Topic:"Demand Side Management" in M07151

Nova Scotia Utility and Review Board IN THE MATTER OF The Public Utilities Act, R.S.N.S. 1989, c.380, as amended. -and- IN THE MATTER OF AN APPLICATION by EfficiencyOne for Approval of a Supply Agreement for Electricity Efficiency and Cons...

AI summary The Nova Scotia Utility and Review Board considers an application by EfficiencyOne for approval of a supply agreement with Nova Scotia Power Inc., seeking establishment of a final agreement and approval of a 2016-2018 Demand Side Management (DSM) Plan under the Public Utilities Act.

2016-2018 DSM Plan NS Power Cost Allocation Proposal

AI summary The 2016-2018 DSM Plan includes a cost allocation proposal by NS Power, outlining how costs related to demand-side management initiatives will be distributed.

October 30, 2015 1 TABLE OF CONTENTS 2 3 1.0 INTR RODUCTION 3 4 2.0 BAC KGROUND 5 5 3.0 NS P POWER'S POSITION 6 6 4.0 COS T ALLOCATION PROPOSAL 8 7 4.1 DSM net contract price 2016-2018 8 8 4.2 Balance Adjustments 2010 & 2014 9 9 4.3 Cost a...

AI summary This document outlines Nova Scotia Power Inc.'s position on the cost allocation methodology for Demand Side Management (DSM) as agreed upon in the Consensus Agreement dated June 16, 2015. The proposal includes DSM cost allocation for 2015, 2016-2018, and the 2014 rate-smoothing adjustment, with input from the DSM Advisory Group.

DATE FILED: October 30, 2015 Page 3 of 12 1 2016-2018 DSM Plan Consensus Agreement (Schedule B), M06733, Approved October 7, 2015, page 6. on the precise terms of this proposal2 1 , the Company did not receive objections from any 2 members...

AI summary NS Power filed a document related to the 2016-2018 DSM Plan Consensus Agreement, noting that no objections were raised about the general cost allocation framework. It also stated that DSM cost recovery is separate from cost allocation and will be addressed in a subsequent filing.

2 For example, the DSM Advisory Group has not reached a consensus on the cost allocation of enabling strategies. 1 2.0 BACKGROUND 2 3 Prior to the recent amendments to the Public Utilities Act (Act), the cost of DSM was 4 recovered through...

AI summary The text discusses the transition of DSM cost recovery from a rider to a new methodology approved by the Board in 2010, which allocates 25% system cost and 75% participant cost. It also notes that the DSM Advisory Group has not reached a consensus on cost allocation for enabling strategies.

1 3.0 NS POWER'S POSITION 2 3 The current 25/75 per cent split between system cost and participant cost was agreed to 4 by stakeholders to the 2009 Settlement Agreement. It appropriately recognizes that rate 5 class benefits from DSM progr...

AI summary NS Power argues the 25/75 cost split between system and participant costs for DSM programs aligns with cost-of-service principles, as participating classes benefit most. They propose maintaining this split but suggest exceptions for Enabling Strategies when benefits exceed $100,000 or are tied to historical averages, reducing tracking requirements.

1 4.0 COST ALLOCATION PROPOSAL 2 3 NS Power proposes the following DSM cost allocation treatment. 4

AI summary Nova Scotia Power (NSP) proposes a Demand Side Management (DSM) cost allocation treatment as part of the regulatory proceeding. The proposal relates to how DSM program costs will be allocated, likely under the DSM Cost Recovery Rate Rider (DCRR) framework governed by the Public Utilities Act.

5 4.1 DSM net contract price 2016-2018 6 In its Decision6 7 to approve the 2016-18 DSM Plan, the Board stated as follows: 8 9 The Board approves a DSM Plan for 2016-2018 in the aggregate amount 10 of $102,150,000. Approved spending is $33,...

AI summary The Board approved a DSM Plan for 2016-2018 with a total spending of $102,150,000, allocating $33,210,000 in 2016, $34,020,000 in 2017, and $34,920,000 in 2018. The net contract price for this period is capped at $93,631,970, as outlined in Schedule B of the Supply Agreement approved in October 2015.

DATE FILED: October 30, 2015 Page 8 of 12 6 2016-2018 DSM Plan, UARB Decision 2015 NSUARB 204, M06733, August 12, 2015, page 1. 7 2016-2018 DSM Plan, UARB Order 2015 NSUARB 204, M06733, October 7, 2015. 8 The 2017 payments owing by NS Powe...

AI summary The text discusses the financial adjustments related to the 2016-2018 DSM Plan, referencing UARB decisions and orders, and outlines how payments to E1 by NS Power will be adjusted based on under-spending and surplus funds from previous years.

12 4.3 Cost allocation of 2016-2018 13 14 Please refer to Appendix A for allocation of DSM Program costs from years 2016 to 15 2018 among rate classes using the current costing methodology. The calculations were 16 based on a DSM cost allo...

AI summary The document refers to Appendix A for the allocation of DSM Program costs from 2016 to 2018 among rate classes using a costing methodology provided by E1 following their Compliance Filing in September 2015.

12 Efficiency Nova Scotia Financial Statement for the year ending December 31, 2014, issued March 27, 2015, page 14. 1 the approved DSM spending of $102, 500 for 2016-2018). The model was subsequently 2 updated by NS Power with its own usa...

AI summary NS Power proposes a true-up mechanism to reconcile DSM expenditures with actual customer load and programming, ensuring accurate cost recovery. The process involves annual adjustments based on forecast and actual data, with details to be filed in November 2015.

DATE FILED: October 30, 2015 Page 11 of 12 1 4.5 Rate Smoothing Adjustment 2 3 NS Power proposes that the inter-class DSM loans incurred in 2014 be repaid over a 4 three year period. The Company will propose an appropriate approach for rec...

AI summary NS Power proposes repaying inter-class DSM loans from 2014 over three years and plans to submit a cost recovery filing on November 30, 2015. The proposal aligns with the Consensus Agreement and input from the DSM Advisory Group, requesting the Board's approval for the DSM cost allocation.

Table 1 (PCR) (2016) Unnamed: 0 Unnamed: 1 Unnamed: 2 Unnamed: 3 Unnamed: 4 Unnamed: 5 Unnamed: 6 Unnamed: 7 Unnamed: 8 Unnamed: 9 Unnamed: 10 Line # NaN Table 1: 2016 PCR - Preliminary allocation of 25% of 2016 program costs associated wi...

AI summary This table presents the preliminary allocation of 25% of 2016 program costs associated with system benefits, including the distribution of costs across different categories such as generation, transmission, and demand-related factors. It also outlines the classification of system benefit DSM costs and their respective shares.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary The document outlines NSPI's responses to information requests from the Consumer Advocate regarding DSM cost allocation and recovery under the proceeding NSUARB M07151.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 Please provide a rationale for using historical averages as part of the formula for allocating 4 Enabling Strategies expenditures among rate classes as proposed in the 2016-2018 DSM 5 Plan NS Power Cost...

AI summary The document discusses the rationale for using historical averages to allocate Enabling Strategies expenditures among rate classes as proposed in the 2016-2018 DSM Plan. The company argues this method simplifies tracking and proposes conditions for exceptions when costs exceed $100,000 or are clearly tied to specific rate classes.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary This document outlines NSPI's responses to information requests from the Consumer Advocate regarding DSM cost allocation and recovery in the NSUARB M07151 proceeding.

NON-CONFIDENTIAL 1 Request IR-3: 2 3 Please explain exactly what historical data was used and how it was used in dollar terms to 4 allocate Enabling Strategies expenditures by rate class in NSPI's proposed allocation of 5 Enabling Strategi...

AI summary The request (IR-3) asks NS Power to explain the historical data used for allocating Enabling Strategies expenditures by rate class. NS Power responds that they used allocation factors provided by E1, referencing a 2015 spreadsheet. The matter is part of NSUARB M07151.

REDACTED DSM Cost Allocation and Recovery CA IR-4 Attachment 1 Page 1 of 12 COLUMN Α В С D E F G Н Program Cost Recovery by Bo enefits System Benefits Combined Class and 25% $8,302,500 Participant Benefits 75% $24,907,500 Total 1 100% $33,...

AI summary The document outlines the allocation and recovery of DSM (Demand Side Management) program costs, with 25% allocated to system benefits and 75% to participant benefits. It details how costs are distributed across generation, transmission, and energy-related factors, along with the financial breakdown by rate class.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary This document outlines NSPI's responses to information requests from the Consumer Advocate regarding DSM cost allocation and recovery under the NSUARB M07151 proceeding.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary The document outlines NSPI's responses to information requests from the Consumer Advocate regarding DSM cost allocation and recovery under the NSUARB M07151 proceeding.

Date Filed: February 1, 2016 NSPI (CA) IR-8 Page 1 of 1 DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary The document outlines NSPI's responses to information requests from the Consumer Advocate regarding DSM cost allocation and recovery under the NSUARB proceeding M07151, dated February 1, 2016.

1 NS Power 2016-2016 DSM Plan, NSUARB Decision, M06733, August 12, 2015, page 26, paragraph 74. DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary The text references the NS Power 2016-2016 DSM Plan and NSUARB Decision M06733, as well as NSPI's responses to consumer advocate information requests in the context of DSM cost allocation and recovery, as addressed in NSUARB M07151.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary This document outlines NSPI's responses to information requests from the Consumer Advocate regarding the allocation and recovery of Demand Side Management (DSM) costs under the NSUARB proceeding M07151.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Consumer Advocate Information Requests

AI summary This document outlines NSPI's responses to information requests from the Consumer Advocate regarding DSM cost allocation and recovery under the NSUARB proceeding M07151.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 Reference: Page 2, 2015 DSM Amounts. "For 2015, DSM was established at $35 million 4 plus any remaining DSM balance from 2013. NS Power will expense the 2016 amortization 5 amount in its 2016 operating...

AI summary The document discusses a request regarding the amortization of the 2015 DSM amount, confirming that it will be based on the 2015 amount of $35 million, not including the 2013 balance. It also asks about the interest rate used and whether a repayment agreement with EfficiencyOne is possible.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Industrial Group Information Requests 1 Request IR-1: 2 3 Please define "Cost Allocation", "Cost Accounting" and "Cost Recovery" as it applies to 4 DSM. 5 6 Response IR-1:...

AI summary NS Power defines 'Cost Allocation' as distributing DSM costs among rate classes and 'Cost Recovery' as customer reimbursement through rates for DSM activities. NS Power states it is unfamiliar with 'Cost Accounting' in this context. The proceeding relates to DSM cost allocation and recovery under matter M07151.

NON-CONFIDENTIAL 1 Request IR-2: 2 3 (a) Please outline any differences in what was proposed by NSPI in its October 4 30, 2015, Cost Allocation Proposal, its November 30, 2015, letter to the Board 5 and its December 18, 2015, letter to the...

AI summary The document outlines NSPI's submissions regarding DSM cost allocation and cost recovery, noting differences between the October 30, 2015, November 30, 2015, and December 18, 2015, filings. It also references a UARB directive for additional details and states that NS Power's positions on cost recovery and cost allocation remain consistent across the filings.

CONFIDENTIAL (Attachment Only) 1 Request IR-4: 2016 Jan 2016 Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016 Jul 2016 Aug 2016 Sep 2016 Oct 2016 Nov 2016 Dec Annual Peak 3CP Requirements Residential non ToD 1,204.3 1,167.8 982.4 709.9 678.9 4...

AI summary The table presents monthly and annual electricity demand data for various customer categories in Nova Scotia from January to December 2016. It includes figures for residential non ToD, residential ToD, small general, general demand, large general, small industrial, medium industrial, large industrial with interruptible, and large industrial firm.

MONTHLY SYSTEM COINCIDENT PEAKS: REQUIREMENTS, SALES, AND LOSSES BY RATE CLASS IN MWh PER HOUR 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Annual Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Peak 3CP Small General 6.5 6....

AI summary The document presents monthly system coincident peak data for 2016, detailing energy requirements, sales, and losses by rate class (e.g., Small General, Large Industrial) in MWh per hour. Totals show varying peak demand across months, with annual figures highlighting seasonal trends and differences between rate classes.

REDACTED DSM Cost Allocation and Recovery IG IR-4 Attachment 1 Page 5 of 15 REDACTED (CONFIDENTIAL INFORMATION REMOVED) Losses as %Sales Residential non ToD Residential ToD Residential Total Small General General Demand Large General Small...

AI summary The document provides a table showing the percentage of losses across various customer categories and months. It outlines the distribution of losses for different types of users, including residential, industrial, and general demand, over a 12-month period.

MONTHLY SYSTEM COINCIDENT PEAKS: REQUIREMENTS, SALES, AND LOSSES BY RATE CLASS IN MWh PER HOUR 2018 Jan 2018 Feb 2018 Mar 2018 Apr 2018 May 2018 Jun 2018 Jul 2018 Aug 2018 Sep 2018 Oct 2018 Nov 2018 Dec Annual Peak 3CP Large Industrial Wit...

AI summary The document presents monthly system coincident peaks by rate class in MWh per hour for 2018, and includes responses by NSPI to information requests regarding DSM cost allocation and recovery, referencing the 2014 COSS and 2016 budget variances.

Universal Parameters Effective Interest Rate 7.8% Amortization Period 8 Years Year Min Max 2014 0.500% 1.50% 2015 0.00% 2.00% 2016 0.00% 2.00% Legend: Manual Input Dropdown Input Output Cell Documentation (click the buttons to view): Assum...

AI summary The document presents universal parameters including an effective interest rate of 7.8% and an 8-year amortization period. It also includes a table with minimum and maximum values for different years. The document is part of a redacted attachment related to DSM cost allocation and recovery.

NON-CONFIDENTIAL 1 Request IR-10: 2 3 Reference: 2013 and 2014 Balance Adjustments 4 5 Please explain what is meant by the underlined phrase: "…this variance should be 6 attributed to the 2016 DSM Program and could be allocated such that c...

AI summary The response to Request IR-10 explains that the variance attributed to the 2016 DSM Program can be reallocated among classes based on their surplus or debit positions, allowing EfficiencyOne to adjust program offerings accordingly while meeting energy savings targets.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 The Board letter of December 3, 2015 requested additional detail on "2014 DCRR amounts 4 currently in rates" (item d). NSP's submission response (page 4 of 8) was "This item is 5 addressed above in comm...

AI summary The document discusses a request for clarification regarding the 2014 DCRR amounts currently in rates and references a response that directs to Multeese IR-6. It is part of a proceeding related to DSM cost allocation and recovery.

NON-CONFIDENTIAL 1 Request IR-3: 2 3 It is apparent that the benefit of increasing DSM costs is a reduced fuel bill for NSP as a 4 result of reduced KWH production requirements. Please indicate why, or why not, in 5 NSP's opinion DSM costs...

AI summary The document addresses whether DSM costs should be included in the FAM. NS Power agrees, citing section 79M(5) of the Public Utilities Act, as DSM costs are fully recoverable and align with FAM processes.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Multeese Information Requests

AI summary The document pertains to DSM Cost Allocation and Recovery under the NSUARB M07151 proceeding, with NSPI providing responses to Multeese Information Requests.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 With respect to the cost allocation methodology proposed on October 30, please discuss 4 how this will relate to NSPI's cost of service methodology used to assign other costs to 5 classes. For example,...

AI summary The response discusses how NSPI views the DSM cost allocation methodology as part of the overall cost of service framework, with DSM costs being subject to R/C ratio adjustments and recovered through prospective base cost rates, similar to base cost of fuel under the FAM.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Multeese Information Requests 1 Request IR-2: 2 3 On page 2 of the December 18 submission, NSPI notes that "it views the DSM quantum of 4 $102.2 million as a flow through e...

AI summary NSPI explains its approach to expensing and recovering DSM costs, noting that the 2016 DSM amounts will be expensed and that a determination for years beyond 2016 will be made by June 30, 2016 or with the filing of a General Rate Application. It confirms that all 2015 and 2016 DSM costs will be recovered from customers by the end of 2016.

NON-CONFIDENTIAL 1 Request IR-6: 2 3 Re the statement under the heading "DCRR Amounts currently in rates" on page 4 of the 4 December 18 submission, please elaborate on how this is addressed in the comments re: 5 2016-2018 Program Costs. 6...

AI summary NS Power explains that its non-fuel rates do not currently include DSM funds. While previous GRA revenue was not explicitly allocated for DSM programming, NS Power considered 2016 DSM costs in its expense forecasting and will make similar decisions for future GRA applications under the Electricity Plan Implementation (2015) Act.

CONFIDENTIAL (Attachment Only) 1 Request IR-14: 2 3 In Appendix A, referencing the column labelled "2015 DSM Plan Amortized over 8 years", 4 5 (a) Please confirm that these costs are based on the full amount of approved 6 expenditures capp...

AI summary Request IR-14 seeks clarification on NSPI's 2015 DSM Plan amortization, calculation of 2016 costs, carrying cost adjustments, and variance significance between allocation methods. NSPI confirms costs are capped at $35M and refers to attachments for detailed calculations and variances. The proceeding involves DSM cost allocation and recovery under NSUARB M07151.

NON-CONFIDENTIAL 1 Request IR-1: 2 3 In a letter to the UARB dated December 18, 2015, NSPI provided, pursuant to the Board's 4 letter dated December 3, 2015, additional detail regarding NSPI's specific cost recovery or 5 accounting treatme...

AI summary The document outlines a request to the UARB regarding NSPI's cost recovery and accounting treatment for specific DSM components, including the approval of a $102.2 million DSM quantum and the interpretation of Section 79 M (5) of the Public Utilities Act. The request also seeks clarification on how NSPI interprets Section 45 of the Act in relation to DSM cost recovery.

1 NSUARB DSM Decision, August 12, 2015, page 26, paragraph 24.

AI summary A reference to a decision made by the NSUARB regarding DSM on August 12, 2015, specifically page 26, paragraph 24.

NON-CONFIDENTIAL 1 Request IR-4: 2 3 NSPI also identifies its decision to not seek a general rate increase for 2016 as a 4 contributing factor that "hampers" its ability to rebalance through the 2016 to 2018 DSM 5 plan. Please describe, an...

AI summary NSPI claims not seeking a 2016 general rate increase hampers its ability to rebalance through the 2016-2018 DSM plan. The response cites a changed cost recovery model and notes an alternative approach using a GRA with per-class DSM cost forecasting for the 2016 test year.

NSPI's Filing Dated December 18, 2015 In its December 18, 2015 letter, NSPI stated: - 1) One-eighth of the 2015 program cost will be expensed in its 2016 operating costs. - 2) The 2016 DSM program costs will be absorbed in existing rates a...

AI summary NSPI outlined cost management strategies for DSM programs, proposing to expense 2015 and 2016 program costs in operating expenses, deferring 2017-2019 cost recovery decisions, and suggesting three options for addressing the 2014 RSA. It also proposed methodologies for true-ups and allocation of DSM funds, including alignment with COS or E1 program budgets.

or allocating 2015 to 2018 costs, stating that the past cost allocation methodology discourages participation on a rate class level by increasing rates for the rate classes as participation increases. Regarding cost allocation for Enabling...

AI summary The document discusses disputes over cost allocation methodologies for Enabling Strategies expenditures between NSPI and Elenchus. The Industrial Group supports NSPI's approach of direct assignment and a 25/75 split, while the CA favors Elenchus' method to avoid double-charging residential classes. Concerns include fairness, cost causation, and tracking complexities.

NSPI's Reply Submission dated Feb 23, 2016 In response to participant submissions, NSPI noted the following: - a) Program costs should be allocated in alignment with E1 's budgets, then compared against actual DSM expenditures on an annual...

AI summary NSPI outlines responses to regulatory submissions, proposing program cost allocation aligned with E1 budgets, rate smoothing adjustments via rate changes, Enabling Strategies methodology, treating 2016 DSM costs as operating expenses, and deferring 2017-2018 DSM cost decisions until a GRA filing or June 30, 2016.

Board Decision The Board understands that 2013 and 2014 Balance Adjustments have been rolled into the 2015 and 2016 DSM programs, respectively, and accepts that approach. Regarding treatment of the 2015 DSM program costs, which are being a...

AI summary The Board approves NSPI's proposal to recover 2015 DSM program costs over 8 years, with one-eighth recovered as 2016 operating costs and the rest via financing. It rejects deferring 2017-2019 DSM cost decisions. NSPI failed to file required details by November 30, 2015, despite prior directives. The Board's Order M06733 mandated this filing.

November 30, 2015 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: Nova Scotia Power Inc. – DSM Cost Recovery – M07151 Dea...

AI summary The Nova Scotia Utility and Review Board ordered Nova Scotia Power Inc. (NSPI) to file its 2015 and 2016-18 DSM cost recovery proposals by November 30, 2015. NSPI noted lack of consensus on cost allocation from the DSM Advisory Group but emphasized cost recovery as a separate matter. The Board deferred stakeholder timelines pending NSPI's filing due to interdependencies between cost allocation and recovery.

efficiency charges will be included. 1 The Plan provides that new legislation will be introduced in Fall, 2015 to enable rate stability, innovation and competitively priced community solar. Following the changes to electricity policy, NS P...

AI summary Nova Scotia Power Inc. (NSPI) plans to absorb 2016 Demand Side Management (DSM) costs without rate adjustments, citing new legislation for rate stability and community solar. NSPI seeks to defer DSM cost recovery discussions for 2017-2019 and requests a filing extension. DSM expenses are unique due to caps, refunds, and multi-year benefits.

evenue requirement. For the DSM proposed accounting treatment and cost recovery recommendation for the 2017-2019 period, NS Power requests the Board extend the date for filing its proposal as follows: - (1) If NS Power determines that an a...

AI summary NS Power requests the Board's approval to incorporate 2016 DSM cost recovery in its financials and defer 2017-2018 DSM cost recovery. It proposes filing deadlines contingent on a non-fuel-related rate increase application and allocates variances based on cost of service. The submission includes a footnote referencing 2014 variance allocation.

Nova Scotia Power Inc. DSM Cost Allocation and Recovery (M07151/E-R-15) The DSM Consensus Agreement signed by parties to Matter M06733, and approved by the Board in its Decision dated August 12, 2015, included the following: The Parties ag...

AI summary Nova Scotia Power Inc. (NSPI) is required to file detailed cost allocation and recovery models for its DSM programs, including 2015 and 2016-2018 periods, as well as related adjustments. The Board is concerned about NSPI's non-compliance with previous orders and has directed it to submit complete details by specific deadlines. NSPI also requested an extension for filing its proposals for the 2017-2019 period.

December 18, 2015 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: Nova Scotia Power Inc. – DSM Cost Recovery – M07151/E-R...

AI summary Nova Scotia Power Inc. (NS Power) submitted its 2016 DSM cost recovery proposal to the Utility and Review Board (UARB), citing legislative changes from the provincial electricity plan. The UARB requested additional details on specific DSM components, including rate-smoothing adjustments and balance adjustments, and noted no consensus among parties. NS Power argues the approved DSM quantum of $102.2 million should be fully recovered as a flow-through expense under the Public Utilities Act.

2015 DSM Amounts In 2015, legislative changes restructured the way that DSM is delivered to NS Power's customers as well as the period costs are recovered. DSM program costs were determined by legislation and recovery of the associated cos...

AI summary Legislative changes in 2015 restructured DSM delivery for NSP, deferring costs over eight years. DSM was set at $35M plus 2013 balance, with NSP expensing 2016 amortization.

2016-2018 DSM Program Costs On November 10, 2015, following the changes to Nova Scotia's electricity policy, the Company announced that it will not apply for a General Rate Application for 2016. This means that for the 2016 period NS Power...

AI summary NS Power announced in 2015 it would absorb 2015-2016 DSM program costs into existing rates without a General Rate Application. Uncertainty remains for post-2016 costs, with a legislative deadline of April 30, 2016, to determine rate increases. NS Power deferred a decision until a rate application or June 30, 2016, citing unresolved cost absorption plans.

2014 Rate Smoothing Adjustment In its 2014 DSM Cost Recovery Rider Application, Efficiency One's (E1) predecessor, Efficiency Nova Scotia Corporation (ENSC), realized that the Small General and Large General classes would experience revenu...

AI summary In 2014, Efficiency Nova Scotia Corporation (ENSC) applied for a DSM Cost Recovery Rider, leading to revenue increases for certain classes. The UARB approved a rate smoothing adjustment allowing over-recovered classes to loan funds to under-recovered ones, reducing the DCR Rider impact. Under-recovered classes agreed to repay with interest (2015–2017). The 2015 Settlement Agreement deferred repayment details to the 2016–2018 DSM plan. NS Power proposed options to resolve inter-class imbalances, including reallocation, true-up during rate applications, or fuel cost filings.

DCRR Amounts currently in rates This item is addressed above in comments re: 2016 – 2018 DSM Program Costs

AI summary The document references a prior discussion on 2016–2018 DSM Program Costs, indicating that the topic of DCRR amounts in rates has been previously addressed in the regulatory proceeding. No new claims or data are presented in this specific text fragment.

2013 and 2014 Balance Adjustments As referenced above, the 2013 amount has been applied to DSM funding in 2015. NS Power suggests that the 2014 imbalance amounts should be dealt with in a similar manner. However, the costs were collected t...

AI summary NSP proposes applying 2014 imbalance amounts to DSM funding like 2013, but costs were collected via DCRR under the ENSC budget. Variance analysis between recovery and expenditure should be allocated to 2016 DSM programs per the Board's decision, with details in Appendix B.

True Up Proposals Although true ups do not have a direct impact on NS Power, the Company supports the manner in which true ups were managed when DSM was recovered through a rate rider. Essentially, a customer class rate rider amount was ba...

AI summary NSP supports managing true ups through rate riders, proposing contract periods instead of annual rebalancing to allow cost-effective DSM programs. However, 2015-2016 lacks specific class rate riders, creating no baseline for budget allocation. Three alternatives—cost of service allocation, actual DSM alignment, and no allocation—are presented. NSP opposes true up mechanisms hindering E1's energy savings goals.

Cost of Service Allocation This option would allocate DSM funds among customer classes in the same manner that NS Power allocates earnings above its approved range of return – allocate based on NS Power's cost of service. Any true ups woul...

AI summary This approach allocates DSM funds based on NS Power's cost of service, mirroring how earnings above approved returns are distributed. It uses a 75% class cost / 25% system cost split, justified by prior customer agreement and NS Power's 2015 recommendation. True ups would compare this allocation to actual expenditures.

Traditional DSM Allocation This proposal would allocate DSM funds in accordance with E1's DSM program budget. Once the DSM program has been delivered, the actual costs would be compared to assess any imbalance. Although this aligns with ho...

AI summary The proposal allocates DSM funds based on E1's program budget, comparing actual costs post-delivery to identify imbalances. While aligning with the rate rider formula, it differs as funds aren't collected based on the E1 budget. The initial allocation is deemed flawed but establishes a baseline for E1's program obligations if budget variances occur.

No Allocation There is also merit in considering whether any initial budget should be set or imbalance calculated during this period. Until the next general rate application, DSM will not have a specific allocation in rates and, as such, D...

AI summary The document discusses the allocation of Demand Side Management (DSM) costs in the absence of a specific rate allocation, proposing that DSM expenses be absorbed into existing rates. NS Power requests the Board to acknowledge the recovery of 2015 and 2016 DSM costs as operating expenses and to address cost recovery for 2017-2019. The document also outlines the need for stakeholder input on cost allocation.

c. Tim Wood DSM Intervenors 2016 DSM Costs apportioned to rate classes using DSM cost allocation methodology 2016 DSM Costs apportioned to rate classes using class relative shares in rate base from 2014 COSS Variance between two approaches...

AI summary The table presents the apportionment of 2016 DSM costs to various rate classes using two different methodologies — the DSM cost allocation methodology and class relative shares in rate base from 2014 COSS — and highlights the variance between the two approaches. The data includes revenue figures, cost allocations, and percentages for each rate class.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION by Nova Scotia Power Incorporated ("NSPI") for Approval of the DSM Cost Allocation and Recovery

AI summary The Nova Scotia Utility and Review Board is considering an application by Nova Scotia Power Incorporated (NSPI) under the Public Utilities Act for approval of Demand Side Management (DSM) cost allocation and recovery. The proceeding involves regulatory review of NSPI's proposed methodology for recovering DSM program costs from ratepayers.

Request IR-1: - 2 With respect to the cost allocation methodology proposed on October 30, please discuss how - 3 this will relate to NSPI's cost of service methodology used to assign other costs to classes. For - 4 example, does NSPI see t...

AI summary Request IR-1 asks NSPI to clarify whether its proposed DSM cost allocation methodology operates within its overall cost of service framework or as a separate method. It seeks confirmation on whether DSM costs would be integrated into total class costs for R/C ratio calculations or treated independently.

Request IR-2: - 11 On page 2 of the December 18 submission, NSPI notes that "it views the DSM quantum of $102.2 - 12 million as a flow through expense to be fully recovered from customers". Is it correct to interpret - 13 this statement to...

AI summary The document questions NSPI's interpretation of DSM costs as a fully recoverable, annual expense rather than an amortized cost. NSPI claims the $102.2 million DSM quantum is a flow-through expense to be recovered from customers each year, raising regulatory scrutiny over its accounting treatment.

Request IR-3: - 18 On page 3 of the December 18 submission, it is stated with respect to 2015 DSM costs that the - 19 Company will expense the 2016 amortization amount in its 2016 operating costs. Also on page - 20 3, it is stated with res...

AI summary The request seeks confirmation that NSPI's 2016 amortization and DSM program costs will be fully recovered from customers by year-end, based on their submission stating 2016 costs will be expensed and absorbed into existing rates.

Request IR-4: - 26 On page 3 of the December 18 submission, NSPI proposes to defer a determination regarding - 27 DSM cost recovery for the 2017 through 2019 period until the earlier of NS Power filing a General - 28 Rate Application or Ju...

AI summary NSPI proposes deferring DSM cost recovery for 2017-2019 until a GRA filing or June 30, 2016, despite legislation requiring a GRA by April 30, 2016. The request asks if NSPI's non-filing would imply absorbing 2017-2018 costs like 2016 and full recovery by 2018. Additional requests address rate smoothing adjustments, DORR amounts, and 2013-2014 balance adjustments.

Request IR-11: 26 27 28 considering whether any initial budget should be set or imbalance calculated during this period". In the subsequent paragraph, it is noted that "there is merit in considering that, for 2016 forward until the next GR...

AI summary Request IR-11 seeks clarification on the timeframe for initial budget and imbalance calculations, noting consideration of not tracking DSM variances by class from 2016 until the next GRA. The No Allocation alternative's timeline (2015 through next GRA) is questioned, with requests for explanation.

Request IR-12: 1 5 7 8 14 15 16 17 18 20 21 22 23 24 25 26 27 28 - 2 In discussing the No Allocation alternative, it is stated in the last sentence on page 6 that "The - 3 expectation that E1 would continue to execute its undertaking in ac...

AI summary The document requests clarification on how E1 would mitigate inequities under the No Allocation alternative by referencing the 2016-2018 DSM program approval from the Board. It emphasizes E1's obligation to adhere to prior regulatory undertakings to address potential inequities.

Request IR-14: - 19 In Appendix A, referencing the column labelled "2015 DSM Plan Amortized over 8 years", - a) Please confirm that these costs are based on the full amount of approved expenditures capped at $35 million, unadjusted for act...

AI summary Request IR-14 asks NSPI to clarify the calculation and assumptions behind the 2015 DSM Plan amortization, including how the 2016 portion was calculated, the impact of a 3% carrying cost, and whether the variances between traditional and cost of service allocation methods are considered insignificant.

2015 M07151/E-R-15 NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: The Public Utilities Act , R.S.N.S. 1989, c.380 as amended IN THE MATTER OF: An Application by EfficiencyOne for Approval of a Supply Agreement for Electricity Effic...

AI summary The document outlines an application by EfficiencyOne for approval of a supply agreement with Nova Scotia Power Inc. and the 2016-2018 Demand Side Management (DSM) Plan. The Industrial Group submitted information requests to NSPI, with responses due January 25, 2016. The proceeding is governed by the Public Utilities Act.

Request IR-1: Please define "Cost Allocation", "Cost Accounting" and "Cost Recovery" as it applies to DSM.

AI summary The text requests definitions of 'Cost Allocation', 'Cost Accounting', and 'Cost Recovery' in the context of Demand Side Management (DSM).

Request IR-2: (a) Please outline any differences in what was proposed by NSPI in its October 30, 2015, Cost Allocation Proposal, its November 30, 2015, letter to the Board and its December 18, 2015, letter to the Board. (b) If there are di...

AI summary The document requests clarification on differences in NSPI's cost allocation proposals from October 2015 to December 2015, including rationales for changes. It references NSPI's support for a 25/75 system/participant cost split for DSM programs and a 2016-specific cost-of-service allocation approach. Discrepancies between these methods are highlighted, along with requests for data on demand and energy figures.

service (p.3). 1 2 3 4 5 (a) Appendix A to the December 18, 2015 letter shows an alternative allocation based on "class relative shares in rate base from 2014 COSS". Is this intended to be the same as allocation "based on cost of service"?...

AI summary The text presents a series of questions and requests related to the allocation of costs based on the 2014 COSS study, the derivation of amortization amounts for the 2015 DSM plan, and the deferral of DSM amounts beyond 2016. These questions aim to clarify the methodology and assumptions used in cost allocation and recovery.

Request IR-9: - Appendix A shows the "Inter-class DSM loan" being repaid over 2016-2018 as part of the - apportionment using DSM cost allocation methodology. Please explain this treatment, in light of - the three options discussed.

AI summary Appendix A details the repayment of an 'Inter-class DSM loan' from 2016-2018 under DSM cost allocation methodology. The request seeks clarification on this treatment relative to three previously discussed options.

2013 and 2014 Balance Adjustments

AI summary The document discusses balance adjustments for the years 2013 and 2014, likely related to regulatory proceedings involving Nova Scotia Power Incorporated (NSPI) and Demand Side Management (DSM) programs.

Request IR-10: - Please explain what is meant by the underlined phrase: "…this variance should be attributed to - the 2016 DSM Program and could be allocated such that classes receive their actual over or - under recovery via 2016 programs...

AI summary The text requests clarification on allocating variance from the 2016 DSM Program to classes via those programs, emphasizing the program's role in over or under recovery.

Request IR-11: - At p.4, NSPI states that "imbalances could either be worked into the next DSM contract period - or rebalanced separately during rate applications." - (a) Please explain what is meant by "worked into". Is this a financial -...

AI summary NSPI states imbalances can be 'worked into' the next DSM contract period or rebalanced during rate applications. The regulator seeks clarification on whether 'worked into' refers to financial reconciliation or modifying DSM programs to adjust efficiency measure delivery across customer classes.

Request IR-13: - …[W]ould allocate DSM funds among customer classes in the same manner as NS Power allocates earnings above its approved rate of return – allocate based on NS power's cost of service. Any true ups would be based on this all...

AI summary The text discusses allocating DSM funds using NS Power's cost-of-service model, mirroring how earnings above approved rates are distributed. It references a 75% class cost/25% system cost allocation, citing customer representatives' prior agreement as a 'reasonable proxy.' Questions probe the methodology's application, definition of terms, and whether a 25/75-based allocator would be constructed.

Request IR-15: - (a) With respect to Appendix A, please confirm that the two alternative apportionment approaches show the amount each customer class will be deemed to have contributed toward efficiency programs in 2016. - (b) Does the COS...

AI summary Request IR-15 seeks clarification on Appendix A's alternative apportionment approaches for 2016 efficiency program contributions and whether the COS apportionment aligns with the DSM allocation methodology. NSPI (Industrial Group) filed the request on January 11, 2016, requesting an apples-to-apples comparison if components differ.

1 2016 NSUARB-NSPI-P-M07151 / E-R-15 2 3 NOVA SCOTIA UTILITY AND REVIEW BOARD 4 IN THE MATTER OF: The Public Utilities Act, R.S.N.S. 1989, c.380 as amended 5 -and - 6 IN THE MATTER OF: Nova Scotia Power DSM Cost Recovery Proposal dated Dec...

AI summary The Nova Scotia Utility and Review Board is handling a proceeding under the Public Utilities Act regarding Nova Scotia Power's DSM Cost Recovery Proposal dated December 18, 2015. Responses are due by January 25, 2016, with contact details provided for Nova Scotia Power Inc. and E.A. Nelson Blackburn, Q.C. of Blackburn Law.

Date Filed: January 11, 2016 l Request IR-4: 2 NSPI also identifies its decision to not seek a general rate increase for 2016 as a contributing factor that 3 "hampers" its ability to rebalance through the 2016 to 2018 DSM plan. Please desc...

AI summary The document contains several requests for information related to NSPI's decision not to seek a general rate increase in 2016, its impact on rebalancing through the 2016 to 2018 DSM plan, and the implications of various cost recovery models and allocation mechanisms.

7 Request IR-11: - 8 What are the alternative cost recovery mechanisms the Company is considering for DSM costs in 2017 - 9 thrcugh 2019? Date Filed: January 11, 2016

AI summary The document requests information on alternative cost recovery mechanisms for DSM (Demand Side Management) costs from 2017 to 2019. Filed on January 11, 2016, the inquiry seeks clarification on the Company's (likely NSPI) proposed approaches to recovering these costs during the specified period.

Request IR-1: Please provide a rationale for using historical averages as part of the formula for allocating Enabling Strategies expenditures among rate classes as proposed in the 2016-2018 DSM Plan NS Power Cost Allocation Proposal dated...

AI summary The document requests a rationale for using historical averages in allocating Enabling Strategies expenditures among rate classes, as proposed in the 2016-2018 DSM Plan by NS Power in their 2015 Cost Allocation Proposal.

Request IR-4: Please provide a calculation that shows the allocation of Enabling Strategies expenditures by rate class using the program benefits as a method for calculation enabling strategies as recommended by Elenchus in the May 7 Memor...

AI summary The request asks for a calculation allocating Enabling Strategies expenditures by rate class using program benefits as a method, as recommended by Elenchus in their May 7 Memorandum.

7 Request IR-7: 8 9 The attached spreadsheet of showing coding to rate classes of Enabling Strategies expenditures was 10 provided to G. Foote upon request by Matthew Davidson of Efficiency (e-mail also attached). This 11 spreadsheet shows...

AI summary A spreadsheet shows Enabling Strategies expenditures coded to all rate classes, not just BNI, leading to residential ratepayers being charged 50 cents for a program not addressing residential DSM. The document questions whether NSPI reviewed historical averages before submitting its cost-allocation proposal.

26 Request IR-9: 27 28 Please provide an analysis of exactly how NS Power will be able to absorb 2016 DSM expenditures 29 and the first year of amortized 2015 expenditures, including: 30 31 (a) The nature and magnitude in reductions in oth...

AI summary The request asks NS Power to analyze how it will absorb 2016 DSM expenditures and the first year of amortized 2015 costs, including revenue reductions and changes in sales/revenues by customer class compared to the 2013-2014 GRA Decision.

37 Request IR-10: 38 39 Please explain any options that are available to NS Power to implement the Board's Decision that 40 the "2014 DSM…variance should be attributed to the 2016 DSM program and could be allocated 41 such that classes rec...

AI summary The document requests Nova Scotia Power Incorporated (NSPI) to explain options for implementing the Board's decision to attribute the 2014 Demand Side Management (DSM) variance to the 2016 DSM program, ensuring classes receive actual over or under recovery via 2016 programs.

43 Request IR-11: 44 45 Please explain in more detail how a cost of service allocation would permit true-up of DSM 46 expenditures, including the variance between 2014 DSM collection and allocation by customer class.

AI summary The request asks for a detailed explanation of how a cost of service allocation would allow for the true-up of DSM expenditures, particularly focusing on the variance between 2014 DSM collection and allocation by customer class.

47 1 2 Request IR-12: 3 4 5 Would NSPI be seeking interest on post-2016 DSM expenditures, if it does not make a General Rate Application on June 30, 2016? 6 7 Request IR-13: 8 9 10 The December 15, 2018 submission proposes two methods for...

AI summary The text outlines several requests for clarification regarding NSPI's approach to interest on post-2016 DSM expenditures and the methods for true-ups, including 'Cost of Service Allocation' and 'Traditional DSM Allocation.'

Memorandum To: Julie-Ann Vincent, Efficiency Nova Scotia From: Andrew Frank Date: May 7, 2014 Re: Enabling Strategies Allocation This memo is prepared in response to your requests to review our advice provided in February 2012 on the alloc...

AI summary This memo from Andrew Frank to Efficiency Nova Scotia reviews prior advice on Enabling Strategies cost allocation and updates recommendations based on a year of experience. It addresses invoice allocations to rate classes and revises cost allocation methods for Enabling Strategies.

1 REVIEW OF DIRECT ALLOCATION OF ENABLING STRATEGIES INVOICES We have reviewed a sample of invoices provided, being sure to examine some invoices which were assigned to each of the rate classes. The sample turned up many invoices assigned...

AI summary A review of invoices for enabling strategies found many assigned to 'All Rate Classes' with costs like IT development, DSM planning, and marketing. These costs impact multiple rate classes. Invoices assigned to specific rate classes were appropriately allocated in reasonable proportions.

2 REVIEW OF ENABLING STRATEGIES COST ALLOCATION In response to your request to review the Enabling Strategies allocation methodology, we have reviewed the recommendation provided by Elenchus in February 2012. Email: [email protected]; dir...

AI summary The document reviews Elenchus' 2012 recommendation for allocating Enabling Strategies costs using a System/Participant Benefit approach, with 75% allocated based on customer classes benefiting from the strategy. Elenchus reaffirms this methodology's validity, emphasizing its continued appropriateness for Nova Scotia's cost allocation framework.

Coding to Rate Classes Couling to Nate Classes Enabling Stategies Initiative All Rate Classes All BNI Rate Classes Residential Small General Genera l Large Gene eral Small Industr ial Medium Industria Large Industrial Municipal Unmetered B...

AI summary The text presents a table outlining the distribution of various programs and initiatives across different rate classes, including Enabling Strategies, Bright Business Conference, Habitat for Humanity, and others, with varying percentages allocated to each rate class.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: Nova Scotia Power Incorporated - DSM Cost Recovery and Allocation INFORMATION REQUESTS To: Nova Scotia Power Incorporated c/o David L...

AI summary The Nova Scotia Utility and Review Board is handling a proceeding under the Public Utilities Act regarding Nova Scotia Power Incorporated's DSM Cost Recovery and Allocation. EfficiencyOne has requested information from Nova Scotia Power, with responses due January 25, 2016, and copies to be submitted to Breton Law Group.

Request IR-1: Reference: Page 2, 2015 DSM Amounts . "For 2015, DSM was established at $35 million plus any remaining DSM balance from 2013. NS Power will expense the 2016 amortization amount in its 2016 operating costs." - a) Please confir...

AI summary The document discusses the 2015 DSM amounts established at $35 million, including a request to confirm the basis for the 8-year amortization, the interest rate NS Power plans to apply, and whether NS Power would consider an agreement with EfficiencyOne to amortize and repay the $35M.

Request IR-2: - Reference: Page 4, 2013 and 2014 Balance Adjustments. "As referenced above, the 2013 amount has been applied to DSM funding in 2015. NS Power suggests that the 2014 imbalance amounts should be dealt with in a similar manner...

AI summary The document discusses the handling of the 2014 Balance Adjustment of $8,518,030 by NS Power, suggesting that the Net Contract Price of $24,691,970 should be expensed in 2016, as outlined in Schedule B of the Compliance Filing Supply Agreement from September 15, 2015.

Request IR-3: - Reference: Page 4, True Up Proposals. "Although true ups do not have a direct impact on NS - Power, the Company supports the manner in which true ups were managed when DSM was - recovered through a rate rider. Essentially,...

AI summary The document discusses NSP's support for managing true ups via a rate rider based on E1's budget versus actual expenses for DSM. A question is raised about whether 'actual amount collected' should replace 'budget amount' in the referenced text. The context involves rate rider methodology and DSM recovery.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: The Public Utilities Act , R.S.N.S. 1989, c.380 as amended IN THE MATTER OF: An Application by EfficiencyOne for Approval of a Supply Agreement for Electricity Efficiency and Conservat...

AI summary EfficiencyOne seeks approval for a supply agreement with Nova Scotia Power Inc. under the Public Utilities Act, R.S.N.S. 1989, c.380, for electricity efficiency and conservation activities, including a 2016-2018 Demand Side Management (DSM) Plan. The application involves establishing a final agreement between the parties.

INFORMATION REQUESTS To: Nova Scotia Power Inc. ("NSPI") From: The Municipal Electric Utilities of Nova Scotia Co-operative Donald Regan, Superintendent, Berwick Electric Commission 236 Commercial Street, Berwick, NS, B0P 1E0 902 538 4007;...

AI summary The Municipal Electric Utilities of Nova Scotia Co-operative is requesting detailed information from Nova Scotia Power Inc. regarding the 2014 DCRR amounts in rates, the allocation of DSM funds in 2015 and 2016, and whether DSM costs should be included in the Fuel Adjustment Mechanism (FAM). The letter references past Board decisions and seeks clarification on how these funds are accounted for in current rates.

February 2, 2016 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: NS Power Inc. – DSM Cost Allocation Proposal (M07151/E‐R...

AI summary NS Power Inc. submitted responses to Information Requests related to its DSM Cost Allocation Proposal in regulatory matter M07151/E-R-15. The letter is addressed to Doreen Friis of the Nova Scotia Utility and Review Board, dated February 2, 2016.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: The Public Utilities Act , R.S.N.S. 1989, c.380 as amended - and - IN THE MATTER OF: NS Power Inc. – DSM Cost Allocation Proposal (M07151/E-R-15)

AI summary The Nova Scotia Utility and Review Board is considering NS Power Inc.'s proposal related to demand-side management (DSM) cost allocation under the Public Utilities Act. The proceeding is referenced as M07151/E-R-15.

sing a Cost of Service methodology does not promote rate stabilization. It also masks any difference due to lower rate class participation, which is a specjfic concern for the SBA. 3 Page 5 4 See Attachment SBA-1. Note that the 2016 DSM Pl...

AI summary The SBA argues that the Cost of Service methodology fails to stabilize rates and obscures disparities from lower rate class participation. NSP defends the methodology, citing its ability to absorb DSM program costs and referencing a Settlement Agreement (M06475) that permits its use. NSP also notes customer representatives' agreement to a similar allocation approach.

All of which is hereby agreed to this 211<1 day of December 2014 N S ti P I ed at ov a co a ow er n co rp or C A dv at on su m er oc e Pe r: S al l B si A dv at m u ne ss oc e du ri al In G st ro p u Pe r: Pe r: ic i al le ri ti li ti C O...

AI summary The text presents a proposal related to the 2016-2018 DSM Cost Allocation, indicating an agreement dated December 2014. It includes a table with partially obfuscated text and mentions entities involved in the proceeding.

3.0 NS POWER'S POSITION The current 25/75 per cent split between system cost and participant cost was agreed to by stakeholders to the 2009 Settlement Agreement. It appropriately recognizes that rate class benefits from DSM programs are hi...

AI summary NS Power advocates maintaining the 25/75 cost split between system and participant costs for DSM programs, citing the 2009 Settlement Agreement and cost-of-service principles. They propose adjusting Enabling Strategies allocation, fully assigning costs to rate classes when benefits are clear and costs exceed $100,000. The current methodology assigns 75% of DSM costs to participating classes.

DSM Cost Allocation and Recovery (NSUARB M07151) NSPI Responses to Small Business Advocate Information Requests

AI summary Nova Scotia Power Inc. (NSP) provided responses to the Nova Scotia Small Business Advocate (SBA) regarding Demand Side Management (DSM) cost allocation and recovery mechanisms under NSUARB matter M07151. The responses address SBA information requests on DSM program cost allocation methodologies and recovery processes.

NON-CONFIDENTIAL 1 Request IR-7: 2 3 Please confirm whether each of the alternatives NSPI presents for consideration on pp. 5-6, 4 as well as the reference on page 7 to "additional variations that could be considered", 5 presume that the t...

AI summary NSP responds to IR-7 by clarifying that its proposed alternatives (Cost of Service Allocation, Actual DSM alignment, No Allocation) do not presume the 75%/25% cost allocation for true-up under the 'No Allocation' method. The Company confirms the allocation applies only to the first two alternatives.

Delivered by E-mail Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 3rd Floor 1601 Lower Water Street PO Box 1692 Unit "M" Halifax NS B3J 3S3 Dear Ms. Friis: Re: M07151 – DSM Cost Allocation and Recovery...

AI summary The Industrial Group submits comments on Nova Scotia Power Inc.'s (NSPI) DSM cost allocation and recovery proposals, referencing NSPI's October 2015 position on cost allocation and November 2015 request to expense 2016 DSM costs while deferring 2017-2018 recovery until a General Rate Application (GRA) filing. The comments align with NSPI's December submission structure.

2015 AND 2016 DSM AMOUNTS NSPI has indicated that it will be able to absorb the 1/8 share of the 2015 DSM spending and the 2016 DSM budget in its general rates and so, asks for approval to expense these in its 2016 operating costs. 2015 DS...

AI summary NSPI proposes to expense 2015 and 2016 DSM amounts in its 2016 operating costs, having already deferred and amortized the 2015 spending over eight years. EfficiencyOne has suggested a potential agreement to reduce financing costs, which could save over $9 million over eight years. The Industrial Group supports reducing the carrying costs of the deferred DSM expense and recommends discussions between NSPI and E1 to achieve this.

2017-2019 DSM EXPENSE RECOVERY NSPI has requested that any determination on cost recoveryof the 2017-2019 DSM expenses be deferred to the general rate application ("GRA") filing or June 30, 2016 , if there is no GRA application. It has off...

AI summary NSPI requests deferral of 2017-2019 DSM expense recovery to the GRA filing or June 30, 2016, citing forecasting uncertainties and legislative requirements. DSM costs are integrated into general rates, with 2019 capped at $34.05M by legislation. NSPI argues uncertainty in revenue forecasts precludes April 30, 2016, determination, while the Board retains discretion to defer DSM costs.

2014 RATE SMOOTHING ADJUSTMENT Appendix B to NSPI's October 30, 2015 letter sets out the outstanding amounts owing and to be repaid as of the end of 2015. There were two "borrowing" classes (Small General and Large General) and four "lendi...

AI summary The 2014 Rate Smoothing Adjustment involves outstanding repayment amounts between borrowing and lending classes as of 2015. NSPI proposes three options for reallocation or true-up adjustments, while the Industrial Group opposes converting funds to efficiency services and advocates for three-year recovery with interest. E1's program challenges and NSPI's lack of discussion with E1 are noted.

2013 AND 2014 BA AMOUNTS NSPI has indicated that the 2013 variance was applied to DSM funding in 2015 i.e., ENSC had underspent by approximately $4 Million and these amounts were added to the legislated $35 million for the 2015 time period...

AI summary NSPI addressed the 2013 and 2014 BA variances by applying the 2013 variance to DSM funding in 2015 and planning to expense the 2014 BA in 2016. NSPI suggests resolving the 2014 variance through customer class adjustments, and the Industrial Group supports NSPI's calculation.

3.0 NS POWER'S POSITION The current 25/75 per cent split between system cost and participant cost was agreed to by stakeholders to the 2009 Settlement Agreement. It appropriately recognizes that rate class benefits from DSM programs are hi...

AI summary NS Power defends the 25/75 split of DSM costs between system and participant classes, aligning with cost-of-service principles and the 2009 Settlement Agreement. It argues that participating classes should bear 75% of DSM costs due to direct benefits, while non-participating classes cover external benefits. DSM allocation is integrated into the COS framework, with true-ups handled via GRA filings.

True-Up As regards the true-up, NSPI outlines three possible approaches: - 1) Traditional method (also called "actual DSM alignment"); - 2) Cost of Service; and - 3) No Allocation. NSPI stated that it supports the manner in which true-ups...

AI summary NSPI proposes three true-up approaches: traditional method, cost of service, and no allocation. It advocates aligning true-ups with three-year contract periods (e.g., 2016-2018) instead of annual rebalancing. The Industrial Group agrees, citing alignment with E1's targets. The traditional method allocates DSM variances across classes, while the cost-of-service approach distributes costs based on rate base proportions. NSPI notes potential fairness concerns with allocating DSM budgets to commercial/industrial classes.

ENABLING STRATEGIES As outlined in its October 30, 2015, letter, NSPI proposes to maintain the current cost allocation methodology but proposes a change to the methodology for Enabling Strategies that would limit the need for tracking by r...

AI summary NSPI proposes maintaining the current cost allocation methodology for Enabling Strategies but suggests limiting tracking by rate class. Exceptions include full allocation to rate classes for strategies exceeding $100,000 in cost or those attributable to historical averages pre-2014.

CONCLUSION To summarize, the Industrial Group recommends: - 1. the Board acknowledge NSPI may properly expense the first year of 2015 DSM costs and all of 2016 DSM costs as operating expenses in 2016; - 2. the Board direct NSPI and E1 to u...

AI summary The Industrial Group recommends that the Board acknowledge NSPI's 2015-2016 DSM cost expensing, direct cost reduction discussions, adjust deferred cost amortization, align DSM cost inclusion with GRA timelines, use BCF for RSA true-ups, retain the current DSM allocation methodology, and accept NSPI's Enabling Strategies proposal. These recommendations address rate design, deferred costs, and DSM implementation.

1. Recovery of 2017-18 DSM Costs At page 2 of its submission of December 18, 2015, NSPI states: On November 10, 2015, following the changes to Nova Scotia's electricity policy, the Company announced that it will not apply for a General Rat...

AI summary NSPI claims it can absorb 2015-2016 DSM costs into existing rates but has not determined if this applies beyond 2016. The Consumer Advocate disputes NSPI's assertion that 2016-2018 DSM costs are not already in rates. The Board's M07151 decision emphasized that all of NSPI's costs, not just DSM costs, determine rate increases.

The Board further noted: As noted earlier, in 2014 approximately $53 million was in rates in the DSM rider. By Order of the Board, at the request of the various customer classes, those funds which were not needed for DSM in 2015 because of...

AI summary The Board noted that $53 million from the DSM rider in 2014 was used for excess fuel costs in 2015 but remains in rates as a DSM charge. NSPI proposes to recover 2017-2018 DSM costs if not covered by current rates, while the Consumer Advocate argues the funds are sufficient and opposes additional rate revenue requests.

2. True-up of 2015 and 2016 DSM Expenditures At page 5 of its submission of December 18, 2015, NSPI states: The issue for 2015 and 2016 is that there is no specific class rate rider nor is there a similar allocation for DSM in NS Power's g...

AI summary NSPI argues that without a specific rate rider for DSM in 2015-2016, there is no baseline for allocating budgets to rate classes, making true-up calculations impossible. The Consumer Advocate counters that the 2014 rate rider allocation of $53 million provides a valid starting point for comparing actual DSM expenditures and adjusting budgets accordingly.

Allocation of 2015-2018 Program Costs EfficiencyOne supports the Cost of Service Allocation approach provided by NS Power for the allocation of 2015 to 2018 DSM costs. As indicated below, this approach, in EfficiencyOne's view, would: (a)...

AI summary EfficiencyOne supports NS Power's Cost of Service Allocation approach for 2015-2018 DSM costs, citing alignment with legislation, societal benefits, short-term cost recovery, and rate stability. NS Power, under the Public Utilities Act, provides DSM activities to reduce energy demand. The methodology reflects broader recognition of DSM's non-participant benefits and aligns with the 'beneficiary pays' principle.

Allocation of Enabling Strategies As a result of an Elenchus recommendation made in 2012, EfficiencyOne directly allocates the participant benefit portion of Enabling Strategies investments.[8](#page-2-0) In its October 30th filing to the...

AI summary The document discusses the allocation of Enabling Strategies investments, with NS Power proposing a 75/25 split for DSM programs. Elenchus recommends allocating based on rate class share of all program investment, citing risks of double-counting. EfficiencyOne supports Elenchus's 2014 methodology, noting that NS Power's approach may exacerbate allocation issues. A reexamination of Elenchus's 2012 recommendation is referenced, along with cross-references to regulatory filings.

Rate Smoothing Adjustment Repayment and Application of the 2013 and 2014 Balance Adjustments With respect to the repayment of the Rate Smoothing Adjustment (RSA) and the application of the 2013 and 2014 Balance Adjustments by rate class, N...

AI summary NS Power proposes modifying DSM program access to recover RSA and balance adjustments, but EfficiencyOne opposes this, arguing it risks failure and harms program effectiveness. EfficiencyOne prefers financial recovery through GRA or Base Cost of Fuel hearings, citing the Consensus Agreement and concerns over program costs, savings targets, and customer satisfaction.

Conclusion In summary, EfficiencyOne offers the following recommendations: - adopt the Cost of Service Allocation approach, provided by NS Power, for the allocation of DSM costs; - adopt NS Power's proposal to true up after each three-year...

AI summary EfficiencyOne recommends adopting NS Power's Cost of Service Allocation approach, triennial true-ups, Elenchus' 2014 methodology for Enabling Strategies, and recovering RSA amounts via GRA or Base Cost of Fuel. The text references a regulatory proceeding involving DSM cost allocation and recovery mechanisms.

Memorandum To: Julie-Ann Vincent, Efficiency Nova Scotia From: Andrew Frank Date: May 7, 2014 Re: Enabling Strategies Allocation This memo is prepared in response to your requests to review our advice provided in February 2012 on the alloc...

AI summary The memo from Andrew Frank to Julie-Ann Vincent discusses reviewing cost allocations for Enabling Strategies and invoice allocations to rate classes, with updates based on a year of experience.

1 REVIEW OF DIRECT ALLOCATION OF ENABLING STRATEGIES INVOICES We have reviewed a sample of invoices provided, being sure to examine some invoices which were assigned to each of the rate classes. The sample turned up many invoices assigned...

AI summary A review of invoices allocated to rate classes found that 'All Rate Classes' assignments included IT, DSM planning, and marketing costs, potentially impacting all classes. Individual rate class assignments and apportionments were deemed appropriate and reasonable where applied.

allocation if one is available. If a direct allocation does not exist, or is not practical, then we would consider an appropriate allocator to use as a proxy for the benefit derived by the rate class. In evaluating the methodology for allo...

AI summary The document reviews Enabling Strategies cost allocation methods, noting that 71% of expenditures are not directly tied to rate classes. Originally expecting most costs to be directly attributable, the analysis now emphasizes challenges in allocating non-Residential classes due to program-specific targeting, with Residential being more distinct and easier to allocate.

February 23, 2016 Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor P.O. Box 1692, Unit "M" Halifax, NS B3J 3S3 Re: Nova Scotia Power Inc (NSPI) DSM Cost Recovery – M07151...

AI summary Nova Scotia Power Inc (NSPI) submitted a reply addressing the Nova Scotia Utility and Review Board's request for details on DSM cost recovery methods. The submission highlights divergences and alignments with intervenors, emphasizing opposition to a true-up mechanism that could hinder EfficiencyOne's energy savings goals.

Intervenor Alignment NS Power has identified the following areas where alignment in the Intervenor positions may be possible: - Customer representatives prefer that cost allocation for the 2015 through 2018 period reflect the traditional D...

AI summary NS Power and intervenors align on DSM cost allocation methods for 2015-2018, rate smoothing adjustments, true ups, and enabling strategies. Disagreement remains on post-2016 DSM cost recovery. NS Power classifies 2016 DSM as an operating expense.

Cost Allocation The IG and the CA appear to support the traditional approach to cost allocation. This approach is most simply described as collection of DSM costs based on the DSM budget with a 25% allocation to system benefits and a 75% s...

AI summary The IG and CA support the 'Traditional Approach' to DSM cost allocation, which splits costs 25% to system benefits and 75% to class participation, with a true-up mechanism. This mimics the defunct DSM Cost Recovery Rider (DCRR) via embedded rates. The approach is detailed in NS Power's submission (M07151).

2016 – 2018 Cost Allocation In accordance with the Consensus Agreement dated June 16, 2015 and approved by the Board in its decision dated August 12, 2015, the parties agreed to refer the issue of cost allocation methodology to the Demand...

AI summary The 2016–2018 cost allocation methodology for DSM in Nova Scotia was referred to the DSM Advisory Group, which failed to reach consensus. NS Power proposed a Traditional Approach, aligning DSM budgets with E1's figures and ensuring customers pay only for achieved energy savings. The Board's 2015 decision and Consensus Agreement guided the process, with NS Power emphasizing alignment with rate class representatives and avoiding impacts on E1's cost-effectiveness.

Rate Smoothing Adjustment In its submission dated December 18, 2015, NS Power proposed three separate options for the rebalancing of the 2014 Rate Smoothing Adjustment (RSA) or Inter‐class Loan. The Company noted that the RSA could be reba...

AI summary NS Power proposed three options to rebalance the 2014 Rate Smoothing Adjustment (RSA) via DSM programming, the next GRA, or the 2017-2019 Fuel Stability Plan under the Electricity Plan Implementation (2015) Act . The Industrial Group (IG) opposed using DSM for rebalancing, advocating instead for three-year rate recovery of the true-up, with interest, via GRA or BCF. No party supported NS Power's alternate proposals, leading NS Power to suggest incorporating the RSA into the Fuel Stability Plan proceeding.

True‐up period The CA, SBA and the IG each expressed support for a true‐up between budget and actual DSM costs. As noted above, NS Power proposes that DSM revenues be trued up against actuals in accordance with how the previous true‐up mec...

AI summary The CA, SBA, and IG support truing up DSM costs annually. NS Power proposes using the DCRR mechanism to align recoveries with actual costs annually, tracking variances for future rate settings. SBA advocates annual true-ups, but NS Power cannot adjust general rates outside GRA processes if DSM is classified as non-fuel, though annual tracking will still occur.

Enabling Strategies The CA and E1 expressed support for the allocation of Enabling Strategies to be aligned in accordance with the methodology recommended in the Elenchus Memo dated May 7, 2014. The Company, in its submission dated Decembe...

AI summary The CA and E1 support aligning Enabling Strategies with the Elenchus Memo (May 7, 2014). NS Power proposed an alternate method using direct allocation and historical averages, supported by the Industrial Group. NS Power requests the Board adopt their methodology.

2016 DSM NS Power has requested the Board acknowledge that the 1/8 share of the 2015 DSM costs and all of the 2016 DSM costs are appropriately recovered as operating expenses in 2016. Intervenors have taken issue with the cost recovery pro...

AI summary NS Power seeks approval to recover 2015 and 2016 DSM costs as operating expenses. Intervenors oppose the proposal for years beyond 2016, but the Industrial Group supports the 2016 request.

Post 2016 DSM Cost Recovery The CA and the IG have opposed NS Power's proposal to defer its decision on the accounting treatment of post 2016 DSM cost recovery until June 30, 2016. The CA has done so on the basis that current rates contain...

AI summary Nova Scotia Power Inc (NSPI) sought to defer a decision on post-2016 DSM cost recovery until June 30, 2016, but the Consumer Advocate (CA) and Industrial Group (IG) opposed this, arguing current rates already fund DSM costs and NSPI failed to justify the deferral. NSPI countered that existing rates do not explicitly cover DSM expenses and requested additional time for the Utility and Ratepayer Board (UARB) to rule on the matter.

Conclusion NS Power notes that many of the cost allocation issues before the Board in this matter pertain to how DSM costs are divided amongst and collected from the various rate classes. The Company recommends as follows: - The Board conf...

AI summary NS Power outlines DSM cost allocation recommendations, requesting confirmation of 2015/2016 cost recovery, a timeline for 2017-2018 submissions, and adoption of the 'Traditional Approach' methodology. True-ups will be annually adjusted via GRA, with enabling strategies aligned to prior proposals. The Company acknowledges intervenor contributions.

NSPI's Filing Dated December 18, 2015 In its December 18, 2015 letter, NSPI stated: - 1) One-eighth of the 2015 program cost will be expensed in its 2016 operating costs. - 2) The 2016 DSM program costs will be absorbed in existing rates a...

AI summary NSPI outlined its approach to DSM program costs, proposing deferral of 2017-2019 cost recovery decisions, three options for addressing the 2014 RSA, and methods for true-up adjustments. It emphasized aligning DSM funding with the 2013/2014 BA and supporting a DSM contract-period-based true-up methodology over annual rebalancing.

or allocating 2015 to 2018 costs, stating that the past cost allocation methodology discourages participation on a rate class level by increasing rates for the rate classes as participation increases. Regarding cost allocation for Enabling...

AI summary The document discusses disputes over cost allocation methodologies for Enabling Strategies expenditures. NSPI proposes direct assignment and historical averages, while Elenchus advocates minimizing double-counting risks for residential classes. The Industrial Group supports NSPI's approach, whereas the CA backs Elenchus's method to avoid double charges and reduce tracking costs. Document: 245123.

Board Decision The Board understands that 2013 and 2014 Balance Adjustments have been rolled into the 2015 and 2016 DSM programs, respectively, and accepts that approach. Regarding treatment of the 2015 DSM program costs, which are being a...

AI summary The Board approved NSP's proposal to recover 2015 DSM program costs over eight years, with one-eighth recovered in 2016 and the rest via financing. It denied deferring 2017-2019 DSM cost decisions and cited non-compliance with filing deadlines. NSP's incomplete submission on 2017-2019 costs was noted, with a reference to Board Order M06733.