and...
AI summary Mr. Bowman argues that EfficiencyOne (E1) should prioritize cost-effective measures in its programs, minimizing other criteria that might support less cost-effective initiatives. This submission references evidence from Efficiency Canada and prior testimony.
E1 Response - E1 submits that the non-USIs considered in the proposed BCA test address the goals of strategic - electrification, sustainable development and sustainable prosperity. All these goals are legislated matters - for consideration...
AI summary E1 argues that non-USIs in the BCA test align with legislated goals of strategic electrification and sustainable development. They oppose narrowing DSM criteria, claiming it would undermine secondary objectives and contradict stakeholder-supported Balanced Plan Approach, harming ratepayer interests and effective demand-side management.
Bowman Mr. Bowman suggests that E1's focus on balanced plan design is problematic. He explains: [T]his is generally inconsistent with NSPM Principle 1, unless explicitly established by policy. Just as generation energy resources are compar...
AI summary Mr. Bowman argues that E1's emphasis on balanced plan design conflicts with NSPM Principle 1, which prioritizes cost-effectiveness for DSM over equity and access. He highlights that utility resources are not typically designed for balance, using wind developer PPA examples. He reaffirms Nova Scotia's IRP principles: safety, reliability, least cost, decarbonization, and robustness to assumption changes, unless explicit policy mandates balanced DSM access.
ISSIONS - Bowman - Mr. Bowman asks that the Board require E1 to show that any avoided GHG emissions are in fact the result - of DSM, and not due to an outside factor such as a cap.[15](#page-11-2) - E1 Response - As part of the 'evergreen'...
AI summary E1 responds to Bowman's request for demonstrating GHG emission reductions from DSM by proposing a methodology that accounts for emissions caps. E1 clarifies that PCT and payback periods are program design tools, not directly addressed by BCA. The analysis emphasizes differentiating DSM impacts from external factors and aligns with E1's incentive-setting framework.
E1 Response - E1 supports this recommendation with the addition of a review and update for all impacts—not solely - those related to NEB proxies—commencing prior to the development of the next DSM Plan via the - proposed 'evergreen' proces...
AI summary E1 supports a recommendation to review all impacts, not just non-energy benefits (NEB) proxies, via an 'evergreen' process before developing the next DSM Plan. Engagement with DSMAG is expected to begin in 2029. E1 proposes a multi-step process to ensure the BCA test remains current, including quantifying impacts using jurisdictional data and customer surveys, with DSMAG input.
Green Energy Mr. Wyatt states: I express overall support of the proposed benefit cost test as a more balanced test. The new benefit values in the proposed test should be vetted and include stakeholders in the process.[20](#page-13-2)
AI summary Mr. Wyatt supports the proposed benefit-cost test as more balanced, advocating for stakeholder involvement in vetting new benefit values.
Green Energy Mr. Wyatt raised the following concern: I support the addition of externalized cost of carbon in the new test, but ask that the internalized cost of carbon be kept separate from the externalized cost of carbon for use with the...
AI summary Mr. Wyatt supports including externalized carbon costs in the new test but advocates keeping internalized carbon costs separate for use with the Program Administrator Cost (PAC) test, as noted in footnote 21.
Daymark - Melissa Whitten of Daymark Energy Advisors, Inc. ("Daymark") provides the following observations and - conclusions regarding the Application: - The proposed BCA test framework relies on proxy values for certain non-energy - benef...
AI summary Daymark Energy Advisors criticizes the proposed BCA test framework for relying on unquantifiable proxy values for non-energy benefits, warning that this could introduce bias and lead to suboptimal DSM Plan decisions. They argue that plans derived from biased frameworks should not be prioritized for customers.
E1 Response E1's position is that the use of proxy values for certain non-energy benefits is both reasonable and appropriate and consistent with jurisdiction specific studies. The NSPM for screening energy efficiency and distributed energy...
AI summary E1 argues that using proxy values for non-energy benefits (NEBs) in BCA is reasonable and aligns with the NSPM, supported by EFG and Synapse Energy Economics. E1 rejects claims of bias, emphasizing symmetric treatment of impacts. Daymark's Melissa Whitten counters, requesting third-party validation of NEB quantification (amenity, empowerment, pride).
5.3 QUANTIFICATION
AI summary This section outlines the quantification process in the Nova Scotia regulatory proceeding, involving Nova Scotia Power (NSP) and the Nova Scotia Utility and Review Board (NSUARB). It focuses on Benefit-Cost Analysis (BCA) and Demand Side Management (DSM), with considerations of non-energy benefits (NEB) and adherence to the National Standard Practice Manual (NSPM).
Daymark - In the alternative to the recommendation for further analysis on NEBs, Ms. Whitten suggests that the - Board "make the value assigned to the Unquantified Non-Energy Benefits Nil until the work outlined above - can be completed an...
AI summary Ms. Whitten recommends that the Board set the value of Unquantified Non-Energy Benefits (NEBs) to Nil until further analysis is completed and approved. This suggestion is part of a regulatory proceeding involving a Benefit-Cost Analysis (BCA) framework for Nova Scotia, with references to evidence and appendices from Matter M12282.
E1 Response - To assign a nil value to unquantified NEBs defaults such benefits to zero, notwithstanding the associated - benefit. Utilising this approach would lead to greater distortion of the results than employing the - conservative pr...
AI summary The response criticizes assigning nil values to unquantified Non-Energy Benefits (NEBs) in Benefit-Cost Analysis (BCA), arguing this distorts results. It advocates using E1's conservative proxy values instead, citing Francis Wyatt of Green Energy's perspective on the issue.
Posterity Group - Posterity Group Consulting Inc. ("Posterity") "recommends that E1 specifically recognize the benefits of - hybrid heating to reduce peak load impacts as part of the 2027-2031 DSM Plan,"[34](#page-18-4) and prepared two -...
AI summary Posterity Group Consulting Inc. recommends that E1 recognize hybrid heating's benefits in reducing peak load impacts for the 2027-2031 DSM Plan, supported by BCA examples. They cite evidence from M12282.
E1 Response - E1 acknowledges the value of hybrid heating. Such measures can accurately be evaluated under the - proposed BCA framework. The inclusion of specific hybrid heating measures may be considered in the - 2027-2031 DSM Plan, but p...
AI summary E1 acknowledges the value of hybrid heating measures, which can be evaluated under the proposed BCA framework. Specific hybrid heating measures may be included in the 2027-2031 DSM Plan, though program design decisions remain pending.
E1 Response - E1 notes that NS Power's avoided cost of capacity implicitly includes reliability impacts through a planning reserve margin adjustment. This captures any changes in reliability requirements based on changes in load. If reliab...
AI summary E1 notes that NS Power's avoided cost of capacity includes reliability impacts via a planning reserve margin adjustment. This accounts for reliability changes based on load variations. E1 suggests that if reliability differs between scenarios, incremental reliability impacts beyond existing avoided costs could be assessed.
Eastward Eastward Energy also argues: [...A]ny benefit cost analysis related to natural gas must incorporate the expanded legislated mandate of the natural gas system as noted above. It must also capture the lost value of the natural gas s...
AI summary Eastward Energy argues that any benefit-cost analysis (BCA) for natural gas must account for the expanded legislated mandate of the natural gas system and the lost value of system reliability, as highlighted in a cited reference.
7.5 DSMAG PARTICIPATION EASTWARD
AI summary Section 7.5 discusses DSMAG's participation in the Eastward project, emphasizing the need for Benefit-Cost Analysis (BCA) and Non-Energy Benefits (NEB) assessments. The NSUARB oversees the process, with E1 and EFG involved as key participants.
Rebuttal Evidence of Energy Futures Group Inc. M12282 IN THE MATTER OF The Public Utilities Act , RSNS 1989, c. 380, as amended -and- IN THE MATTER OF An Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Si...
AI summary Energy Futures Group Inc. (EFG) submits rebuttal evidence in M12282 regarding a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans under the Public Utilities Act. The proceeding involves Nova Scotia Energy Board and focuses on DSM program evaluation methodologies.
Synapse Courtney Lane of Synapse states: - The use of proxy values is a reasonable approach to estimate host customer non energy benefits (NEB) in cost-effectiveness analysis. However E1 has not sufficiently justified its proposal for NEB...
AI summary Courtney Lane of Synapse argues that while proxy values are reasonable for estimating non-energy benefits (NEB) in cost-effectiveness analysis, EfficiencyOne (E1) has not adequately justified its proposed NEB proxy values. She emphasizes the need for proxies to be grounded in literature, other jurisdictions' practices, and jurisdictional differences rather than arbitrary choices.
EFG Response The approach of using proxy values was deliberate and not arbitrary. The approach was reviewed and discussed with the Demand Side Management Advisory Group ("DSMAG") in two workshop sessions, and open to written review and com...
AI summary EFG defends using proxy values for non-energy impacts (NEIs), citing discussions with DSMAG and referencing the ACEEE database. They argue that adopting values from other jurisdictions is imprecise and that proxy adders, though small, require regular review to remain accurate. EFG recommends adopting their proposed values with an ongoing 'evergreening' process.
EFG Response - To make the value assigned to the unquantified NEBs nil would result in bias the result which Ms. Whitten - is seeking to avoid. E1 notes that completely excluding known, but hard-to-quantify benefits would default - such be...
AI summary EFG argues against setting unquantified non-energy benefits (NEBs) to zero in benefit-cost analysis (BCA), stating it would bias results. They suggest using conservative proxy values instead, as proposed by E1, to avoid distorting BCA outcomes.
8 4. BOWMAN EVIDENCE
AI summary Section 8.4 of the regulatory proceeding document presents Bowman's evidence, which likely involves analysis related to energy efficiency, demand-side management, and benefit-cost assessments in Nova Scotia. Key entities and acronyms are referenced, including regulatory bodies and programs.
4.2 2% DISCOUNT RATE
AI summary This section discusses the application of a 2% discount rate in the Benefit-Cost Analysis (BCA) for regulatory proceedings in Nova Scotia. The analysis involves considerations by Nova Scotia Power (NSP) and the Nova Scotia Utility and Review Board (NSUARB), focusing on the implications of this rate for energy and non-energy benefits.
100256Board Decision
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IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF AN APPLICATION by EFFICIENCYONE for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans BEFORE: Stephen T. McGrath, K.C., Chair Steven...
AI summary EfficiencyOne applied for approval of a new benefit-cost analysis test for demand side management plans. The Board rejected the application, directing instead to focus on reducing electricity costs for customers. Multiple intervenors, including consumer advocates, industry groups, and Nova Scotia Power, participated in the proceeding.
- [1] In the course of addressing EfficiencyOne's (E1) application to the Nova Scotia Utility and Review Board (NSUARB) for approval of its supply agreement with Nova Scotia Power Incorporated (NS Power) and demand-side management (DSM) re...
AI summary The NSUARB is reviewing EfficiencyOne's application for a supply agreement with NS Power and its DSM plan. Concerns were raised about the cost-effectiveness test used, specifically the TRC test, which excludes non-energy benefits. Synapse recommended using the PAC test instead, though it does not account for participant costs and benefits.
2.0 PROPOSED BENEFIT-COST ANALYSIS TEST - [8] E1 is the holder of a franchise issued by the Minister of Energy to provide demand-side management activities to NS Power. Under the Public Utilities Act , E1 must develop a demand-side managem...
AI summary E1, a franchise holder under the Public Utilities Act, must develop demand-side management (DSM) plans for NS Power, subject to Nova Scotia Utility and Review Board approval. The DSM framework uses a tiered structure (measure, program, portfolio levels) and cost-effectiveness testing to evaluate plans, ensuring measurable benefits for ratepayers.
3.1 Consumer Advocate [28] The Consumer Advocate is a signatory to the Consensus Agreement. The Consumer Advocate argues that recent amendments to the Public Utilities Act altered the criteria the Board is to apply in evaluating E1's propo...
AI summary The Consumer Advocate argues that amendments to the Public Utilities Act require the NSUARB to evaluate demand-side management at the portfolio level, incorporating sustainability and environmental factors. They support E1's BCA test over the PAC test, citing its alignment with policy goals like sustainable development and greenhouse gas reduction. The 2% social discount rate is preferred for long-term impacts, and the 10% proxy value for beneficial electrification is maintained.
3.2 Industrial Group [34] The Industrial Group is not a party to the Consensus Agreement. It objects to the use of the proposed BCA test as the new primary cost-effectiveness test. It recommends the Board approve the PAC test as the primar...
AI summary The Industrial Group opposes using the BCA test for DSM Plan applications, advocating instead for the PAC test at portfolio, program, and measure levels. They argue the Board should exclude non-energy impacts like carbon social effects. The group also highlights changes to the Public Utilities Act that expanded DSM to include strategic electrification, emphasizing cost reduction as the Act's focus.
3.3 Small Business Advocate [45] The Small Business Advocate agreed to the Consensus Agreement and recommends the Board adopt the proposed BCA test as amended by the Consensus Agreement. In closing submissions, the Small Business Advocate...
AI summary The Small Business Advocate agreed to the Consensus Agreement, recommending the Board adopt the amended BCA test. Concerns were raised about quantifying non-energy benefits like amenity and empowerment, with recommendations to set unquantified benefits to zero or adopt the PAC test instead. The Advocate emphasized the need for further work on quantifying non-energy benefits.
3.4 Nova Scotia Power [48] NS Power does not support E1's proposed BCA test and recommends the Board approve the current TRC with two modifications which would consider, in the context of strategic electrification, GHG emissions reductions...
AI summary Nova Scotia Power opposes E1's proposed BCA test, advocating for TRC modifications to include GHG emissions reductions (net tonnage) and electricity cost reductions. It emphasizes that the Public Utilities Act mandates strategic electrification to reduce emissions and costs, arguing that the Board's core mandate is ensuring just and reasonable rates, not broader social considerations.
3.6 Eastward Energy [61] In its submissions, Eastward Energy asked the Board to make a preliminary and final order that Eastward be added as a full member of DSMAG. On November 4, 2025, the Board noted that Eastward has a valuable perspect...
AI summary Eastward Energy requested DSMAG membership, which the NSUARB approved. They supported strategic electrification testing methods aligning with Posterity Group's recommendations and advocated for hybrid heating in E1's 2027-2031 DSM Plan, emphasizing economic benefits and regulatory alignment with the PUA.
4.1.1 Introduction [69] The Public Utilities Act requires NS Power to engage E1 to undertake "costeffective demand-side management". The Board must approve these agreements and "determine the cost-effective demand-side management that must...
AI summary The NSUARB must determine the cost-effectiveness test for demand-side management under the Public Utilities Act. E1 argues the Board now has jurisdiction to consider non-energy impacts, while some intervenors disagree. Legislative amendments since 2020, including the Energy Reform (2024) Act, expanded the Energy Board's consideration scope. The Board will assess statutory interpretation and the meaning of 'cost-effective' in DSM provisions.
Incorporated, and Nova Scotia Power Incorporated may rely upon the expertise of the franchise holder in respect of the delivery of demand-side management. - (4) The Energy Board shall approve an application pursuant to this Section if, in...
AI summary The Energy Board must approve demand-side management (DSM) applications if they serve customers' best interests and meet Section 79I requirements. Evaluations must occur at the portfolio level per Section 79H, considering aggregate DSM programs. The Board also assesses cost-effectiveness and relies on franchise holder expertise for delivery.
4.1.4 The 2020 Non-energy Benefits Decision - [83] The NSUARB determined it did not have the jurisdiction to consider nonenergy benefits in the cost-effectiveness testing for demand-side management in Re EfficiencyOne , 2020 NSUARB 56. In...
AI summary The NSUARB ruled it lacked jurisdiction to consider non-energy benefits in DSM cost-effectiveness testing in Re EfficiencyOne , 2020 NSUARB 56. E1 argued that the Public Utilities Act grants the NSUARB broad discretion to assess factors like thermal comfort and property value impacts as part of customers' best interests, beyond mere electricity savings.
4.1.6 The Meaning of "Cost-effective" under the Public Utilities Act [96] From the text used by the Legislature in s. 79I(1) of the Public Utilities Act , it follows that NS Power's statutory duty relates to demand-side management (as defi...
AI summary Section 79I of the Public Utilities Act mandates that NS Power's demand-side management (DSM) must be cost-effective and reasonably available, with the goal of reducing customer costs. The NSUARB must review DSM agreements, ensuring compliance with s. 79I and evaluating cost-effectiveness at the portfolio level. The Act does not explicitly define 'cost-effective,' leaving regulatory interpretation to the Board.
The current version is: (iv) strategic electrification of energy end uses currently powered by fossil fuels in a manner that reduces overall greenhouse gas emissions and electricity costs [108] E1 submits that strategic electrification can...
AI summary E1 argues that strategic electrification, defined under the PUA amendment, requires expanding cost-effectiveness testing beyond traditional PAC/TRC frameworks to account for non-utility benefits like fuel savings and GHG reductions. E1 claims this is essential to fulfill its mandate under the updated DSM definition.
nergy supply in the Province" in s. 6(2)(c) could alter the requirement in s. 67 of the Public Utilities Act that all tolls, rates and charges shall always, under substantially similar circumstances and conditions in respect of service of...
AI summary The NSUARB interprets the Public Utilities Act (PUA) to require NS Power to implement demand-side management (DSM) to reduce electricity costs. The Industrial Group emphasizes that legislative objectives cannot override clear statutory language, and the Board confirms NS Power's obligation is met via its agreement with E1. The Board rejects ambiguity in PUA provisions regarding DSM.
4.2 Benefit-Cost Test Alternatives [143] No party in this proceeding argued that the existing TRC test should be maintained in its present form. [144] As discussed in more detail previously, E1's proposed BCA test includes utility system a...
AI summary No party supports maintaining the existing TRC test. E1 proposes a BCA test incorporating utility and non-utility system impacts, aligning with Nova Scotia's legislative changes and sustainability goals. Table 5 compares the existing TRC and proposed BCA tests.
[146] In its closing submissions, the Industrial Group said: Where the PUA has clearly mandated the focus of DSM to be on the reduction of costs, the PAC is able to demonstrate that as a primary test; the Proposed BCA cannot. As confirmed...
AI summary The Industrial Group argues that the Program Administrator Cost (PAC) test aligns with the PUA's mandate to reduce electricity costs, unlike the Proposed BCA. NS Power proposes a modified Total Resource Cost (TRC) test to account for fuel switching benefits, while E1 criticizes both approaches, claiming they fail to meet legislative requirements or address strategic electrification mandates. The debate centers on cost-effectiveness criteria for demand-side management.
4.2.1 Findings [151] E1 and its consultants purported to follow guidance in the NSPM in determining the proposed BCA test. However, a process that simply takes account of an inventory of energy and climate change policy goals and objective...
AI summary The NSUARB rejects E1's proposed BCA test for DSM cost-effectiveness, citing misalignment with the PUA's mandate to reduce electricity costs. The TRC test is criticized for asymmetrical application, while the PAC test is endorsed as it aligns with statutory goals. The Board directs E1 to use the PAC test for DSM plans starting in 2027.
4.3 Strategic Electrification [158] Strategic electrification that reduces overall GHG emissions and electricity costs is included in the definition of "demand-side management" in s. 79A(b)(iv) of the Public Utilities Act . The PAC test, a...
AI summary The document discusses challenges in applying the traditional PAC test to strategic electrification programs under the Public Utilities Act. Mr. Bowman proposes modifying the PAC test to include increased revenues from electrification as a benefit, ensuring cost-effective programs. The Industrial Group supports this approach, aligning with E1's mandate to reduce electricity costs for NSPI customers.
[160] Eastward made similar comments in its submissions: In this regard the IG has noted that the approach proposed by Mr. Bowman to costeffectiveness testing for E1 for strategic electrification – running the PAC test with the additional...
AI summary Eastward supports Mr. Bowman's modified PAC test for strategic electrification, aligning with Posterity Group's recommendations to ensure cost-effective programs. E1 argues the test assesses rate impacts, not cost-effectiveness, and has focused on GHG emissions rather than electricity cost reductions in its BCA.
4.3.1 Findings [162] The Board accepts the Industrial Group's suggestion that traditional cost effectiveness tests may be modified to suit specific jurisdictional requirements. The means of assessing strategic electrification in Nova Scoti...
AI summary The NSUARB accepts modifying traditional cost-effectiveness tests for strategic electrification in Nova Scotia. E1's approach to demonstrating cost reductions remains incomplete, so it must follow Mr. Bowman's PAC test recommendation temporarily. The Board allows E1 to propose an alternative method in its 2027-2031 DSM Plan if it meets statutory requirements for reducing both GHG emissions and electricity costs.
4.4 Portfolio Level Assessment [164] Section 79H(2) requires the Board to evaluate the proposed cost-effective demand-side management at the portfolio level. In its submissions, the Industrial Group urged that it was particularly important...
AI summary Section 79H(2) of the PUA mandates the NSUARB to assess demand-side management at the portfolio level. The Industrial Group and NS Power argue for applying cost-effectiveness tests at portfolio, program, and measure levels, while E1 insists on portfolio-level screening.
4.4.1 Findings [166] There is no ambiguity in s. 79H(2): the Board must evaluate the proposed cost-effective demand-side management at the portfolio level. As noted previously in this decision, the Board agrees with E1 that there is a diff...
AI summary The NSUARB mandates evaluation of cost-effective demand-side management (DSM) at the portfolio level, not individual measures. E1 must justify DSM measures failing primary cost-effectiveness tests and may use revised BCA tests with NS Power's WACC comparisons. The Board allows alternative tests if the overall portfolio passes, citing s. 6(2) of the Energy and Regulatory Boards Act.
4.5 Discount Rate [169] Benefit-cost analysis involves comparing all the costs and benefits of a program over a period of time. There will be a stream of costs and benefits that are usually spread over several years, and in some cases, dec...
AI summary The section discusses the role of discount rates in Benefit-Cost Analysis (BCA) for distributed energy resources. It explains that discount rates determine the present value of future costs and benefits, with the NSPM outlining three categories: WACC, customer-focused rates, and societal discount rates. Higher rates prioritize near-term costs, while lower rates balance long-term considerations.
4.5.1 Findings [192] Discounting is a fundamental component of BCA. Applying a social discount rate places greater emphasis on future benefits than a standard discount rate typically would. Environment and Climate Change Canada's SC – GHGs...
AI summary The document discusses the importance of discounting in BCA, noting that Environment and Climate Change Canada's SC-GHG guidance uses a lower discount rate. It criticizes E1 for not following the Treasury Board's policy on when to apply a social discount rate, emphasizing compliance with the Treasury Board's Cost-Benefit Analysis Guide.
s. 7.1 about the discount rate to be used: The discount rate is the rate at which future costs and benefits are converted to their present equivalents. Discounting accounts for the fact that: - there is a time preference for current consum...
AI summary The NSUARB mandates using the opportunity cost of capital (WACC) as the discount rate for DSM programs, aligning with Treasury Board guidelines. This reflects the alternative investment returns of funds from NS Power ratepayers. The Board rejects social discount rates except for long-term regulatory proposals, emphasizing WACC's consistency with NS Power's IRP and PAC test requirements.
[201] In its response, E1 stated: The approach E1 is proposing in the 'evergreen' process for calculating the emissions intensity of DSM savings for the purposes of benefit cost analyses is the Difference in Carbon Emissions (DICE) method....
AI summary E1 proposes using the Difference in Carbon Emissions (DICE) method for calculating emissions intensity in DSM savings, aligning with NSPM and IRP for long-term planning. They argue this is more accurate than using marginal generator emissions, especially for significant load changes. In BCA, they use average emissions rates for illustrative examples.
4.6.1 Findings [204] The Board considers the issue regarding average versus marginal generation emission rates to be worthy of further consideration. During crossexamination, E1's witnesses stated that, for expediency, average emission rat...
AI summary The Board emphasizes using long-run marginal emission rates over average rates in E1's BCA modeling, citing the need for refined assumptions. E1 used average data from NS Power but acknowledges the need for improvement.
4.8 Avoided Costs [212] Eastward raised concern about NS Power's avoided cost values and requested confirmation that ancillary service costs, peak costs and system reliability are embedded in the avoided cost values. Eastward also requeste...
AI summary Eastward questioned NS Power's avoided cost values, seeking confirmation that ancillary service costs, peak costs, and system reliability are included. NS Power explained that peak demand, ancillary services, and reliability are factored into avoided cost modeling, using the latest IRP model and ongoing DSMAG discussions. The Board accepted this response as adequate.
4.9 Natural Gas System Reliability [215] In its evidence [Exhibit E-11], Eastward raised concerns about the potential for E1 to propose natural gas to electricity conversion as a strategic electrification project in its upcoming DSM portfo...
AI summary Eastward raised concerns about E1's proposed natural gas-to-electricity conversion project, citing a negative net benefit and low benefit-cost ratio. Eastward emphasized the need to account for natural gas system reliability in such projects. E1 responded that it agrees to consider reliability impacts in future proposals, which the Board accepted as sufficient.
5.0 SUMMARY OF BOARD FINDINGS [217] The Board finds it does not have the authority to approve E1's proposed BCA because the Public Utilities Act restricts the Board's ability to consider non-energy and societal benefits in assessing the co...
AI summary The Board cannot approve E1's proposed BCA due to Public Utilities Act restrictions on non-energy benefits. E1 must use PAC test and NS Power's WACC for DSM plan assessments. Strategic electrification must meet GHG and cost reduction criteria. Eastward is added to DSMAG. Portfolio-level evaluation allows overall cost-effective DSM plans despite individual measure failures.
98033NSEB (E1) IR 1 to 46
27 passages
Request IR-2: - Page 2 of 38 of EfficiencyOne's (E1) Evidence states: "Including non-utility impacts reflects both - best practice in benefit cost analysis test design, as well as recently enacted provincial legislation. - While the relati...
AI summary EfficiencyOne (E1) argues that including non-utility impacts in the BCA test framework aligns with best practices and provincial legislation like the Public Utilities Act and Energy Reform (2024) Act . The request seeks clarification on indirect benefits/costs, weight assignments, sensitivity analysis, policy alignment, and performance requirements for non-utility benefits in DSM evaluations.
Request IR-3: - With regards to Table 2 on page 4 of 38 of E1's Evidence: - a) Did E1 review any Canadian jurisdictions with similar policy objectives as Nova Scotia to assess how the current TRC test aligns with standard for cost-effectiv...
AI summary Request IR-3 asks E1 (EfficiencyOne) to explain whether it reviewed Canadian jurisdictions with similar policy objectives to Nova Scotia regarding the TRC test's alignment with cost-effectiveness standards. It also requests a comparative table and identification of similar DSM policy objectives in listed states.
Request IR-4: - Page 4 of 38 discusses the shortfalls of the TRC test as ignoring the symmetrical benefits - corresponding to a cost, arguing that such an approach "unjustly favour or disadvantage certain - resources." - a) In the BCA are...
AI summary The text critiques the TRC test for ignoring symmetrical benefits, leading to unfair resource treatment. It questions the BCA's completeness, asking if benefits without costs or costs without benefits are included, highlighting potential methodological gaps in cost-benefit analysis.
Request IR-5: - Please describe how the BCA as proposed by E1 aligns with the Treasury Board of Canada - Secretariat Canada's Cost-Benefit Analysis Guide for Regulatory Proposals, 2019 and Canada's - Policy on Cost-Benefit Analysis (2018)...
AI summary Request IR-5 asks EfficiencyOne (E1) to explain how its proposed Benefit-Cost Analysis (BCA) aligns with Canada's 2019 Cost-Benefit Analysis Guide and 2018 Policy on Cost-Benefit Analysis. Specific elements under review include scope, time horizon, market distortions, health impacts, and social costs of greenhouse gases.
Request IR-6: - Page 17 of 38 of E1's Evidence states: "To perform cost effectiveness testing of strategic - electrification you must include the relevant benefits and costs. In the case of strategic - electrification, the electric utility...
AI summary The document raises two key questions regarding strategic electrification's cost-effectiveness testing. First, whether host customer costs (e.g., EV chargers) are included in BCA tests. Second, how the proposed BCA ensures strategic electrification reduces electricity costs as mandated by the Public Utilities Act's definition of demand-side management.
Request IR-7: - On page 18 of 38 of E1's Evidence, a hyperlink to the "National Energy Screening Project (NESP), National Standard Practice Manual (NSPM) for Benefit-Cost Analysis of Distributed Energy Resource" is provided: - a) Please de...
AI summary Request IR-7 seeks information on the National Energy Screening Project (NESP), deviations from the NSPM in the proposed BCA test, use of the MTR handbook for quantifying benefits/costs, and data from the DSPs on states' adoption of NSPM, SCT, and resilience metrics in energy efficiency evaluations.
Request IR-8: - With respect to the NSPM for Benefit-Cost Analysis of Distributed Energy Resource: - a) Please identify any Canadian jurisdictions that have adopted the NSPM as their standard approach to BCA for DSM or Distributed Energy R...
AI summary Request IR-8 seeks information on Canadian jurisdictions adopting Nova Scotia Power's (NSPM) BCA methodology for DER/DSM, differences in application compared to E1's proposal, and alternative BCA methodologies used, including California's Standard Practice Manual.
Request IR-9: - Please provide a summary of the feedback provided by the DSMAG regarding the final draft EFG - report, as referenced on page 20 of 38 of E1's Evidence. - Request IR-10: - Table 4: NSPM BCA Guiding Principles - a) Principle...
AI summary The document outlines regulatory requests related to DSM and DER BCA analyses. Key issues include clarifying the basis for comparing DER scenarios in BCA, identifying unlisted utility impacts, and evaluating the inclusion of policy goals in BCA tests. E1 is asked to confirm the Board's discretion in approving portfolios despite BCA results.
Request IR-13: - Page 30 of 38 of E1's Evidence states: "The impact of changes in pipeline gas consumption are based on commodity prices, and do not reflect gas utility system impacts. However, presuming gas commodity prices are the larges...
AI summary E1's Evidence in Request IR-13 questions whether avoided gas costs in DSM include base energy and transportation charges, not just commodity prices. The BCA test is based on commodity prices as an approximation. The request is for confirmation if avoided costs include those other charges.
Request IR-17: - Please provide supporting empirical evidence demonstrating causation for the following Host - Customer Impacts: - a) energy efficiency investments and increases in business productivity in industries that operate in Nova S...
AI summary The document requests empirical evidence linking energy efficiency investments in Nova Scotia to increased business productivity, economic benefits, and health/safety improvements, emphasizing the need for causation.
Request IR-20: - a) Please cite the source for the cost of carbon used in the BCA. - b) Please explain how the proxy for the host customer was selected and measured. - i. Please describe how the proxy is estimated and applied in the BCA. -...
AI summary Request IR-20 seeks clarification on the BCA's carbon cost source, proxy selection methodology, discount rate justification, and use of Canadian vs. American rates in NSPM. Questions focus on transparency, methodology, and regional applicability of economic assumptions.
Request IR-21: - Table 10: Impact Categories for BCA Test identifies that Impacts Measured for Gas is embedded in Other Fuels, Resilience is embedded in Host Customer, and that Public Health is embedded in another GHG Emissions. Please con...
AI summary The text references Table 10 of the BCA Test, which lists impact categories such as Gas embedded in Other Fuels, Resilience in Host Customer, and Public Health in GHG Emissions. It requests confirmation and an explanation for their inclusion in the presentation.
Request IR-23: - Page 8 of 18 of Mr. Hill's evidence notes that criteria air pollutant non-utility impacts for the - proposed BCA test are based on modelling of estimated health impacts for the New England - region. Are there any reasons t...
AI summary The document raises a question about whether health impact models from the New England region, used in the BCA test, are applicable to Nova Scotia, given potential differences in health impacts.
Request IR-25: - Table 3 on Page 12 of 18 of Mr. Hill's Evidence: Data Sources and Application in Developing Recommended Nova Scotia Test: - a) For the Utility System Impact "Program Administration and Incentives", the Application in Repor...
AI summary Request IR-25 seeks clarification on assumptions in the BCA related to program administration, fuel price adjustments, placeholder cost assumptions, and proxy values for non-energy benefits. Questions focus on EFG's assumptions, carbon price removal rationale, US Energy Information Administration fuel cost data, and adjustments to avoid double-counting energy benefits.
Request IR-26: - Please provide the proposed BCA in excel format with cells intact and worksheets unprotected. - Additionally, provide references for each measure, with empirical evidence that supports the link - between the benefit and as...
AI summary Request IR-26 seeks the proposed Benefit-Cost Analysis (BCA) in Excel format with intact cells and unprotected worksheets, along with empirical evidence linking each measure's benefits to costs. The request emphasizes transparency in data presentation and rigorous validation of cost-benefit claims.
Request IR-27: - Page 8, under Non-Energy benefits states "If host customer benefits are not included in a jurisdictional test, then the host customer costs should be excluded." - a) Please describe the host customer costs and if they incl...
AI summary Request IR-27 seeks clarification on host customer costs and benefits related to E1 programs, specifically whether E1's costs are included and if benefits are uniform across programs. It references a rule excluding host customer costs if benefits are not included in jurisdictional tests.
Request IR-28: - Page 8, under Not Material explains that some outcomes that don't produce a large enough effect - are excluded from the BCA. Please identify and briefly describe the outcomes/impacts identified - by E1/EFG/DSMAG that have...
AI summary Request IR-28 asks to identify outcomes excluded from the BCA by E1/EFG/DSMAG due to insufficient impact. The query focuses on excluded impacts not producing a large enough effect in the analysis.
Request IR-30: - Table 4: Non-Utility Impacts Consistent with Nova Scotia Policy Goals in the Notes for Econ - Devt/Jobs state that these impacts should be separate from the BCA calculations to avoid double - counting. Please describe how...
AI summary The text requests E1 to explain how non-utility impacts related to Nova Scotia policy goals are separated from BCA calculations to avoid double-counting in their analysis.
Request IR-31: - Text Box 1: Summary of Key EFG Recommendations item 3) states that actual avoided capacity - cost stream should have a planning reserve margin adjustment. It also states that constrained - and unconstrained locations can b...
AI summary Request IR-31 seeks explanations on three aspects of E1's costing methodology: (a) avoided capacity adjustment and data sources, (b) constrained/unconstrained transmission/distribution locations influenced by E1 programs, and (c) basis for estimating transmission/distribution cost growth.
Request IR-33: - Text Box 1: Summary of Key EFG Recommendations item 8) recommends using benefit per kWh - for local non-greenhouse gas air pollutants using estimates from the US Environmental Protection - Agency for New England. - a) Plea...
AI summary Request IR-33 seeks clarification on using benefit per kWh for local non-GHG pollutants in Nova Scotia's BCA, referencing E1's programs and US EPA data from New England. It asks to identify local pollutants, explain appropriateness of local vs. New England data, and describe pollutant sources/measures.
Request IR-34: - Text Box 1: Summary of Key EFG Recommendations item 11) states that secondary tests are - not meant to be used in a sequential fashion or as a replacement of the recommended primary - test. Please elaborate on this recomme...
AI summary Request IR-34 seeks clarification on EFG's recommendation that secondary tests should not replace primary tests in BCA evaluations for demand-side management. It asks how secondary tests would function in Nova Scotia's context, particularly regarding portfolio-level cost-effectiveness assessments.
Request IR-35: - Please confirm that Table 5: Illustrative Example of Recommended Nova Scotia Test, provides - only the summary of the benefits associated with 1,000 Heat Pumps Replacements in Program - Year 2026. If the BCA test is and me...
AI summary Request IR-35 seeks clarification on Table 5's scope, which summarizes benefits of 1,000 heat pump replacements in 2026. It also asks if E1 will provide detailed BCA calculations if the Board approves the BCA test methodology.
Request IR-36: - Page 20 describes the example in Table 5 as showing that the cost effectiveness of the 1,000 - heat pump replacements is influenced by which fuel is displaced. - a) Are the costs to E1 for heat pump incentives and programs...
AI summary The text examines the cost-effectiveness of 1,000 heat pump replacements, questioning whether E1's costs are limited to Financial Incentives and Program Administration, and how displaced fuel affects cost-effectiveness. It references Table 5 and seeks clarification on additional costs incurred by E1.
Request IR-37: - Table 6: Illustrative Example Present Value Benefits, Costs and Ratios, provides the present - value of the heat pump replacements. Not limited to this table, how many years will the costs and - the benefits be discounted...
AI summary Request IR-37 asks about the discount period for present value calculations in Table 6, which illustrates benefits, costs, and ratios for heat pump replacements. The request seeks clarification on the number of years used to discount costs and benefits, and the specific years associated with each impact.
Request IR-38: - Page 36, Credit and collections, highlights that NS Power hasn't found a change for costs associated with delinquent accounts, disconnection and reconnection costs. Why does E1 consider it appropriate to include this measu...
AI summary Request IR-38 questions E1's inclusion of credit and collection costs in DSM, challenging how E1 attributes savings to DSM versus other programs like Customer Energy Management or Low-Income Working Group initiatives. It also asks why DSM incentives are expected to significantly reduce credit and collection expenditures, particularly for low-income renters.
Request IR-40: - Table 9 identifies the impacts included in the BCA. Please explain the reasons that E1 considers - the effects from DSM on Transmission and Distribution are significant enough to be included.
AI summary Request IR-40 asks E1 to justify including DSM's impacts on transmission and distribution in the BCA. The inquiry focuses on why these effects are deemed significant enough to be part of the analysis, highlighting the importance of transmission and distribution considerations in DER evaluations.
Request IR-41: - Table 13 in Appendix B lists the Host Customer Impacts. How does E1 propose to quantify the - following: - a) Transaction Costs - b) Risks - c) Resilience - d) Productivity - e) Comfort - f) Amenity - g) Empowerment - h) P...
AI summary The document requests E1 to explain how it quantifies various Host Customer Impacts, including transaction costs, risks, resilience, and others, as listed in Table 13 of Appendix B.
99638Closing Submission - E1
18 passages
EfficiencyOne IN THE MATTER OF The Public Utilities Act , RSNS 1989, c. 380, as amended -and- IN THE MATTER OF An Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans
AI summary The document pertains to an application under the Public Utilities Act for approval of a new benefit-cost analysis test to evaluate Demand Side Management Plans. The proceeding involves EfficiencyOne and focuses on regulatory approval for a methodological change in assessing demand-side management initiatives.
On May 16, 2025, EfficiencyOne ("E1") submitted its Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management ("DSM") Plans (the "Application") to the Nova Scotia Energy Board ("NSEB" or "the Board"...
AI summary EfficiencyOne submitted an application for approval of a new benefit-cost analysis test for evaluating demand-side management plans to the Nova Scotia Energy Board, in accordance with a 2022 directive. The application includes a partial Consensus Agreement supported by various stakeholders, including the Consumer Advocate and Efficiency Canada, and addresses methodological improvements for DSM cost-effectiveness testing.
2. CONTEXT AND USE OF THE COST EFFECTIVENESS TEST IN DSM PLAN REVIEW Cost effectiveness testing has long been utilized in the evaluation of DSM plans in Nova Scotia, serving as a foundational element in the Board's assessment process to en...
AI summary Nova Scotia's Board uses the Total Resource Cost (TRC) test for DSM plan reviews, but proposes replacing it with a jurisdiction-specific Benefit-Cost Analysis (BCA) test to address TRC's deficiencies. The BCA test aligns with NSPM principles and Nova Scotia policy, following prior Board approvals to shift TRC analysis from measure to program level starting 2012.
3.2 ALIGNMENT OF PROPOSED BCA WITH STATUTORY PROVISIONS As is discussed further below, E1 asserts that its Proposed BCA aligns with the above-noted policy and legislative objectives of the province, by incorporating utility system impacts,...
AI summary E1 argues its Proposed BCA aligns with provincial policy and legislative objectives by incorporating utility system, fuel, GHG, and health impacts into cost-effectiveness testing. EFG followed NSPM guidelines, while Ms. Lane testified that existing policies, not direct legislation, justify including societal factors like resilience and GHG reduction in the BCA framework.
4. OVERVIEW OF PROPOSED BCA FRAMEWORK & QUANTIFICATIONS, WITH PCA CONSIDERATIONS
AI summary The section introduces the proposed BCA framework and quantifications for a regulatory proceeding, incorporating PCA considerations. Key entities and acronyms related to energy regulation and stakeholder groups are referenced.
4.1 CORE ELEMENTS E1 is requesting the Board approve the Proposed BCA as the new cost-effectiveness test for DSM, which is to be screened at the portfolio level. In designing the Proposed BCA, EFG followed the NSPM. None of the experts con...
AI summary E1 is requesting the Board to approve a new Benefit-Cost Analysis (BCA) as the cost-effectiveness test for Demand-Side Management (DSM), designed using the National Standard Practice Manual (NSPM) and aligned with Nova Scotia's policies. Experts like Ms. Lane and Mr. Bowman acknowledge the NSPM's value and policy neutrality. The Proposed BCA addresses utility system impacts, countering claims that it is disconnected from the utility and its customers.
- against the TRC test which is currently used by the Board for cost-effectiveness testing.[18](#page-12-0) Impact Category Sub-Category BCA Test TRC Test Utility System Electric Generation Transmission Distribution General All All Gas Onl...
AI summary The text discusses the comparison between the BCA test and the TRC test for cost-effectiveness, highlighting differences in impact categories and sub-categories, such as the inclusion of gas commodity costs, societal resilience, and public health impacts. The Proposed BCA does not reduce the utility system impact categories compared to the TRC test.
4.3 APPLICABLE DISCOUNT RATE E1, relying on expert analysis provided by EFG, submits that the adoption of a 2% real discount rate for evaluating impacts under the Proposed BCA test is both reasonable and legally sound. It reflects a societ...
AI summary E1, supported by EFG, argues that a 2% real discount rate is legally sound and aligns with NSPM and Nova Scotia legislation, including GHG mitigation and sustainable development. They oppose using WACC, claiming it misrepresents long-term benefits and legislative goals, with support from Efficiency Canada.
4.4 EVERGREEN PROCESS - E1's proposed evergreen process represents a foundational commitment to maintaining the integrity, - relevance, and adaptability of its Proposed BCA framework. This process ensures that the BCA test remains - aligne...
AI summary E1's evergreen process ensures the BCA framework remains aligned with evolving legislation, policy, and market conditions in Nova Scotia. It involves periodic reviews, stakeholder engagement, and collaboration with DSMAG to quantify non-energy impacts. E1 claims no opposition to the process.
5. SUMMARY OF EVIDENCE AND HEARING RECORD Cost-effectiveness testing is not new in Nova Scotia. Section 79H(1) of the Public Utilities Act requires that the Board "determine the cost-effective demand-side management that must be undertaken...
AI summary The Nova Scotia Utility and Review Board is evaluating the replacement of the Total Resource Cost (TRC) test with a Benefit-Cost Analysis (BCA) for demand-side management (DSM) cost-effectiveness. Critics, including EfficiencyOne and the Consumer Advocate, argue the TRC test is asymmetrical and fails to incorporate new legislative priorities like sustainable development. E1 proposes the BCA test as a more comprehensive alternative.
6.1 INTRODUCTION - It is E1's position that the Proposed BCA satisfies the legislative requirements for cost-effectiveness testing, - including new or amended legislative requirements. More specifically, E1 submits that the Proposed BCA -...
AI summary E1 argues that their proposed BCA meets legislative requirements for cost-effectiveness testing, including portfolio-level DSM assessment and sustainable development considerations. They also claim Mr. Bowman's approach fails to satisfy statutory requirements.
6.3 THE PURPOSE OF COST-EFFECTIVENESS LEGISLATION
AI summary The section discusses the purpose of cost-effectiveness legislation, though no detailed content is provided in the given text. It likely addresses how such legislation aims to balance cost and benefit considerations in regulatory decisions.
6.3.1 E1'S PROPOSED BCA In addressing this matter, it is appropriate to apply the rules of statutory interpretation and consider the relevant provisions "in their entire context and in their grammatical and ordinary sense harmoniously with...
AI summary E1's proposed BCA under the Public Utilities Act outlines statutory obligations for the NSUARB to evaluate DSM initiatives at the portfolio level. The Act requires NS Power to enter DSM purchase agreements with E1, which must be approved by the Board. The evaluation of cost-effectiveness is distinct from high-level portfolio assessments.
6.3.2 THE IG'S PROPOSED APPROACH - The IG's proposed approach differs from the legislated direction and context. Mr. Bowman recommends - that "[t]he primary energy efficiency test should be the PAC test, applied at the measure and program...
AI summary The Industrial Group (IG) proposes using the Program Administrator Cost (PAC) test as the primary energy efficiency metric, alongside supplementary tests for electrification, societal impacts, and rate impacts. This approach contrasts with EfficiencyOne's (E1) broader 'societal test' framework. The IG emphasizes narrower criteria and specific cost-effectiveness metrics for DSM reviews.
6.4.2 IG'S PROPOSED APPROACH E1 notes that Mr. Bowman's proposed cost-effectiveness test is insufficient to address E1's legislated DSM mandate, in particular its expanded strategic electrification mandate. Mr. Bowman's proposal is to use...
AI summary E1 argues that the PAC test is insufficient for evaluating strategic electrification under its DSM mandate, as it only considers costs. E1 proposes the BCA as a more effective primary test, citing flaws in the PAC approach and complexity from using multiple tests. Experts like Dr. Hill (EFG) and Mr. Neme support this, emphasizing legislative requirements for electrification.
6.5.1 E1'S PROPOSED BCA Fourth, E1 submits that its Proposed BCA allows the Board to give appropriate consideration to the extent to which a cost-effectiveness test can support the goals (including sustainability goals) set out by the Legi...
AI summary E1 argues its proposed BCA aligns with legislative goals, unlike the IG's tests. The Energy Reform Act (2024) mandates cost-effectiveness considerations in Board decisions. Section 6(2) of the Energy and Regulatory Boards Act requires the Board to evaluate cost-effectiveness when approving rates or other matters.
6.5.2 IG'S PROPOSED APPROACH The evidence presented to the Board supports the finding that the Proposed BCA is the test which best addresses these policy concerns. In fact, the IG's expert, Mr. Bowman, indicates that in order to address br...
AI summary The IG's expert, Mr. Bowman, advocates for the Proposed BCA as a societal test to address sustainable development and GHG reductions. However, his primary PAC test fails to incorporate legislative policy goals outlined in the NSPM, which mandates integrating DER-related policy considerations into cost-effectiveness analyses. The Proposed BCA allows the Board to consider societal factors within a cost-effective framework.
9 7. REQUESTED BOARD ORDER - Based the evidence and analysis before the Board in this matter, including as set out in this Closing - Submission, E1 respectfully requests the Board approve the Proposed BCA as supplemented by the PCA, - spec...
AI summary E1 requests the NSUARB to approve the Proposed BCA with PCA modifications, including a 2% discount rate and evergreen process. It aligns with PUA, supports decarbonization goals, and reflects stakeholder input via DSMAG. The BCA is deemed evidence-based, consistent with legislation, and in the public interest.
99640Closing Submission - IG
15 passages
Delivered by E-mail Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Energy Board 3rd Floor, 1601 Lower Water Street PO Box 1692, Unit "M" Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M12282 - E1- New Benefit Cost Analysis Test for...
AI summary Efficiency One (E1) proposes a new benefit-cost analysis (BCA) test for demand-side management (DSM) plans, incorporating non-energy impacts like social cost of carbon. The Industrial Group opposes this, arguing the Board should not consider non-energy benefits and instead adopt a Program Administrator Cost (PAC) test. The proceeding addresses whether the Board can/should use the Proposed BCA under the Public Utilities Act.
Background and Principles of Statutory Interpretation This application arose out of the Board's direction to undertake a "thorough assessment of the relative merits of both the PAC test and a jurisdiction-specific test,["](#page-1-0) 2 as...
AI summary The Board directed an assessment of PAC test vs. jurisdiction-specific test for DSM. E1 engaged EFG and DSMAG, but omitted comparative analysis with PAC. Province amended PUA, and E1 argues these changes expanded the Board's jurisdiction over DSM, contrary to prior rulings limiting non-energy impact considerations.
Applicable Legislative Provisions for Cost Effectiveness Testing The issue before the Board now, is what costs and what benefits should be weighed when evaluating DSM. Energy efficiency and conservation activities are contained within thei...
AI summary The Board considers legislative provisions under the PUA governing DSM cost-effectiveness testing. NSPI and E1 have statutory obligations under ss 79A-79W of the PUA , with E1 serving as NSPI's franchisee for energy efficiency. The PUA mandates NSPI to contract with E1 for DSM activities, emphasizing alignment with regulatory objectives.
Prior Interpretation of the Board's Jurisdiction Up until this application, the predecessor Board made clear that it did "not have the jurisdiction to take into account non-energy impacts in cost-effectiveness testing" in relation to DSM.[...
AI summary The Board clarified its jurisdiction excludes non-energy impacts in DSM cost-effectiveness testing, focusing solely on energy-based costs and benefits. EfficiencyOne argued for broader environmental considerations under the PUA, but the Board rejected this, citing statutory definitions. The Board emphasized 'cost-effective' means evaluating electricity efficiency activities for affordability and long-term cost reduction, acknowledging limited environmental benefits.
The Board Still Cannot Account for Non-energy Benefits The Industrial Group recognizes that certain recent legislative amendments may impact the ongoing interpretation of the PUA provisions. However, the additional factors provide guidance...
AI summary The Industrial Group acknowledges recent legislative changes but argues they don't alter the PUA's focus on reducing electricity costs. E1's environmental goals must align with PUA provisions, not override them. The Board must adhere to statutory mandates, and non-energy benefits aren't within the legislative framework for cost-effectiveness evaluation.
Negative implications of Broad interpretation When interpreting the PUA, this Board should recall Sullivan's third question: what are the consequences of adopting a proposed interpretation? Approving a broad ranging costeffectiveness test...
AI summary The document warns that a broad interpretation of the PUA's cost-effectiveness testing could undermine existing practices, expand E1's mandate beyond legislative intent, and misapply the social cost of carbon (SC-GHG) as a ratepayer tool. It emphasizes that SC-GHG, derived from federal guidelines, is intended for legislative cost-benefit analyses, not utility rate-making.
2. THE BOARD SHOULD NOT TAKE INTO CONSIDERATION NON-ENERGY AND BROAD SOCIETAL IMPACTS In the alternative, if the Board determines it has the jurisdiction to incorporate non-energy and broad societal impacts into the cost-effectiveness test...
AI summary The Industrial Group argues that the Board should not consider non-energy and broad societal impacts in evaluating Demand-Side Management (DSM). They claim this would expand Benefit-Cost Analysis (BCA) beyond ratepayer-focused tests, introducing unquantifiable factors. E1's proposed BCA includes non-energy benefits and carbon costs, which the Small Business Advocate's consultant opposes, aligning with the Program Administrator Cost (PAC) test instead.
Host Customer Non-Energy Benefits The proposed BCA test suggests that the Board should weigh a number of unquantifiable proposed benefits, including customer pride, empowerment, economic well-being, comfort, amenity, and health and safety....
AI summary The proposed BCA test includes subjective non-energy benefits like customer pride and health, valued via proxy percentages of energy benefits. Critics argue these are vague and unsupported, conflicting with PUA's DSM definition. E1 clarified non-energy impacts, but the Industrial Group opposes proxy adders for intangible benefits. Synapse's consultant Courtney Lane raised concerns about proxy value arbitrariness.
Broad Societal Impacts E1 also proposes to include broad societal impacts within its cost-effectiveness testing. This goes well beyond the approach taken by any other Canadian jurisdiction. The global cost of carbon as a percentage of the...
AI summary E1 proposes including global carbon costs in its BCA for energy efficiency programs, a unique approach in Canada. Critics argue this is inappropriate as Nova Scotia does not tax carbon, and the PUA mandates cost reduction, not broad societal impacts. The Industrial Group opposes integrating societal impacts into DSM cost-effectiveness tests.
Inconsistency across DERs The Industrial Group takes no issue with the use of the National Standard Practice Manual (" NSPM ") for Distributed Energy Resources (" DERs" ) as a guiding framework in formulating an appropriate cost-effectiven...
AI summary The Industrial Group supports using the NSPM for DERs but highlights inconsistent application of its principles. Concerns include E1's proposed 2% discount rate, which is deemed too low and not aligned with standard practices. The need for non-green energy investments to meet net-zero goals is acknowledged, but the BCA's consistency across NSPI and IESO remains unexplored. The Industrial Group disputes the discount rate's justification and cites legislative gaps.
ALTERNATIVE COST-EFFECTIVENESS TEST If DERs are to be treated consistently, the proposed societal test should not be approved. The Proposed BCA is inconsistent with the current IRP, and NSPI capital asset treatment. The cost effectiveness...
AI summary The text argues against approving a proposed societal test for DERs, citing inconsistencies with the current IRP and NSPI's capital asset treatment. It advocates for aligning E1's cost-effectiveness testing with NSPI's methods and recommends using the utility cost test (PAC) instead.
Evidence of Patrick Bowman The Industrial Group relies on the evidence filed by Mr. Bowman, and his oral evidence at the hearing, and specifically supports his recommendation to use the PAC as the primary costeffectiveness test. This appro...
AI summary The Industrial Group supports Patrick Bowman's recommendation to use PAC as the primary cost-effectiveness test for DSM programs, aligning E1 with Canadian utilities and PUA goals of reducing electricity costs. Bowman notes PAC's widespread use across Canada and its alignment with customer interests.
Modified PAC test for Electrification The PAC need not be rigid or "ruthlessly applied".[73](#page-19-0) It can be applied or modified as needed, like a jurisdictional test. As suggested by Mr. Bowman, this can be done with respect to stra...
AI summary The document discusses modifying the PAC test for electrification, proposing inclusion of increased revenues from electrification to better assess system costs. Mr. Bowman's approach aligns with Posterity Group's hybrid heating recommendations, reducing utility costs and passing PAC tests. This aligns with the PUA and E1's mandate to lower electricity costs for NSPI customers.
DSMAG CONSULTATION While the purpose and role for the DSMAG is not currently an issue before the Board, the Industrial Group wishes to reiterate its concerns with respect to E1's overreliance on the DSMAG consultations within E1's and EFG'...
AI summary The Industrial Group criticizes E1's reliance on DSMAG consultations as implicit support for the Proposed BCA, emphasizing that DSMAG discussions do not endorse the BCA or its non-energy benefits. They note DSMAG's confidentiality and lack of consensus on the BCA, while welcoming Eastward Energy's potential DSMAG membership.
CONCLUSION The Industrial Group respectfully requests that the Board: - 1. Direct E1 to use the PAC as its primary test for further DSM Plan applications, and a modified version of the PAC in relation to the strategic electrification progr...
AI summary The Industrial Group requests the Board to direct E1 to use the Program Administrator Cost (PAC) as the primary test for DSM Plan applications, apply primary testing at multiple levels, confirm secondary testing, modify the BCA test if accepted, and reject a 2% social discount rate for cost-effectiveness evaluations.
99732Reply Submission - E1
14 passages
EfficiencyOne IN THE MATTER OF The Public Utilities Act , RSNS 1989, c. 380, as amended -and- IN THE MATTER OF An Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans
AI summary The document outlines a regulatory proceeding under the Public Utilities Act, involving an application for approval of a new benefit-cost analysis test to evaluate demand side management plans.
2.1 LEGISLATIVE INTERPRETATION & JURISDICTIONAL LIMITS The IG contends that the Board, under the Public Utilities Act (" PUA "), is not empowered to consider broad societal impacts or non-energy benefits when evaluating the cost-effectiven...
AI summary The Industrial Group (IG) argues that the Board under the Public Utilities Act (PUA) cannot consider societal impacts or non-energy benefits when evaluating demand-side management (DSM) cost-effectiveness, emphasizing ratepayer cost reduction. They claim the new strategic electrification provision in the Energy Efficiency and Renewable Energy Act (ERBA) allows EfficiencyOne (E1) to expand programs but still requires adherence to cost-effectiveness, with sustainability limited to specific proposals.
2.3 RECOMMENDATION FOR THE PROGRAM ADMINISTRATOR COST (PAC) TEST The IG recommends the Program Administrator Cost (PAC) test as the primary cost-effectiveness test, citing its alignment with other Canadian jurisdictions and its focus on ut...
AI summary The IG recommends the Program Administrator Cost (PAC) test for its alignment with other Canadian jurisdictions and utility cost focus. E1 counters that the test must align with Nova Scotia's legislation, not other provinces, and notes that key stakeholders like NS Power, CA, and SBA do not support PAC. E1 emphasizes NSPM guidance and jurisdiction-specific approaches.
2.5 CONSISTENCY - The submission also highlights concerns about inconsistency across distributed energy resources (DERs), - suggesting that the BCA test would require expansion to other areas and create regulatory challenges. The - IG stat...
AI summary The Industrial Group (IG) argues that the Proposed BCA test is inconsistent with Nova Scotia Power's Integrated Resource Plan (IRP) and capital asset treatment, advocating for the utility cost test (PAC). EfficiencyOne (E1) counters that the NSPM is tailored for DERs, the TRC test isn't linked to IRP, and NS Power opposes the PAC test. The debate centers on cost-effectiveness testing for DSM and DERs.
2.6 ALTERNATIVE APPROACH FOR ELECTRIFICATION PROGRAMS - Regarding electrification programs, the IG proposes a modified PAC test that includes increased revenues - from electrification as a benefit, aiming to better assess true system costs...
AI summary The IG proposes a modified PAC test for electrification programs, incorporating revenue benefits. E1 argues the PAC test has a 'fundamental flaw' as noted by Dr. Hill. The IG's approach is criticized as a rate-impact test, not cost-effectiveness, conflicting with NSPM and PUA definitions. References to M12282 and evidence from Bowman and E1 are cited.
2.7 SUPPORT FOR PRIMARY AND SECONDARY TESTING - 2 The IG supports both primary (PAC) and secondary tests for DSM cost-effectiveness specifically the - 3 Proposed BCA and relevant information on the host customer or Participant Cost test ("...
AI summary The Industrial Group (IG) supports both primary and secondary tests for demand-side management (DSM) cost-effectiveness, including the Proposed BCA and Participant Cost Test (PCT). EfficiencyOne (E1) maintains that cost-effectiveness screening must occur at the portfolio level under the Public Utilities Act (PUA), as outlined in section 79H(2), and clarifies it has not retreated from its original position.
3.2 HYBRID PEAKING RESOURCES Eastward Energy expresses the following concern[:26](#page-11-4) There simply does not appear to be the level of acknowledgement of the significant value hybrid heating can bring to the integrated electricity s...
AI summary Eastward Energy argues that E1 (EfficiencyOne) has not adequately acknowledged the value of hybrid heating in the electricity system. However, E1's representative, Ms. Thompson, confirmed during the hearing that E1 recognizes hybrid heating's potential value. The text clarifies hybrid heating is not central to the current application's focus on DSM cost-effectiveness methodology.
3.4 NATURAL GAS TO ELECTRIC CONVERSIONS With respect to natural gas to electric conversions, Eastward Energy raises concerns with regard to an illustrative example regarding conversion of gas heating systems to electric heat pumps, noting...
AI summary Eastward Energy expresses concern over E1's illustrative example of natural gas-to-electric conversions, citing a negative benefit and benefit-cost ratio below 1.0. E1 clarifies the example is hypothetical and reaffirms that justification would be required under existing Board directives if the example were accurate. The Board has already provided guidance on this issue.
3.5 RELIABILITY IMPACTS - Eastward insists that benefit-cost analyses must fully account for the reliability advantages of natural gas - systems, and that any loss of reliability from electrification should be explicitly considered. - The...
AI summary Eastward Energy argues that reliability impacts of electrification must be explicitly considered in benefit-cost analyses, while E1 agrees in principle under specific conditions, such as full electrification without backup gas. E1 proposes addressing these issues via the proposed BCA test and the evergreen process. Eastward seeks immediate action, but lacks evidence of imminent impacts. E1 trusts NS Power's avoided costs include ancillary service costs, pending further confirmation.
6 3.7 SUSTAINABLE DEVELOPMENT AND PROSPERITY CONSIDERATIONS - Eastward cautions against overemphasizing sustainable development and prosperity in benefit-cost tests, - advocating for a balanced approach that considers all legislative requi...
AI summary Eastward cautions against overemphasizing sustainable development in benefit-cost tests, advocating for balance. E1 argues its Proposed BCA test appropriately considers societal impacts as one factor. Eastward Energy warns against applying social cost of carbon to other matters. E1 emphasizes the Board's specific focus on approving the BCA test as a replacement for the TRC test in DSM Plan evaluations.
4. RESPONSE TO NS POWER - NS Power's position regarding the Proposed BCA was first communicated to E1 and the DSMAG in its - Closing Submission. - The Closing Submission invites the Board to narrow Nova Scotia's DSM cost-effectiveness fram...
AI summary NS Power proposes revising the BCA framework to use its WACC and exclude certain benefits, conflicting with post-2022 legislation, the proceeding's record, and NSPM methodology. E1 argues for maintaining the current cost-effectiveness framework, including a 2% discount rate and portfolio-level screening under PUA.
greenhouse gas emissions has been added, as well as the introduction of the required "appropriate consideration" requirements of Energy And Regulatory Boards Act and the More Access To Energy Act . The Board's consideration of the Proposed...
AI summary The Board must apply legislative amendments, including 'appropriate consideration' requirements from the Energy And Regulatory Boards Act and More Access To Energy Act , when evaluating the Proposed BCA. These amendments reflect clear legislative intent, not mere policy objectives, and any methodology failing to comply, such as NS Power's TRC test, must be rejected.
4.2 CONFLATING DSM PLAN CONSIDERATIONS WITH COST-EFFECTIVENESS SCREENING E1 takes no issue with the "operational requirements" interpretation of NS Power with respect to the approval of DSM programs. However, this Application is not a broa...
AI summary E1 supports aligning DSM cost-effectiveness screening with PUA statutory requirements, opposing NS Power's integration of affordability into the screening test. Affordability should be addressed separately through mechanisms like the Balanced Plan Approach, not via cost-effectiveness criteria. The application focuses on statutory compliance under s. 79H(2) PUA, distinguishing screening from broader DSM plan approval processes.
4.3 APPROPRIATE DISCOUNT RATE NS Power asserts that the WACC should be the discount rate for DSM cost-effectiveness screening. NS Power's reliance on WACC as the appropriate discount rate is both legally and conceptually flawed for several...
AI summary NS Power argues for using WACC as the discount rate for DSM cost-effectiveness screening, but opponents claim it is legally and conceptually flawed. They argue WACC misapplies NSPM principles, ignores sustainability and long-term GHG benefits, and undervalues DSM programs. A 2% social discount rate is recommended, aligning with federal guidance and legislative mandates.
100256Board Decision
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IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF AN APPLICATION by EFFICIENCYONE for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans BEFORE: Stephen T. McGrath, K.C., Chair Steven...
AI summary EfficiencyOne applied for approval of a new benefit-cost analysis test for demand-side management plans. The Board denied the application, directing instead a focus on reducing electricity costs for customers. Multiple intervenors, including consumer advocates, industry groups, and environmental organizations, participated in the proceeding.
- [1] In the course of addressing EfficiencyOne's (E1) application to the Nova Scotia Utility and Review Board (NSUARB) for approval of its supply agreement with Nova Scotia Power Incorporated (NS Power) and demand-side management (DSM) re...
AI summary The NSUARB's cost-effectiveness test for DSM plans was questioned for excluding non-energy benefits, leading to potential skewed results. Synapse recommended using the PAC test instead, which focuses on utility costs but ignores participant costs and benefits. This issue arose during the review of EfficiencyOne's application.
2.0 PROPOSED BENEFIT-COST ANALYSIS TEST - [8] E1 is the holder of a franchise issued by the Minister of Energy to provide demand-side management activities to NS Power. Under the Public Utilities Act , E1 must develop a demand-side managem...
AI summary E1, a franchise holder under the Public Utilities Act, must develop demand-side management (DSM) plans for NS Power, structured in tiers (measure, program, portfolio). The NSUARB evaluates these plans using cost-effectiveness testing, ensuring measurable benefits for ratepayers and aligning with Nova Scotia's regulatory practices.
3.1 Consumer Advocate [28] The Consumer Advocate is a signatory to the Consensus Agreement. The Consumer Advocate argues that recent amendments to the Public Utilities Act altered the criteria the Board is to apply in evaluating E1's propo...
AI summary The Consumer Advocate argues that recent amendments to the Public Utilities Act require evaluating demand-side management programs at the portfolio level, including strategic electrification. They emphasize incorporating sustainability factors in the BCA test, preferring E1's approach over the PAC test, and support a 2% social discount rate for long-term impacts. They also maintain the 10% proxy value for electrification and acknowledge the PAC test as a potential secondary measure.
3.2 Industrial Group [34] The Industrial Group is not a party to the Consensus Agreement. It objects to the use of the proposed BCA test as the new primary cost-effectiveness test. It recommends the Board approve the PAC test as the primar...
AI summary The Industrial Group opposes using the BCA test as the primary cost-effectiveness standard, advocating instead for the PAC test for DSM Plan applications and a modified PAC test for strategic electrification. It argues that programs failing the PAC test require justification and that non-energy impacts, like carbon social effects, should not be considered. The group emphasizes complementary use of the PAC test with secondary evaluations and notes the Public Utilities Act amendment adding strategic electrification to DSM's definition.
3.3 Small Business Advocate [45] The Small Business Advocate agreed to the Consensus Agreement and recommends the Board adopt the proposed BCA test as amended by the Consensus Agreement. In closing submissions, the Small Business Advocate...
AI summary The Small Business Advocate agreed to the Consensus Agreement, recommending the Board adopt the amended BCA test. Concerns were raised about quantifying non-energy benefits like amenity and empowerment, with suggestions to set unquantified benefits to zero or adopt the PAC test instead. The Advocate emphasized the need for further analysis on non-energy benefits.
tes" and that the "listed factors in section 6(2)(a-e) [of the Energy and Regulatory Boards Act ] supplement, but do not replace, the Board's primary mandate." In its closing submissions, it states: The operative phrase of section 6(2) is...
AI summary NS Power argues that section 6(2) of the Energy and Regulatory Boards Act requires 'appropriate consideration' of factors without prescribing their weight, and that 'sustainable development' in the BCA test lacks clear linkage to non-utility impacts. It contends E1's approach misinterprets legislative intent by transforming policy language into prescriptive requirements.
3.5 East Coast Environmental Law [56] East Coast Environmental Law (ECEL) is a party to the Consensus Agreement and supports E1's proposed new BCA test as amended by the contents of the agreement. It states in its closing submissions: … We...
AI summary East Coast Environmental Law (ECEL) supports E1's revised BCA test, emphasizing inclusion of carbon social costs in DSM evaluations. It argues that the Energy Reform (2024) Act expands the Board's environmental mandate, requiring alignment with sustainability goals under multiple acts. ECEL stresses that sustainable development and prosperity must be considered alongside affordability and reliability in energy regulation.
3.6 Eastward Energy [61] In its submissions, Eastward Energy asked the Board to make a preliminary and final order that Eastward be added as a full member of DSMAG. On November 4, 2025, the Board noted that Eastward has a valuable perspect...
AI summary Eastward Energy requested DSMAG membership, which the Board approved. They supported strategic electrification testing via PAC with NS Power revenue inclusion, aligned with Posterity Group's advice. Eastward emphasized hybrid heating's economic benefits and urged E1 to prioritize it in the 2027-2031 DSM Plan, citing the Public Utilities Act's cost-reduction mandate.
4.1.1 Introduction [69] The Public Utilities Act requires NS Power to engage E1 to undertake "costeffective demand-side management". The Board must approve these agreements and "determine the cost-effective demand-side management that must...
AI summary The NSUARB must determine the cost-effectiveness test for demand-side management under the Public Utilities Act, with parties disagreeing on whether non-energy impacts should be considered. Post-2020 jurisdictional changes and the 2024 Energy Reform Act split NSUARB into two boards, expanding the Energy Board's consideration scope. E1 argues the Board now has jurisdiction to include non-energy impacts, while some intervenors oppose this. The Board will assess statutory interpretation and decide on BCA approval if jurisdiction is confirmed.
Incorporated, and Nova Scotia Power Incorporated may rely upon the expertise of the franchise holder in respect of the delivery of demand-side management. - (4) The Energy Board shall approve an application pursuant to this Section if, in...
AI summary The Energy Board (NSUARB) must approve demand-side management (DSM) applications if they serve customers' interests and meet PUA requirements. Evaluations occur at the portfolio level, emphasizing cost-effectiveness. Nova Scotia Power may leverage franchise holders' expertise for DSM delivery.
4.1.4 The 2020 Non-energy Benefits Decision - [83] The NSUARB determined it did not have the jurisdiction to consider nonenergy benefits in the cost-effectiveness testing for demand-side management in Re EfficiencyOne , 2020 NSUARB 56. In...
AI summary The NSUARB ruled in Re EfficiencyOne (2020 NSUARB 56) that it lacked jurisdiction to consider non-energy benefits in cost-effectiveness testing for demand-side management. E1 argued that the NSUARB's duty to act in customers' best interests, under the Public Utilities Act , allowed consideration of factors like thermal comfort and property value impacts beyond electricity savings.
4.1.6 The Meaning of "Cost-effective" under the Public Utilities Act [96] From the text used by the Legislature in s. 79I(1) of the Public Utilities Act , it follows that NS Power's statutory duty relates to demand-side management (as defi...
AI summary The Public Utilities Act (PUA) mandates NS Power to implement cost-effective demand-side management, with the NSUARB ensuring compliance. The Act does not explicitly define 'cost-effective,' leaving interpretation to the Board. The Board must evaluate proposals at the portfolio level and ensure they align with s. 79I's requirements.
(2) A franchise (a) gives the franchise holder the exclusive right to supply Nova Scotia Power Incorporated with reasonably available, cost-effective demand-side management for the purpose of this Act; … - 79K (1) Nova Scotia Power Incorpo...
AI summary The franchise grants exclusive rights to Nova Scotia Power Incorporated (NSPI) for cost-effective demand-side management. NSPI must share customer data with franchise holders and cooperate with the IESO on integrated resource planning. Provisions emphasize cost-effectiveness and 'reasonably available' demand-side management, with E1 arguing for a broader benefits-costs test beyond utility impacts.
The current version is: (iv) strategic electrification of energy end uses currently powered by fossil fuels in a manner that reduces overall greenhouse gas emissions and electricity costs [108] E1 submits that strategic electrification can...
AI summary E1 argues that strategic electrification cannot be evaluated using traditional PAC or TRC tests, as utility impacts are primary costs and non-utility impacts (e.g., fuel savings, GHG reductions) are primary benefits. The 2022 PUA amendment defines strategic electrification as reducing GHG emissions and electricity costs, requiring expanded cost-effectiveness analysis to include non-utility benefits.
[124] Eastward expressed similar comments in its reply submissions: E1 has continued in its Closing Submissions to put considerable emphasis on the Board's requirement at section 6(2)(d) of the Energy and Regulatory Boards Act to give "app...
AI summary Eastward's reply submissions emphasize E1's focus on the Board's duty under the Energy and Regulatory Boards Act to prioritize sustainable development in DSM plans. E1 argues that the Board must explicitly address sustainable development, while East Coast Environmental Law notes this responsibility does not override other statutory considerations like affordable energy rates. NSPI aligns with E1's BCA approach, and E1 disputes the Industrial Group's interpretation of legislative changes.
osts. As noted already, strategic electrification may only be undertaken if, in addition to reducing greenhouse gas emissions, it reduces electricity costs. This is explicitly stated in s. 79A(b)(iv). [130] While the NSUARB's 2020 decision...
AI summary The NSUARB examines legislative requirements for demand-side management, emphasizing cost reduction and alignment with sections 79A(b)(iv), 79I(1), and 79H(2) of the PUA. The Board agrees with the Industrial Group and NS Power that cost reduction remains central, rejecting broader interpretations of sustainable development overriding specific cost mandates. References to Matter M12171 highlight tensions between general and specific legislative provisions.
4.2 Benefit-Cost Test Alternatives [143] No party in this proceeding argued that the existing TRC test should be maintained in its present form. [144] As discussed in more detail previously, E1's proposed BCA test includes utility system a...
AI summary No party supports maintaining the current TRC test. E1's proposed BCA test includes utility and non-utility system impacts, informed by Nova Scotia's legislative changes, with objectives of sustainability, GHG reduction, and equitable access. Table 5 compares the existing TRC test and the proposed BCA test.
[146] In its closing submissions, the Industrial Group said: Where the PUA has clearly mandated the focus of DSM to be on the reduction of costs, the PAC is able to demonstrate that as a primary test; the Proposed BCA cannot. As confirmed...
AI summary The Industrial Group advocates for the PAC test over the Proposed BCA, emphasizing cost reduction alignment with the PUA. NS Power proposes a modified TRC test incorporating fuel impacts and GHG reductions. E1 criticizes both approaches, arguing they conflict with post-2022 statutory mandates and fail to balance utility and customer costs.
4.2.1 Findings [151] E1 and its consultants purported to follow guidance in the NSPM in determining the proposed BCA test. However, a process that simply takes account of an inventory of energy and climate change policy goals and objective...
AI summary The Board rejects the proposed BCA test for DSM cost-effectiveness due to misalignment with the PUA's focus on reducing customer electricity costs. The TRC test is criticized for asymmetrical application. The Industrial Group supports the PAC test, which aligns with PUA's statutory requirements. The Board directs E1 to use PAC for future DSM plans.
4.3 Strategic Electrification [158] Strategic electrification that reduces overall GHG emissions and electricity costs is included in the definition of "demand-side management" in s. 79A(b)(iv) of the Public Utilities Act . The PAC test, a...
AI summary The text discusses the challenges of applying the traditional PAC test to strategic electrification programs under the Public Utilities Act. It highlights Mr. Bowman's proposal to modify the PAC test by including increased revenues from electrification as a benefit, ensuring cost-effective programs. The Industrial Group supports this approach, emphasizing alignment with the PUA's mandate to reduce electricity costs for NSPI customers through hybrid heating and other measures.
[160] Eastward made similar comments in its submissions: In this regard the IG has noted that the approach proposed by Mr. Bowman to costeffectiveness testing for E1 for strategic electrification – running the PAC test with the additional...
AI summary Eastward argues that modifying the PAC test to include NSPI's revenue aligns with Posterity Group's recommendations, emphasizing cost-effective hybrid heating programs. E1 counters that this approach assesses rate impacts, not cost-effectiveness, and criticizes E1's BCA focus on GHG reductions over electricity cost savings.
4.3.1 Findings [162] The Board accepts the Industrial Group's suggestion that traditional cost effectiveness tests may be modified to suit specific jurisdictional requirements. The means of assessing strategic electrification in Nova Scoti...
AI summary The Board accepts modifying traditional cost-effectiveness tests for strategic electrification in Nova Scotia. It endorses Mr. Bowman's PAC test approach for E1 but notes E1's incomplete work on demonstrating cost reductions. The Board requires E1 to meet both GHG reduction and cost-effectiveness criteria, allowing future alternative proposals in its 2027-2031 DSM Plan.
4.4 Portfolio Level Assessment [164] Section 79H(2) requires the Board to evaluate the proposed cost-effective demand-side management at the portfolio level. In its submissions, the Industrial Group urged that it was particularly important...
AI summary Section 79H(2) mandates portfolio-level evaluation of demand-side management cost-effectiveness. The Industrial Group and NS Power argue tests must apply at portfolio, program, and measure levels with E1 justifying failures. E1 insists screening should occur only at the portfolio level.
4.4.1 Findings [166] There is no ambiguity in s. 79H(2): the Board must evaluate the proposed cost-effective demand-side management at the portfolio level. As noted previously in this decision, the Board agrees with E1 that there is a diff...
AI summary The NSUARB mandates evaluating cost-effective demand-side management (DSM) at the portfolio level, not individual measures. The Board allows alternative cost-effectiveness tests, including BCA, and requires E1 to justify measures failing primary tests. NS Power's WACC must be compared if a social discount rate is used in BCA. The Energy and Regulatory Boards Act (ERBA) permits justification based on factors under s. 6(2).
4.5 Discount Rate [169] Benefit-cost analysis involves comparing all the costs and benefits of a program over a period of time. There will be a stream of costs and benefits that are usually spread over several years, and in some cases, dec...
AI summary The section explains the role of discount rates in Benefit-Cost Analysis (BCA), emphasizing their importance in reflecting time preference and opportunity costs. It outlines three categories of discount rates from the National Standard Practice Manual (NSPM): WACC, customer-focused rates, and societal discount rates, each serving different purposes in evaluating distributed energy resources.
4.5.1 Findings [192] Discounting is a fundamental component of BCA. Applying a social discount rate places greater emphasis on future benefits than a standard discount rate typically would. Environment and Climate Change Canada's SC – GHGs...
AI summary The text discusses the use of social discount rates in Benefit-Cost Analysis (BCA), noting that Environment and Climate Change Canada's SC-GHG guidance employs a lower discount rate to prioritize future benefits. It criticizes E1 for not following the Treasury Board's policy on when to apply a social discount rate, as outlined in the Policy on Cost-Benefit Analysis .
s. 7.1 about the discount rate to be used: The discount rate is the rate at which future costs and benefits are converted to their present equivalents. Discounting accounts for the fact that: - there is a time preference for current consum...
AI summary The document establishes that the discount rate for regulatory analyses should be based on the opportunity cost of capital (WACC), as per Treasury Board guidelines. It emphasizes alignment with NS Power's IRP and the Public Utilities Act, rejecting social discount rates except for specific long-term cases. The NSUARB mandates WACC for cost-effectiveness testing of DSM programs, citing NS Power's funding source and the need for comparable evaluations.
[201] In its response, E1 stated: The approach E1 is proposing in the 'evergreen' process for calculating the emissions intensity of DSM savings for the purposes of benefit cost analyses is the Difference in Carbon Emissions (DICE) method....
AI summary E1 proposes using the Difference in Carbon Emissions (DICE) method for calculating emissions intensity in benefit-cost analyses, aligning with NSPM guidance and IRP modeling. This method considers long-term generation resource mix impacts, contrasting with short-term marginal emissions approaches. E1 also notes average emissions rates are used for illustrative BCA examples.
4.8 Avoided Costs [212] Eastward raised concern about NS Power's avoided cost values and requested confirmation that ancillary service costs, peak costs and system reliability are embedded in the avoided cost values. Eastward also requeste...
AI summary Eastward questioned NS Power's avoided cost values, specifically regarding ancillary services, peak costs, and reliability. NS Power responded that these factors are included in their avoided cost modeling, particularly with DSM programs like electrification of transportation, and referenced the IRP model and DSMAG. The Board accepted NS Power's response.
4.9 Natural Gas System Reliability [215] In its evidence [Exhibit E-11], Eastward raised concerns about the potential for E1 to propose natural gas to electricity conversion as a strategic electrification project in its upcoming DSM portfo...
AI summary Eastward raised concerns about E1's proposed natural gas-to-electricity conversion project, citing a negative net benefit and low benefit-cost ratio. E1 clarified its example was illustrative and agreed to consider reliability impacts in future proposals. The Board accepted E1's response to address reliability concerns in such projects.
5.0 SUMMARY OF BOARD FINDINGS [217] The Board finds it does not have the authority to approve E1's proposed BCA because the Public Utilities Act restricts the Board's ability to consider non-energy and societal benefits in assessing the co...
AI summary The Board rejects E1's proposed BCA due to the Public Utilities Act's restrictions on non-energy benefits. E1 must use PAC test and NS Power's WACC for DSM plan assessments. Strategic electrification requires GHG reduction and cost savings. Eastward is added to DSMAG. Portfolio-level cost-effectiveness evaluations are mandated.