Topic:"Demand Side Management" in M12282

EfficiencyOne IN THE MATTER OF The Public Utilities Act, RSNS 1989, c 380, as amended - and – IN THE MATTER OF An Application by EfficiencyOne for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Pla...

AI summary EfficiencyOne seeks approval from the Nova Scotia Energy Board to implement a new benefit-cost analysis test for evaluating Demand Side Management (DSM) Plans. The application follows the extension of the 2023-2026 DSM Plan through legislative amendment, with EfficiencyOne holding the Efficiency Nova Scotia Franchise under the Public Utilities Act.

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.

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.

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.

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.

ii EfficiencyOne Benefit-Cost Analysis Test Application Evidence Table 5: Comparison of Input Categories for TRC Test and Proposed New BCA Test............................... 26 Table 6: Electric System Impact Categories .....................

AI summary EfficiencyOne's application introduces a new BCA test for evaluating energy efficiency programs, contrasting with the existing TRC test. Tables and figures outline impact categories (system, fuel, societal) and DSM planning terminology. Appendices include evidence from David Hill and a jurisdictional BCA framework by Energy Futures Group.

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.

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.

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.

Page 5 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence

AI summary EfficiencyOne (E1) submits a Benefit-Cost Analysis (BCA) test application under the Public Utilities Act (PUA) and Energy Reform (2024) Act (ERA) to evaluate the cost-effectiveness of its demand-side management (DSM) programs. The application seeks regulatory approval to align DSM benefits with customer interests and compliance standards.

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.

gst 24 stakeholders, and was signed by E1, NS Power, the CA, the SBA, the MEUs, the AEC and 25 the EAC. 26 27 The NSUARB has endorsed the Balanced Plan approach in past DSM plans, 7 and has recognized that the 28 PUA contains language that...

AI summary The NSUARB has endorsed the Balanced Plan approach in past DSM plans, citing the PUA's provision granting the Board discretion in assessing DSM plans. The Board considers factors like customer best interests, affordability, and other matters when evaluating supply agreements, as outlined in EfficiencyOne (E1) (Re), 2022 NSUARB 137 [M10473].

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.

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.

Page 8 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 4.3 2027-2031 FIVE-YEAR DSM PLAN 2 The March 26, 2025 amendment to the PUA also prescribes the term of the next DSM Plan as five years, 3 commencing January 1, 20...

AI summary EfficiencyOne (E1) seeks approval of a new Best Interest of Customers (BCA) test to inform its 2027-2031 Demand Side Management (DSM) Plan, aligning with the Public Utilities Act (PUA) amendment requiring a five-year DSM Plan term starting January 1, 2027. E1 plans to file the DSM Plan application in early 2026, contingent on BCA test approval.

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.

Plan •The full suite of DSM activities to be delivered over a specific period of time. •Example: 2023-2025 DSM Plan •Used interchangeably with ‘Plan’ (i.e., The full suite of DSM activities to be Portfolio delivered over a specific period...

AI summary The text outlines definitions related to demand-side management (DSM) in energy programs, including the terms 'Plan,' 'Portfolio,' 'Program,' and 'Program Component,' with examples provided for each. It emphasizes the structure and categorization of DSM initiatives.

• Example: Instant Savings; Affordable Single-Family Homes; Small Business Energy Solutions; Residential Demand Response • A specific technology, action or practice that reduces energy consumption Measure of shift energy uses. • Example: M...

AI summary The document discusses the application of the Best Interest of Customers (BCA) test under the Public Utilities Act (PUA) for the development of future Demand Side Management (DSM) Plans. EfficiencyOne (E1) commits to providing data at the measure, program component, and portfolio levels to ensure cost-effectiveness and adherence to the Balanced Plan approach.

1 current practice, E1 also commits to providing Program Administrator Cost (PAC) test results to 2 stakeholders in the course of DSM Plan applications, for information purposes. 3 4 5.2 JURISDICTION TO CONSIDER NON-ENERGY IMPACTS 5 The qu...

AI summary The document discusses the jurisdiction of the NSUARB to consider non-energy impacts in DSM plan evaluations, referencing a 2020 case where E1 applied for approval to use non-energy impacts in cost-effectiveness testing. The NSUARB concluded that the legislation does not grant it the authority to consider environmental factors in such evaluations, limiting cost-effectiveness to affordability and long-term electricity costs.

mscribed by the wording of the 24 legislation to be limited to whether DSM activities are affordable and result in the lowest long-term 25 electricity costs for ratepayers: 14 26 27 [47] The Board finds that “cost-effective” means consider...

AI summary The text discusses the interpretation of the Public Utilities Act (PUA) in 2020 regarding the definition of 'cost-effective' in the context of EfficiencyOne's demand-side management (DSM) activities. It states that 'cost-effective' involves assessing whether DSM activities are affordable and result in the lowest long-term electricity costs for ratepayers.

Page 11 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 occurred, and outlines how, in E1’s submission, these legislative changes now direct the Energy Board to 2 consider non-energy impacts as part of its evaluation...

AI summary EfficiencyOne (E1) is proposing a new Best Interest of Customers (BCA) test for demand-side management (DSM) cost-effectiveness, developed in collaboration with the DSMAG as directed by the NSUARB in its 2022 Decision on the 2023-2025 DSM Plan. The EFG Report outlines the proposed test and its development process.

1 (iii) the alteration of the consumption pattern of an end-user of electricity 2 that has the effect of reducing demand during Nova Scotia Power 3 Incorporated’s periods of highest demand, 4 5 (iv) the utilization or management by Nova Sc...

AI summary The text discusses the legislative amendment to the definition of 'demand-side management' under section 79A(b), expanding it to include strategic electrification of energy end uses currently powered by fossil fuels, with the aim of reducing greenhouse gas emissions and electricity costs.

stomers, or 31 32 (vii) any other prescribed activities, plans or programs; 33 34 [emphasis added] 35 36 This legislative amendment expanded the definition of demand-side management to now include 37 strategic electrification programs targ...

AI summary This text discusses a legislative amendment that expanded the definition of demand-side management to include strategic electrification programs aimed at reducing GHG emissions and electricity costs in line with environmental goals and legislation.

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.

responsibility are integrated and recognized as being 34 interconnected. 18 35 36 Furthermore, the More Access to Energy Act states that one purpose of the legislation is to support the 37 sustainable development, sustainable prosperity, e...

AI summary The text discusses the integration of responsibilities under the More Access to Energy Act and the Environmental Goals and Climate Change Reduction Act, emphasizing energy efficiency and equitable access for low-income and marginalized communities. It highlights legislative changes that expand the Energy Board's considerations, particularly in relation to DSM activities.

ative changes noted above have broadened the scope of what the Energy Board must now 7 consider when assessing the applications that come before it, including those pertaining to DSM activities. 8 9 6.3 LEGISLATIVE MANDATE TO CONSIDER NON-...

AI summary Recent legislative changes have expanded the Energy Board's mandate to consider non-utility impacts, including environmental and sustainability factors, when assessing DSM activities. The Environmental Goals and Climate Change Reduction Act and the More Access to Energy Act now require the integration of GHG reduction targets and sustainable development into regulatory decisions.

ctrification programs, which can 27 be influenced by the commodity costs of displaced fuels 19 Environmental Goals and Climate Change Reduction Act, SNS 2021, c 20, section 7(b) DATE FILED: May 16, 2025 Page 16 of 38 EfficiencyOne Benefit-...

AI summary The text discusses the importance of including non-utility impacts, such as fuel savings and GHG emissions, in the cost-effectiveness analysis of strategic electrification programs under the BCA. The amendment to the PUA in 2022 expanded the definition of demand-side management to include strategic electrification.

Page 17 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 • environmental impacts of DSM programs generally, including how these programs contribute to 2 reducing greenhouse gas emissions and other pollutants; 3 • encou...

AI summary The text discusses the environmental and social benefits of DSM programs, including reducing greenhouse gas emissions, promoting energy efficiency, and creating green jobs. It also outlines E1's efforts to develop a new BCA test through a competitive RFP process by retaining EFG as a consultant.

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.

ut its mandate, EFG followed the eight guiding principles set out under the NSPM, which are 3 listed in Table 4, below. 4 5 Table 4: NSPM BCA Guiding Principles Principle 1 Treat DERs as a Utility System Resource DERs are one of many energ...

AI summary The document outlines the eight guiding principles from the NSPM for the BCA, emphasizing the treatment of DERs as utility resources, alignment with policy goals, symmetry in cost-benefit analysis, inclusion of material impacts, and forward-looking long-term analyses.

thin the BCA consistent with design principles. 24 Energy Futures Group, Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia, May 13, 2025, Figure 2, page 27 DATE FILED: May 16, 2025 Page 22 of 38 EfficiencyOne...

AI summary The BCA test ensures symmetry in evaluating benefits and costs of DSM activities, emphasizing relevance and transparency. It distinguishes between the definition and application of the test, including relevant impacts regardless of their magnitude, while documenting immaterial impacts.

ufficient magnitude to affect the result of a BCA. Impact 17 determined to be immaterial should be documented, but not necessarily included in the 18 application of the BCA test. 19 20 In developing the new BCA test, E1 and EFG followed th...

AI summary The document discusses the development of a new Best Interest of Customers (BCA) test by E1 and EFG, which includes all relevant non-utility impact categories to ensure proper assessment of E1’s performance and effective implementation of DSM Plans in the best interests of ratepayers. The approach is based on guidance from the NSPM and considers policy objectives under legislation.

Page 23 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 categories are expected to carry significant weight in the cost-effectiveness determination, does nothing 2 to diminish their relevance, and therefore the approp...

AI summary EfficiencyOne (E1) supports the adoption of an evergreening process for the Best Interest of Customers (BCA) test, ensuring it remains current with policy goals, utility costs, and customer behavior. The process will involve the Demand Side Management Advisory Group (DSMAG) and be implemented ahead of the 2027-2031 DSM Plan filing, with Energy Board approval sought for any changes.

h to reactive power production are matched merit routine with demand inclusion Financial Incentives Utility financial support provided to DER host customers or other market actors to  encourage DER implementation Utility Direct Direct cost...

AI summary The text outlines various aspects of utility involvement in distributed energy resources (DER), including financial incentives, direct investment, program administration, performance incentives, and risk factors such as operational, financial, and regulatory risks.

 Requirements Federal Energy Regulatory Commission (FERC) Order No. 2222 1 2 3 10.3 NON-UTILITY SYSTEM IMPACTS 4 As explained in the NSPM, best practices suggest that all impacts relating to a jurisdiction’s policy goals 5 and objectives...

AI summary The document outlines the inclusion of non-utility system impacts (N-USIs) in the Best Interest of Customers (BCA) test, emphasizing the need to consider efficiency and distributed energy resources (DERs). It references legislative changes, particularly the More Access to Energy Act, and recommendations from the EfficiencyOne Group (EFG) and the Demand Side Management Advisory Group (DSMAG).

y increased Effects fuels resulting from large enough to EV usage in NS. Cross fuel DRIPE DATE FILED: May 16, 2025 Page 30 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence Other Fuel Description and Examples Inclusion in...

AI summary The text discusses the inclusion of other fuel impacts in the Best Interest of Customers (BCA) analysis, particularly focusing on changes in consumption levels and the effects of gas DER on the electric system. It notes that cross-fuel impacts may be non-material for most customers but could be significant for large industrial users.

tric system (e.g., gen. to DSM in Nova utility DERs. capacity, Scotia

AI summary The text discusses the integration of distributed energy resources (DERs) within the utility system, particularly in the context of demand-side management (DSM) in Nova Scotia. It references the role of DERs in capacity planning and system reliability.

Other Utility If electric DER, impact on Not material, or Further analysis required to System Impacts gas system (e.g., T&D, large enough to determine potential decline in storage, reliability, etc.) merit routine gas consumption and deman...

AI summary The text discusses host customer impacts related to distributed energy resources (DER), emphasizing that non-energy impacts should be included in the Best Interest of Customers (BCA) test. It references the Energy Reform Act, the 2022 NSUARB Decision, and practices in other jurisdictions to support this inclusion. A proxy adder method is used to quantify these impacts.

ethod used in other jurisdictions 15 rather than quantifying a value stream for each separate impact. Table 8 presents the other fuel impact 16 categories, their description and indicates whether they are included in the new BCA proposed b...

AI summary The text discusses the inclusion of various host customer impacts in the new BCA proposed by E1, such as DER measure costs, transaction costs, interconnection fees, and risk. These impacts are relevant to different types of DER and are outlined in Table 8.

y Impacts Measured Public Health Commodity costs are embedded in the “Other Fuels” category. Resilience is embedded in “Host Customer” category. Public Health impacts embedded in “GHG Emissions” and “Other Environmental” categories. 1 2 E1...

AI summary This section presents test case results for the Best Interest of Customers (BCA) framework, focusing on the impact of replacing different fuel types with heat pumps. The test cases include utility system impacts, host customer impacts, and cost-benefit analyses for 1,000 heat pump installations.

Page 37 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 12. CONCLUSION 2 In accordance with the NSUARB’s direction, E1 has developed an optimal cost-effectiveness test tailored 3 to Nova Scotia. In the development of...

AI summary EfficiencyOne (E1) has developed a new Best Interest of Customers (BCA) test for evaluating Demand Side Management (DSM) Plans in Nova Scotia, following guidance from the Nova Scotia Utility and Regulatory Board (NSUARB). The test was designed with input from the DSMAG and aligns with provincial policy objectives and the NSPM. E1 argues the BCA test is in the best interest of ratepayers and requests approval from the Energy Board.

of David Hill, Energy Futures Group, Inc. EfficiencyOne Benefit-Cost Analysis Test Application Appendix A NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT, RSNS 1989, C 380, AS AMENDED IN THE MATTER OF: EFFICIENCYONE APP...

AI summary This document outlines the application by EfficiencyOne for the approval of a new Nova Scotia Benefit-Cost Analysis (BCA) test for evaluating Demand-Side Management (DSM) plans, prepared by David G. Hill of Energy Futures Group, Inc. It includes sections on qualifications, development of the BCA test using the National Standard Practice Manual, alignment with legislative frameworks, and data sources.

lysis Test Application Appendix A 1 1. Identification and Qualifications 2 Q: Please state your name and professional affiliation. 3 A: My name is David G. Hill. I am a Managing Consultant at Energy Futures Group. 4 Q: On whose behalf are...

AI summary David G. Hill, a Managing Consultant at Energy Futures Group, testifies on behalf of EfficiencyOne, which has an exclusive agreement with Nova Scotia Power to provide demand-side management services. EfficiencyOne operates under the Nova Scotia Energy Board's regulation.

8 Board, which approves agreements between NS Power and EfficiencyOne on the level of DSM activity. 9 Q: Please describe the role of your current employer in the energy efficiency industry. 10 A: Energy Futures Group (EFG) is a clean-energ...

AI summary The testimony discusses the role of Energy Futures Group (EFG) in the energy efficiency industry, highlighting their work with regulators, utilities, and governments in designing and evaluating energy efficiency programs. EFG has contributed to efficiency programs in multiple states and provinces, including Nova Scotia.

8 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A 1 Q: Please describe your professional work experience and education. 2 A: I joined EFG in January of 2020. Prior to joining EFG I worked at Vermont Energy Investment 3 Corp...

AI summary The witness has over 30 years of professional experience in energy efficiency and demand side management, including work with Vermont Energy Investment Corporation, Tellus Institute, and EFG. They have provided expert testimony and analysis on various energy-related proceedings in multiple states.

usetts and New York. From 2010 to 2020, I provided ongoing 17 expert review and testimony on EmPOWER Maryland’s energy efficiency portfolio on behalf of that 18 state’s Office of People’s Counsel. 19 For Nova Scotia, I served as a senior a...

AI summary David G. Hill, Ph.D., has provided expert testimony and advisory services on energy efficiency programs and infrastructure in multiple jurisdictions, including Nova Scotia, Maryland, and Ontario, with a focus on demand-side management, avoided costs, and gas infrastructure planning.

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.

1 2. Review and discuss the consideration of utility system impacts in the Nova Scotia test. One 2 of the core principles of the NSPM is that to provide an accurate comparison of demand side 3 and supply side options, all utility system im...

AI summary The document discusses the consideration of utility system impacts and non-utility system impacts in the Nova Scotia test. It highlights the inclusion of avoided costs for energy, capacity, transmission, and distribution for the electric system, while gas system non-commodity impacts are not quantified. Non-utility impacts such as greenhouse gas emissions, air pollutants, and host customer costs are also addressed.

Page 11 of 18 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A 1 4. Data Sources and Their Application in Developing the 2 Recommended BCA Framework 3 Q: What data sources and collection were used by EFG during the work with...

AI summary EFG used data from Canadian and U.S. sources, including E1 and Nova Scotia Power, in developing the recommended Nova Scotia benefit-cost analysis test framework. The National Energy Screening Project's National Standard Practice Manual was referenced for methodological guidance. Data usage is detailed in Table 3, with updates expected for the 2027-2031 DSM portfolio screening.

tely 13 used by E1 for screening the 2027-2031 DSM portfolio are likely to be from the same sources, but in 14 many cases will be updated from the values used by EFG for the illustrative examples. 15 Table 3: Data Sources and Application i...

AI summary The document discusses data sources used by E1 for the 2027-2031 DSM portfolio, noting that they are likely from the same sources as EFG but may be updated. It also references the National Energy Screening Project and National Standard Practice Manuals used in benefit-cost analysis and utility system impacts.

with environmental regulations and Direct Testimony of David G. Hill, Ph.D. / May 16, 2025. Page 10 On Behalf of EfficiencyOne DATE FILED: May 16, 2025 Page 12 of 18 EfficiencyOne Benefit-Cost Analysis Test Application Appendix A Data Sour...

AI summary EfficiencyOne's benefit-cost analysis test application discusses data sources and references for transmission and distribution capacity, including the use of forward-looking avoided costs from the 2023-2025 DSM Plan and the allocation of costs between transmission and distribution.

oided distribution. grid locations. Transmission and distribution line losses should be based on marginal losses from generator. Program E1 program administration costs EFG made assumptions about program Administration including marketing...

AI summary The document discusses assumptions made by EFG regarding program administration costs, fuel price trends, greenhouse gas emissions, and host customer impacts. It references data from Natural Resources Canada and the US Energy Information Administration, and reviews proxy values for non-energy benefits based on DSMAG work.

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.

ended by EFG for screening the 2027-2031 DSM Plan is 8 compared to the two prior tests in Table 4. 9 Table 4: Impact Category Comparison of Recommended Nova Scotia and Prior Tests 10 11 Another difference relates to GHG impacts. The 2023-2...

AI summary The document discusses differences between the 2023-2025 TRC test and the new recommended Nova Scotia test, particularly in GHG impact calculations. The new test accounts for societal avoided costs of carbon, unlike the prior test, which only considered the avoided cost of carbon as an electric utility system impact. An example is provided using heat pump replacements in 2026 to illustrate cost-effectiveness results.

ctric resistance heat, fuel oil, natural gas, show benefits above the horizontal axis 2 and costs below. 3 Figure 1: Illustrative Results Using Recommended New Nova Scotia Test 4 5 6 Under the recommended new Nova Scotia BCA Test, the bene...

AI summary The document compares the benefit-cost ratios of replacing different heating systems under the new Nova Scotia BCA Test and the prior TRC Test. Under the new test, electric resistance heating replacement is highly cost-effective, while natural gas replacement is not. The prior test showed similar results for electric resistance but failed to capture benefits from other fuel impacts and host customer benefits, leading to lower ratios for fuel oil and natural gas replacements.

of the Attorney General, and filed with the Federal Energy Regulatory Commission in Docket No.CP22-2-00, on behalf of the States of Washington, California, and Oregon. 2022 In the Matter of Avoided Costs for EfficiencyOne’s 2023-2025 Deman...

AI summary The text outlines various appearances and expert testimonies provided on behalf of different organizations and states in regulatory proceedings related to energy efficiency, renewable natural gas, and integrated resource planning. These appearances were before various regulatory bodies such as the Nova Scotia Utility and Review Board, Illinois Commerce Commission, and New Hampshire Public Service Commission.

and analysis of energy efficiency and demand response in Dominion’s 2020 IRP. Docket No. 2019-226-E. 2019 Efficiency One 2020-2022 DSM Plan: Portfolio Diversification and Lighting Transition. Expert Witness Testimony submitted on behalf of...

AI summary This text lists various expert witness testimonies and presentations related to energy efficiency, demand response, and utility regulation, including matters involving Nova Scotia Power, Efficiency Nova Scotia, and the Office of People’s Counsel in Maryland and Pennsylvania.

Pennsylvania Public Utility Commission. On behalf of the Office of Consumer Advocate, regarding Petitions of the Pennsylvania Power Company for Approval of its Act 129 Phase II Energy Efficiency and Conservation Plan (Docket Nos. M-2012-23...

AI summary The text outlines various regulatory proceedings and testimonies related to energy efficiency and conservation plans in multiple jurisdictions, including Pennsylvania, Maryland, and Ontario, with involvement from the Office of People’s Counsel and other regulatory bodies.

2005 Market Response to Photovoltaic Incentive Offerings: An Analysis of Trends and Indicators. Presented at the International Solar Energy Society Solar World Congress, 2005. 2003 Solar Energy Value and Opportunities in Vermont, Invited S...

AI summary The text lists various presentations and publications related to renewable energy, solar energy, and energy efficiency, focusing on case studies, market responses, and software tools developed for evaluating energy efficiency and renewable energy opportunities.

as Utility Commercial Industrial Demand Side Programs. Prepared for the Colonial Gas Company, and presented at ACEEE 1995 Summer Study on Energy Efficiency in Industry. Selected Publications 2017 Smart Electric Power Alliance, 51st State I...

AI summary The text lists publications and reports related to energy efficiency and renewable energy initiatives, including work done for the Colonial Gas Company, the Vermont Solar Market Pathways, and various state energy authorities. It highlights contributions to energy programs and evaluations, with a focus on utility and industrial demand-side management.

1996 Evaluation of the IDB's Policies and Practices in Support of Renewable Energy and Energy Efficiency: A Report to the Inter-American Development Bank. Brower and Company and Tellus Institute. 1996 Action Plan for the Massachusetts' Ind...

AI summary This section lists various reports and studies conducted between 1994 and 1996 on energy policies, renewable energy, and efficiency initiatives, including evaluations and reviews for different regions and organizations.

01234567897 73 ÿ ÿÿ  ÿ   ÿ!"ÿ# ÿ$#%&'ÿ()''ÿ#ÿ ' +" ÿ, -)ÿ.'" 'ÿ/0123ÿ45ÿ67ÿ 89:;9<=ÿÿ9ÿ>;?<@964:ÿ4Aÿ67ÿ0964:9<ÿB:75CDÿ1@577::Cÿ254E7@6ÿ/0B12=Fÿ7ÿ0B12ÿÿ57>577:67Gÿ?Dÿ9ÿ69H74 ÿ4Aÿ45C9:...

AI summary The document discusses the 01234567897 73 ÿ and its implications on regulatory processes, including the role of various entities and the use of specific methodologies and standards. It references topics such as energy efficiency, demand-side management, and regulatory compliance.

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AI summary The text appears to be a regulatory proceeding document containing sections and headings related to energy efficiency, demand-side management, and utility operations. It includes sections such as benefit-cost analysis, test for regulatory compliance, and discussions on energy efficiency programs. The content suggests a structured regulatory review process.

!ÿ #!!$%&ÿ '()ÿ +, -.)ÿ-/ÿ0( .ÿ1 7ÿ28ÿ38 ÿ4ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ 78 ÿ123456ÿ89ÿ:;<ÿ=>?@>ABÿCDÿ:8ÿ; :ÿK@D:8=<9DLÿ ) -a), PTÿN+.0- ),.ÿ0-ÿ- 0 i)ÿ0() ,ÿ)PSM+.).ÿVPSÿ /VN W 0 )._ÿ]^.ÿ PNW+S)ÿ]]hÿ\^hÿ\ehÿ\fhÿ N-...

AI summary The document discusses the implementation and evaluation of energy efficiency programs, focusing on topics such as demand-side management, regulatory compliance, and the impact of various initiatives on energy usage and cost recovery. It also references regulatory processes and stakeholder engagement.

_9947; ÿ̀ESÿ H%X)F%H#X!OIÿ.ÿQ4Dÿ9: 7/ 9A4ÿ@<4:4CDÿ/01234554/2 647411ÿ9:./2 /41ÿ5BAADÿ;0/BM472ÿ.AAÿ:4A46.72ÿ 79B218ÿ .11BM92 0718ÿM42<0;0A0N 418ÿ.7;ÿ:41BA21EÿRU44ÿ_9947; ÿ^ÿ.7;ÿ_9947; ÿJÿ50:ÿ:4/0MM47;4;ÿ24M9A.241ÿ .7;ÿ:490:2 7Nÿ50:M.21ESÿ a...

AI summary The text discusses regulatory proceedings involving cost recovery mechanisms, fuel adjustment, and energy efficiency programs. It references various proceedings, including the EfficiencyOne Benefit-Cost Analysis and Nova Scotia Power, and touches on topics such as demand-side management and regulatory oversight.

3/).&0-ÿ-;;&)&-(.ÿ9+& ,&(>'lÿA9Cÿ<+ .&2 -ÿ456ÿ.:2-'ÿ.%/.ÿ /3-ÿ 1)/.-,ÿ&(ÿ/ÿ)-3./&(ÿ>-1>3/2%&)ÿ/3-/ÿ.1ÿ&,-(.&;:ÿ(1(=8&3-'ÿ'1 +.&1('lÿ/(,ÿA)Cÿ<+ .&2 -=456ÿ .:2-'ÿ.%/.ÿ/3-ÿ 1)/.-,ÿ/)31''ÿ.%-ÿ-(.&3-ÿ+.& &.:ÿ':'.-<?ÿi%/2.-3'ÿggmgnÿ2310&,-ÿ)1('&...

AI summary The document discusses the role of the 456 Efficiency Program in addressing energy efficiency and cost management. It highlights the importance of aligning base rates with actual costs and the need for effective program design to avoid perverse incentives. The 456 program is mentioned as a key initiative in this context.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 40 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !ÿ!" #$%!"&ÿ' ()!'#ÿ ' ÿ(#$...

AI summary The text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the application of benefit-cost analysis in the context of energy efficiency programs, including the role of the Building Code Division and the Demand-side Management Plan.

B?BJÿI>A<=?<;ÿ_<<\ B=Eÿ]>aÿ ^=?:?=GÿFGE=;Hÿ b?E=>?W =?\Bÿ b9cEÿ V>ABEH?EE?\Bÿ ^=?:?=GYF A=?\Bÿ K$(#$N7#$+'Q P $#$+' "ÿ $(#$N7#$+'ÿ0" ''$',ÿ ÿ Yÿ Yÿ Yÿ +'"&ÿdÿ%!#$) ""&ÿ $'#!, #! ÿÿ S'#!, #! ÿ $(#$N7#$+'ÿ0" ''$',ÿeSKfgÿ ÿ ÿ Yÿ Yÿ h!#$) ""&ÿ...

AI summary The text discusses the evaluation of benefit-cost analyses and the implementation of demand-side management plans, focusing on the methodologies used to assess energy efficiency programs and their impacts. It references regulatory frameworks and processes for evaluating energy programs.

Aÿ9GEÿEN=DN;8MÿY;<Fÿ<FEÿ;8PGE9AE:ÿCAEÿ=Oÿ 9:N98PE:ÿKE<EG;8Mÿ98:ÿ:9<9ÿ989D[<;PABÿX=<Fÿ9AA=P;9<E:ÿY;<Fÿ9ÿMG=Y;8MÿO=PCAÿ=8ÿHIJAÿLG=N;:;8Mÿ:EK98:ÿ ODE];X;D;<[ÿN9DCEÿ;8ÿ<EGKAÿ=Oÿ<EKL=G9Dÿ98:ÿD=P9<;=89Dÿ;KL9P<AÿQdIIÿ@P<;=8ÿefef9UVÿ WFEÿndoRÿ;Aÿ9...

AI summary The text discusses a regulatory proceeding involving efficiency programs and energy management, referencing a benefit-cost analysis and a demand-side management plan. It also mentions a specific acronym related to a building code division and a Nova Scotia Power initiative.

ÿ&'ÿ(ÿ6&D'ÿ"+&/&+0ÿ) D&#ÿ+ &+% 0ÿ-(0ÿM+'!ÿ50%'!ÿ+,ÿ5% ! )ÿ %.ÿ+,(+ÿ) D&#ÿ+ &+% 0ÿ5#(")ÿ%.ÿ+,ÿ 6&%'(/ÿ'(+" ÿ%.ÿ-%)+ÿ2,%/)(/ÿ-( 3+)1ÿ2,&#,ÿ+'!ÿ+%ÿ '#%-4())ÿ-"/+&4/ÿ"+&/&+0ÿ) D&#ÿ+ &+% &)7ÿE,")1ÿ 6"/(+% )ÿ' !ÿ+%ÿ!#&!ÿ2,+, ÿ+%ÿ&'#/"!ÿ+,ÿ -( 3+...

AI summary The document discusses regulatory proceedings related to energy efficiency programs, including the implementation of demand-side management initiatives and the role of the Nova Scotia Power (NSP) in these efforts. It also covers financial and operational considerations such as cost recovery, fuel adjustment mechanisms, and compliance with regulatory standards.

VWWÿ[\ÿ 10)(80+ÿ90-T: 8'6ÿ45@'8ÿ4+01)ÿ)5ÿ.'')ÿ/(-)5.'8ÿ6'.016<ÿ )ÿ@ ++ÿ2'ÿ+5/;'6ÿ 1)5ÿ)&0)ÿ8'-5(8/'ÿ:58ÿ)&'ÿ )&8''ÿ58ÿ:5(8ÿ,'08-ÿ )ÿ)0;'-ÿ)5ÿ/51-)8(/)ÿ)&'ÿ45@'8ÿ4+01)>ÿ]:ÿBCD-ÿ08'ÿ 1-)0++'6ÿ 1-)'06ÿ5:ÿ)&0)ÿ4+01)<ÿ)&'1ÿ )&'ÿ() + ),ÿ@ ++ÿ&07...

AI summary The document discusses the implementation and implications of BCD (likely a regulatory measure or program), focusing on its impact on cost structures, program design, and compliance with regulatory standards. It highlights concerns about alignment with energy efficiency goals and the need for adjustments in program design and oversight.

90ÿ39C/ÿ90ÿ<?/ÿ9<?/4ÿ1C@76<3ÿ@4/3/2</.ÿ12ÿm7:5/ÿnWORÿm?/>ÿ672ÿ:/ÿ7669;2</.ÿ094ÿ:>ÿ/1<?/4ÿC9.10>12Eÿ<?/ÿ C7E21<;./ÿ90ÿ<?93/ÿ1C@76<3ÿ94ÿ7669;2<12Eÿ094ÿ<?/Cÿ3/@747</5>RÿT1<?/4ÿB7>Aÿ1<ÿ13ÿ1C@94<72<ÿ<9ÿ/23;4/ÿ<?7<ÿ <?/4/ÿ13ÿ29ÿ.9;:5/W69;2<12Eÿ9...

AI summary The document discusses the implementation and evaluation of the ST+ program, including its impact on energy efficiency, cost-effectiveness, and regulatory considerations. It highlights challenges in program design, such as ensuring fair cost distribution and addressing potential inefficiencies. The ST+ program is evaluated in relation to broader energy management goals and regulatory frameworks.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 116 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !ÿ#$%&'() %+'$ÿ -./ÿ012ÿ34...

AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the analysis of benefit-cost for energy efficiency programs, including considerations for 2023-2026 DSM Plan and the Fuel Adjustment Mechanism. The analysis involves evaluating the impact of energy efficiency initiatives on cost recovery and program effectiveness.

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AI summary The text discusses the Fuel Adjustment Mechanism (FGH) and its implications, including the relationship between base rates and actual costs, as well as the role of Nova Scotia Power (NSP) in regulatory proceedings. It also touches on the integration of energy efficiency and demand-side management programs.

!(= 'ÿ) ÿ,! &$'ÿ%+)=0'ÿ ÿ&'' %%'ÿ)!ÿ&ÿ(=/=0&$#-ÿ &%#%ÿ$)ÿ'$ /#!ÿ)- &00ÿ ()%$A""($#-!%%;ÿ M;ÿN0($ÿ&ÿ()!%#%$!$ÿ&!'ÿ 0#& 0ÿ/ $+)'ÿ") ÿ&00)(&$#!,ÿ1 ), &/ÿ()%$%;ÿN)/ ÿ !"#$%ÿ&!'ÿ ()%$%ÿ/&>ÿ ÿ'# ($0>ÿ&00)(& 0;ÿO) ÿP&/10.ÿ(&1&(#$>ÿ/& Q$ÿ % -&$#)!...

AI summary The text discusses regulatory proceedings related to energy efficiency and cost recovery mechanisms, referencing specific programs and regulatory frameworks. It outlines the role of energy efficiency initiatives, cost recovery, and the evaluation of programs such as DSM plans and energy efficiency resource standards.

7$;ÿZ5)$ÿ'.0ÿ #.7ÿ+%ÿ"#7&'#7ÿ 1) $ÿ9%"ÿ'&$+%6#"$ÿ(5%ÿ"#$-%07ÿ+%ÿ-")'#ÿ$)40. $ÿ.07ÿ)0'"#.$#7ÿ1) $ÿ9%"ÿ+5%$#ÿ(5%ÿ7%ÿ0%+;ÿZ5#$#ÿ1) ÿ )6-.'+$ÿ6.,ÿ1#ÿ+5#ÿ"#$& +ÿ%9ÿ6%"#ÿ#99)')#0+ÿ-")'#ÿ$)40. $ÿ+5.+ÿ6%"#ÿ.''&".+# ,ÿ. %'.+#ÿ'%$+$ÿ.''%"7)04ÿ+%ÿ '&...

AI summary The text discusses the evaluation of fuel-cost-adjustment mechanisms and their impact on rate structures, including considerations of cost recovery, affordability, and the alignment of base rates with actual costs. It also touches on the role of demand-side management and efficiency programs in shaping energy policy.

ÿ"#$%&#'(%)"ÿ+),)&-%#.,ÿ&)$.(&/)$ÿ 0123ÿ4156789ÿ:83492;83ÿ718ÿ;8<8=273ÿ5<:ÿ4>373ÿ?>37ÿ98@8A5<7ÿ7>ÿ:23792;B78:ÿC8<89572><ÿDEFGÿ983>B9483HÿI7ÿ 2:8<72=283ÿJ8Kÿ=547>93ÿ7157ÿ5==847ÿEFÿ;8<8=273ÿ5<:ÿ4>373ÿ5<:ÿ69>A2:83ÿCB2:5<48ÿ><ÿ5::98332 ??><ÿ 4...

AI summary The document discusses the Board of Commissioners (BC) and the Board of Fuel Costs (BFC) in the context of a regulatory proceeding involving demand-side management (DSM) and energy standards (ES). It outlines the evaluation of fuel-cost-adjustment mechanisms, the role of energy efficiency programs, and the impact of these policies on rate structures and cost recovery.

33>42578:ÿL271ÿ;54JMB6ÿ389A2483_ÿ 3B66@8?8<75@ÿ389A2483_ÿ>9ÿ718ÿ1>37ÿ4B37>?89ÿB32 37ÿ98A8 37ÿ4B37>?89ÿ:8?5<:ÿ>9ÿ;Kÿ69>A2:2 B@:ÿ15A8ÿ;88<ÿ2<ÿ718ÿ5;38<48ÿ>=ÿ718ÿEFÿ983>B948Hÿ ]ÿ>37ÿ98A8 ?ÿEFÿ983>B9483ÿ?2C17ÿ@85:ÿ7>ÿ2<498538:ÿ95783_ÿ:868<:2...

AI summary The text discusses the Board of Commissioners (BC) and the Board of Fuel Costs (BFC) in the context of fuel cost adjustments and demand-side management (DSM) programs. It references regulatory proceedings and mentions the impact of fuel cost adjustment mechanisms on rate structures and energy efficiency initiatives.

Tÿ Tÿ Tÿ Tÿ UVÿWXIWÿFYGYÿZIYÿ[Mÿ[WXGMÿ\FGHYÿ W[ÿZGJGMIWGÿGHG]WMN]NW^ÿ]IJÿ fGHNIONHNW^ÿ Tÿ Tÿ ]MGIWGÿ][YWYÿ[MÿWXGYGÿN_ I]WYÿ fGYNHNGJ]Gÿ Tÿ Tÿ T8ÿr7ÿ8s ÿsÿvÿÿs 6ÿ678ÿÿts7ÿ8ÿt7ÿ8s sÿ su7ÿTÿÿ7r6ÿÿtsÿ 87ÿ8ÿ 7uÿwÿ6...

AI summary The text discusses regulatory proceedings related to energy management and utility operations in Nova Scotia, mentioning topics such as demand-side management, energy efficiency, and regulatory oversight. It includes references to various programs, policies, and entities involved in energy regulation.

\ÿ bMRÿcFGM[BdÿeMGDBNJÿ Hÿ fÿSBFBQDNgÿ\BKBF\DF^ÿMFÿCDNDF^ÿLF\ÿEMRhDFGM[BÿKLONDGDKLNDMFÿ ZFBO^JÿeBG]ODNJÿ Hÿ f\BÿSKBBFFB\QDDFNÿ^QMÿMOFÿOÿBQ]FBBERL SEBÿTUVÿKMNBFNDLEEJÿLÿGMCNÿQMOÿFMFhOBFBRLSEBÿTUgÿ ÿCM]OGBÿ H8ÿi7ÿ8j ÿjÿmÿÿj 6ÿ67...

AI summary The document discusses the Board of Commissioners' (BC) and Board of Fuel Costs (BFC) handling of fuel cost adjustments, including mechanisms for managing costs and addressing potential perverse incentives. It also touches on the integration of demand-side management (DSM) and energy standards (ES) within regulatory processes.

MGG]OÿMPBOÿN LNÿ[MFN xÿÿ _PBOÿLÿNJKDGLEÿ\LJgÿ[MFN gÿMOÿJBLOgÿCM[BÿTUÿNBG FMEM^DBCÿ[D^ NÿLENBOFLNBÿQOBˆ]BFNEJÿSBNRBBFÿ ^BFBOLNDF^ÿQMOÿEML\ÿOB]GNDMFgÿDF‰BGNDMFÿNMÿN Bÿ^OD\gÿMOÿSMN xÿ TUÿM]NK]NÿN LNÿMGG]OCÿ]ODF^ÿLÿND[BÿR BFÿN Bÿ^OD\ÿDCÿ\MRFÿD...

AI summary The text discusses the Board of Commissioners' (BC) and Board of Fuel Costs (BFC) handling of energy management and regulatory processes, including the impact of fuel-cost-adjustment mechanisms and the evaluation of demand-side management (DSM) programs. It references regulatory decisions and the role of various entities in energy policy.

ÿfÿ8ÿg7ÿ8i ÿ8ÿhÿnÿ 6ÿ78ÿ 7ÿ678ÿiÿ %(o('ÿ q-3ÿ52-//- ,/ÿ829:+/ÿ rCD ÿstÿE EGQYEÿHDEGCOOQRÿHDÿGUQÿuDHGQRÿdGCGQEÿCBQÿscvÿE EGQYESÿNI]QBQRÿV ÿQYHEEHIDE^PBQQÿEIOCBÿ QDQBT wÿ_IBÿGUQEQÿE EGQYESÿBQRXFGHIDEÿHDÿQDZHBIDYQDGCOÿFIYNOHCDFQÿFIEGEÿ...

AI summary The document discusses the Board of Commissioners' (BC) and Board of Fuel Costs (BFC) review of energy efficiency and demand-side management (DSM) programs, including the evaluation of cost recovery mechanisms, fuel-cost-adjustment processes, and the impact of regulatory proceedings on program design and implementation.

ÿ0$ /!'$ÿ#)$ÿ!#9!#ÿ&ÿ#)$ÿ7-ÿ #)ÿ"$#ÿ3(11("5ÿ "%ÿ3!. 11€/$11 11ÿ0$ ) "(/0/ÿ "ÿ&&$'ÿ ÿ4 '($#.ÿ&ÿ 09$"/ #("ÿ' #$/-ÿ^)$ÿ 09$"/ #("ÿ' #$/ÿ "ÿ$ ! 1ÿ#)$ÿ)/#ÿvwxyz{ }~xÿ'$# (1ÿ' #$/ÿi("ÿ#)$ÿ /$ÿ&ÿ"$#ÿ0$#$'("5jÿ#)$.ÿ "ÿ $ ! 1ÿ!#(1(#.ÿ/./#$0ÿ 4(%...

AI summary The document discusses the Board of Commissioners (BC) and Board of Fuel Costs (BFC) in the context of regulatory proceedings. It outlines issues related to fuel cost adjustments, demand-side management (DSM), and energy standards (ES). The text also references cybersecurity and yield zone (CYZ) as areas of concern, and discusses the implications of various regulatory mechanisms and procedures.

$0"%"ÿ$'-ÿ-,/"&%#$)-&ÿ!#$"%ÿ') ÿ3"ÿ$0"ÿ%#,"6ÿ3($ÿ4-!ÿ-$0"!ÿ4-!,%ÿ-4ÿ&"$ÿ 3) )&5ÿ$0"+ÿ') ÿ3"ÿ.)44"!"&$7ÿ :ÿ<-%$ÿ!"="&("%ÿ4!-,ÿ12ÿ!"%-(!"%ÿ') ÿ&-$ÿ"C"".ÿ$0"ÿ0-%$ÿ(%$-,"!ÿ-(&$"!4#$(# ÿ3) %ÿ-="!ÿ$0"ÿ 12ÿ$#!)44ÿ&"$$)&5ÿ/"!)-.7ÿ :ÿD4ÿ#ÿ12ÿ!"%-(!...

AI summary The text discusses the Board of Commissioners' (BC) evaluation of the 12th Demand Side Management (DSM) Plan and its implications on rate design and cost recovery. It highlights concerns about the alignment of base rates with actual costs, the impact of the fuel-cost-adjustment mechanism, and the need for a comprehensive review of the DSM Plan's effectiveness and fairness.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 150 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"!#ÿ %&''() +,ÿ.&/01ÿ21&3...

AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines a process involving the Board of Commissioners and the Board of Fuel Costs, focusing on the evaluation of demand-side management and energy efficiency initiatives, particularly in the context of policy and legislation.

;JÿBA=Eÿ̀H<@@ÿ̀A;IÿCAB= ?E?MÿopEEÿpEF=<8;ÿzMmÿA;IÿlCCE;I<ÿlMtÿ_;ÿF8;I:F=<;Jÿk7l?ÿ̀=KEBEL8BEÿ̀@8?=ÿBENE;:E?ÿ?K8:@IÿHEÿ ÿFA;ÿHEÿCB8CEB@>ÿEF@:IEIÿLB89ÿk7l?ÿA;IÿCB8CEB@>ÿ<;F@:IEIÿ<;ÿBA=Eÿ̀H<@@ÿ̀A;Iÿ CAB= ?E?Mÿ _;ÿJE;EBA@ÿ̀?ENEBA@ÿ]E>ÿLAF=8B?...

AI summary The text discusses the Board of Commissioners and the Board of Fuel Costs in the context of a regulatory proceeding involving fuel cost adjustments and demand side management. It references a proceeding related to the Public Utilities Act and mentions cybersecurity and yield zone considerations.

ÿRÿQLKNRGFKÿHKFEÿZZÿFLrUMFQÿFsÿ 5,2/-22- ,ÿ GKERXMRRMNEÿ}MEFÿ}NRRFRÿ Oÿ NLUFGYMRF^ÿ\NLFELMKVVIÿQNRLRÿM]ÿRLNGKHFÿZFrMQFÿQUKGHFRÿZTGMEHÿ LGKERXMRRMNEÿ\FKtÿ\FGMNZRÿ ~MRLGMSTLMNEÿ[K\KQMLIÿ Oÿ vNLFELMKVVIÿSFEF]MLRÿZF\FEZMEHÿT\NEÿLUFÿRLNGKHFÿTRF...

AI summary The text appears to be a regulatory proceeding document involving discussions on fuel costs, demand-side management, and energy standards. It references various regulatory processes, including fuel-cost-adjustment mechanisms and energy efficiency programs. It also includes mentions of cybersecurity and yield zones, indicating a focus on both energy and regulatory compliance.

XFGÿRKrMEHRÿXKtFÿSMVVÿ\KIXFELÿ MEQNXFÿQTRLNXFGRÿ uMRtÿ Oÿ vNLFELMKVVIÿSFEF]MLRÿZF\FEZMEHÿT\NEÿLUFÿRLNGKHFÿTRFÿQKRFÿKEZÿLUFÿ uFVMKSMVMLIÿ Oÿ kLFbkQlU EoNalVÿN_H IabÿàZcTdGeMÿEgHhÿa\bàFcKÿ̀tiÿNÿgGÿjFjkXFl ÿ̀mkÿinkog aipÿijÿ̀mkÿe iogqkÿ GHF...

AI summary The text discusses the Board of Commissioners (BC) and the Board of Fuel Costs (BFC) in the context of regulatory proceedings involving fuel costs and demand-side management (DSM). It references the need for alignment between base rates and actual costs, and mentions the importance of cybersecurity and yield zone (CYZ) considerations.

STUÿIVVHNWIOHGXÿÿ dMT\MIbÿjKbNJN[UMIUNTJÿ̀T[U[ÿ >+?#5ÿ kUNHNU_ÿdGM]TMbIJWGÿfJWGJUNaG[ÿ MYGZ[GTMFGMÿWIGM[Gÿÿ]JTTMÿÿJKIN[UUFMNMOIFHÿU\GIK[ÿÿF[UUTNHMNUING\G[Xÿÿ ^HGWUMNWJÿFTUUNÿHINU]_]Gÿ[WUUTÿTMIUZ\GGMÿMÿ]GF[GTHF[XMÿWG[ÿKTÿ @6#":ÿ MGKNUÿIJKÿ̀...

AI summary The text discusses regulatory proceedings involving the Board of Commissioners and the Board of Fuel Costs, focusing on topics such as demand-side management, energy standards, and cybersecurity. It mentions proceedings related to fuel-cost-adjustment mechanisms and energy efficiency programs.

c d310/12e%ÿf23102gd1%hÿi1)0/+%ÿj3%ÿ./3%ÿ$0/h%)]]3ÿ klmÿnoÿ456ÿ7 B6ÿ@67FI@96ÿ766R7ÿ D:?: =EÿD:??ÿG>=>B6G6= ??ÿ<5@66ÿF;ÿ<5676ÿD6=6;:<7Nÿ<56ÿ7 B6ÿ@67FI@96ÿGI7<ÿG>:=<>:=ÿ>ÿ96@<>:=ÿ 7<><6ÿF;ÿ95>@B6ÿA:K6Kÿ5FQÿ;I??ÿ<56ÿ7 B6ÿ@67FI@96ÿ:7Hÿ D?6ÿ...

AI summary The document discusses the Board of Commissioners' (BC) evaluation of the fuel-cost-adjustment mechanism and its impact on rate structures, including concerns about base rates lagging behind actual costs and potential perverse incentives. It also addresses the integration of demand-side management (DSM) and the need for alignment between regulatory frameworks and energy efficiency initiatives.

F=ÿ<56ÿ<:G:=Bÿ>=Eÿ E:@69<:F=ÿF;ÿ<56ÿ=66E6Eÿ@678F=767KÿLF@ÿ6M>G8?6Nÿ:;ÿ<56@6ÿ:7ÿ>ÿ<6G8F@>?ÿFJ6@?>8ÿF;ÿ<56ÿ=66E7ÿA6KBKNÿ„‚‚ƒ‰‚‚ÿ †Hÿ>=Eÿ<56ÿ;@6OI6=9Cÿ@6BI?><:F=ÿE:78><95ÿ@6OI:@67ÿ<56ÿ7 B6ÿ@67FI@96ÿ @B6ÿQ5:?6ÿ<56ÿE:7<@:DI<:F=ÿ E6;6@@>?ÿE:78...

AI summary The document discusses the Board of Commissioners' approach to managing fuel costs and the role of demand-side management (DSM) in energy policy. It highlights the need for adjusting fuel costs, the impact of DSM on energy efficiency, and the importance of regulatory oversight to ensure fair and effective energy management practices.

ÿ!"#$%&#'ÿ) +,%$'ÿ-'.,ÿÿ /0ÿ1234ÿ561417ÿ89:;:9:417ÿ5819234<17ÿ60=>2<ÿ9?:<=@A6<9:41ÿ36Bÿ144Cÿ92ÿ:0196;;ÿ38;9:A;4ÿ20@1:94ÿDEF17ÿG?:5?ÿ 36Bÿ96C4ÿH2<3ÿ69ÿ9?4ÿI8:;=:0J7ÿH65:;:9B7ÿ563A817ÿ2<ÿ04:J?I2<?22=ÿ;4K4;LÿM?:1ÿ5?6A94<ÿ=415<:I41ÿ?2Gÿ92ÿ ?2;...

AI summary The document discusses the regulatory considerations surrounding the implementation of DEF (Demand-side Management) programs, including their impact on utility operations, cost recovery, and the need for stakeholder engagement. It highlights the importance of aligning rate structures with program objectives and ensuring that these programs are effectively managed and evaluated.

56;58;69:201ÿ:1ÿ9?4ÿJ<608;6<:9Bÿ2Hÿ=696ÿ=41:<4=ÿ60=ÿ 6K6:;6I;4ÿH2<ÿ606;B1:1LÿM?:1ÿ:1ÿ=4A40=409ÿ20ÿ9?4ÿ1:947ÿ4f:19:0Jÿ:0H<619<8598<4ÿ:0K419340917ÿ60=ÿ ;4K4;ÿ2Hÿ94;4349<BLÿ hÿ%XYQSiNjYWSXÿ ]8;9:A;4ÿa2<ÿ6JJ<4J694=dÿ20@1:94ÿDEF1ÿ560ÿ96C4ÿA;654...

AI summary The text discusses the demand-side management (DEF) program and its role in energy efficiency, focusing on the implementation of DEF1 and its impact on energy consumption, cost management, and policy considerations. It outlines the challenges and strategies related to program execution and regulatory oversight.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 185 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"#$"%&ÿ () +,-+)./ÿ0+1ÿ ,...

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.

2) +,-+)./ÿ7,ÿ2117ÿ7=1)+ÿ,<6ÿ611./ÿ06.c,+ÿ/533,+7ÿ61)-=?,+)6-ÿ,+ÿ/>/712ÿ611./@ÿÿ [ÿAÿ 0235/ÿ2) +,-+).ÿ)/ÿ/)2)80+ÿ7,ÿ0ÿ/)6-81ÿ 5/7,21+ÿ2) +,-+).ÿ1Y 137ÿ)7ÿ/1+L1/ÿ2587)381ÿ?5)8.)6-/ÿ 7=07ÿ 06ÿ?1ÿ ,67)-5,5/ÿ,+ÿ6,6C ,67)-5,5/@ÿV6)L1+/)7)1/Bÿ=,...

AI summary This document discusses the evaluation of a 2) +,-+)./ÿ7,ÿ2117ÿ7=1)+ÿ,<6ÿ611./ÿ06.c,+ÿ/533,+7ÿ61)-=?,+)6-ÿ,+ÿ/>/712ÿ611./@ÿÿ and related proceedings, including topics such as fuel-cost-adjustment, demand-side-management, and regulatory processes. It also examines the impacts of various programs and the associated costs, as well as the need for prudence reviews and compliance with regulations.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 186 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"#$%ÿ$&'()ÿ" ')$("+ ÿ $$'...

AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the methodology for evaluating efficiency programs and their cost-benefit analysis, particularly in the context of demand-side management and regulatory compliance.

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AI summary The document discusses the 5670 program, a demand-side management initiative, and its implementation challenges. It references the need for adjustments in fuel costs, regulatory oversight, and the evaluation of energy efficiency programs. The text also touches on the importance of stakeholder engagement and the role of the Nova Scotia Power (NSP) in these proceedings.

"5%ÿ/)( +%+ÿ6(&"&ÿ(0ÿ("5%'ÿ !&ÿ: "5 ,ÿ"5/"ÿ'%- (,Aÿ75%ÿ3%&"ÿ:/#ÿ"(ÿ/66(9,"ÿ0('ÿ"5 &ÿ%00%6"ÿ &ÿ "5'(9-5ÿ+#,/. 6ÿ&#&"%.ÿ$1/,, ,-ÿ;&%%ÿY5/$"%'ÿ^_@AÿB,ÿ"5%ÿ/3&%,6%ÿ(0ÿ+#,/. 6ÿ$1/,, ,-4ÿ + 00%'%,"ÿ/$$'(/65%&ÿ6/,ÿ3%ÿ9&%+ÿ"(ÿ/$$'(2 ./"%ÿ"5%ÿ ,"%'...

AI summary The document discusses the regulatory analysis of fuel-cost-adjustment mechanisms and their impact on rate structures, highlighting concerns about misalignment between base rates and actual costs. It also examines the role of the 2023-2026 DSM Plan and the implications of energy efficiency programs on cost recovery and affordability.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 202 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"#ÿ$%&!'"ÿ!(!) +#+ÿ,-ÿ./0...

AI summary This document outlines the EfficiencyOne Benefit-Cost Analysis Test, referencing the National Standard Practice Manual. It discusses the application of the test in evaluating energy efficiency programs, including the consideration of cost-benefit analysis and the role of the 2023-2026 DSM Plan in the process.

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AI summary The document discusses the regulation and management of energy efficiency programs, including the implementation of the benefit-cost analysis test and the evaluation of demand-side management (DSM) initiatives. It outlines the process for assessing the effectiveness of these programs and their impact on utility operations.

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AI summary This document discusses the application of the EfficiencyOne Benefit-Cost Analysis Test, referencing the National Standard Practice Manual and outlining various aspects of demand-side management, including program evaluation, performance metrics, and the role of efficiency programs in energy conservation.

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AI summary The document discusses various aspects of regulatory proceedings related to energy efficiency, demand-side management, and utility regulations in Nova Scotia. It includes references to programs, policies, and regulatory processes involving entities like Nova Scotia Power and EfficiencyOne, as well as topics such as benefit-cost analysis and regulatory compliance.

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AI summary The text appears to be a fragment of a regulatory proceeding document, referencing topics such as fuel-cost-adjustment, demand-side-management, and other energy-related mechanisms. It includes acronyms and some legal or procedural references, though the content is not fully legible.

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AI summary The text appears to be a fragment of a regulatory proceeding document involving Nova Scotia Power (NSP) and discussions around energy efficiency programs and regulatory processes. It references the EfficiencyOne Benefit-Cost Analysis Test and mentions demand-side management (DSM) and other regulatory matters.

lC ?@ÿAB@Cÿ@=DEFGÿHIAB=?I CÿAI@=MCNNCA=?JC Cÿ@?S<?N?AB<=ÿTUVÿRC CÿB@@C@@[C<=ÿINÿOPQÿAI@=MCNNCA=?JC CLCÿ=>CÿV]^@ÿBLCÿHIAB=CEGÿ>C<ÿ=>CFÿKLIJ?ECÿ@CLJ?AC@GÿB CÿLC@DH=? CÿCNNCA=ÿ=>B=ÿHIAB=?I BJCÿI<ÿ=>?@ÿ>FKI=>C=?ABHÿOPQZÿ;=ÿ KLC@C<=@ÿ_B ÿ=>CÿRC...

AI summary The text discusses the implementation and evaluation of the EfficiencyOne Benefit-Cost Analysis Test (GH) within the context of Nova Scotia Power's (NSP) regulatory proceedings, focusing on the evaluation of demand-side management (DSM) initiatives and their impact on cost recovery and affordability.

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AI summary The text discusses various regulatory matters related to energy efficiency programs and proceedings, including topics like demand-side management, benefit-cost analysis tests, and regulatory proceedings. It references entities like Nova Scotia Power and EfficiencyOne, as well as regulatory processes and legal frameworks.

!ÿ#$#%&'() +&ÿ+&-ÿ./-%0/1 /#ÿ 2345ÿ63789:;ÿ8;<=4>:5ÿ?@4>7A6:ÿ 4A?ÿ?@4>7A6:ÿ ÿF<;ÿ7CCÿHIJÿ9D8:5Lÿÿ Zÿ\Aÿ7A7CDE4A?ÿ8<;9F 4A?ÿ:A7]C4A?ÿ:FF:695Kÿ57=4A?5ÿ:FF:695Kÿ7A>ÿ7=<4>:>ÿ6<59ÿ :FF:695Lÿ Zÿ\Aÿ7A7CDE4A?ÿ8<;9F 4=:;5:ÿ;7A?:ÿ ÿ7=<4>ÿ @A;:75 ÿ]D...

AI summary The text discusses the implementation and evaluation of the HIJ (Demand-Side Management) program by Nova Scotia Power (NSP), including its impact on cost recovery, program design, and regulatory considerations. It highlights concerns about program effectiveness, compliance, and alignment with regulatory standards.

uÿz@C948C:ÿ6<59^:FF:694=:A:55ÿ9:595Kÿ4Aÿ7>>494 ÿ9<ÿ 8;<=4>:ÿ7>>494 ÿ755:55ÿ93:ÿ;79:Kÿ ]4CCKÿ7A>ÿ87;94648794 456@55ÿ3 ÿ4Aÿ45 4694 456@55:5ÿ3 ÿ9<ÿ<894G4E:ÿG@C948C:ÿHIJ5ÿ7A>ÿ5@88CD^54>:ÿ ;:5<@;6:5Lÿ sÿ_ abcdbefbghicÿ8;4G7;Dÿ6<59^:FF:694=:A:55...

AI summary The text discusses the application of the EfficiencyOne Benefit-Cost Analysis Test in the context of demand-side management (DSM) programs. It references the HIJ DSM plan and related regulatory matters, including the evaluation of program effectiveness and compliance with regulatory standards.

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AI summary The text discusses the STU (possibly a regulatory body or process) and its role in managing demand-side management (DSM) programs, including the evaluation of benefit-cost analysis tests and the impact of STU on energy efficiency initiatives. It highlights the need for proper alignment between rates and costs, as well as the evaluation of DSM programs.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 210 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ ÿÿ66 !ÿ"#$%ÿ&'()ÿ +...

AI summary This document discusses the application of the EfficiencyOne Benefit-Cost Analysis Test, referencing the National Standard Practice Manual and outlining procedures for evaluating demand-side management programs. It includes references to regulatory processes and the use of benefit-cost analysis in decision-making.

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AI summary The text discusses the implementation and evaluation of the &'( (Demand-Side Management) program, focusing on its impact on energy efficiency, cost-effectiveness, and regulatory considerations. It highlights the need for adjustments to ensure proper alignment with policy objectives and the importance of stakeholder engagement in the process.

ÿ278 ]ÿ^^ _ÿÿ̀ a1-$-ÿ"-$!5'$ÿ&(!5%ÿ<-ÿ!$-%ÿ'(ÿb"#("#'#c-ÿ6&"($$ÿ789$ÿ6)%ÿ$-5-&'ÿ'1-ÿ;($'ÿ&($'0-33-&'#4-ÿ()-$ ÿ+("ÿ -d6;b5-:ÿ!'#5#'#-$ÿ("ÿ('1-"$ÿ&(!5%ÿ6&&-b'ÿ'1-ÿ;($'ÿ&($'0-33-&'#4-ÿ789$:ÿ#)ÿ'-";$ÿ(3ÿ-#'1-"ÿ)-'ÿ<-)-3#'$ÿ("ÿ <-)-3#'0&($'...

AI summary The text discusses the implementation and evaluation of the 789$ demand-side management (DSM) plan, including its impact on cost recovery, efficiency, and regulatory considerations. It outlines the role of the 789$ plan in managing energy demand, evaluating benefit-cost analyses, and addressing challenges related to program design and implementation.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 212 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"#$ÿ%&'(ÿ%&)#ÿ )++ÿ,'#-+%...

AI summary The document discusses the application of the EfficiencyOne Benefit-Cost Analysis Test, referencing the National Standard Practice Manual. It outlines procedures for evaluating demand-side management and energy efficiency initiatives, including criteria for assessing the impact of such programs on utility operations and customer benefits.

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AI summary The document discusses the implementation of a demand-side management (DSM) plan and its impact on utility operations, including cost recovery, efficiency measures, and regulatory considerations. It outlines the need for alignment between cost recovery mechanisms and program implementation, and highlights the importance of stakeholder engagement and evaluation of program effectiveness.

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AI summary The document outlines the EfficiencyOne Benefit-Cost Analysis Test Application and refers to the National Standard Practice Manual. It discusses the application of the test in evaluating demand-side management programs and includes various criteria for assessing the benefits and costs associated with these programs.

ONAÿ LRÿI>?OHCNJRÿV=EANAÿTaÿBGH>KN>@Yÿ !"#"#ÿ&'() +,-).ÿ01 23456)ÿ5ÿc,-)48)ÿd516)ÿ2eÿc0d8ÿ bDPNÿ>NK=JHCD>@ÿHEAÿDCGN>@ÿP?KGCÿI>NVN>ÿCDÿNEBD=>HKNÿHÿA?ON>@Nÿ>HEKNÿDVÿSTUÿCRIN@ÿLH@NAÿDEÿCGNÿJDK?Bÿ CGHCÿHJJÿSTUÿCRIN@ÿAN@N>ONÿ@DPNÿ=C?J?CRÿ@=IID>...

AI summary The document discusses the role of the STU in regulatory proceedings, including its involvement in demand-side management (DSM) and the evaluation of programs. It outlines the importance of the STU in analyzing and approving initiatives, as well as the impact of these programs on stakeholders.

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AI summary The text appears to be a fragmented and encoded regulatory document related to energy management and proceedings. It includes references to energy efficiency, demand-side management, and regulatory processes, though the content is not clearly legible or structured.

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AI summary The document discusses the impact of the Gq] mechanism on the efficiency of demand-side management programs and the challenges associated with aligning base rates with actual costs. It highlights the need for adjustments in the benefit-cost analysis test and the implications of these adjustments for the overall effectiveness of energy efficiency initiatives.

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AI summary The text discusses regulatory proceedings involving Nova Scotia Power (NSP) and EfficiencyOne Benefit-Cost Analysis Test, focusing on demand-side management (DSM) and related regulatory processes. It references regulatory bodies and processes, such as the Regulatory body or process (STU), and mentions matters related to cost adjustments and energy efficiency programs.

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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 regulatory proceedings related to Nova Scotia Power's energy and utility practices, including fuel-cost-adjustment mechanisms, demand-side management, and the impact of regulatory decisions on cost recovery and affordability. It also references specific regulatory frameworks and stakeholder engagement in the process.

S>ÿ5YY>7??BTcÿB6VSQ?>ÿSTAÿUC7TÿB?ÿB>ÿT5?aÿbC7ÿ>7Q?B5T>ÿSY?7Dÿ?CS?ÿAB>Q@>>ÿ>7h7DSeÿ7XS6Ve7>ÿ5YÿB6VSQ?>ÿ?CS?ÿ SD7ÿ>567?B67>ÿQ5T>BA7D7Aÿ5YY>7??BTcÿB6VSQ?>ÿSTAÿVD5hBA7ÿc@BASTQ7ÿ5TÿC5Uÿ?5ÿA7?7D6BT7ÿUC7?C7Dÿ?C7Wÿ >C5@eAÿR7ÿBTQe@A7Aÿ5Dÿ7XQe@A7AÿB...

AI summary The text discusses regulatory proceedings involving energy programs and policies, including the Yukon Energy Program (YBZ), Low-Income Energy Assistance Program (LML), and Benefit-Cost Analysis (BCD). It references the Clean Energy (CDE) initiative and Nova Scotia Power (NSP), highlighting topics such as mandatory net output (MNO) and regulatory processes related to energy programs.

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AI summary This text discusses the analysis and evaluation of various energy programs and regulatory considerations, including cost recovery mechanisms, program effectiveness, and the impact of regulatory decisions on energy efficiency and affordability. It references specific programs and regulatory processes.

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AI summary The text contains a mix of encoded or corrupted data, URLs, and references to various regulatory proceedings, including energy efficiency programs and legal matters. It includes mentions of Nova Scotia Power, the Public Utilities Act, and other regulatory topics, though the content is not fully readable or coherent.

oject.org/national- standard-practice-manual/. 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 7 of 68 EfficiencyOne Benefit-Cost Analysis...

AI summary The document discusses the development of a jurisdictional Benefit-Cost Analysis (BCA) test for Nova Scotia, focusing on demand-side management programs and distributed energy resources. It highlights how EfficiencyOne (E1) targets low- and moderate-income households through incentives and outlines the framework for assessing the cost-effectiveness of energy efficiency measures.

alled at a customer site. The demand side management programs being developed and screened by E1 for inclusion in their next plan are composed of individual measures and supporting services. Non-Energy Benefits: Many DERs provide benefits...

AI summary The text discusses the development of a Jurisdiction Specific Test (JST) for Nova Scotia to evaluate the cost-effectiveness of energy efficiency and distributed energy resources (DERs). It highlights that non-energy benefits from DERs, such as improved comfort and health, are harder to quantify and may be relatively small. The report recommends using a proxy adder approach to estimate these benefits and suggests that if not included in a jurisdictional test, host customer costs should be excluded.

economic metrics of supply-side investments. 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 8 of 68 EfficiencyOne Benefit-Cost Analysis Te...

AI summary The document discusses the evaluation of demand-side management (DSM) programs under the Public Utilities Act, emphasizing the use of a jurisdictional-specific benefit-cost analysis test. It outlines the structure of the DSM plan, the role of proxy adders in accounting for non-energy benefits, and the importance of reliability in reducing electricity outages.

energyfuturesgroup.com 10 About the Authors Energy Futures Group (EFG) is a clean energy consulting firm based in Hinesburg, Vermont and satellite offices in New York, North Carolina, and Colorado. EFG specializes in the design, implementa...

AI summary Energy Futures Group (EFG) is a clean energy consulting firm that specializes in energy efficiency, renewable energy, and distributed resources. They were contracted by EfficiencyOne (E1) to develop a benefit-cost analysis framework for Nova Scotia's 2027-2031 DSM Plan. The report draws on national standard practice manuals and resources from the National Energy Screening Project.

creeningproject.org/resources/quantifying-impacts/ 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 10 of 68 EfficiencyOne Benefit-Cost Anal...

AI summary EfficiencyOne (E1) is preparing its 2027-2031 Demand Side Management (DSM) Plan and expects to file it with the Nova Scotia Energy Board (NSEB) in early 2026. E1 is required to work with the DSM Advisory Group (DSMAG) to develop a benefit-cost analysis framework for its DSM Plan, and has engaged Energy Futures Group, Inc. (EFG) to facilitate stakeholder workshops and write a report.

stakeholder workshops and to write a report with recommendations on a benefit cost analysis framework for which E1 would be seeking NSEB approval to use in assessing the 2027- 2031 DSM plan. Consistent with comments on the structure for a...

AI summary EfficiencyOne (E1) is developing a benefit-cost analysis (BCA) framework for its 2027-2031 DSM Plan, informed by stakeholder workshops and a review of the National Standard Practice Manual. The report outlines EFG’s recommendations for a Nova Scotia-specific BCA test, based on stakeholder feedback and policy review.

73. EfficiencyOne 2023-2025 DSM Plan Application. Board Decision. September 6, 2022, page 26, line 73. 7 https://www.nationalenergyscreeningproject.org/national-standard-practice-manual/ Energy Futures Group, Inc PO Box 587, Hinesburg, VT...

AI summary The document references the EfficiencyOne 2023-2025 DSM Plan Application and includes a link to a national standard practice manual. It also mentions the submission of an EfficiencyOne Benefit-Cost Analysis Test Application.

ibution Distribution O&M       Distribution Voltage NM NM NM NM NM NM 10 See for example, Handbook of Public Economics, Vol. 2, 1987, Chapter 14: The Theory of cost-benefit analysis, Jean Dreze, Nicholas Stern. Available at:https://w...

AI summary The document outlines a Benefit-Cost Analysis (BCA) test application for EfficiencyOne, focusing on the impacts of Distributed Energy Resources (DERs) such as energy efficiency, demand response, and distributed generation. It references a handbook on public economics and includes a list of DER types and their applicability in Nova Scotia.

o merit routine inclusion Not included/or partially included in 2023-2025 test DER types not included in the 2023-2025 DSM plan Yellow shaded cells are impacts that were not included, or were only partially included, in the prior screening...

AI summary The text discusses the inclusion of distributed energy resources (DERs) in the 2023-2025 DSM plan, noting that certain DER types were not fully included. It highlights the need for a more comprehensive assessment of system impacts, such as transmission and distribution losses, and references the NSPM process and Energy Futures Group.

energyfuturesgroup.com 15 Non-Utility System Impacts Based on the working group’s review of Nova Scotia policies and the NSPM guidance, EFG recommends the inclusion of non-utility impacts as summarized in Table 4. Table 4: Non-Utility Impa...

AI summary The Energy Futures Group (EFG) recommends the inclusion of non-utility system impacts in Nova Scotia's policy framework, as outlined in Table 4, which categorizes impacts related to energy efficiency (EE), demand response (DR), distributed generation (DG), demand-side management (DS), electric vehicles (EV), and building efficiency (BE).

inclusion in the NS UBCA test Not included/or partially included in 2023-2025 test DER types not included in the 2023-2025 DSM plan Consultant Team Recommendations Based on our research and discussions and feedback received during seven DS...

AI summary The document discusses the need for a new Nova Scotia test for benefit-cost analysis to evaluate E1’s 2027-2031 plan, including recommendations from the Energy Futures Group (EFG) on the impact categories to be included in the test, such as electric utility system impacts, greenhouse gas impacts, and criteria air pollutant impacts.

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.

idering forward looking estimates of transmission and distribution upgrade costs as opposed to relying on historic costs may be adopted. (See Tables 2 and 3, and Section IV). 4) The new jurisdictional test should include other fuel and gas...

AI summary The text discusses the adoption of forward-looking estimates for transmission and distribution upgrade costs, the inclusion of other fuel and gas impacts in a new jurisdictional test based on commodity costs minus carbon price, and the recommendation to treat gas impacts through commodity costs due to the relatively small gas system size and anticipated DSM impacts.

s on the gas system. In the future further consideration of the gas system non- commodity cost impacts may be necessary and appropriate. (See Tables 4 and 11, and Section V). 6) For host customer impacts the new jurisdictional test should...

AI summary The text discusses the need to consider non-commodity costs of the gas system, the inclusion of non-energy benefits in the jurisdictional test for host customers, the use of social cost of carbon for societal impacts, and the recommendation to assess economic and job impacts of DSM separately. It also references specific tables and sections for detailed analysis.

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.

o help identify a portfolio of demand side resources with positive net benefits, when considering the cost and benefit categories aligned with Nova Scotia’s policy priorities and objectives. A jurisdictional benefit cost test does not dire...

AI summary The text discusses the use of a jurisdictional benefit-cost analysis (BCA) to identify cost-effective demand side management (DSM) resources aligned with Nova Scotia's policy goals. It clarifies that while a BCA test helps evaluate net benefits, it does not determine funding sources or amounts. An example is provided using cold climate heat pumps and a 2% social discount rate.

energyfuturesgroup.com 22 Table 6: Illustrative Example Present Value Benefits, Costs and Ratios Benefit PV of Costs PV of Benefits Cost Ratio HP- Fuel Oil $31.66 $57.10 1.80 HP - Fossil Gas $31.66 $14.31 0.45 HP - Electric Resistance $9.9...

AI summary This section presents a benefit-cost analysis of different heating options, including fuel oil, fossil gas, and electric resistance, with cost ratios indicating the economic viability of each. It references the application of the new Nova Scotia test to evaluate EfficiencyOne’s proposed DSM plan for 2027-2031.

energyfuturesgroup.com 23 II. Introduction 1. Background EfficiencyOne (E1) is in the process of developing the next demand-side management (DSM) plan for the period of 2027-2031. As part of the five-year DSM Plan, E1 is reviewing its exis...

AI summary EfficiencyOne (E1) is developing a new demand-side management (DSM) plan for 2027-2031, including updating the Benefit-Cost Analysis (BCA) test and avoided cost methodologies. E1 is working with the DSMAG and NS Power to ensure updated electric system impacts are incorporated into the BCA framework, following best practices from the National Standard Practice Manual (NSPM) for distributed energy resources (DERs).

hat can be used to assess a broad set of DERs including energy efficiency, demand response, distributed generation, distributed storage, and electrification for buildings and transportation. For the 2023-2025 DSM Plan, the cost benefit tes...

AI summary The text discusses the application of a benefit-cost analysis (BCA) test for assessing distributed energy resources (DERs), including energy efficiency and demand response. It references the Total Resource Cost (TRC) test used in the 2023-2025 DSM Plan, noting that it was a variation of the TRC test and excluded certain impacts. The Energy Futures Group (EFG) is mentioned in the context of providing recommendations.

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.

oard Decision. September 6, 2022, page 26, line 73. 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 24 of 68 EfficiencyOne Benefit-Cost Ana...

AI summary This document outlines the proposed new Nova Scotia test(s) for screening the 2027-2031 E1 Plan Application, aiming to maintain the BCA test(s) in an 'evergreen' manner that aligns with Nova Scotia policy objectives. It discusses the consultant team's recommendations for the test, its usage, and methodologies for estimating benefits and costs.

dation for the Nova Scotia test, how the test will be used, and the methodologies for estimating benefits and costs. E1 identified several goals of updating the BCA framework. These include: • Nova Scotia’s BCA framework is updated to refl...

AI summary This document outlines the goals of updating Nova Scotia’s Benefit-Cost Analysis (BCA) framework to align with policy objectives and include all anticipated DSM programs. It emphasizes stakeholder input, the need for finalized frameworks by 2025, and the use of the updated test in E1’s 2027-2031 DSM Plan. The report also discusses the engagement of a consultant to support DSMAG working groups.

26 this report on a proposed Nova Scotia uniform benefit cost analysis (BCA) test for DERs, informed by the NSPM and DSMAG working group discussions. 3. NSPM Overview The NSPM for DERs provides guidance for valuing DER opportunities to inf...

AI summary This document outlines a proposed Nova Scotia uniform benefit-cost analysis (BCA) test for distributed energy resources (DERs), informed by discussions between Nova Scotia Power (NSPM) and the Demand Side Management Advisory Group (DSMAG). The NSPM provides guidance for valuing DER opportunities to support policy goals, including reliability, low-cost energy, and greenhouse gas reduction.

28 Figure 3: NSPM Process to Defining a Jurisdiction's Primary Cost-Effectiveness Test The proposed Nova Scotia BCA test in this report was developed in a process that followed the first three of these five steps; steps 4 and 5 of the NSPM...

AI summary The document outlines the process used to develop a Benefit-Cost Analysis (BCA) test in Nova Scotia, including policy goals, applicable USIs, and non-USIs. The process involved workshops led by E1 and EFG, with participation from various organizations.

• Efficiency One (E1) • Energy Futures Group (EFG) • Synapse Energy Economics, on behalf of Counsel to NSUARB • Consumer Advocate • Nova Scotia Power • Small Business Advocate (SBA) • Industrial Group (IE) • Ecology Action Center (EAC) • Kwi...

AI summary The document outlines participants in a working group discussion on developing a Benefit-Cost Analysis (BCA) framework for Nova Scotia's energy policies. The group reviewed Nova Scotia energy policies and their applicability to DER types, including generation, transmission, distribution, and general/other. They also evaluated the inclusion of USIs and NUSIs in the 2023-2025 DSM Plan BCA test for EE and DR.

Page 30 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 31 and criteria air pollutants are supported by the ERA’s pending amendments to the Public Utilities Act. 2. Nova Scotia Public Utilities...

AI summary The text discusses the Nova Scotia Public Utilities Act, specifically the demand-side management (DSM) section, which supports electrification to reduce greenhouse gas emissions and electricity costs. It outlines the definition of DSM and the Board's role in determining cost-effective demand-side management programs.

79H (2) The Board shall determine the cost-effective demand-side management at the portfolio level that would be the aggregate amount of demand-side management programs. 79L (4) The Board shall approve an application pursuant to this Secti...

AI summary The text discusses the Public Utilities Act's DSM section and its support for including various impacts in a BCA test. It also mentions the consideration of other Nova Scotia energy policies beyond the Energy Reform Act and Public Utilities Act, as identified by E1 and other stakeholders.

y Actions to comply with federal, state, and regional policies. Example Other Requirements would be FERC Order 2222 21 In Nova Scotia, E1 serves as a third-party administrator for DSM programs. The electric system USI’s in this report refe...

AI summary The document discusses actions to comply with federal, state, and regional policies, referencing FERC Order 2222. It outlines EfficiencyOne's role as a third-party administrator for DSM programs in Nova Scotia and mentions the DSMAG working group's focus on accounting for utility system impacts in a new BCA test.

indicating which of the utility system impacts in Table 8 were included in the BCA test that E1 used to screen the 2023-2025 DSM portfolio. Appendix B presents the results of this exercise. The results indicated there was not always a comm...

AI summary The text discusses the need for clarity and consensus on how to treat utility system impacts (USIs) in the Benefit-Cost Analysis (BCA) framework, particularly in the context of the 2023-2025 DSM portfolio. It highlights gaps in understanding around transmission and distribution loss factors and ancillary services valuation, and emphasizes the importance of stakeholder engagement and documentation.

oided costs. The working group further discussed why some impacts have not been included or fully incorporated in the BCA to date for EE and DR and options for including them moving forward: • Environmental compliance- Assuming Nova Scotia...

AI summary The working group discussed why some environmental compliance and utility direct investment impacts have not been fully included in the Benefit-Cost Analysis (BCA) for energy efficiency (EE) and demand response (DR) programs. It noted that environmental compliance costs may be embedded in avoided costs and that utility investments in distributed energy resources (DERs) could increase as technologies evolve.

areas with high saturation of distributed generation or grid constraints may be more likely in the future. • Credit and collections – NS Power stated they have not experienced material impacts on costs associated with account delinquencies...

AI summary The text discusses potential future impacts of distributed energy resources (DERs) on credit and collections, program administration, risk, reliability, and resilience. NS Power notes no material impacts currently but acknowledges future risks as DER deployment increases. Energy efficiency and demand response (DR) are highlighted for their potential resilience benefits.

energyfuturesgroup.com 37 shaded cells indicate an impact that was not included or only partially included in the 2023- 2025 DSM Plan BCA test. Table 9: Generation, Transmission and Distribution USIs Impact Type Impact EE DR DG DS EV BE En...

AI summary The table outlines the impact of various energy efficiency (EE), demand response (DR), distributed generation (DG), demand-side management (DS), electric vehicles (EV), and building efficiency (BE) initiatives on generation, transmission, and distribution utility system impacts (USIs). Shaded cells indicate partial or no inclusion in the 2023-2025 DSM Plan BCA test.

Distribution Distribution O&M       Distribution Voltage NM NM NM NM NM NM Key  Impacts that are both applicable and material NA Impacts that are not applicable to a given DER or in NS market NM Not material, or not large enough to...

AI summary The document discusses the impact of DERs on distribution and voltage, noting that some impacts are material while others are not. It also references two tables summarizing system impacts and costs associated with DSM services, with Table 10 including E1 costs.

p.com 38 Table 10: General Electric USIs As part of the DSM plan development, the DSMAG is also reviewing updates to the electric system avoided costs through a separate engagement led by Nova Scotia Power. E1 anticipates using updated avo...

AI summary The document discusses the review of electric system avoided costs by the DSMAG and the use of updated avoided costs in the new test. It also mentions the inclusion of non-utility system impacts in the BCA test, including customer-specific benefits and policy-related impacts.

s, so not likely to have large GHGs  NM  NM   GHG impacts Societal Other DR can have adverse local environmental impacts if    NM   Environmental customers deploy diesel generators Often related to and overlap w other environmenta...

AI summary The text outlines the environmental and societal impacts of DERs, noting that while DR can lead to adverse local environmental effects, such as from diesel generators, these impacts are generally not material enough for routine inclusion in the NS UBCA test. It also highlights the importance of keeping incremental impacts separate from BCA calculations to prevent double counting.

lusion in the NS UBCA test Not included/or partially included in 2023-2025 test DER types not included in the 2023-2025 DSM plan While, in theory, all the categories in Table 11 are worthy of inclusion, the consultant team recommends a sub...

AI summary The consultant team recommends a subset of categories for inclusion in the BCA test for E1’s 2027-2031 DSM plan, acknowledging overlaps and the need to avoid double counting. They also recommend including other fuels, host customer costs and non-energy benefits, greenhouse gases, and criteria air pollutants as non-utility system impacts in the new Nova Scotia test.

lutants be included as non-utility system impacts in the new Nova Scotia test. The recommended treatment of other fuels, host customer, and societal impacts are discussed sequentially below. 2. Other Fuels Other fuels that can be saved by...

AI summary The document discusses the inclusion of other fuels such as pipeline gas, fuel oil, and propane in the new Nova Scotia test as non-utility system impacts. It notes that impacts are based on commodity prices rather than gas utility system impacts, and recommends including these in the new BCA test.

Table 12: Other Fuel Impacts Other Fuel Impacts Description and Examples EE DR DG DS EV BE Discussion Notes Primarily electrification or efficiency Fuel and related O&M costs of displacing fossil fuels. Distributed Storage Commodity   ...

AI summary The table outlines other fuel impacts, including electrification, efficiency, and compliance costs for environmental regulations. It also addresses market price effects and cross-fuel dripe in Nova Scotia. The discussion notes highlight the displacement of fossil fuels and the embedding of compliance costs in commodity prices.

Cross fuel dripe in NS for pipeline gas could Market Price Effects fuels resulting from changes in NM NM NM NM NM NM be meaningful for large industrial customers, levels of consumption but cross fuel impact is generally expected to be NM....

AI summary The text discusses potential cross-fuel impacts in Nova Scotia, particularly for large industrial customers, and the implications of gas and electric DERs on utility systems. It notes that further analysis is required to understand the effects on gas consumption and infrastructure.

demand created by BE, and implications on reliability, etc.) gas system infrastructure and operations. Key  Impacts that are both applicable and material NA Impacts that are not applicable to a given DER or in NS market NM Not material, o...

AI summary The document discusses host customer impacts related to distributed energy resources (DERs), distinguishing between energy and non-energy impacts. It notes that energy impacts are already accounted for elsewhere and focuses on non-energy benefits and costs, such as measure costs and incentives, which should be considered in a jurisdictional test. This is part of a benefit-cost analysis for a demand-side management (DSM) plan.

Page 41 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 42 Table 13: Host Customer Impacts Host Customer Impact - +/- Direct Estimates EE DR DG DS BE EV Notes Not always for DR, but possible (e....

AI summary The table outlines the host customer impacts of various energy efficiency and demand response measures, including direct estimates, DER measure costs, interconnection fees, tax incentives, and water cost impacts. EfficiencyOne proposes not to include tax incentives as cost reductions due to uncertainty in their continued availability.

include tax or other incentives as reductions to host customer costs. + Water cost impacts  NA NA NA NA NA Some efficiency measures also reduce water consumption +/- Host Customer Energy Impacts Proxy EE DR DG DS BE EV Time required to en...

AI summary The text discusses the impact of various energy efficiency and demand response measures on host customer costs and non-energy benefits. It highlights how some measures reduce water consumption and energy costs, as well as improve resilience and productivity. It also notes the economic well-being benefits from reduced energy bills.

NA Many EE investments in businesses improve productivity + Economic well-being  NM     Energy bill savings reducing stress of disconnections, foreclosures, etc. +/- Comfort   NA NA  NA Most positive for shell measures, DR may have...

AI summary The text discusses the non-energy benefits of energy efficiency (EE) investments in businesses, including economic well-being, comfort, amenity, health and safety, empowerment, and pride. It also references Appendix F from the Database of Screening Practices, which highlights how over 18 jurisdictions consider non-energy host customer benefits in screening tests. E1 and the DSMAG have prior experience with reviewing host customer impacts in BCA testing.

eeningproject.org/state-database-dsp/ 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 42 of 68 EfficiencyOne Benefit-Cost Analysis Test App...

AI summary This section discusses a Benefit-Cost Analysis (BCA) test application by EfficiencyOne, focusing on non-energy benefits (NEBs) derived from Massachusetts and adjusted for Nova Scotia conditions. The analysis was reviewed by the Demand Side Management Advisory Group (DSMAG), with consideration of alternative methods such as percent adders for measure categories.

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.

23-2025 Plan 27 specifically (in August 2022) directed E1 to remove these impacts from the Compliance filing.28 However, the 2023-2025 DSM Plan BCA test did include host customer costs for 25 Efficiency One, In the Matter of the Public Uti...

AI summary The 2023-2025 DSM Plan BCA test included host customer costs for measures installed through E1 initiatives, despite the Public Utilities Act not allowing the Board to consider non-energy benefits (NEB) in the BCA test at the time of filing. The NSPM’s symmetry principle suggests that if host customer costs are counted, host customer benefits should also be considered.

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.

ility impacts, in comparison to market rate activities. The values in Table 14 are also considered by EFG to be broadly consistent with the level of valuation adopted by other jurisdictions. The proxy values in Table 14 recommend different...

AI summary The document discusses non-energy benefits (NEB) proxy values for different customer segments and measure types, noting that higher values are recommended for income-qualified or disadvantaged communities. These values are considered consistent with those used in other jurisdictions.

NA NA   NA NA stations, police, water treatment facilities, etc.) Impact of changes in GHG emissions on Greenhouse Gas Emissions  NM  NM   society and the environment Impact of changes in other emissions or Other Environmental   ...

AI summary The text discusses the recommendation to include quantification of economic and environmental impacts from GHG and other air pollutants in the BCA test for the 2027-2031 DSM plan application. It notes that the E1 portfolio and support for DERs provide additional societal benefits beyond these categories.

sider modifying these values to more accurately reflect specific Nova Scotia conditions and dynamics contributing to the valuation of impacts for criteria air pollutants if deemed desirable. During the discussion of quantifying criteria ai...

AI summary The document discusses the modification of criteria air pollutant values to better reflect Nova Scotia conditions. It raises concerns that absolute emissions caps may not reduce pollutants with increased DER deployment, but recommends adopting New England values for the 2027-2031 DSM plan. A benefit-cost analysis suggests using 0.55 cents per kWh for the BCA test in Nova Scotia.

energyfuturesgroup.com 54 VI. Example Quantification of Impacts for Nova Scotia Test 1. Introduction The consultant team recommends the new Nova Scotia test include electric utility system impacts, other fuel impacts, host customer impacts...

AI summary This section introduces the recommended approach for quantifying impacts in the new Nova Scotia test, including electric utility system impacts, other fuel impacts, host customer impacts, and GHG and air pollution emission impacts. It emphasizes that these examples are illustrative and may be updated based on stakeholder input and future analysis.

Page 54 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 55 The consultant team recommends a real societal discount rate of 2% be used for the primary BCA test. This recommendation is based on th...

AI summary The document discusses a Benefit-Cost Analysis (BCA) test recommending a 2% real societal discount rate for evaluating the DSM plan's impact on reducing greenhouse gases. It provides an example of 1,000 residential heat pumps replacing heating oil, highlighting the discounted value of saved fuel oil and the exclusion of carbon price for heating oil until March 2027.

7,878 $ 567,792 5,275 $ 173 $ 63 $ 925,066 $ 1,009,604 $ 8,561,403 $ 12,422,879 $ 21,458,023 The program administration and incentive costs for E1 to deliver services supporting 1,000 heat pump installations in 2026 are estimated in utilit...

AI summary The text discusses the estimated program administration and incentive costs for E1 delivering services supporting 1,000 heat pump installations in 2026. It notes that these costs, totaling $5.1 million, are included in addition to system energy and capacity costs. The greenhouse gas impacts of replacing 1,000 fuel oil heat pumps with electric ones are also referenced.

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.

E1 Responses to East Coast Environmental Law (ECEL) Information Requests NON-CONFIDENTIAL Request IR-01: Refer to Exhibit E-1, "Notice of Application and Evidence", within the "Evidence" section, dated May 16, 2025. At page 18, lines 21-25...

AI summary The response explains the National Standard Practice Manual (NSPM) is used across North America for developing cost-effectiveness tests. Adhering to NSPM ensures alignment with national standards and Nova Scotia's policy objectives for demand-side management plans.

Request IR-01: - Reference: Evidence Page 7: A benefit-cost ratio threshold of 1.0 or greater of a DSM Plan must - always be satisfied at the portfolio level. While measures that do not meet the ratio threshold - can be included, E1 must j...

AI summary The proceeding addresses EfficiencyOne's (E1) approach to justifying demand-side management (DSM) measures that fail to meet a benefit-cost ratio (BCR) threshold of 1.0. E1 plans to use a regulator-approved cost-effectiveness test, citing factors like equity, emerging technologies, and market needs. The request also asks if prior Board approval is required and if stakeholder input is sought for such measures.

E1 Responses to Eastward Energy Inc. (Eastward Energy) Information Requests NON-CONFIDENTIAL - (b) E1 was directed by the Nova Scotia Utility and Review Board in their Board Order on E1's 2023-2025 DSM Plan "To provide specific justificati...

AI summary E1 is responding to information requests by the Nova Scotia Utility and Review Board (NSUARB), explaining that it will justify DSM measures failing cost-effectiveness testing in future resource plans, including the 2027-2031 DSM Plan. E1 engages with the DSMAG, sharing modelling details and seeking input during plan development.

1 Request IR-05: 2 3 Reference: Appendix 8, page 17: "EFG recommends treating gas impacts through the 4 commodity costs is appropriate due to the relatively small size of the gas system and the 5 anticipated level of "DSM portfolio impacts...

AI summary The text discusses the anticipated level of DSM portfolio impacts on the gas system, noting that gas savings from DSM programs are expected to be significantly less than for electricity and other fuels due to the limited service territory of the gas system and program design choices. This is supported by the EFG Report's illustrative example.

- 2 Fuel Impact Nat Gas' worksheet. 3 2.0% 15 2040 $ 10.39 $ 15.71 $ 5.33 84,470 0.74 $ 334,282 $ 6,196,318 1 Request IR-07: 2 3 Reference: General 4 5 (a) How does the benefit-cost test capture the cost of additional pressure on meeting t...

AI summary The document discusses the benefit-cost analysis of strategic electrification, including how it captures the costs of increased electric utility peak demand and infrastructure upgrades. It also asks whether E1 has coordinated with the electric utility's planning department and whether hybrid peaking or dual fuel opportunities were evaluated.

M12282 – EfficiencyOne (E1) Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans 1 Request IR-08: 2 3 Reference: Appendix B, Table 5 4 5 (a) Please explain what is meant by "S...

AI summary The document includes a request for clarification on the methodology used in a Benefit-Cost Analysis (BCA) for evaluating Demand Side Management (DSM) plans. Questions pertain to the social cost of carbon, direct measure costs, and the reliability impact of measures that increase peak load on the electric system.

- 8 ii) Installation costs are included in the estimated measure costs. - 9 iii) Changes in operating and maintenance costs (which can be positive or negative) are 10 considered in estimation of the host customer non-energy benefits. Incre...

AI summary The text discusses the inclusion of installation and operating costs in the estimation of non-energy benefits for host customers. It also outlines the impact of heat pumps on electric system costs and savings, noting that replacing fuel oil and natural gas with heat pumps increases costs, while replacing electric resistance heat decreases them.

l of electric system impact savings for this option. The value of increased or decreased system peak impacts and reliability are assumed to be embedded in the avoided cost values provided by NS Power. (e) Yes, reliability impacts are assum...

AI summary The text discusses how reliability impacts are embedded in avoided cost values provided by NS Power, aligning with E1's current practice. This relates to the evaluation of system impact savings and reliability considerations in the context of demand-side management.

Emissions Factor Year (tonnes CO2e/MWh) 2026 0.448 2027 0.355 2028 0.431 2029 0.393 2030 0.086 2031 0.159 2032 0.320 2033 0.360 2034 0.369 2035 0.269 2036 0.355 2037 0.288 2038 0.239 2039 0.218 2040 0.221 (b) Please provide the source of t...

AI summary The document requests the source and clarification of projected electricity emissions factors for 2026-2040, confirms the natural gas combustion emissions factor used, and asks for recent emissions factors for 2024. It also inquires about the appropriateness of using average or marginal emissions factors for estimating emissions increases. The response indicates the values are derived from the DICE method used in the 2023-2025 DSM Plan and provides context on furnace efficiency assumptions.

1 Request IR-01: 2 3 Reference: E-1, Application, page 5, para 26 (pdf page 6 of 450). 4 5 E1 submits that the proposed BCA test is appropriate, reasonable, is in the 6 best interest of ratepayers, and should replace the existing TRC test...

AI summary The document discusses E1's proposed BCA test as a replacement for the existing TRC test for evaluating DSM plans. E1 argues the BCA test is in the best interest of ratepayers and more balanced than the TRC test, which is criticized for being biased due to its inclusion of host customer costs but not participant benefits.

Recent legislative changes and evolving energy priorities—especially related to electrification and decarbonization—have further prompted a re-evaluation of this framework. The Nova Scotia Utility and Review Board (now Nova Scotia Energy B...

AI summary Recent legislative changes and energy priorities have prompted a re-evaluation of the cost-effectiveness framework for demand-side management (DSM). The Nova Scotia Energy Board has directed E1 to work with the DSMAG to develop a jurisdiction-specific BCA test to better evaluate DSM investments and align with Nova Scotia's evolving energy and environmental goals.

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 in Nova Scotia. The application aims to establish a revised methodology for assessing DSM initiatives under regulatory oversight.

E1 Responses to Industrial Group (IG) Information Requests NON-CONFIDENTIAL 1 (d) E1's assertion that the BCA test is in the "best interest of ratepayers" does indicate that the 2 test is intended to continue serving as a key tool for eval...

AI summary E1 responds to Industrial Group (IG) requests regarding the proposed Benefit-Cost Analysis (BCA) test, emphasizing its alignment with policy priorities and provincial legislation. It contrasts the BCA with the existing Total Resource Cost (TRC) test, noting that energy impacts outweigh non-energy impacts. Energy Futures Group (EFG) confirms energy impacts dominate in the BCA test (77% of total impacts). The 2026 DSM Plan extension and DSMAG engagement are referenced.

Request IR-03: (a) Approximately how much additional work does E1 anticipate will be required to accomplish its new BCA test compared to the existing TRC for both forecasting and reporting results? (b) Please provide detail of the work pro...

AI summary EfficiencyOne (E1) anticipates some incremental work to implement a new BCA test compared to the existing TRC test, focusing on quantifying new impact streams. The BCA test is intended to be a more accurate and practical tool for assessing the cost-effectiveness of DSM plans. E1 has initiated this work with the DSMAG and believes the BCA balances analytical rigor with practical feasibility.

9 Impact Category Impact Type Impact Work Products Utility Direct Investment in DERs E1 expects the quantification of these impacts to come from NS Power and/or the NSIESO Program Administration E1 expects program administration estimates...

AI summary The text outlines various impact categories and their quantification expectations, primarily involving E1 and NS Power/NSIESO. It discusses DERs, program administration, credit and collection, risk, reliability, resilience, compliance, gas system impacts, commodity costs, environmental compliance, market price effects, and other utility system impacts. Most quantifications are expected to be provided by NS Power and NSIESO, while some are to be proposed by E1 with potential external support.

4 1 Request IR-06: 2 3 Reference: E-1, Evidence, Section 5.2, Jurisdiction to Consider Non-Energy Impacts, pages 11- 4 12. 5 6 (a) Is it E1s position that the new legislation to consider non-energy impacts eliminates the 7 Board's conclusi...

AI summary The document discusses the implications of new legislation on the definition and assessment of cost-effectiveness for DSM plans, referencing the removal of section 79L from the Public Utilities Act and the substitution with new requirements for the Board to assess the best interests of customers and the approval of demand-side management applications.

ation of how E1 proposes to address the contents of Appendix - A of the NSPM (Rate Impacts) including which tests would be applied, and at which stage of - the BCA approval? Response IR-11: - The National Standard Practice Manual's (NSPM)...

AI summary E1 responds to the Industrial Group's query about addressing NSPM Rate Impacts and BCA approval by stating that rate impacts are separate from cost-effectiveness analyses. E1 conducts a Rate and Bill Impact Analysis (RBIA) alongside DSM Plan Applications, aligning with NSPM recommendations. References include M12282 and M12249.

(c) Please refer to part (b) of this IR response. M12282, E1 BCA Test Application, May 16, 2025, Appendix A, Attachment 2: National Standard Practice Manual, pages 264-265 of 302. 1 Request IR-13: 2 3 References: E-1, Appendix B; and Evide...

AI summary The document requests an explanation of why only American jurisdictions were reviewed in the E1 BCA Test Application and asks for analysis on DSM cost-effectiveness metrics used in Canadian jurisdictions, including benefit-cost analysis tests and whether electrification, solar-PV, and storage are evaluated together with energy efficiency and demand-side management plans.

(a) Please refer to EfficiencyOne's (E1) response to NSEB IR-03 part (a). (b) Please refer to E1's response to NSEB IR-03 part (a). (c) The process and workshops conducted by EFG focused on the development of a jurisdictional test, based o...

AI summary The document references EfficiencyOne's response to NSEB IR-03 part (a) and discusses the development of a jurisdictional test for distributed energy resources (DERs) by EFG, based on the NSPM. The test is recommended to be applied at the portfolio level for all DERs, with information on screening at the measure and program level provided for informational purposes.

Date Filed: July 4, 2025 E1 (IG) IR-13 Page 2 of 2 M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, S...

AI summary This document discusses the request for approval of a new Benefit-Cost Analysis (BCA) framework, including the use of a 2% social discount rate and the inclusion of proxy adders for non-energy benefits. It outlines the mathematical representation of the BCA test, which includes utility system impacts, host customer impacts, and societal impacts.

ased on policy priorities and objectives established under legislation. Applying this lens to non-utility impacts, in E1's submission, supports the inclusion of the impact categories proposed under - (a) Please identify all the indirect be...

AI summary The text requests the identification and explanation of indirect benefits and costs in the BCA, including how they are quantified and supported by empirical evidence under relevant legislation. It also asks for an explanation of why including these is considered a best practice in BCA design for DSM.

- v) If indirect costs and benefits are removed from the proposed BCA, would the ratio of 1.0 or greater remain as the threshold? 1 (b) Please provide the list of the proposed weights to be assigned to each utility impact used 2 in develop...

AI summary The text requests clarification on the proposed BCA test, including the weights assigned to utility and non-utility impacts, whether a sensitivity analysis was conducted, and how non-utility benefits align with policy objectives in the Public Utilities Act. It also asks about the impact of repealing specific sections on the BCA and whether performance requirements will be proposed for non-utility benefits.

Response IR-02: (a) The following IR response has been provided by Energy Futures Group (EFG). All proposed impact categories are directly related to demand side management (DSM). Some may be harder to quantify, but harder to quantify does...

AI summary The Energy Futures Group (EFG) outlines three impact categories related to demand side management (DSM) that are harder to quantify: health impacts from air pollutants, avoided damages from greenhouse gas emissions, and non-energy benefits for host customers. They recommend methods for quantifying these impacts, including the EPA's benefit per kWh method and guidance from the Government of Canada.

Ibid, page 4 of 38. Ibid, page 4 of 38. 1 Request IR-04: 2 3 Page 4 of 38 discusses the shortfalls of the TRC test as ignoring the symmetrical benefits 4 corresponding to a cost, arguing that such an approach "unjustly favour or disadvanta...

AI summary The document discusses the shortfalls of the Total Resource Cost (TRC) test, noting that it ignores symmetrical benefits corresponding to costs, which may unjustly favor or disadvantage certain resources. It also addresses the Benefit-Cost Analysis (BCA) test, explaining that all measures in the BCA have costs and benefits, though some benefits may not be measured or included.

- 2 system benefit that is not measured and is considered not material. 1 Request IR-05: 5 (a) Treasury Board of Canada Secretariat Guidance (TBCS): Include all relevant economic, 6 environmental, and social impacts 7 BCA: includes utility...

AI summary The document outlines the considerations for a Benefit-Cost Analysis (BCA) in relation to Demand Side Management (DSM) programs, emphasizing the inclusion of economic, environmental, and social impacts, full lifecycle analysis, and market adjustments. It notes that Nova Scotia does not participate in an organized wholesale electricity market, affecting the inclusion of certain metrics.

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.

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.

Date Filed: July 4, 2025 E1 (NSEB) IR-07 Page 9 of 9 1 Request IR-08: 2 3 With respect to the NSPM for Benefit-Cost Analysis of Distributed Energy Resource: 4 5 (a) Please identify any Canadian jurisdictions that have adopted the NSPM as t...

AI summary The document discusses a request for information on the adoption of the National Standard Practice Manual (NSPM) for Benefit-Cost Analysis (BCA) in Canadian jurisdictions, and the response by Energy Futures Group (EFG) stating no jurisdictions have adopted it. It also references feedback from the Demand Side Management Advisory Group (DSMAG) regarding the final draft EFG report, emphasizing stakeholder engagement and confidentiality.

Ibid. 1 Request IR-10: 2 3 Table 4: NSPM BCA Guiding Principles 4 5 (a) Principle 5 identifies that the analysis should be forward looking and compared against a 6 scenario without the Distributed Energy Resources (DER). Please explain why...

AI summary This document discusses the application of a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans. It addresses the principle of using a scenario without Distributed Energy Resources (DER) as the basis for comparison in BCA analysis and confirms that all utility system impacts included in the TRC test are identified in Table 6 of E1's Evidence.

- Page 29 of 38 of E1's Evidence states: "As explained in the NSPM, best practices suggest that - all impacts relating to a jurisdiction's policy goals and objectives should be included in a - jurisdiction's BCA test." - (a) Is E1 or its c...

AI summary E1's evidence references the NSPM's guidance on including all policy impacts in a BCA test. The response from EFG confirms no alternative practices exclude such impacts. The Nova Scotia Energy Board retains discretion to approve DSM portfolios not meeting the BCA threshold based on broader planning objectives and public interest, as mandated by the Public Utilities Act.

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.

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 largest...

AI summary The response to IR-13 clarifies that the impact of changes in pipeline gas consumption in the BCA test is based on gas commodity costs, which are considered to represent the majority of gas utility system impacts. The response also notes that estimating impacts related to fixed base energy charges or transportation costs is not currently feasible due to a lack of available data.

The proxies in Table 14 recommend different values depending on the measure type and the customer segment. For example, for residential customers, building shell measures are deemed most likely to result in improved comfort, durability, an...

AI summary The proxies in Table 14 vary based on measure type and customer segment, with higher values for income-qualified or disadvantaged communities. This reflects the recognition that non-energy benefits may be greater for these groups due to past limitations in energy investments. The analysis is drawn from an E1 BCA Test Application and an EFG Report.

(c) In a benefit cost test for demand side management, the social discount rate is used to convert future costs and benefits into their present-day values. This allows for a comparison of costs and benefits that occur at different points i...

AI summary This section discusses the use of a 2% real social discount rate in benefit-cost tests for demand side management, emphasizing its alignment with Nova Scotia's sustainability and prosperity goals. It notes that this rate is lower than a utility weighted average cost of capital and places greater value on future impacts. Figure G-1 from the National Standard Practice Manual illustrates how different discount rates affect DER benefits.

1 Request IR-24: 2 3 Reference: Appendix A, Mr. Hill's Evidence 4 5 With regards to Table 2 on page 11 of 18 of Mr. Hill's evidence: 6 7 (a) Please provide the names of the DSMAG organizations that provided completed 8 homework assignments...

AI summary The document requests information about the Demand Side Management Advisory Group (DSMAG), including the names of organizations that provided homework assignments and the number of DSMAG members. The response refers to EfficiencyOne's previous submission and outlines that there are thirteen members of the DSMAG, including EfficiencyOne and the Consumer Advocate.

- Halifax Regional Municipality. 1 Request IR-25: 2 3 Reference: Appendix A, Mr. Hill's Evidence 4 5 Table 3 on Page 12 of 18 of Mr. Hill's Evidence: Data Sources and Application in Developing 6 Recommended Nova Scotia Test: 7 8 (a) For th...

AI summary The response to Request IR-25 discusses assumptions made by Energy Futures Group (EFG) regarding program administration and incentive costs, as well as the removal of carbon costs for fuel under 'Other Fuels' to avoid double counting. EFG used a 40% market rate incentive and installed measure costs of $8,000 for heat pumps in 2026. Carbon costs for fuels were excluded from 'Other Fuels' and accounted for under 'Societal' impacts using the social cost of carbon.

Date Filed: July 4, 2025 E1 (NSEB) IR-25 Page 4 of 4 1 Request IR-26: 2 3 Reference: Appendix B EFG Report 4 5 Please provide the proposed BCA in excel format with cells intact and worksheets unprotected. 6 Additionally, provide references...

AI summary The document outlines requests and responses related to the Benefit-Cost Analysis (BCA) framework for evaluating Demand Side Management (DSM) plans in Nova Scotia. It includes a request for an Excel version of the BCA and references for each measure, as well as a response providing an illustrative workbook and clarification on host customer costs and benefits.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL - 1 programs, but the estimated non-energy benefit varies by measure category and customer - 2 segment as illustrated in Table 14.

AI summary The document provides responses to information requests by the Nova Scotia Energy Board (NSEB), focusing on programs and the estimated non-energy benefits, which vary by measure category and customer segment as illustrated in Table 14.

Date Filed: July 4, 2025 E1 (NSEB) IR-27 Page 2 of 2 1 Request IR-28: 2 3 Reference: Appendix B EFG Report 4 5 Page 8, under Not Material explains that some outcomes that don't produce a large enough 6 effect are excluded from the BCA. Ple...

AI summary The response to Request IR-28 identifies several impacts excluded from the BCA due to insufficient effect size, including renewable portfolio standard compliance, ancillary services for electric vehicles, and distribution voltage impacts for DER. These impacts are considered unlikely to significantly affect cost-effectiveness screening results.

- 2 Table 4: Non-Utility Impacts Consistent with Nova Scotia Policy Goals - 3 GHG reductions for demand response and distributed storage.

AI summary The text mentions Table 4, which outlines non-utility impacts aligned with Nova Scotia's policy goals, and highlights GHG reductions associated with demand response and distributed storage initiatives.

- 4 Other environmental and public health for distributed storage. 1 Request IR-29: 2 3 Reference: Appendix B EFG Report 4 5 With regards to Table 2 on page 13 of 68 of the EFG Report: 6 7 (a) Please describe any initiatives that E1 curren...

AI summary The response to Request IR-29 outlines that E1 is exploring solar-PV for its 2027-2031 DSM Plan but has no current or planned initiatives for distributed storage (DS) incentives. E1 currently supports existing batteries through its demand response program, not for new installations. This response highlights the distinction between existing and new battery initiatives.

- 3 Operator (NSIESO) to better understand this issue. 1 Request IR-32: 2 3 Reference: Appendix B EFG Report 4 5 Text Box 1: Summary of Key EFG Recommendations item 6) makes reference to an Appendix F 6 and item 7) refers to Appendix C. Pl...

AI summary The document discusses a request for information related to the Energy Futures Group (EFG) report, including the need for Excel versions of appendices and details on local non-GHG pollutants in Nova Scotia. It also references the use of benefit per kWh for local non-GHG air pollutants and their connection to EfficiencyOne (E1) programs.

- 3 Fulfillment of any directives provided by the NSEB outlined in their decision on E1's 4 BCA Application. 1 Request IR-36: 5 Table 6: Illustrative Example Present Value Benefits, Costs and Ratios, provides the present 6 value of the hea...

AI summary The text discusses the time horizon for discounting costs and benefits in a benefit-cost analysis (BCA) related to heat pump replacements. The analysis spans 15 years, from 2026 to 2040, and applies to measures within a demand-side management (DSM) plan with varying lifetimes.

- (a) The Demand Side Management Advisory Group (DSMAG) identified this impact category as one where NS Power could provide more information. It is reasonable to assume that efficiency efforts help to improve affordability of energy servic...

AI summary The Demand Side Management Advisory Group (DSMAG) suggests NS Power could provide more information on how efficiency efforts improve affordability and reduce credit, collection, and disconnection costs. While some renters may live in master metered buildings, others pay their own bills, and efficiency initiatives can help make electric service more affordable. However, the reduction in bill collections or disconnections is not quantified in the example.

M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 14 of 68. 1 Request IR-39: 2 3 Reference: Appen...

AI summary The response to Request IR-39 discusses the resilience benefits of E1's demand side management (DSM) portfolio, noting that current benefits are not material but future resilience impacts from distributed generation, storage, and demand response may exist. Energy efficiency and vehicle-to-building support are also mentioned as potential contributors to system resilience.

- (h) Please refer to part (a) of this IR response. 1 Request IR-42: 2 3 Reference: Appendix B EFG Report 4 5 In reference to Table 14, please provide empirical evidence demonstrating cause between the 6 measure type and the customer segme...

AI summary The document contains responses to requests for information regarding empirical evidence for measure types and customer segments, and an explanation of 'weatherization' in the context of energy efficiency. The Energy Futures Group (EFG) states they have not conducted empirical research to demonstrate causality and explains that weatherization involves improving building thermal performance through measures like air-sealing and insulation.

Request IR-46: Reference: Appendix B EFG Report Page 58 notes that the cost of carbon is based on December 2022 updates from Environment Canada. Given that Canada has effectively abolished the federal carbon tax system in April 2025. Does...

AI summary The response to Request IR-46 clarifies that the social cost of carbon is based on December 2022 data and is not affected by the abolition of the federal carbon tax in 2025. EfficiencyOne (E1) will continue to use updated carbon pricing values in its Benefit-Cost Analysis (BCA) framework for Demand Side Management (DSM) Plan Applications.

Request IR-01: Refer to Exhibit E-1 EfficiencyOne's Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans, (the "Application") filed May 16, 2025, E1 Evidence, page 34 of 38, T...

AI summary The document details a regulatory request (IR-01) for EfficiencyOne's (E1) application to approve a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans. E1's response refers to Energy Futures Group's (EFG) workbook and report, which provide formulas, data sources, and examples for calculating non-utility impact categories. Key references include EFG's report (Appendix B) and specific tables from E1's evidence.

ity, greenhouse gas reductions) would have better results than seen under the TRC, however this is not a comment on whether they will pass or fail. Date Filed: July 4, 2025 E1 (SBA) IR-17 Page 1 of 1 Request IR-18: Please list all the fact...

AI summary EfficiencyOne (E1) outlines factors beyond the Benefit Cost Analysis (BCA) test for determining DSM program funding, including equitable allocation, customer bill impacts, Integrated Resource Plan (IRP) requirements, historical spending, industry capacity, and emerging technology support. Responses to IR-19 are incomplete, focusing on financing arrangements and per capita funding data requests.

efits' being proposed in this application. (a) Please indicate if the programs are 100% financed by the respective utilities or if there is a different financing arrangement. 9 Response IR-19: - EfficiencyOne (E1) was unable to obtain elec...

AI summary The response from EfficiencyOne (E1) addresses the financing of efficiency programs and notes the lack of uniformity in cost-effectiveness testing across Canadian provinces and territories. E1 references the Efficiency Canada 2024 Scorecard and the Policy Tracking System for data on program funding and cost-effectiveness tests.

(a) Summary Table – Canadian Cost Effectiveness Testing Province Primary Test Additional Tests Used Non-Energy Benefits British Columbia • The "Demand-Side Measures Regulation" (BC Reg 117/2017) under the Utilities Commission Act establish...

AI summary British Columbia's 'Demand-Side Measures Regulation' (BC Reg 117/2017) outlines cost-effectiveness testing for utilities. Recent amendments in June 2023 replaced the Total Resource Cost (TRC) test with the Utility Cost Test (UCT) for evaluating demand-side management (DSM) programs, and increased income thresholds for low-income programs.

Request IR-01: Refer to EfficiencyOne's (E1) Evidence at page 28, which includes the list of distribution impacts included in the new benefit-cost analysis (BCA) test. (a) Did the Demand Side Management Advisory Group (DSMAG) consider incl...

AI summary The response to IR-01 confirms that DSMAG and EFG considered distribution voltage in the Nova Scotia Jurisdictional Benefit Cost Test but did not assign it a zero value. EFG notes that while DERs can impact voltage on distribution lines, NS Power evaluates these effects during interconnection processes. The analysis references EFG's Report and M12282.

E1 Responses to Synapse Energy Economics (Synapse) Information Requests NON-CONFIDENTIAL - 1 reflect actual EfficiencyOne (E1) program design or delivery costs, which would be included - 2 as inputs in the application of the BCA test for a...

AI summary This document outlines EfficiencyOne's (E1) responses to Synapse Energy Economics' information requests, specifically addressing program design and delivery costs and their inclusion in the Benefit Cost Analysis (BCA) test for a Demand Side Management (DSM) Plan.

1 Request IR-10: 2 3 Refer to the EFG Report on page 17, which states "The gas utility system non-commodity 4 impacts are not recommended for quantification for the new jurisdictional test. Additional 5 data on gas system costs would be re...

AI summary The document discusses the definition and applicability of non-commodity impacts on gas utility systems, particularly in relation to distributed energy resources (DERs) in Nova Scotia. It also asks about the data required to quantify these impacts and whether they will be addressed in future filings.

le, and the recommended values by impact category and market segment were shared and reviewed with the Demand Side Management Advisory Group (DSMAG) in workshops 4-6, and during follow on discussions. If over time, through evaluation or ot...

AI summary The document discusses the review of recommended values by the Demand Side Management Advisory Group (DSMAG) and the Energy Futures Group's (EFG) stance on delaying the approval of a new Nova Scotia jurisdictional test for a new E1 DSM portfolio until further studies are available.

(d) Please refer to parts (b) and (c) of this IR response. 1 Request IR-18: 2 3 Refer to Table 14 on page 45 of the EFG Report. 4 5 (a) Please identify which Measure Categories will be applied to both the residential customer 6 segment and...

AI summary The response to IR-18 explains that proxy adders for distributed storage will be applied to both residential and BNI customers, and confirms that percentage adders in the non-income qualified column apply to both segments except for BNI Customer Measures. It also asks for clarification on how certain measure categories align with E1's existing programs.

E1 Responses to Synapse Energy Economics (Synapse) Information Requests NON-CONFIDENTIAL 1 (b) No. Please refer to part (a) of this IR response. Date Filed: July 4, 2025 E1 (Synapse) IR-22 Page 2 of 2 1 Request IR-23: 2 3 Provide Table 18,...

AI summary EfficiencyOne (E1) responds to Synapse Energy Economics' information requests, indicating that certain tables from the Energy Futures Group (EFG) report are not provided and directing to a previous response for related information.

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.

1 customers qua customer interests (e.g., price, reliability, availability, etc.) which appears to be 2 consistent with the Board's earlier determinations as well.4 This does not appear to prohibit the 3 Board taking into account any numbe...

AI summary The text discusses the Board's consideration of customer interests, including price, reliability, and availability, in determining Demand Side Management (DSM) activities and programs. It references the Public Utilities Act and the Energy and Regulatory Boards Act, particularly section 6(2), which outlines factors the Board must consider when approving rates and other matters, such as supporting competition, innovation, and sustainable development.

E1 PROPOSAL 2 E1 conducted a review of possible BCA tests. What was the objective of this review? - As per E1's submission to the Board in M10473 (the E1 2022-2025 DSM Resource Plan proceeding), E1 was

AI summary E1 conducted a review of possible BCA tests as part of its submission to the Board in M10473, which relates to the E1 2022-2025 DSM Resource Plan proceeding. The objective of this review is under consideration.

- decision making tool to approve or reject the DSM Plan as is the case with the approved screening test." 8 - This includes the following: - "E1 currently provides and intends to continue to provide the results from the Program Administra...

AI summary E1 proposes using the Benefit-Cost Analysis (BCA) as the primary decision-making tool for approving DSM Plans, while providing Program Administrator Cost (PAC) results for informational purposes. E1 argues that non-binding metrics like PAC and BCA at the measure/program level will inform portfolio development, which also considers criteria such as balanced investment and equitable access. The NSUARB retains discretion to evaluate DSM components beyond the BCA.

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.

Does E1 appear to accurately portray the economic and policy framework for DSM in Nova

AI summary The document evaluates whether E1 accurately represents the economic and policy framework for Demand Side Management (DSM) in Nova Scotia, involving regulatory considerations and stakeholder inputs.

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.

- To understand these options, it must be recognized that there are broadly five assessment scales that can be considered in evaluating DSM activities. - Utility-Specific Perspective (including the utility's customers generally). This pers...

AI summary The text outlines three assessment scales for evaluating DSM activities: Utility-Specific (UCT, PAC), Participant-Specific (PCT), and Combined Utility/Participant (TRC). Each perspective considers different cost and benefit allocations, with TRC combining PAC and PCT but not accounting for non-participant customers or transactions.

- 6 As is clear from the above examples, a large range of input values in the Proposed BCA are derived from - 7 considerations that are widely delinked from NSPI customers (e.g., health impacts). The PAC by - comparison uses values that ar...

AI summary The document discusses the use of the Public Acceptability Criteria (PAC) as a primary screening tool for Demand Side Management (DSM) activities, noting that it considers utility economics and customer impacts. It addresses concerns that using PAC might exclude societal benefits or reduce cost-effectiveness, clarifying that PAC can still allow for consideration of broader factors like GHG emissions and that it has been more favorable than other tests in past DSM plans.

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.

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.

BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...

AI summary Bowman Economic Consulting Inc. provides utility regulation consulting, focusing on rate design, cost of service analysis, and demand-side management. They represent industrial energy users in regulatory proceedings before Manitoba and Newfoundland boards, including General Rate Applications and resource planning hearings.

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.

I. INTRODUCTION AND QUALIFICATIONS - Q. Please state your name, title, and employer. - A. My name is Courtney Lane. I am a Senior Principal at Synapse Energy Economics, Inc. - ("Synapse"), located at 485 Massachusetts Avenue, Cambridge, MA...

AI summary Courtney Lane, a Senior Principal at Synapse Energy Economics, Inc., describes her firm's expertise in energy regulation, including demand-side and supply-side analysis, energy efficiency, and utility filings. She highlights over 20 years of experience in energy policy, including work on performance-based regulation and grid modernization, prior to joining Synapse at National Grid.

- A. The purpose of my evidence is to review EfficiencyOne's (E1) proposal for a new - benefit-cost analysis (BCA) test for evaluating demand side management (DSM) plans, - referred to as the Nova Scotia Test.

AI summary The purpose of the evidence is to review EfficiencyOne's proposal for a new benefit-cost analysis (BCA) test for evaluating demand side management (DSM) plans, referred to as the Nova Scotia Test.

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.

Evidence of E1 in M12282, May 16, 2025, pages 19-20. 12 Evidence of E1 in M12282, May 16, 2025, Table 3, page 20, line 12. 1 Step 2: Identifying and including the full range of utility system impacts to include in 2 the BCA test. 3 Step 3:...

AI summary The text discusses the steps involved in developing a Benefit-Cost Analysis (BCA) test, including identifying utility system impacts, deciding on non-utility impacts, ensuring consistent treatment of benefits and costs, and establishing documentation. It also references a report by EFG on a jurisdictional BCA framework for Nova Scotia's DSM Plan and mentions the NSPM, a five-step process used in developing DERs.

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.

3 Q. Will each impact included in the Nova Scotia Test be applicable to every DER type? 4 A. Not necessarily. Not all impacts will be applicable to all types of DERs. For example, a 5 host customer installing solar PV will incur the host c...

AI summary The Nova Scotia Test's impacts may not apply to all DER types. For example, solar PV incurs interconnection fees, while energy efficiency may not. Some impacts are not material enough for certain DERs. The DSMAG process's EFG report discusses this in tables.

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. Does E1 propose how the impacts will be quantified? - A. Except for host customer NEBs, which I will address later in my testimony, the - quantification of impacts has not been determined. The quantification of each impact - category wi...

AI summary E1 has not yet determined how to quantify impacts, except for host customer NEBs, which will be addressed later. The quantification will occur when E1 completes the 2027–2031 DSM portfolio and plan.

Q. How does the proposed Nova Scotia Test compare to the TRC? - A. [Table 2](#page-16-0) below provides a comparison between the proposed Nova Scotia Test and the - TRC test as most recently applied in the 2023–2025 DSM Plan. Response to N...

AI summary The proposed Nova Scotia Test is compared to the TRC test in Table 2, referencing the 2023–2025 DSM Plan. The response cites the amended Public Utilities Act (SNS 2022, c 53) and references NSEB IR-01 and IR-07(c).

Q. Should the Nova Scotia Test include other fuels? A. Yes. There are several policies and energy goals that support the inclusion of other fuels, such as natural gas, fuel oil, propane, and gasoline and diesel for electric vehicles, in th...

AI summary The Nova Scotia Test should include other fuels like natural gas and propane to align with climate policies and electrification goals. The Climate Change Plan for Clean Growth and amended Public Utilities Act support this, emphasizing reduced heating oil use and strategic electrification. The Energy Reform Act and related legislation also expand regulatory considerations to include sustainable development and host customer impacts.

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.

3 Table 4. EFG Host Customer NEB Proxy Recommendations Host Customer Impact – by Measure Category and Customer Segment Non-Income Qualified/Target Market Segment Income Qualified Target Market Segment Notes Building Shell Measures (Air Sea...

AI summary Table 4 presents NEB proxy recommendations for various energy efficiency and demand response measures, categorized by host customer impact. It shows varying percentages of benefit for non-income and income qualified market segments, with notes on factors such as health, safety, economic well-being, and resilience.

EFG Report page 46. EFG Report page 48. 1 The main justification provided by EFG are the notes summarized in Table 4 above and 2 statements that custom projects, which often highlight productivity or process 3 improvements, should have hig...

AI summary The witness expresses concerns about EFG's approach to determining NEB proxy values, particularly the lack of documentation for the 20% adder used for building shell measures and BNI Custom Measures. They recommend including host customer NEBs in the Nova Scotia Test, citing literature from other jurisdictions that quantify NEBs associated with DERs.

by Lawrence Berkely National Laboratory cites 27 studies across a range of 16 NEIs, Response to NSEB IR-15(a). many of which are proposed by E1, including comfort, health and safety, and productivity.[62](#page-29-0) In addition, Skumatz E...

AI summary The text discusses the monetization of non-energy benefits (NEBs) in the context of the Nova Scotia Test, citing studies from E1 and SERA. It recommends reducing NEB proxy values for the 2027-2031 DSM Plan to align with other jurisdictions and the SERA report, while allowing other values to be approved as they are within the recommended range.

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.

L Electric Utilities Corporation for an Evidentiary Hearing on the Energy Efficiency Benchmarks Established for the Period June 1, 2013 through May 31, 2016. On behalf of PennFuture. October 19, 2012. Pennsylvania Public Utility Commission...

AI summary Courtney Lane provided testimony on behalf of PennFuture in multiple Pennsylvania regulatory proceedings, including energy efficiency benchmarks, retail electricity market investigations, solar energy permitting fees, and alternative energy conservation. Testimonies span 2008 to 2012.

BEFORE THE NOVA SCOTIA ENERGY BOARD An Application by EfficiencyOne for Approval of a New Benefit-Cost Analysis : : : Test for Evaluating Demand Side Management (DSM) Plans : Matter No. M12282 : : : DIRECT TESTIMONY OF FRANCIS WYATT GREEN...

AI summary EfficiencyOne applied for approval of a new benefit-cost analysis for evaluating Demand Side Management (DSM) plans in Matter No. M12282. Francis Wyatt of Green Energy Economics Group testified on behalf of the Consumer Advocate during the proceeding on July 17, 2025.

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.

Nova Scotia Consumer Advocate of Nova Scotia Provided review and comments on proposed DSM portfolio and DSM potential study. Member of the DSM Advisory Group (DSMAG). 2019 - Present.

AI summary The Consumer Advocate of Nova Scotia has provided review and comments on a proposed demand-side management (DSM) portfolio and DSM potential study since 2019. They are also a member of the DSM Advisory Group (DSMAG).

Texas - Cost and savings analysis on proposed Public Utility Commission rules for utilities pursuing statutory DSM savings goals, on behalf of the Sierra Club. May-June 2012. - Analysis of and report on achievable savings and costs for Aus...

AI summary Analysis of Texas Public Utility Commission rules on DSM savings goals for utilities, conducted for the Sierra Club (May-June 2012), and a report on energy efficiency resource acquisition options for Austin Energy, commissioned by the Austin City Council (April 2012). Both efforts focus on cost and achievable savings assessments.

Oklahoma - Energy efficiency potential analysis in support of comments on PUC rulemaking regarding DSM programs on behalf of the Sierra Club, December 2013 – January 2014. - Analysis, technical assistance and testimony support on potential...

AI summary The text outlines energy efficiency analyses conducted between 2011 and 2014 on behalf of the Sierra Club, focusing on substituting fossil fuel generation with energy efficiency investments in Oklahoma. These efforts supported proceedings before the Oklahoma Commerce Commission and PUC rulemaking regarding demand-side management (DSM) programs.

British Columbia, Canada Analysis and testimony support on FortisBC Gas and FortisBC Electric long-term DSM plans, submitted to the British Columbia Utilities Commission, on behalf of the BC Sustainable Energy Association and Sierra Club (...

AI summary Analysis and testimony support were provided to the British Columbia Utilities Commission (BCUC) by the BC Sustainable Energy Association and Sierra Club (BC Chapter) on various utility DSM plans (FortisBC, BC Hydro, Terasen Gas) from 2006 to 2014, assessing their adequacy, reasonableness, and energy-efficiency outcomes.

- Developed DSM measure and program cost-effectiveness screening tools to be used by Massachusetts utilities and led training sessions for using the tool. Derived measure and program screening inputs for commercial and industrial programs...

AI summary The text outlines the development of demand-side management (DSM) cost-effectiveness tools and models for utilities in Massachusetts, Vermont, New York, and New Brunswick. Activities include creating screening tools, conducting analyses for energy efficiency programs, and providing training for commercial and industrial initiatives.

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.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c. 380 as amended - and - IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Managem...

AI summary The Nova Scotia Energy Board is handling a proceeding under the Public Utilities Act, 1989, regarding EfficiencyOne's application for approval of a new benefit-cost analysis test to evaluate Demand Side Management (DSM) plans. The matter is designated as M12282.

Participation in the DSMAG In response to Eastward's IR-03 E1 stated three specific reasons why in its view Eastward's participation in the Demand Side Management Advisory Group ("DSMAG") is not suitable. Eastward wishes to address each of...

AI summary Eastward challenges E1's claim that its participation in the DSMAG is unsuitable due to potential conflicts, arguing that NSPI's existing membership (a fossil fuel provider) creates a greater conflict. Eastward also highlights its interest in strategic electrification and the BCA test for cost-effectiveness analysis.

Natural Gas to Electric Conversions In response to Eastward's IR-04(a), EFG confirmed that " if 1,000 heat pumps were all replacing gas as a primary heating fuel, the results of the illustrative example are a negative net benefit of $17.4...

AI summary EFG reported a negative net benefit of $17.4M and a 0.45 benefit-cost ratio for replacing gas with heat pumps. Despite EFG's findings, E1 did not confirm it would exclude such measures from its 2027-2031 DSM Plan. Eastward argues that including this low-benefit measure contradicts EFG's conclusion that gas DSM savings are less than electricity savings, raising concerns about validity of strategic electrification projects.

Conclusion 17 18 19 20 21 22 23 24 25 26 16 Eastward provides the following points to summarize its position on this matter: - Participation in DSMAG - Eastward's involvement in the DSMAG would pose no further conflict of interest than wha...

AI summary Eastward argues its DSMAG participation poses no greater conflict of interest than NSPI's. It highlights expertise in hybrid heating, natural gas systems, and GHG reduction via hydrogen/RNG blending. The GDA and More Access to Energy Act support hybrid heating for demand management. Eastward aligns with NSPI's IRP analysis and E1's 2027–2031 DSM Plan goals.

• Marginal Emissions o Marginal emissions would be a more appropriate and representative approach to calculating emissions for DSM initiatives.

AI summary The text argues that using marginal emissions is a more appropriate and representative method for calculating emissions related to Demand Side Management (DSM) initiatives.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c. 380 as amended - and - IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Managem...

AI summary The Nova Scotia Energy Board is considering EfficiencyOne's application for approval of a new benefit-cost analysis test to evaluate demand side management (DSM) plans under the Public Utilities Act. The proceeding is designated as Matter M12282.

Introduction - Posterity Group was retained by Eastward Energy to review EfficiencyOne's (E1) Application for - Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management - (DSM) Plans and make potential recom...

AI summary Posterity Group was retained by Eastward Energy to evaluate EfficiencyOne's application for a new Benefit-Cost Analysis (BCA) Test for Demand Side Management (DSM) Plans. Posterity Group specializes in energy use analysis, climate change, and decarbonization consulting, providing evidence-based recommendations for energy decisions.

Benefits of Hybrid Heating - Posterity Group recommends that E1 specifically recognize the benefits of hybrid heating to - reduce peak load impacts as part of the 2027-2031 DSM Plan. The benefits of hybrid heating in - Nova Scotia are reco...

AI summary Posterity Group recommends that E1 recognize the benefits of hybrid heating in reducing peak load impacts as part of the 2027-2031 DSM Plan. Nova Scotia Power and E3 acknowledge these benefits, citing reduced costs and the need to incentivize dual-fuel heat pumps to mitigate peak load impacts.

1 Table 1: Illustrative Example - Hybrid System Replacing Electric Resistance Heating Category Impact Basis for Estimation Hybrid Replacing Electric Resistance Baseboard Heaters (E1 Costs) Hybrid Replacing Electric Resistance Baseboard Hea...

AI summary Table 1 compares costs and benefits of hybrid systems replacing electric resistance heating in Nova Scotia. It includes avoided costs, environmental compliance, financial incentives, and other factors. EfficiencyOne (E1) and Nova Scotia Power (NSP) are key entities, with calculations involving energy generation, transmission, and distribution impacts. The Benefit-Cost Analysis (BCA) highlights a 4.10 ratio for E1 costs and 4.53 for E3 costs.

1 BEFORE THE NOVA SCOTIA ENERGY BOARD 2 3 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 an Application by EfficiencyOne 7 for Approval of a New Benefit-Cost Analysis Test 8 for Ev...

AI summary This document is a regulatory proceeding before the Nova Scotia Energy Board, concerning an application by EfficiencyOne for approval of a new benefit-cost analysis test for evaluating demand side management (DSM) plans. Melissa Whitten, on behalf of the Small Business Advocate, provides direct evidence in the matter.

- regulatory change and competitive energy market conditions may impact utilities and their 1 customer classes. In doing so, I also assess transmission and distribution issues for both 2 electric and natural gas service, review energy comm...

AI summary The text discusses the impact of regulatory change and competitive energy market conditions on utilities and their customer classes. It also mentions involvement in demand side management programs and representation of the SBA in regulatory proceedings.

- A. The purpose of my evidence today is to outline my concerns with the conclusion reached by EfficiencyOne (E1) that their proposed new Benefit-Cost Analysis (BCA) test is 1 appropriate to be used to evaluate the cost effectiveness of E1...

AI summary The speaker outlines concerns with EfficiencyOne's proposed new Benefit-Cost Analysis (BCA) test for evaluating the cost-effectiveness of their Demand Side Management (DSM) plans. Two main concerns are raised regarding the inclusion of non-energy benefits and the ability to quantify them.

- 2) Whether the inclusion of host customer benefits and/or host customer costs in the proposed BCA test used to determine the cost effectiveness of future DSM plans is consistent with the legislative support cited in the Application.

AI summary The document raises a question about whether the inclusion of host customer benefits and costs in the BCA test for evaluating future DSM plans aligns with the legislative support cited in the Application.

II. SBA PERSPECTIVE ON DEMAND SIDE MANAGEMENT INVESTMENTS Q. What is the perspective of small businesses regarding DSM versus other types of investments recovered through customer rates? A. Having participated in DSMAG meetings for several...

AI summary The SBA acknowledges DSM's potential to reduce peak demand and lower capital investments, aligning with Nova Scotia's Clean Energy goals. However, factors like maintenance, load growth, and regulatory requirements may offset DSM savings, as evidenced by NS Power's capital expenditure filings. This is framed as an 'all else equal' comparison.

1 The SBA represents a constituency of small businesses who receive service under three of 2 NS Power's rate classes, specifically the Small General, General and Small Industrial 3 classes. These small businesses pursue investments they ho...

AI summary The Small Business Advocate (SBA) represents small businesses affected by NS Power's rate classes and emphasizes the need for a Benefit-Cost Analysis (BCA) that minimizes DSM Plan costs while achieving energy policy goals. The SBA stresses that the BCA should not lead to increased costs for customers without corresponding benefits and highlights the importance of reliability and consistency for small businesses during Nova Scotia's energy transition.

- Relying on benefits in a benefits-cost analysis that cannot be quantified nor independently measured and verified could introduce bias into the test results. M10431(December 14, 20220 , Closing Submission of Small Business Advocate page...

AI summary The text raises concerns about the use of non-energy benefits in a benefits-cost analysis (BCA) for a Demand Side Management (DSM) Plan, arguing that unquantifiable benefits could introduce bias. It recommends that the BCA test not be approved until non-energy benefits like comfort, amenity, empowerment, and pride are independently verified.

6 Q. Why did Efficiency One (E1) submit this Application at this time? - 7 A. E1 submitted this Application in response to a directive in the 2022 Decision issued by the 8 NSUARB that directed E1 to develop an optimal cost-effectiveness te...

AI summary Efficiency One (E1) submitted an application to the NSEB to replace the total resource cost (TRC) test with a benefit-cost analysis (BCA) test for assessing future DSM plans, citing changes in Nova Scotia legislation and regulations since the NSUARB's 2022 directive.

1 expanded list of factors beyond what is mentioned in recent legislation, on the basis that 2 the BCA it serves the interests of ratepayers and provides a framework for the Board to 3 assess future DSM plans. 7 4 5 Q. How does E1 justify...

AI summary The document discusses how E1 justifies the recent regulatory changes supporting their proposed BCA test framework, noting the amendment to the Public Utilities Act, which expanded the definition of demand-side management to include strategic electrification programs aimed at reducing GHG emissions and electricity costs.

V. BCA FRAMEWORK PROXY VALUES FOR EVALUATING E1's DSM PLAN - Q. What are your objections to E1's proposed framework based on host customer non-utility impacts? - A. The Application is intended to persuade the Board and intervenors that the...

AI summary The text discusses objections to E1's proposed BCA Test framework, citing shortcomings in aligning with new legislation (ERBA, MAEA, PUA). The answer references E-1 Application, Section 6.1, and highlights gaps in compliance with the Energy Reform Act (ERA).

- A. As stated in the Application, E1 will quantify host customer non energy benefits "using - proxy adders applied as a percentage of net energy benefits or of measure costs (for - electrification) depending on the impact category, target...

AI summary The discussion focuses on concerns raised about E1's and EFG's approach to quantifying non-energy benefits in the BCA. The response highlights that some benefits, like health and safety, may be quantifiable, but others like 'amenity' and 'pride' lack clear valuation sources. Concerns were previously raised during stakeholder sessions.

M12282, Exhibit E-1, Application, Evidence, Section 2.1 Current Methodology, page 3 of 38, lines 23-24 and page 4 of 38, lines 1-2. M12282, Exhibit E-1 Application, Evidence, Section 7.5 Guiding Principles, Table 4: NSPM BCA Guiding Princi...

AI summary The review of the Application highlights deficiencies in the BCA test's reliance on proxy values for non-energy benefits, citing a lack of quantifiable data. This could introduce bias into the BCA results, potentially leading to suboptimal decisions regarding the DSM Plan's composition and cost. The reviewer recommends obtaining independent third-party evidence to verify these non-energy benefits.

Managing Consultant Melissa Whitten joined Daymark Energy Advisors in 2009 with more than 25 years of experience in energy management and energy and financial consulting. Her work experience includes six years as Director of Gas Supply, Tr...

AI summary Melissa Whitten, with over 25 years of experience in energy management and consulting, joined Daymark Energy Advisors in 2009. She has expertise in natural gas and electric utilities, including supply, transportation, storage, LNG, RNG, and renewable diesel procurement.

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.

- decision making tool to approve or reject the DSM Plan as is the case with the approved screening test."[8](#page 1-9) - This includes the following: - "E1 currently provides and intends to continue to provide the results from the Progra...

AI summary E1 proposes using the BCA test for DSM Plan approval, committing to provide PAC test results and other data for informational purposes. It suggests non-binding metrics like PAC and BCA at measure/program levels will inform portfolio development, while the NSUARB retains discretion to consider non-BCA compliant components. E1 emphasizes balanced portfolio design and equitable sector allocation.

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).

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.

- To understand these options, it must be recognized that there are broadly five assessment scales that can be considered in evaluating DSM activities. - Utility-Specific Perspective (including the utility's customers generally). This pers...

AI summary The text outlines five assessment scales for evaluating DSM programs, including Utility-Specific (UCT/PAC), Participant-Specific (PCT), Combined Utility/Participant (TRC), Societal Cost (SCT), and Jurisdiction-Specific (JST) tests. Each perspective focuses on different stakeholders' costs and benefits, suggesting alternatives to the E1 BCA.

- 6 As is clear from the above examples, a large range of input values in the Proposed BCA are derived from - 7 considerations that are widely delinked from NSPI customers (e.g., health impacts). The PAC by - comparison uses values that ar...

AI summary The document discusses the use of the Public Acceptability Criterion (PAC) as a primary screening tool for Demand Side Management (DSM) activities, emphasizing its relevance to utility economics and customer impact. It addresses concerns that using PAC might exclude societal benefits and sustainability considerations, clarifying that PAC can still accommodate these factors through additional information. The PAC is shown to be more favorable than the Total Resource Cost (TRC) in the 2023-2025 DSM plan.

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 principles requiring consistent methods with utility IRP (using WACC). Treasury Board guidance cited by E1 applies to regulatory proposals, not infrastructure investments, and emphasizes uniform discount rates for cost-benefit analysis.

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.

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. E1 must provide PCT results by measure or comparable metrics (e.g., customer payback periods) to demonstrate reasonable incentive scales for demand-side management (DSM). Incentives, paid by utility customers, must balance cost-effectiveness and avoid excessive or imprudent levels to ensure DSM participation.

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).

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 es...

AI summary The text provides recommendations for the Board regarding the use of benefit-cost analysis (BCA) tests in evaluating DSM activities. It suggests using the PAC test as the primary energy efficiency test, rejecting the E1 BCA test as a primary test, and incorporating multiple tests for balanced evaluation. It also highlights the importance of using NSPI WACC as the discount rate and ensuring accurate GHG emission calculations.

BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...

AI summary Bowman Economic Consulting Inc. provides regulatory consulting services for utility rate design, cost of service analysis, and demand side management (DSM) initiatives. They represent industrial energy users in Manitoba and Newfoundland and Labrador before regulatory bodies, including the Manitoba Public Utilities Board and Newfoundland Board of Commissioners of Public Utilities, on matters such as rate structures, surplus energy rates, and resource planning hearings.

Nova Scotia Energy Board Clerk of the Board P.O. Box 1692, Unit "M" Halifax, N.S. B3J 3S3 [email protected] Re: An application by EfficiencyOne for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM)...

AI summary Efficiency Canada submits comments on EfficiencyOne's application for a new benefit-cost analysis test for DSM plans in Nova Scotia. The submission highlights their role as national policy analysts, ongoing review of Canadian energy efficiency policies, and preliminary findings. Authors include Brendan Haley, Carol Maas, and Katharine Turner, with ties to Nova Scotia energy policy and EfficiencyOne.

Ontario Independent Electricity System Operator PAC Previously reported TRC for info purposes with non-energy benefits based on a 2021 study, which replaced a 15% adder. Enbridge Gas TRC-Plus 15% adder to account for non-energy benefits ef...

AI summary The text discusses various approaches and tests used in energy regulation, including the Program Administrator Cost test (PAC), Total Resource Cost (TRC), and Prescriptive Cost Test (PCT), with examples from different organizations and regulatory decisions.

Strategic or unstrategic electrification? A renewed cost-effectiveness test is particularly important for Nova Scotia to make sound decisions about managing electrification. The proposed test enables the inclusion of other fuel impacts alo...

AI summary Nova Scotia seeks a renewed cost-effectiveness test to evaluate electrification's strategic value by incorporating multi-fuel impacts. Efficiency Canada's report emphasizes aligning energy efficiency with net-zero goals across fuels. Efficiency Nova Scotia is positioned to balance interests as a multi-fuel administrator, mitigating electricity system costs through integrated programs like demand response and heat pumps.

Learning from the past by accounting for the future Re-balancing Nova Scotia's cost-effectiveness test has a particular salience for one of our co-authors (Brendan Haley). Acting as an intervener for the Ecology Action Centre during the 20...

AI summary The document discusses the 2007 Nova Scotia Integrated Resource Plan (IRP) process, highlighting concerns about the Total Resource Cost (TRC) test's exclusion of customer benefits in Demand Side Management (DSM) cost assessments. Ecology Action Centre (EAC) intervenor Brendan Haley criticized the unbalanced methodology, which led to an arbitrary decision by Nova Scotia Power. The text advocates for updating the Nova Scotia Test framework to adapt to evolving DSM strategies and ensure comprehensive cost-benefit analysis.

Katharine Turner Policy Research Associate, Energy Poverty Efficiency Canada August 26, 2025 Nova Scotia Energy Board 3rd Floor, Summit Place 1601 Lower Water Street Halifax, Nova Scotia B3J 3P6 ATTN: Crystal Henwood Clerk of the Board E-m...

AI summary Katharine Turner, acting on behalf of the Kwilmu'kw Maw-klusuaqn Negotiation Office and the Assembly of Nova Scotia Mi'kmaw Chiefs, supports EfficiencyOne's proposed DSM plan with a Benefit-Cost Analysis (BCA) test. They emphasize the inclusion of non-energy benefits as a positive policy development, highlighting its potential to benefit Mi'kmaq communities by reflecting broader impacts beyond utility savings.

Potential Effects on Mi'kmaq Communities The consideration of non-energy benefits means that DSM programs may be more effective in supporting Mi'kmaq communities, particularly those in remote or underserved areas. Programs that account for...

AI summary The text highlights that incorporating non-energy benefits (NEB) into Demand Side Management (DSM) programs can better support Mi'kmaq communities, especially in remote areas, by improving home comfort, affordability, and resilience. It also emphasizes potential community-level benefits like green jobs and local capacity-building through partnerships with Mi'kmaq groups.

Mi'kmaq Perspective From a Mi'kmaq perspective, this represents a positive step toward equitable program design. By valuing more than just kilowatt-hours, the new BCA test provides a framework that allows DSM programs to better serve Mi'km...

AI summary The Mi'kmaq perspective highlights the BCA test's potential to improve DSM program design for Mi'kmaq communities but criticizes the lack of explicit inclusion of Mi'kmaq circumstances in the filing. They recommend collaboration with EfficiencyOne to address unique challenges, including poverty, land dispossession, and infrastructure gaps, and emphasize the need for tailored support to advance self-determination and NetZero goals.

EfficiencyOne's Application for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans (NSEB M12282) SBA Responses to NSEB Board Staff Information Requests NON-CONFIDENTIAL

AI summary EfficiencyOne seeks approval for a new Benefit-Cost Analysis Test to evaluate Demand Side Management (DSM) plans under NSEB matter M12282. The SBA has responded to information requests from the NSEB Board Staff regarding the application.

Response to Information Requests Request IR-1: Reference: Exhibit E-13, page 5-6. Ms. Whitten indicates that "a well-crafted DSM plan can be successful in reducing or delaying an increase in peak demand that then should translate into cust...

AI summary The text discusses Ms. Whitten's testimony regarding the benefits of a well-crafted DSM plan, emphasizing customer bill savings and the need for the BCA test to avoid increased costs for customers without corresponding benefits. It raises questions about the meaning of 'benefits' and whether Ms. Whitten supports DSM costs being incurred for broader societal benefits rather than just utility and customer bill benefits.

Response to IR-1: 1 2 a) My interpretation of benefits, as referenced in my evidence cited above, are those benefits 3 that flow through utility revenue requirements, and thus to the customer. 4 (i) My interpretation of benefits would incl...

AI summary The response outlines the interpretation of benefits related to utility revenue requirements and customer impact, emphasizing reliability, cost avoidance, and quantifiable emission reductions. It rejects the use of broad societal non-utility non-energy benefits for justifying expenditures recovered through customer bills. The response also aligns with the PAC test for DSM plans and suggests further evaluation using the TRC test.

2025 M12282 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit- Cost Analysis Test for Evaluating Demand Side Management Plans RESPONSES TO IN...

AI summary EfficiencyOne seeks approval for a new benefit-cost analysis test for demand side management (DSM) plans. Bowman Economic Consulting Inc. and The Industrial Group respond to East Coast Environmental Law's inquiry about Nova Scotia's regulatory framework, noting that DSM analysis at the societal level is uncommon in Canada. The response references clause 6(2)(d) of the Energy and Regulatory Boards Act, which mandates consideration of sustainable development.

2025 M12282 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit- Cost Analysis Test for Evaluating Demand Side Management Plans RESPONSES TO IN...

AI summary The document responds to an information request (IR-1) regarding definitions of 'sustainable development' and 'sustainable prosperity,' citing the Brundtland Report and referencing legislation like Nova Scotia's Environment Act and Manitoba's Sustainable Development Act. It emphasizes the need for measurable targets under the UN Sustainable Development Goals (SDGs), including renewable energy and climate action targets.

2025 M12282 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit- Cost Analysis Test for Evaluating Demand Side Management Plans RESPONSES TO IN...

AI summary EfficiencyOne seeks approval for a new benefit-cost analysis test for evaluating demand side management plans. Synapse Energy Economics requests information on how energy efficiency measures impact utility revenues, differences in treating electrification measures, and jurisdictional practices regarding BCA tests and the PAC test.

Response: (a) Yes. (b) In Nova Scotia, it is necessary under the Public Utilities Act s. 79L(4) for the Energy Board to consider whether the Demand Side Management (including electrification activities, programs and plans) are in the best...

AI summary The Energy Board must assess whether electrification programs benefit all Nova Scotia Power customers under the Public Utilities Act. Critics argue E1's proposals focus on global societal benefits (e.g., GHG reductions) rather than specific customer impacts, violating legislative requirements. The Board must consider non-participating customers' rate impacts, which E1's portfolio-level analysis may overlook.

Response IR-1: - (a) Synapse considered the factors that the Energy Board must take into account when evaluating whether a DSM application is in the best interest of customers. See response to IR-1(b). - (b) Synapse's understanding is that...

AI summary Synapse evaluated factors for the Energy Board's DSM application, citing the Energy Reform Act and Energy and Regulatory Boards Act as expanding regulatory considerations to include sustainable development, prosperity, and GHG emission reductions.

Request IR-2:

AI summary The document outlines Request IR-2, focusing on distributed energy resources (DER), demand-side management (DSM), and benefit-cost analysis (BCA) within a Nova Scotia regulatory proceeding. Key arguments and entities are not explicitly detailed in the provided text.

Synapse Energy Economics Responses to the Industrial Group Information Requests NON-CONFIDENTIAL test to the utility function. A BCA test that only links benefits/costs to the utility function is essentially the PAC (also known as the util...

AI summary Synapse Energy Economics argues that the BCA test (PAC/UCT) does not align with Nova Scotia's policy goals, as noted in Courtney Lane's evidence. The Energy Board evaluates DSM plans at the portfolio level, not individual DER measures. Synapse contends that DER measures with cost-effective BCA results, including non-energy benefits, are 'useful' and 'used' once operational.

Professional Summary Chris specializes in analysis of markets for energy efficiency, demand response, renewable energy and strategic electrification measures, as well as the design and evaluation of programs and policies – including climat...

AI summary Chris has over 25 years of experience in energy efficiency, demand response, renewable energy, and strategic electrification. He has worked globally with regulators, utilities, and governments, testified in 75+ regulatory cases, and authored reports on clean energy policies, including a national standard practice manual for distributed energy resources.

Selected Projects - Natural Resources Defense Council (Illinois, Michigan and Ohio). Critically review energy efficiency, demand response, electrification, distribution system investment and integrated resource plans filed by IL, MI and OH...

AI summary The document outlines two key projects: Natural Resources Defense Council (NRDC) engaging in energy efficiency reviews, regulatory testimony, and legislative support in Illinois, Michigan, and Ohio from 2010 to present. E4TheFuture co-authored the National Standard Practice Manual (NSPM) for distributed energy resources (DERs) and conducted training from 2016 to present, with updates expected in 2025.

Energy Futures Group, Inc - Maryland Public Service Commission. Part of team that led a year-long stakeholder Work Group in the development of a unified benefit-cost analysis (UBCA) framework for consideration of all distributed energy res...

AI summary Energy Futures Group, Inc. leads benefit-cost analysis frameworks for DERs in Maryland and Nova Scotia, advises on gas DSM and IRP committees in Ontario, and represents environmental groups in regulatory proceedings. They focus on UBCA development, demand response, electrification, and decarbonization strategies.

Brian Purcell and Judy Simon) - National Standard Practice Manual for Assessing Cost-Effectiveness of Energy Efficiency Resources , Edition 1, Spring 2017 (with Tim Woolf, Marty Kushler, Steven Schiller and Tom Eckman) - The Next Quantum L...

AI summary The document lists publications by Brian Purcell and Judy Simon on energy efficiency, cost-effectiveness, and regulatory strategies. Key works include the National Standard Practice Manual, studies on efficiency goals, and reports on using energy efficiency to defer transmission and distribution investments. These publications address topics like demand-side management, integrated resource planning, and compliance with EPA regulations.

Experience Summary Chris brings a collaborative approach to his work, leveraging client knowledge and resources to ensure sound, actionable results. He has spent his career working to identify opportunities for energy efficiency, character...

AI summary Chris has extensive experience in energy efficiency and demand management, leading studies on energy conservation potential across six provinces and territories. He specializes in technical analysis, modelling, and project management for commercial and institutional sectors, along with conducting market and prefeasibility studies on energy solutions.

Energy Efficiency Technology and Market Research - Year 8 Building Energy Benchmarking: City of Edmonton (Nov. 2024 ongoing) - Building Controls Program Design Support: FortisBC (Jun. 2024 November 2024) - 2024 Conservation Potential Revie...

AI summary The document outlines multiple energy efficiency and market research initiatives underway in 2023-2025, involving organizations like FortisBC, Fortis Energy Inc., Natural Resources Canada, and others. Projects include building benchmarking, conservation reviews, retrofit studies, and grid integration analyses, spanning provinces and focusing on residential, commercial, and transportation sectors.

Strategic Planning for Energy Management - Review of Building Energy Mapping Applications: Natural Resources Canada Buildings and Renewables, CanmetENERGY Ottawa (Feb. 2021-Apr. 2021) - DSM Planning Support: Enbridge Gas Inc. (Jan. 2021-Ja...

AI summary The document outlines a series of energy management and efficiency initiatives led by Natural Resources Canada (NRCan), FortisBC, Enbridge Gas, and other organizations between 2007 and 2021. Projects include building energy mapping, demand forecasting, conservation potential studies, and development of energy retrofit guidelines. Key partners include Fortis Energy Inc., CEATI International, and the Independent Electricity System Operator (IESO).

Regulatory Experience - G-215-24 2024 Consolidated Resource Plan: Pacific Northern Gas - EB-2021-0002 Multi-Year Natural Gas DSM Plan: Enbridge Gas Inc. - G-371-22 2023- 2027 Demand-Side Management Expenditures Plan: Fortis BC Inc. (Electr...

AI summary The document lists regulatory filings related to energy plans in Nova Scotia, including demand-side management, long-term gas resource plans, and energy conservation initiatives by companies such as FortisBC Energy Inc., Enbridge Gas Inc., and Pacific Northern Gas. Multiple matter numbers and plan years are referenced.

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.

2. BOWMAN EVIDENCE

AI summary The document section titled '2. BOWMAN EVIDENCE' introduces evidence submitted by Bowman in a Nova Scotia regulatory proceeding. Key terms like NSP, BCA, and DSM are referenced, but no detailed arguments or claims are present in the provided text.

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.

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.

E1 Response and rate impacts.[11](#page-10-0) The balanced plan approach has been an established design principle of DSM in Nova Scotia for several years. In 2016, the Standardized Filing Framework ("Framework") was developed in consultati...

AI summary The document discusses the 'balanced plan approach' in Nova Scotia's Demand Side Management (DSM), established via the 2016 Standardized Filing Framework. Developed with E1, NSP, and DSMAG, it ensures DSM plans balance energy avoidance, costs, and accessibility. The NSUARB endorsed the framework, and E1 has adhered to it since 2016. The Industrial Group signed the Consensus Agreement supporting this approach.

3.1 2029 UPDATING PROCESS - Synapse - Ms. Lane suggests that "[t]he Board should direct E1 to launch a process for updating the NEB proxies in - 2029 for use in the next DSM Plan." [19](#page-12-4)

AI summary Ms. Lane recommends that the Board direct EfficiencyOne (E1) to initiate a process in 2029 for updating non-energy benefits (NEB) proxies, which will be used in the subsequent Demand Side Management (DSM) Plan. This suggestion is part of the 2029 updating process discussion.

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.

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).

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.

6 7. EASTWARD EVIDENCE

AI summary The document section 'EASTWARD EVIDENCE' introduces evidence submissions in a Nova Scotia regulatory proceeding. Key entities include Nova Scotia Power (NSP) and the Nova Scotia Utility and Review Board (NSUARB), with acronyms like BCA and DSM referenced for analysis and management frameworks.

E1 Response 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. This approach conside...

AI summary E1 proposes using the Difference in Carbon Emissions (DICE) method for calculating the emissions intensity of DSM savings in benefit-cost analyses, aligning with NSPM guidance and IRP assumptions. E1 clarifies that an illustrative example of gas-to-electric conversions by Eastward Energy does not reflect actual results and would require justification if included in future DSM plans.

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.

Eastward Eastward Energy argues for inclusion in the DSMAG. In particular, it notes: [...T]his Application is the first time that E1 has substantively referred to the potential for it to start strategic electrification, and has in its Appl...

AI summary Eastward Energy seeks inclusion in the DSMAG to contribute expertise on gas-to-electric conversions and strategic electrification, emphasizing their role as a natural gas supplier and hybrid peaking resource facilitator.

E1 Response E1 acknowledges that Eastward's valuable information and perspectives regarding DSM are best understood within the scope of its specific, narrowly focused interest. Given this context, E1 recognises that engaging Eastward throu...

AI summary E1 acknowledges Eastward's focus on DSM and suggests one-on-one meetings with the DSMAG to address concerns and avoid conflicts. It also notes Eastward's potential role as an intervenor in Board processes, reflecting its specific involvement.

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.

- 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 "Board") in Matter 1...

AI summary EfficiencyOne submitted an application for a new BCA test for DSM plans before the Nova Scotia Energy Board. The application was supported by a report from Energy Futures Group. Multiple intervenors and consultants submitted evidence, and EFG responded to concerns raised in their rebuttal evidence.

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.

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.

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.[6](#page-29-3)

AI summary Mr. Bowman requests the NSUARB to require E1 to demonstrate that avoided GHG emissions result from DSM programs, not external factors like a cap, emphasizing the need for clear attribution in regulatory proceedings.

EFG Response - We agree the avoided emissions estimate for E1 initiatives should be based on emission impacts caused - by the DSM activity and be net of emission impacts due to an outside factors such as Nova Scotia's Output - Based Perfor...

AI summary EFG agrees that avoided emissions from E1's DSM initiatives should account for external factors like Nova Scotia's OBPS, using social cost of carbon and the DICE method from E1's 2023-2025 plan. This approach aligns with E1's prior methodology and illustrative examples.

Bowman - Mr. Bowman opposes the use of a 2% social discount rate, in favour of the NSPI Weighted Average Cost of - Capital ("WACC") as the discount rate for calculations. He argues: E1 indicates that the social discount rate is appropriate...

AI summary Mr. Bowman opposes the use of a 2% social discount rate, advocating for Nova Scotia Power's (NSP) Weighted Average Cost of Capital (WACC) instead. He argues that E1's reference to the Treasury Board applies to federal policy, not infrastructure, and that NSPM Principle 1 requires Demand Side Management (DSM) to use the same discount rate as utility Integrated Resource Planning (IRP), which is WACC.

EFG Response The WACC is insufficient as a discount rate. While it can be used by NS Power for their own capital planning, it does not represent the regulatory perspective, which needs to consider broader societal and multigenerational imp...

AI summary EFG argues that the Weighted Average Cost of Capital (WACC) is insufficient as a discount rate for regulatory decisions, advocating instead for a 2% social discount rate aligned with Nova Scotia policy objectives and federal guidance on decarbonization. This rate accounts for societal and multigenerational impacts, including greenhouse gas emissions, as outlined in Canadian government guidance.

1 2 BEFORE THE NOVA SCOTIA ENERGY BOARD 3 4 IN THE MATTER OF The Public Utilities Act, R.S.N.S. 1989, c.380 as amended 5 and - 6 7 IN THE MATTER OF an Application by EfficiencyOne for Approval of a New Benefit Cost Analysis Test for Evalua...

AI summary The Small Business Advocate (SBA) provides an opening statement regarding EfficiencyOne's application for a new benefit-cost analysis (BCA) test for evaluating demand-side management (DSM) plans. The SBA represents Small General, General, and Small Industrial Classes of ratepayers and has been involved in discussions with EfficiencyOne and the DSMAG over the past 20 months.

- 2 Nova Scotia introduced several pieces of legislation that impact on the way in which - 3 EfficiencyOne must develop and implement its DSM plan. The details of those legislative changes - 4 are set out in detail in the Application, and...

AI summary EfficiencyOne is required to develop and implement a DSM plan under new legislation, which includes considering energy efficiency and sustainability goals. The SBA supports the inclusion of new benefits in the BCA test but has concerns about unquantified non-energy benefits. The SBA will explore these issues during the hearing.

M12282 NOVA SCOTIA ENERGY BOARD 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 OPENING STATEM...

AI summary The Consumer Advocate supports a new Benefit-Cost Analysis (BCA) Test for evaluating Demand Side Management (DSM) Plans proposed by EfficiencyOne, but recommends that the new test be vetted with stakeholders and that internalized and externalized costs of carbon be treated separately. The Board will need to address several issues, including the appropriateness of the test and the justification for proxy values used.

3 NOVA SCOTIA UTILITY AND REVIEW BOARD 4 IN THE MATTER OF: The Public Utilities Act 5 IN THE MATTER OF: An Application by EfficiencyOne for approval of a New 6 Benefit-Cost Analysis Test for Evaluating Demand Side 7 Management Plans 8

AI summary The Nova Scotia Utility and Review Board is considering an application by EfficiencyOne under the Public Utilities Act for approval of a new benefit-cost analysis test to evaluate demand side management plans. The proceeding involves regulatory review of a proposed method for assessing energy efficiency initiatives.

9 COUNSEL OPENING STATEMENT 10 ON BEHALF OF THE INDUSTRIAL GROUP 11 As required by the Public Utilities Act , NSPI is required to undertake cost-effective, reasonably - 12 available, demand side management (" DSM ") by entering into a purc...

AI summary The Industrial Group argues against the Proposed E1 BCA test, which incorporates non-energy benefits and societal impacts, and instead recommends the Program Administrator Cost (PAC) test as the primary measure of cost-effectiveness for demand side management (DSM) programs. They emphasize alignment with Canadian regulatory practices and the best interests of customers.

- Ontario, PEI, Saskatchewan, Newfoundland and Labrador, and Yukon. This PAC test also has the 1 M12282 - EfficiencyOne 26 27 28 29 30 31 The second option would be to change from the TRC test, to now add in not only customer benefits, but...

AI summary The text discusses a proposed change from the TRC test to include broader societal costs and benefits in the evaluation of demand-side management programs. This approach is not commonly used in Canada and has only been referenced in the now-abandoned Alberta Energy Efficiency Office.

- benefit of being a key part of the approach needed to fulfill the Board's role under section 79L(4) of - the Act, where it must specifically assess impacts on NS Power's customers. - The PAC test is also beneficial as it permits a BCA as...

AI summary The text argues for the adoption of the PAC test over E1's proposed BCA approach, emphasizing cost-effectiveness and the inclusion of customer incentives. It also criticizes the use of a low discount rate for assessing DSM measures and highlights the importance of including revenue benefits from electrification in the PAC test.

a DSM measure, the only way to assess impacts on NS Power's customers is to include the benefits of the added revenue that will be received, as part of the PAC test. Absent including this revenue, there is basically no benefit to the remai...

AI summary The text argues that assessing the impact of DSM measures on NS Power's customers must include the benefits of added revenue, which E1's BCA proposals ignore. It also criticizes E1's approach for not providing guidance on incentive levels and suggests that DSM should be assessed at a more granular level than just the portfolio level.

olio level. I have reviewed the E1 rebuttal on this matter, and I suspect that ultimately my position differs from E1's in nomenclature more than substance. To be clear - DSM should be assessed at the - measure, and program, and portfolio...

AI summary The text argues that Demand Side Management (DSM) should be assessed at measure, program, and portfolio levels, not just portfolio level, to ensure individual components are evaluated for cost-effectiveness. It clarifies that the PAC test may yield different metrics but does not necessarily reduce DSM investment, emphasizing that the Board could still prioritize societal benefits despite potential rate impacts.

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 an application for approval of a new benefit-cost analysis test to evaluate demand-side management (DSM) plans under the Public Utilities Act. The proceeding involves regulatory considerations for assessing the cost-effectiveness of DSM initiatives.

EfficiencyOne Opening Statement M12282 Filed with the NOVA SCOTIA ENERGY BOARD September 11, 2025 Opening Statement by Stephen MacDonald President and Chief Executive Officer, EfficiencyOne Thank you for the opportunity to present Efficien...

AI summary EfficiencyOne proposes replacing the Total Resource Cost (TRC) test with a Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) Plans, citing legislative changes and the need for a broader cost-effectiveness framework. The application seeks regulatory approval and an 'evergreen' review process for future DSM Plans.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended – and – IN THE MATTER OF: NSEB Matter No. M12282 – EfficiencyOne – New Benefits Cost Analysis Test for Evaluating Demand Side Management (DSM...

AI summary The Nova Scotia Energy Board is addressing a proceeding under the Public Utilities Act, evaluating EfficiencyOne's proposed New Benefits Cost Analysis Test for assessing Demand Side Management (DSM) plans. The matter focuses on regulatory evaluation of DSM plan cost-effectiveness under amended legislation.

ication. Similarly, Nova Scotia Power's most recent Integrated Resource Plan (IRP) modelling analysis shows potential savings of $2.3 Billion for a hybrid peak scenario compared to the IRP baseline. In response to the Board's IR-06(b) E1 s...

AI summary Nova Scotia Power's IRP analysis highlights potential $2.3B savings from hybrid peak scenarios. Eastward Energy emphasizes the need to include hybrid peaking resources in the upcoming 2027-2031 DSM Plan and urges immediate collaboration with E1 and DSMAG to analyze opportunities, given the Plan's development timeline and anticipated urban growth in Halifax.

Natural Gas to Electric Conversions In its Rebuttal Evidence E1 states that "in the actual event that conversion of gas heating systems to electric heat pumps results, under the application of the proposed BCA yielded a negative net benefi...

AI summary E1's rebuttal evidence highlights a negative net benefit of $17.4 million and a 0.45 benefit-cost ratio for gas-to-electric conversions under the proposed BCA, requiring justification for DSM Plan inclusion. Eastward Energy opposes this, arguing such conversions are not valid strategic electrification measures.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended – and – IN THE MATTER OF: NSEB Matter No. M12282 – EfficiencyOne – New Benefits Cost Analysis Test for Evaluating Demand Side Management (DSM...

AI summary The Nova Scotia Energy Board is addressing a proceeding under the Public Utilities Act, RSNS 1989, c.380, concerning EfficiencyOne's proposed New Benefits Cost Analysis Test for evaluating Demand Side Management (DSM) Plans. The matter (M12282) focuses on assessing the cost-effectiveness of DSM initiatives.

Benefits of Hybrid Heating In our filed evidence, Posterity Group recommended that "E1 specifically recognize the benefits of hybrid heating to reduce peak load impacts as part of the 2027-2031 DSM Plan." This recommendation is supported b...

AI summary Posterity Group advocates for hybrid heating's inclusion in the 2027-2031 DSM Plan to reduce peak load impacts, supported by Nova Scotia Power, E3, and E1. Examples from Québec, Ontario, and British Columbia highlight hybrid systems' value for reliability and cost-effectiveness. Analysis under the BCA framework shows hybrid heating provides substantial net benefits in Nova Scotia.

IN THE MATTER OF AN APPLICATION BY EFFICIENCYONE for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans WHEREAS Efficiency One ("E1") is the Franchise Holder in accordance with the Public Utilities Act...

AI summary Efficiency One (E1) seeks approval from the Nova Scotia Energy Board for a new Benefit-Cost Analysis Test to evaluate Demand Side Management (DSM) Plans. Intervenors have reached a consensus agreement, subject to potential amendments based on further evidence. The agreement outlines terms for executing the consensus and electronic delivery methods.

Appendix "A" - a) The proposed benefit cost analysis ("BCA") test framework, as set out in the Application, is a suitable DSM cost-effectiveness testing methodology for Nova Scotia, subject to the clarifications and alterations set out in...

AI summary The text discusses the proposed benefit cost analysis (BCA) test framework for Nova Scotia's demand-side management (DSM) programs, noting that it is suitable subject to clarifications and alterations. It also outlines that the Nova Scotia BCA would include non-energy benefits impacts as described in the E1 Application.

Table 1: Host Customer Non-Energy Impacts Asset Value O&M Costs Productivity Economic well-being Comfort Amenity Health & Safety Empowerment Pride c) The quantification of the host customer NEBs for the purposes of the 2027 – 2031 DSM Plan...

AI summary The 2027–2031 DSM Plan assumes zero quantification for non-energy benefits (NEBs) related to amenity, empowerment, and pride. Efficiency One (E1) will explore methods to quantify these values during the period between the hearing of the Application and the filing of the 2032–2036 DSM Plan.

Table 2: Host Customer Non-Energy Impact Proxy Values Host Customer Impact – by measure category and customer segment Non-Income Qualified/Target Market Segment Income Qualified Target Market Segment Building Shell Measures (air sealing, i...

AI summary Table 2 presents proxy values for non-energy benefits (NEBs) associated with various energy efficiency and demand response measures for different customer segments. The values are reduced from the Application's proposed levels, with some measures like Demand Response and Electric Vehicle (managed charging, VtG) having zero proxy values. These proxy values represent an aggregate NEB value and do not quantify individual impacts.

- f) As an integral component of the Evergreen process for systematically reviewing and refining the BCA framework and impact quantification in preparation for the 2032–2036 DSM Plan, E1 will undertake comprehensive literature reviews, jur...

AI summary E1 will conduct comprehensive research and analysis as part of the Evergreen process to refine the BCA framework and quantify non-energy impacts for the 2032–2036 DSM Plan. This includes literature reviews, jurisdictional analysis, customer surveys, and stakeholder engagement with the DSMAG.

1 Undertaking U-1: 2 3 To provide the results using the Program Administrator Costs (PAC) test method and exclude 4 the Host Customer Impacts from the proposed BCA to the analysis of the differences in the 5 screening results as presented...

AI summary The document outlines an undertaking (U-1) to apply the Program Administrator Costs (PAC) test method while excluding Host Customer Impacts from a Benefit-Cost Analysis (BCA) of a Demand Side Management (DSM) plan. Energy Futures Group (EFG) responds, referencing Dr. Hill's evidence and an illustrative example of 1,000 heat pump replacements. The matter is linked to Exhibit E-1 of application M12282.

Figure 1: Program Administrator Cost Test - Illustrative Results Under the PAC test, the benefit cost ratio for replacement of electric resistance systems is 4.95. Using the PAC test, the benefit cost ratio for replacing fuel oil and natur...

AI summary The PAC test yields a benefit-cost ratio of 4.95 for replacing electric resistance systems but 0.0 for fuel oil and natural gas systems due to absent utility benefits. The analysis references Dr. Hill's evidence and EfficiencyOne's proposed BCA methodology, excluding host customer impacts.

Figure 2: Proposed BCA With Host Customer Costs and Benefits Removed – Illustrative Results Using the E1 proposed BCA test with host customer impacts removed, the benefit cost ratio for replacement of electric resistance systems is 7.93, t...

AI summary Figure 2 presents the proposed BCA test with host customer impacts removed, showing benefit cost ratios for replacing electric resistance, fuel oil, and natural gas systems. The removal of host customer impacts increases the benefit cost ratios due to higher host customer costs compared to non-energy benefits.

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 The document outlines a regulatory proceeding under the Public Utilities Act, involving EfficiencyOne's application to approve a new benefit-cost analysis test for evaluating demand side management plans. The proceeding is before a three-member board chaired by Stephen T. McGrath, K.C., with Steven M. Murphy and Darlene Willcott as members.

HEARING ORDER EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans.

AI summary EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, seeking approval for a new benefit-cost analysis test to evaluate demand side management (DSM) plans. The application aims to establish a framework for assessing the economic viability of DSM initiatives.

NOTICE OF PUBLIC HEARING _____________________________________________________________________________ EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis Test for Evaluat...

AI summary EfficiencyOne (E1) seeks approval from the Nova Scotia Energy Board for a new Benefit-Cost Analysis Test to evaluate Demand Side Management (DSM) Plans. A public hearing is scheduled for September 22-23, 2025, at the Office of the Board in Halifax.

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.

3.5 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 avoided carbon social costs in DSM evaluations. It argues that the Energy Reform (2024) Act expands the Board's environmental mandate, aligning regulatory decisions with sustainable development and prosperity goals under multiple acts. ECEL stresses that these new responsibilities complement, not override, affordability and reliability 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 Demand-side Management Legislation and Policies in Nova Scotia

AI summary The section discusses Nova Scotia's demand-side management (DSM) legislation and policies, highlighting key entities like the Nova Scotia Utility and Review Board (NSUARB) and Nova Scotia Power (NS Power). It references acronyms such as TRC, PAC, and BCA, and mentions the role of programs like DSMAG and the National Standard Practice Manual (NSPM).

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.

n the present tense, it shall be applied to the circumstances as they arise, so that effect may be given to each enactment, and every part thereof, according to its spirit, true intent, and meaning … - (5) Every enactment shall be deemed r...

AI summary The text outlines principles for statutory interpretation under the Public Utilities Act (PUA), emphasizing consideration of legislative context, purpose, and remedial intent. The NSUARB must evaluate the cost-effectiveness of demand-side management (DSM) by analyzing the text, context, and purpose of relevant statutory provisions.

4.1.3 Board Approval of Demand-side Management [78] Before 2010, NS Power undertook its own demand-side management programs. In 2009, responding to growing concerns over the potential inherent conflict between selling electricity and takin...

AI summary Before 2010, NS Power managed its own DSM programs. In 2009, the Legislature enacted the Efficiency Nova Scotia Corporation Act, creating a not-for-profit to administer DSM programs and a fund, with NSUARB approving expenditures. The act aimed to resolve conflicts between electricity sales and demand reduction.

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.

4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...

AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The new definition of 'demand-side management' includes strategic electrification, and affordability requirements were removed from legislation previously considered in the 2020 NSUARB decision.

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.

(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 agreement outlines Nova Scotia Power Incorporated's (NSP) obligations to provide information for demand-side management (DSM) activities, emphasizing cost-effectiveness and availability. The IESO's role in integrated resource planning and avoided cost calculations is highlighted, with references to the Energy Reform Act 2024. E1 argues for broader benefit-cost analysis beyond utility impacts, while the NSUARB reinforces cost-effectiveness requirements.

nt" must reduce "electricity costs" (in addition to greenhouse gas emissions). This strongly suggests that the objective of reducing costs for customers in s. 79I(1) is referring to electricity costs. [113] The activities listed in the sub...

AI summary The analysis focuses on Section 79I(1) of the PUA, emphasizing electricity cost reduction as a key objective. Subclauses in Section 79A(b) are examined, with subclause (iv) highlighted as unique due to its focus on electrification. E1 argues that regulatory decisions must now consider nonutility impacts and sustainability factors, citing legislative mandates.

[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 E1 emphasizes the Board's duty under the Energy and Regulatory Boards Act to consider sustainable development in DSM evaluations, while East Coast Environmental Law argues this does not override other considerations like affordable energy rates. NSPI notes E1's BCA is driven by sustainability, not overall legislative requirements. E1 also disputes the Industrial Group's interpretation of legislative changes.

4.1.6.1 Findings [128] Considering the text, context and purpose of the legislation, the Board finds that the purpose of the demand-side management provisions in the Public Utilities Act is to reduce electricity costs for customers. Demand...

AI summary The NSUARB finds that demand-side management under the PUA aims to reduce electricity costs for customers, primarily through NS Power's initiatives. Strategic electrification, now included in DSM definitions, must also reduce electricity costs. The removal of 'affordability' from legislative provisions suggests cost reduction (specifically electricity costs) remains the focus.

[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.

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.

pdated SC-GHG guidance is to be used in accordance with the Treasury Board Secretariat's regulatory guidance on cost-benefit analysis, Canada's Cost-Benefit Analysis Guide for Regulatory Proposals ." [175] In response to Board IR-5(h) aski...

AI summary The document discusses E1's use of a 2% social discount rate, which is criticized by Mr. Bowman from the Industrial Group. He argues that NSPM Principles require using WACC for evaluating DSM resources, aligning with Treasury Board guidelines and IRP practices. E1 is urged to provide discount rate sensitivity analyses.

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.

4.6 Average v Marginal Generation Emissions [199] Eastward raised a concern about E1's proposal to calculate emissions impacts for the DSM portfolio by using average emissions rates in its modelling analysis. Eastward suggested marginal em...

AI summary Eastward raised a concern about E1's use of average emissions rates in its DSM portfolio modelling, suggesting that marginal emissions rates should be used instead. This is due to the expectation that incremental generation will come from less efficient sources like coal, heavy fuel oil, and natural gas. NS Power's data showed that coal-fired baseload generation was on the margin over 75% of the time from 2014 to 2024.

[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.

4.7 Eastward Energy on DSM Advisory Group [206] Eastward Energy requested the Board order that it be added as a full member of the DSMAG. Although E1 acknowledged Eastward's valuable information and perspectives regarding natural gas hybri...

AI summary Eastward Energy requested to join the DSMAG, arguing its expertise in hybrid peaking resources and legislative mandates under the Gas Distribution Act. E1 opposed, citing narrow focus and potential conflicts, suggesting one-on-one engagement. Eastward emphasized its pilot projects and data on GHG emissions, urging inclusion in the 2027-2031 DSM Plan.

4.7.1 Findings [209] Noting that E1 is currently preparing its 2027-2031 DSM Plan, Eastward asked the Board to make an early finding about its membership in the DSMAG before its input may be too late to be incorporated into the new plan. [...

AI summary The NSUARB ruled in favor of Eastward's inclusion in the DSMAG, countering E1's objection that Eastward's narrow focus conflicts with DSMAG's purpose. The Board emphasized the value of Eastward's contributions, directing E1 to include Eastward in the DSMAG ahead of the 2027-2031 DSM Plan.

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.

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 seeks approval for a new Benefit-Cost Analysis Test to evaluate Demand Side Management Plans under the Public Utilities Act. The proceeding is before a three-member regulatory board, including Chair Stephen T. McGrath and Members Steven M. Murphy and Darlene Willcott.

ORDER EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans. The Board issued its Decision on December 10, 2025....

AI summary EfficiencyOne (E1) sought approval for a new BCA test for DSM plans, but the Nova Scotia Energy Board rejected it, directing E1 to use the PAC test with NS Power's WACC. The Board mandated portfolio-level screening, strategic electrification criteria, and inclusion of Eastward in the DSM Advisory Group. E1 may use a revised BCA test for supplemental information.

James R. Gogan Direct +1 (902) 563 5920 [email protected] 292 Charlotte Street Suite 300 Sydney NS Canada B1P 1C7 Tel +1 (902) 563 1000 Fax +1 (902) 563 1113 Our File: 254441 May 16, 2025 Nova Scotia Energy Board 3rd Floor, Sum...

AI summary EfficiencyOne is seeking regulatory approval for a new Benefit Cost Analysis Test to evaluate Demand Side Management (DSM) Plans. This follows a previous request for approval of its 2023-2025 DSM Plan and a review of cost-effectiveness testing methodologies. The Board directed EfficiencyOne to work with the DSM Advisory Group to determine the optimal testing methodology for Nova Scotia.

ing methodology for Nova Scotia[:](#page-0-0) 1 1 Efficiencyone (E1) (Re), 2022 NSUARB 137 [M10473], Board Decision, paragraph 73. mcinnescooper.com The Board finds that E1's suggested approach is reasonable. The Board, therefore, directs...

AI summary The Nova Scotia Utility and Review Board directed Efficiencyone (E1) to develop an optimal DSM cost-effectiveness testing methodology with the DSMAG. Legislative changes in 2022 and 2024, including amendments to the Public Utilities Act and the Energy Reform (2024) Act, significantly impacted the BCA test.

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 This proceeding involves an application by EfficiencyOne for approval of a new benefit-cost analysis test for evaluating demand side management (DSM) plans under the Public Utilities Act.

HEARING ORDER EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans.

AI summary EfficiencyOne (E1) has submitted a request to the Nova Scotia Energy Board for approval of a new benefit-cost analysis test for evaluating Demand Side Management (DSM) Plans.

NOTICE OF PUBLIC HEARING _____________________________________________________________________________ EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis Test for Evaluat...

AI summary EfficiencyOne (E1) has applied to the Nova Scotia Energy Board for approval of a new benefit-cost analysis test for evaluating Demand Side Management (DSM) Plans. A public hearing is scheduled to consider this matter on September 22, 2025.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended - and - IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Managem...

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne for approval of a new benefit-cost analysis test to evaluate demand side management plans under the Public Utilities Act.

NOVA SCOTIA ENERGY BOARD 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 SBA Consultant Melissa Whitten Daymark Energy Advi...

AI summary The Nova Scotia Energy Board is considering EfficiencyOne's application for approval of a new benefit-cost analysis test for evaluating Demand Side Management Plans under the Public Utilities Act. Melissa Whitten from Daymark Energy is involved as an SBA Consultant.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c.380, as amended - and - IN THE MATTER OF: NSEB Matter No. M12282 – EfficiencyOne – New Benefits Cost Analysis Test for Evaluating Demand Side Management (DSM...

AI summary The Nova Scotia Energy Board is addressing a proceeding under the Public Utilities Act, involving EfficiencyOne's proposed new benefits cost analysis test for evaluating Demand Side Management (DSM) plans, referenced as NSEB Matter No. M12282.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , RSNS 1989, c 380, as amended – and – IN THE MATTER OF: An Application by EfficiencyOne for approval of a new Benefit- Cost Analysis test for evaluating demand-side manag...

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne under the Public Utilities Act for approval of a new Benefit-Cost Analysis test to evaluate demand-side management (DSM) plans. The proceeding involves regulatory review of a proposed methodological change for assessing DSM initiatives.

RE: An Application by EfficiencyOne for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans Please find enclosed the following document: - (i) Notice of Intervention on behalf of: - a) Kwilmu'kw Maw-klu...

AI summary EfficiencyOne seeks approval for a new Benefit-Cost Analysis Test to evaluate Demand Side Management Plans. The Kwilmu'kw Maw-klusuaqn Negotiation Office (KMKNO) and Assembly of Nova Scotia Mi'kmaw Chiefs (ANSMC) have filed a Notice of Intervention. Twila Gaudet, Director of Consultation at KMKNO, signed the notice.

NOVA SCOTIA ENERGY BOARD 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

AI summary The Nova Scotia Energy Board is considering matters under the Public Utilities Act and an application by EfficiencyOne for approval of a new benefit-cost analysis test to evaluate demand side management plans.

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 This proceeding involves an application by EfficiencyOne for approval of a new benefit-cost analysis test to evaluate demand side management plans under the Public Utilities Act.

HEARING ORDER EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans.

AI summary EfficiencyOne (E1) has applied to the Nova Scotia Energy Board for approval of a new benefit-cost analysis test for evaluating Demand Side Management (DSM) Plans.

NOVA SCOTIA ENERGY BOARD 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

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne under the Public Utilities Act to approve a new benefit-cost analysis test for evaluating demand side management plans. The proceeding involves regulatory review of a proposed methodology for assessing energy efficiency initiatives.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , RSNS 1989, c 380 as amended - and – IN THE MATTER OF: an application by EFFICIENCYONE for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Managem...

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne for approval of a new benefit-cost analysis test to evaluate demand side management plans under the Public Utilities Act. The proceeding involves regulatory review of proposed methodologies for assessing energy efficiency initiatives.

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

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne to approve a new benefit-cost analysis test for evaluating demand side management plans. The proceeding involves assessing the methodology proposed by EfficiencyOne for regulatory approval.

File Reference: SM002557.00003 Nancy G. Rubin, K.C. Direct Dial: 902.420.3337 [email protected] June 11, 2025 Via Electronic Mail Ms. Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Energy Board 1601 Lower Water Stree...

AI summary The Industrial Group requests an extension until June 16, 2025, to submit Information Requests (IRs) for Matter M12282, citing consultant time constraints. E1's counsel agrees to the extension.

June 11, 2025 [[email protected]](mailto:[email protected]) Nancy Rubin Stewart McKelvey Suite 600 – 1741 Lower Water Street P.O. Box 997 Halifax, NS B3J 2X2 Dear Ms. Rubin: M112282 - EfficiencyOne - New Benefit Cost Anal...

AI summary The Board grants an extension to the Industrial Group for filing Information Requests related to EfficiencyOne's new benefit cost analysis test for Demand Side Management (DSM) plans, moving the deadline to June 16, 2025. The original request was dated June 11, 2025.

NOVA SCOTIA ENERGY BOARD 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

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne under the Public Utilities Act for approval of a new benefit-cost analysis test to evaluate demand side management plans. The proceeding focuses on methodological standards for assessing energy efficiency initiatives.

Request IR-7: - Refer to lines 22-23 on page 15 of the evidence of David Hill and pages 30-33 of Appendix B. - a. What specific instructions did EFG give to the DSMAG for completing the assignment for reviewing Nova Scotia energy policies?...

AI summary Request IR-7 seeks clarification on instructions given by EFG to DSMAG for reviewing Nova Scotia energy policies and the number of DSMAG participants who submitted responses. It references specific pages in David Hill's evidence and Appendix B.

Request IR-11: - Refer to the EFG Report on page 17, which states "For host customer impacts the new - jurisdictional test should include both measure costs and non-energy benefits. EFG recommends - a proxy adder approach to estimate the c...

AI summary The EFG Report recommends using proxy adders to estimate non-energy benefits for host customers, varying by DER type and segment. It suggests this approach addresses harder-to-quantify benefits, with rationale in Section V and Appendix F. Questions ask if DSMAG or EFG discussed jurisdiction-specific studies for NEB and whether proxy adders are preferred over such studies.

Request IR-15: Refer to page 36 of the EFG Report, which states that "Program administration and financial incentives – In Nova Scotia these refer to E1 costs as the DSM program administrator." Please clarify whether Nova Scotia Power cost...

AI summary The text requests clarification on whether Nova Scotia Power's costs for developing and implementing demand response programs are included in E1 costs as defined by the EFG Report, which refers to E1 costs as the DSM program administrator.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , RSNS 1989, c 380, as amended – and – IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit- Cost Analysis Test for Evaluating Demand-side Manag...

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne under the Public Utilities Act for approval of a new benefit-cost analysis test to evaluate Demand-side Management (DSM) plans. The proceeding involves regulatory review of a proposed method for assessing DSM initiatives.

Request IR-1 Refer to Exhibit E-1, "Notice of Application and Evidence", within the "Evidence" section, dated May 16, 2025. At page 18, lines 21-25, EfficiencyOne states: "EFG's scope included assisting E1 in leading a series of DSMAG work...

AI summary EfficiencyOne states that EFG's scope included leading DSMAG workshops, researching Nova Scotia legislation, and ensuring cost-effectiveness test design aligns with the National Standard Practice Manual (NSPM). The request asks for an explanation of NSPM's application in North America and its relevance to Nova Scotia's demand-side management (DSM) cost-effectiveness testing.

M12282 NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , RSNS 1989, c 380, as amended – and – IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit- Cost Analysis Test for Evaluating Demand Sid...

AI summary The Nova Scotia Energy Board is handling a proceeding related to the Public Utilities Act, involving EfficiencyOne's application for a new benefit-cost analysis test for DSM plans. Eastward Energy Inc. has been requested to provide responses by July 4, 2025.

its proposed New Benefit-Cost Analysis Test. - Reference: Evidence Pages 18/19: E1 indicates that the identified DSMAG members participated in workshops led by E1s Consultant Energy Futures Group, Inc. - (a) Please confirm that Eastward En...

AI summary The text references a proposed New Benefit-Cost Analysis Test and asks whether Eastward Energy can join the DSMAG and whether E1 would implement a heat pump replacement program with a negative net benefit. It also references evidence about the financial impact of replacing natural gas with heat pumps.

- (c) Please explain in detail the basis for the development of each of the Impact categories Benefits and Costs figures shown under the Heat Pump replacing Natural Gas heading of Table 11. 2 Reference: Appendix 8, page 17: "EFG recommends...

AI summary The text requests an explanation of the basis for the development of benefits and costs figures under the 'Heat Pump replacing Natural Gas' category in Table 11, and references discussions on DSM portfolio impacts on the gas system and the application of a carbon price to pipeline gas.

- (b) For the "direct measure costs" impact, the "Basis for Estimation" column includes the description "Host customer measure costs net of incentives". Please explain what should be considered in the calculation of "Host customer measure...

AI summary The text requests clarification on the calculation of 'Host customer measure cost' for direct measure costs, including equipment, installation, and maintenance costs. It also asks whether the $4.8M figure represents the full or incremental cost of 1000 heat pumps and seeks discussion on how reliability impacts of measures that increase peak load are reflected in avoided costs, and if this practice is consistent with E1's current approach.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION by EfficiencyOne for Approval of New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne for approval of a new benefit under the Public Utilities Act, involving a Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans.

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-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-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-24: - With regards to Table 2 on page 11 of 18 of Mr. Hill's evidence: - a) Please provide the names of the DSMAG organizations that provided completed homework assignments to inform the find outlined in Table 2. - i. Please pro...

AI summary Request IR-24 seeks information on DSMAG members who submitted homework assignments referenced in Table 2 of Mr. Hill's evidence and the number of DSMAG working group members.

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-29: - With regards to Table 2 on page 13 of 68 of the EFG Report: - a) Please describe any initiatives that E1 currently has underway or is considering related to Distributed Generation (DG). - b) Please describe any initiatives...

AI summary Request IR-29 seeks information from E1 (EfficiencyOne) regarding current or planned initiatives in Distributed Generation, Distributed Storage, Electric Vehicles, and Building and Industry Electrification. The inquiry is part of a regulatory proceeding involving Nova Scotia Power's Benefit-Cost Analysis (BCA) of Distributed Energy Resources (DER).

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-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.

1 2 M12282 3 4 5 NOVA SCOTIA ENERGY BOARD 6 7 8 9 IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - 10 11 12 13 14 15 16 IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit-Cost Analysis Test for Evaluating Dem...

AI summary The Nova Scotia Energy Board has issued an information request (IR-1) to EfficiencyOne regarding an application for approval of a new benefit-cost analysis test for evaluating Demand Side Management (DSM) Plans. The Small Business Advocate is requesting a response by Friday, July 4, 2025.

- Refer to Exhibit E-1 EfficiencyOne's Application for Approval of a New Benefit-Cost Analysis - (BCA) Test for Evaluating Demand Side Management (DSM) Plans, (the "Application") filed - May 16, 2025, E1 Evidence, page 34 of 38, Table 10....

AI summary The document references Exhibit E-1, which includes EfficiencyOne's application for approval of a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans. It outlines requirements for providing detailed formulas, data sources, and examples for calculating benefits and costs, including avoided fuel prices and social cost of carbon values.

Request IR-8: - Refer to Exhibit E-1, the Application, page 18 of 38, line 5. Regarding the creation of green jobs and stimulating economic growth, please provide the results of econometric modeling that EOne has performed or commissioned...

AI summary Request IR-8 asks EOne to provide econometric modeling results demonstrating net jobs created and economic growth from adopting the BCA Test compared to the current methodology, including work papers with spreadsheets. The request references Exhibit E-1, page 18, line 5 of the Application.

- b) Please note for each category's impact how it was measured for Nova Scotia, as 1 2 compared with adopting something used in other provinces or in a US State. 3 Request IR-11: 4 5 Regarding Exhibit E-1, the Application, page 26 of 38,...

AI summary The text outlines various requests for information related to the impact measurement of categories in Nova Scotia, including definitions and examples for terms such as 'Host Benefits', 'Resilience', 'Public Health', 'improved comfort', and 'health'. It also requests explanations on how certain benefits are monetized for the BCA Test and how terms like 'resiliency' and 'reliability' are defined and contrasted.

Request IR-17: - Please list the programs and potential funding level that are expected to pass the new BCA Test - that would not have passed the current cost-benefit testing.

AI summary Request IR-17 seeks programs and funding levels expected to pass the new BCA Test but fail under current cost-benefit testing. Key entities include Nova Scotia Power Inc. (NSPI) and Demand Side Management (DSM), with reference to the National Standard Performance Manual (NSPM).

Request IR-18: - Please list all the factors that EOne will evaluate to decide on program funding in addition to the - proposed new BCA test.

AI summary Request IR-18 asks EOne to list factors beyond the proposed new BCA test for evaluating program funding. The context involves DSM programs and NSPI, with BCA and DSM as key acronyms.

1 2025 M12282 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 5 6 IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit Cost Analysis Test for Evaluating Demand Side Management Plans 7 8...

AI summary The Nova Scotia Energy Board has issued information requests to EfficiencyOne regarding its proposed BCA test for evaluating Demand Side Management (DSM) plans. The requests seek clarification on how the BCA test is in the best interest of ratepayers, whether it would reduce the impact on electricity rates, and if it would promote broader diversity in DSM programs and participation.

12 Request IR-2: 13 Reference: E-1, Evidence, page 2 of 38. Including non-utility impacts reflects both best practice in benefit cost analysis test design, as well as recently enacted provincial legislation. While the relative weight of sp...

AI summary The text argues that including non-utility impacts in the cost-effectiveness framework is appropriate, citing best practices and provincial legislation. The decision to include such impacts should be based on their relevance to DSM activities in Nova Scotia, guided by policy priorities and legislative objectives.

21 And References: E-1, Evidence, Section 4.2 – 2026 DSM Plan Extension, page 8; and 22 Section 11, pages 35 – 36 - 23 (a) To compare the new BCA test with the existing approved TRC test, for the 24 entirety of the 2026 DSM Plan, at the po...

AI summary The text requests a comparison between the new BCA test and the existing TRC test for the 2026 DSM Plan, asking whether non-energy impacts outweigh energy-related impacts. This relates to the evaluation of the DSM Plan Extension and involves considerations of cost-effectiveness and regulatory processes.

- 28 (b) Please compare the new BCA test against the current TRC test for the 29 three examples provided in section 11 of E1's Evidence. 1 2 (i) In the calculation provided, do the "non-energy impacts" outweigh the "energy-related" impacts...

AI summary The text requests a comparison between the new BCA test and the current TRC test using examples from E1's Evidence. It also asks whether E1's position aligns with the new legislation considering non-energy impacts and challenges the Board's previous conclusion on cost effectiveness. The text further inquires about E1's stance on having a single test for cost effectiveness and the rationale behind not proposing multiple tests.

- 1 (b) Please provide analysis undertaken on DSM cost effectiveness metrics 2 utilized by Canadian jurisdictions. - 3 (c) For each jurisdiction reviewed (including any Canadian jurisdictions not 4 included in the Application), please prov...

AI summary The text requests analysis of DSM cost-effectiveness metrics used in Canadian jurisdictions, including benefit-cost analysis tests and other DSM evaluation methods. It also asks whether electrification, solar-PV, and storage are evaluated together with energy efficiency and demand-side management plans, and whether they are assessed in a single or separate BCA tests.

James R. Gogan Direct +1 (902) 563 5920 [email protected] 292 Charlotte Street Suite 300 Sydney NS Canada B1P 1C7 Tel +1 (902) 563 1000 Fax +1 (902) 563 1113 Our File: 254441 July 4, 2025 Nova Scotia Energy Board 3 rd Floor, 16...

AI summary EfficiencyOne submits responses to multiple information requests in regulatory proceeding M12282 concerning a proposed new benefit-cost analysis test for evaluating demand side management plans. Responses are provided by various stakeholders including environmental groups, industry representatives, and the Nova Scotia Energy Board.

July 17, 2025 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M12282 – EfficiencyOne Application for a Benefit Cost Analysis Test for DSM Evaluation Dear Ms. Henwood: N...

AI summary NS Power is not submitting evidence regarding EfficiencyOne's application (M12282) for a Benefit Cost Analysis Test for DSM Evaluation. The application is being processed by the Nova Scotia Energy Board, with Jennifer Ross of NS Power informing the clerk, Crystal Henwood, of their non-participation. Tim Wood and Jamie Chipp are cc'd.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION by EfficiencyOne for Approval of New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne under the Public Utilities Act for approval of a new benefit related to a cost analysis test for evaluating Demand Side Management (DSM) plans. The proceeding focuses on assessing DSM plan effectiveness through cost analysis methodologies.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION by EfficiencyOne for Approval of New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans INFORMATION REQU...

AI summary Nova Scotia Energy Board requests information from Bowman Economic Consulting Inc. regarding a cost analysis test for Demand Side Management (DSM) plans under the Public Utilities Act. EfficiencyOne applied for approval of a new benefit. Responses are due August 21, 2025.

In Reference to PRE-FILED TESTIMONY OF PATRICK BOWMAN

AI summary The document references Patrick Bowman's pre-filed testimony in a Nova Scotia regulatory proceeding. The context involves Demand Side Management (DSM), a program aimed at managing energy demand. No further details or arguments are provided in the text.

Request IR-2: - Please provide versions of the two tables on page 14 that also include a column for the total - resource cost test, adjusted to include non-energy benefits, as contemplated in "Option 1" - described on page 12.

AI summary Request IR-2 seeks updated versions of two tables on page 14, including a column for total resource cost test adjusted to incorporate non-energy benefits as outlined in 'Option 1' on page 12. The request emphasizes modifying existing data to reflect comprehensive cost evaluations.

Request IR-3: - On pages 13-15, Mr. Bowman discussed why a focus on the program administrator test as the - primary test would be preferred to the "Proposed BCA". Please explain why a focus on the - program administrator test as the primar...

AI summary Mr. Bowman argues that prioritizing the program administrator test over the total resource cost test (adjusted for non-energy benefits in Option 1) and the Proposed BCA is preferable. The discussion centers on test methodology preferences for regulatory proceedings, emphasizing program administrator evaluation criteria.

1 2025 M12282 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit- 5 Cost Analysis Test for Evaluating Demand Side Management 6 Plans 7 8...

AI summary The document is an information request related to EfficiencyOne's application for a new benefit-cost analysis test for evaluating demand side management (DSM) plans under the Public Utilities Act. The request focuses on clarifying the term 'benefits' in the context of potential customer cost increases and bill savings.

1 (i) Does this mean energy system benefits (e.g., increased 2 reliability, avoided new investment in generation, etc.), or 3 does it include other societal benefits, such as the comfort 4 and pride of E1 program participants? - 5 (b) Does...

AI summary The text questions whether energy system benefits, such as reliability and avoided new generation investment, are included in the definition of energy system benefits, or if other societal benefits like comfort and pride of E1 program participants are also considered. It also asks if Ms. Whitten's testimony supports the idea that DSM costs are appropriately incurred and paid for by NSPI customers to support societal and participant-specific non-utility benefits.

1 2025 M12282 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit- 5 Cost Analysis Test for Evaluating Demand Side Management 6 Plans 7 8...

AI summary EfficiencyOne seeks approval for a new Benefit-Cost Analysis (BCA) test to evaluate demand-side management plans. The Industrial Group requests clarification from Synapse Energy Economics on whether Synapse considered the Public Utilities Act's requirement that DER activities serve customers' best interests and whether a broad societal-type BCA test aligns with Nova Scotia policy goals.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act , RSNS 1989, c 380, as amended – and – IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit- Cost Analysis Test for Evaluating Demand-side Manag...

AI summary The Nova Scotia Energy Board is considering EfficiencyOne's application to approve a new benefit-cost analysis test for evaluating demand-side management (DSM) plans under the Public Utilities Act, RSNS 1989, c 380, as amended.

Issued at Halifax, Nova Scotia on this 31st day of July, 2025. 1 Request IR-1 2 3 Refer to Exhibit E-14, "Pre-filed Testimony of Patrick Bowman", dated July 28, 2025 (revised), 4 at page 13, line 16: 5 6 "DSM analyzed at the societal level...

AI summary The document references a pre-filed testimony stating that analyzing Demand-side Management (DSM) at the societal level for regulator approvals is uncommon in Canada. It raises a question about whether other Canadian energy regulators have legislated responsibilities similar to those in Nova Scotia's Energy and Regulatory Boards Act, specifically regarding sustainable development and prosperity.

NOVA SCOTIA ENERGY BOARD 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

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne for approval of a new benefit-cost analysis test to evaluate demand side management plans under the Public Utilities Act. The proceeding involves regulatory review of proposed methodologies for assessing energy efficiency initiatives.

August 21, 2025 By Email Dear Parties: M112282 - EfficiencyOne - New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans – Hearing Logistics The public hearing in this matter will start on Monday, September 22, 202...

AI summary The Board announces a public hearing (M112282) for EfficiencyOne's proposed new benefit cost analysis test for Demand Side Management (DSM) plans. The hearing will occur September 22-23, 2025, in Halifax. Parties must submit witness lists, virtual attendance preferences, and objections to virtual testimony by specified deadlines.

RE: M12282 – EfficiencyOne – New Benefit Cost Analysis Test for Evaluating DSM Plans Further to your letter of August 21, 2025, the Consumer Advocate requests that its witness, Francis Wyatt of Green Energy Economics Group, appear virtuall...

AI summary The Consumer Advocate requests virtual testimony for Francis Wyatt of Green Energy Economics Group at the September 22, 2025 hearing for M12282. They also confirm no objection to other virtual witness testimony.

Our File: 254441 August 26, 2024 Nova Scotia Energy Board 3 rd Floor, 1601 Lower Water Street Halifax, Nova Scotia B3J 3S3 Dear Ms. Henwood, RE: M12282 EfficiencyOne Application for Approval of a New Benefit-Cost Analysis Test for Evaluati...

AI summary EfficiencyOne notifies the Nova Scotia Energy Board of participants for the hearing in M12282, including counsel James Gogan and Lucia Westin-Eastaugh, and witnesses Gina Thompson, Kate McDonald, David Hill, and Christopher Neme. Enclosures include resumes for expert witnesses.

East Coast Environmental Law 6061 University Ave. PO Box 15000 Halifax, NS B3H 4R2 Nova Scotia Energy Board 3rd Floor, 1601 Lower Water St. Halifax, NS B3J 3S3 August 27, 2025 Dear Ms. Henwood, Re: M12282 – EfficiencyOne: Application for A...

AI summary East Coast Environmental Law (ECEL) confirms participation in the hearing for M12282, represented by Kostantina Northrup. ECEL will not call witnesses and does not object to virtual testimony by other parties' witnesses. The proceeding involves EfficiencyOne's application for a new benefit-cost analysis test for Demand Side Management (DSM) plans.

From: [Henwood, Crystal D](mailto:[email protected]) To: [Nancy G Rubin;](mailto:[email protected]) [Alice Napoleon](mailto:[email protected]); [Allison Coffin](mailto:[email protected]); [Angela Co...

AI summary The Board has approved an extension until August 29, 2025, for the M12282-E1 proceeding related to a new BCA Test for Demand Side Management (DSM). The email is addressed to multiple stakeholders, including legal and energy consulting professionals.

mailto:[email protected])[[email protected]](mailto:[email protected])>; Patel, Girish [ ; Patrick Bowman [ ; Pronko, Steve [ ; Rebekah Powell [ ; Scott, Jessica [ ](mailto:Jessica.Scott@nova...

AI summary Matter M12282 involves EfficiencyOne proposing a new benefit-cost analysis test for evaluating demand-side management (DSM) plans. The email chain includes stakeholders such as Nova Scotia government officials, consultants, and legal representatives, indicating a regulatory review process.

T 902 424 1332 TF 1 833 809 0040

AI summary Document relates to a Nova Scotia regulatory proceeding involving Nova Scotia Power (NSP) and Demand Side Management (DSM) programs. Key entities include NSP, DSM, and King's Counsel (K.C.). No substantive content provided in the text beyond headings and an image reference.

From: [Painting-MacLean, Kimberly](mailto:[email protected]) To: [Painting-MacLean, Kimberly](mailto:[email protected]) Subject: M12282 - EfficiencyOne - New Benefit Cost Analysis Test for Evalua...

AI summary The document outlines a regulatory proceeding (M12282) regarding EfficiencyOne's proposed new Benefit Cost Analysis Test for evaluating Demand Side Management (DSM) Plans. Daniel Boyle from the Department of Energy (DOE) confirms attendance on behalf of the DOE, states no witnesses will be presented, and does not object to late filings or virtual witness participation.

August 27, 2025 VIA EMAIL Ms. Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M12282 - EfficiencyOne - New Benefit Cost Analysis Test for Evaluating De...

AI summary A letter from Melissa P. MacAdam, Small Business Advocate, confirms attendance at the hearing for M12282 - EfficiencyOne's new benefit cost analysis test for DSM plans. The Small Business Advocate requests virtual testimony for Melissa Whitten of Daymark Energy Advisors Inc., with no objection to other virtual witnesses.

August 27, 2025 Nova Scotia Energy Board 1601 Lower Water St. - 3rd Floor Halifax, NS B3J 3S3 Dear Ms. Henwood: Re: M12282 EfficiencyOne Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Pla...

AI summary The letter outlines hearing logistics for matter M12282, detailing Eastward Energy's counsel (David MacDougall, McInnes Cooper) and witnesses (John Hawkins, Jordan MacNeil, Chris Pulfer). Eastward Energy does not object to virtual testimony by opposing parties' witnesses.

From: [Nancy G Rubin](mailto:[email protected]) To: [Henwood, Crystal D](mailto:[email protected]); [Alice Napoleon;](mailto:[email protected]) [Allison Coffin](mailto:[email protected]); [Angela Co...

AI summary This email is part of a regulatory proceeding (M12282) concerning a new BCA test for DSM in Nova Scotia. It outlines communication logistics for a hearing, with multiple stakeholders including energy firms, consultants, and legal entities involved in the process.

Nancy G. Rubin, K.C.\ Partner She/Her Stewart McKelvey D: 902.420.3337 \ Law Corporation From: Henwood, Crystal D Sent: August 27, 2025 11:12 AM To: Nancy G Rubin ; Alice Napoleon ; Allison Coffin ; Angela Costello ; Angela Zeng ; Bill Mah...

AI summary An email from Crystal Henwood regarding hearing logistics for a new Benefit-Cost Analysis (BCA) test for Demand Side Management (DSM) under matter M12282. Recipients include legal counsel, energy consultants, and Nova Scotia Power (NSP) representatives involved in the proceeding.

m](mailto:[email protected])>; Theo Love <[[email protected]>](mailto:[email protected]); Twila Gaudet <[[email protected]](mailto:[email protected])> Subject: RE: M12282 - E1 - New BCA Tes...

AI summary Email correspondence related to regulatory proceeding M12282-E1 concerning a new Benefit-Cost Analysis (BCA) test for Demand Side Management (DSM) in Nova Scotia. Stakeholders include participants from Washington Mahody, Green Energy Economics, and Mikmaq Rights.

encyone.com)>; Taylor Montgomery [ ; Theo Love [ ; Twila Gaudet [ Subject: M12282 - EfficiencyOne - New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans

AI summary The document pertains to regulatory proceeding M12282, involving EfficiencyOne's proposal for a new Benefit-Cost Analysis (BCA) test to evaluate Demand Side Management (DSM) plans under Nova Scotia Power (NSP). The proceeding focuses on assessing DSM plan effectiveness through updated BCA methodologies.

September 4, 2025 By Email Dear Parties: M12282 - EfficiencyOne - New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans – Hearing Logistics The Board did not receive any requests for the Board Counsel Consultant,...

AI summary The Board is managing hearing logistics for M12282, involving EfficiencyOne's new benefit cost analysis test for Demand Side Management (DSM) plans. No in-person witnesses were requested, so virtual testimony will occur. Technical requirements include cameras at specific tables and PDF exhibits submitted to Svitlana Lykhina and Robert Norwood. Clerk Crystal Henwood oversees the process.

James R. Gogan Direct +1 (902) 563 5920 [email protected] 1969 Upper Water St., Suite 1300 McInnes Cooper Tower - Purdy's Wharf Halifax, NS B3J 3R7 TEL: 902.425.6500 FAX: 902.425.6350 Our File: 254441 September 4, 2025 Nova Sco...

AI summary EfficiencyOne submits rebuttal evidence, including Energy Futures Group's Appendix A, supporting their application (M12282) for approval of a new benefit-cost analysis test for evaluating demand side management plans before the Nova Scotia Energy Board.

James R. Gogan Direct +1 (902) 563 5920 [email protected] 1969 Upper Water St., Suite 1300 McInnes Cooper Tower - Purdy's Wharf Halifax, NS B3J 3R7 TEL: 902.425.6500 FAX: 902.425.6350 Our File: 254441 September 11, 2025 Nova Sc...

AI summary EfficiencyOne submits an Opening Statement to the Nova Scotia Energy Board (M12282) proposing a new Benefit-Cost Analysis Test for evaluating Demand Side Management Plans. Stephen MacDonald, EfficiencyOne's CEO, will present the statement at the hearing. The application seeks approval for the proposed test methodology.

James R. Gogan Direct +1 (902) 563 5920 [email protected] 1969 Upper Water St., Suite 1300 McInnes Cooper Tower - Purdy's Wharf Halifax, NS B3J 3R7 TEL: 902.425.6500 FAX: 902.425.6350 Our File: 254441 September 19, 2025 Nova Sc...

AI summary EfficiencyOne has reached consensus with the Consumer Advocate, Small Business Advocate, and East Coast Environmental Law on specific issues related to its application for a new benefit-cost analysis test for evaluating demand side management plans. A Consensus Agreement is submitted to the Nova Scotia Energy Board for consideration.

UNDERTAKING LIST MATTER NAME: EfficiencyOne - New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans

AI summary The document outlines an undertaking list for a regulatory proceeding concerning EfficiencyOne's proposal for a new benefit cost analysis test to evaluate Demand Side Management (DSM) Plans.

James R. Gogan Direct +1 (902) 563 5920 [[email protected]](mailto:[email protected]) 1969 Upper Water St., Suite 1300 McInnes Cooper Tower - Purdy's Wharf Halifax, NS B3J 3R7 TEL: 902.425.6500 FAX: 902.425.6350 Our...

AI summary Closing submissions from EfficiencyOne regarding their application for approval of a new benefit-cost analysis test for evaluating demand side management plans in matter M12282 before the Nova Scotia Energy Board. Submitted by James R. Gogan of McInnes Cooper on behalf of EfficiencyOne.

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.

3.1 OVERVIEW OF RELEVANT STATUTORY PROVISIONS E1 is the franchise holder, granted the exclusive right to supply Nova Scotia Power Incorporated (NS Power) with reasonably available, cost-effective DSM pursuant to section 79A and following o...

AI summary This section outlines the statutory provisions relevant to demand-side management (DSM) in Nova Scotia, including the 2022 amendment to the Public Utilities Act and the 2024 Energy Reform Act . These amendments expanded E1's mandate and the Nova Scotia Energy Board's responsibilities to include sustainable development, climate goals, and the transition to an independent energy system operator.

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.

4.1 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.

4.2 HOST CUSTOMER NON-ENERGY IMPACT PROXY VALUES - E1 is also seeking approval of the Board to include certain quantifications for use in the 2027-2031 DSM - Plan. In line with the PCA, E1 is seeking the host customer non-energy impact cat...

AI summary E1 is requesting approval from the Board to use proxy values for quantifying non-energy impact categories in the 2027-2031 DSM Plan, in accordance with the PCA. This approach would be subject to an ongoing review process.

Ibid, s a), page 2. Ibid , s d), Table 2, page 3. Host Customer Impact – by measure category and customer segment Non-Income Qualified/Target Market Segment Income Qualified Target Market Segment Building Shell Measures (air sealing, insul...

AI summary The text discusses reductions in proposed proxy values for various energy efficiency measures under the 2027–2031 DSM Plan, as outlined in the PCA. Notably, values for amenity, empowerment, and pride were set to zero for non-energy impacts. These changes were noted by E1.

ile it is acknowledged that federal departments rely on the Federal Social Cost of GHG Guidance to assess the costs and benefits associated with greenhouse gas emissions in Regulatory Impact Analyses, this does not preclude the use of the...

AI summary The text discusses the use of Federal Social Cost of GHG Guidance beyond Regulatory Impact Analyses, referencing hearing transcript M12282 and past NSUARB decision M06733. It emphasizes that DSM cost-effectiveness tests should use discount rates aligned with public interest, not utility shareholder preferences, and highlights the relevance of GHG emission considerations in regulatory decisions.

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.

6.3.1 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 ENERGY REFORM ACT

AI summary The section introduces the Energy Reform Act, a legislative framework under consideration in Nova Scotia's regulatory proceedings. It sets the context for discussions involving energy policy, demand-side management, and regulatory oversight, though specific arguments or details are not elaborated in the provided text.

Public Utilities Act , RSNS 1989, c 380, s 79L(5). 1 (a) support competition and innovation in the provision of energy resources 2 in the Province; 3 (b) support the development of a competitive electricity market; 4 (c) ensure the provisi...

AI summary The text references the Public Utilities Act and the More Access to Energy Act, emphasizing the Energy Board's authority over cost-effectiveness testing and DSM Plan applications. It highlights the need to consider Section 6(2) of the Energy and Regulatory Boards Act in these applications.

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.

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.

urd results. While cost-effectiveness testing for both NSPI and IESO-NS goes beyond the scope of this proceeding, it demonstrates the implications of such a broad-reaching interpretation of the PUA . Moreover, if the authority to include a...

AI summary The text warns against broad interpretations of the PUA and ERBA , arguing they could create regulatory challenges by extending authority to include social costs of carbon and competition. The Industrial Group disputes E1's claims that legislative amendments changed DSM cost-effectiveness rules, emphasizing potential unintended consequences on utility regulation in Nova Scotia.

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.

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.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c. 380 as amended IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM...

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne for approval of a new Benefit Cost Analysis Test to evaluate Demand Side Management (DSM) Plans under the Public Utilities Act. The proceeding is designated as Matter M12282.

MEMBERSHIP IN THE DSMAG Eastward has requested that E1 accept it as a member of the Demand Side Management Advisory Group ("DSMAG") but E1 has declined to do so, and instead has proposed that it engage Eastward through one-on-one meetings...

AI summary Eastward requested membership in the DSMAG, but E1 declined, citing a conflict of interest. Eastward argues no conflict exists and emphasizes alignment with E1 and DSMAG goals. The Nova Scotia Energy Board's mandate to support energy competition is highlighted as context for Eastward's desire to participate in integrated energy solutions.

And similarly. Bowman stated: "Electrification is a tricky topic when you get into traditional DSM metrics, and Mr. Neme pointed this out, but it doesn't fit easily into any of the tests, but particularly it doesn't fit in when you have le...

AI summary Bowman discusses challenges of evaluating electrification under traditional DSM metrics, noting legislative requirements that electrification must reduce customer costs to qualify as DSM. He proposes using a utility-focused PAC test with revenue considerations to assess benefits and demonstrate cost reductions. Fuel oil-to-heat-pump conversion is cited as an example with high utility costs due to capacity-driven expenses.

HYBRID PEAKING RESOURCES Subsection 2(c) of the Gas Distribution Act was added to the Act to make one of the specified purposes of the Act to facilitate the use of gas as a hybrid peaking resource to satisfy the integrated electricity syst...

AI summary Subsection 2(c) of the Gas Distribution Act enables hybrid peaking resources to meet electricity demand. Posterity Group advocates for hybrid heating in the 2027-2031 DSM Plan, supported by Nova Scotia Power, E3, and provincial examples. E1 acknowledges hybrid heating's evaluation under the BCA framework, with the IRP highlighting potential $2.3 billion savings.

And he further commented as follows: "But in that measure design, hybrid heating being an easy one to talk about, like you say, it's already got people talking about it, there's going to be others that aren't yet on our agenda that I want...

AI summary The speaker emphasizes the need for E1 to be involved early in designing hybrid heating measures, highlighting the importance of incentives for natural gas furnaces to avoid peak demand. They argue that revising measures during hearings is ineffective and that E1 should lead the design process from the start.

And Mr. Bowman concluded: "So the PAC is signalling even more savings than the TRC, and I think in some cases it may signal even more savings than the BCA. But it will also help achieve more investment, for example, in the again, something...

AI summary Mr. Bowman highlights PAC's potential for greater savings and investment compared to TRC and BCA. Ms. Thompson acknowledges hybrid heating's value under E1's BCA framework. Eastward criticizes E1 for insufficient emphasis on hybrid heating's benefits, urging the Board to mandate its inclusion in future plans. Commissioner Murphy questions E1's Rebuttal on hybrid heating timelines.

AVERAGE VERSUS MARGINAL EMISSIONS RATES On cross-examination Dr. Hill confirmed that the emissions rates that EFG used for the illustrative examples in the Application "were based on information from Nova Scotia Power and represented avera...

AI summary The document discusses the use of average versus marginal emissions rates in regulatory proceedings. EFG used average rates for illustrative examples, while E1 argued for marginal rates. Eastward emphasized that future generation sources (coal, fuel oil) justify marginal rates, contrasting with hybrid heating's high efficiency. Hybrid heating's impact on peak demand and electrification's upward pressure on peaks are noted.

NATURAL GAS TO ELECTRIC CONVERSIONS In its Rebuttal Evidence E1 stated that: "In the actual event that conversion of gas heating systems to electric heat pumps results, under that application of the proposed BCA yielded a negative benefit...

AI summary EfficiencyOne (E1) argues that converting natural gas heating systems to electric heat pumps would result in a negative benefit of $17.4 million and a benefit-cost ratio of 0.45, requiring justification under existing Board directives. Eastward challenges this, arguing such a measure should not be considered valid strategic electrification and urges the Board to provide guidance on the level of justification required for such a low benefit-cost ratio.

CONCLUSION In conclusion Eastward respectfully requests that the Board: - 1. make a preliminary and final order that Eastward be added as a full member of the DSMAG in accordance with the Board's general supervision of E1 pursuant to secti...

AI summary Eastward requests the Board to add it as a DSMAG member, prioritize hybrid heating in E1's DSM plan, use marginal emissions in modelling, guide benefit-cost thresholds, assess natural gas reliability impacts, confirm ancillary costs from Nova Scotia Power, adjust electrification values, balance legislative requirements in BCA tests, and consider EFG's sustainable development emphasis.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c 380, as amended – and – IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit Cost Analysis Test for Evaluating Demand-side Managem...

AI summary East Coast Environmental Law submits a closing statement supporting EfficiencyOne's proposed new Benefit-Cost Analysis test for evaluating DSM plans, emphasizing the inclusion of avoided social costs of carbon and the Board's responsibility under the Energy and Regulatory Boards Act to consider non-energy impacts in cost-effectiveness testing.

The Board's Jurisdiction to Take Non-energy Impacts into Account in Cost-effectiveness Testing for Demand-side Management Plans The second issue concerns the Board's jurisdiction to take non-energy impacts into account in cost-effectivenes...

AI summary The document addresses whether the Nova Scotia Utility and Review Board (UARB) can consider non-energy impacts in cost-effectiveness testing for Demand-side Management (DSM) plans. It references the Energy Reform (2024) Act and the EfficiencyOne (Re) case, where the UARB previously ruled against considering non-energy impacts. ECEL supports EfficiencyOne's argument that the new Act expanded the Board's jurisdiction to include non-energy benefits in DSM cost-effectiveness analyses.

October 14, 2025 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: 2025 M12282 Demand Side Management (DSM) Benefit Cost Analysis Test (BCAT) Closing Submission Dear Ms....

AI summary Nova Scotia Power Incorporated (NS Power) submits closing arguments in the 2025 M12282 Demand Side Management (DSM) Benefit Cost Analysis Test (BCAT) proceeding before the Nova Scotia Energy Board. The submission addresses DSM program evaluations and cost-benefit analyses.

INTRODUCTION NS Power acknowledges the significant effort and collaboration that took place through the Demand Side Management Advisory Group (DSMAG) process to arrive at the proposal now before the Nova Scotia Energy Board (NSEB, Board) f...

AI summary NS Power submits a proposal for a new Benefit Cost Analysis (BCA) Test, emphasizing cost-effective demand-side management (DSM) under section 79I of the Public Utilities Act. The submission outlines NS Power's and EfficiencyOne's (E1) positions, legal review, and recommendations to the Nova Scotia Energy Board (NSEB). The focus is on affordability and cost reduction obligations.

EFFICIENCYONE'S PROPOSAL E1's DSM Plan is currently subject to the application of the Total Resource Cost ("TRC") Test, as the M03669 Board approved cost effectiveness test applied at the program level. The TRC Test compares benefits and c...

AI summary EfficiencyOne's DSM Plan uses the modified TRC Test post-M10473, which considers host costs but not benefits, creating imbalance. E1 proposes a jurisdiction-specific BCA including non-energy benefits, aligning with societal impact perspectives. Legislative changes reflecting Nova Scotia's policy goals are highlighted as critical for the new BCA framework.

LEGISLATIVE AND REGULATORY FRAMEWORK AND ANALYSIS Though there have been legislative changes in Nova Scotia, the Board's decision in M08888 issued April 15, 2020 holds. There, the Board found that it did not have the jurisdiction to consid...

AI summary The Nova Scotia Energy Board's 2020 decision (M08888) reaffirms its jurisdictional limits, emphasizing cost-effectiveness, safe service, and reasonable rates over non-energy benefits. Sections 79H and 79I of the PUA mandate NSP to implement cost-effective DSM programs, with cost-effectiveness defined to include E1's efficiency activities. Current legislation does not empower the Board to consider non-energy impacts except for greenhouse gas reduction through electrification.

The Energy and Regulatory Boards Act Bill 404 also created the Energy and Regulatory Boards Act which was proclaimed on April 5, 2025. Section 6(2) states: In approving or fixing rates, tolls, charges, tariffs, capital applications and all...

AI summary Bill 404 established the Energy and Regulatory Boards Act (ERBA), requiring the Nova Scotia Energy Board (NSEB) to consider factors like competition, sustainability, and alignment with other legislation when approving energy-related matters. E1 argues that recent amendments (including MAEA and ERBA) expanded the Board's considerations, particularly for demand-side management (DSM), but failed to provide statutory analysis or contextualize proposed benefits.

The More Access to Energy Act Bill 404 created the More Access to Energy Act (MAEA) which carriesthe following purpose: The purpose of this Act is to - (a) increase competition and innovation in the Province's energy sector; - (b) ensure t...

AI summary The MAEA aims to boost energy sector competition, ensure reliable energy supply, and integrate sustainability goals from the EGCCRA and EA. E1 emphasizes these goals, but the text notes ambiguity in applying sustainable development principles to the JST and distinguishes policy language from prescriptive BCA requirements.

Climate change response and greenhouse gas emissions goals (b) to support, strengthen, and set targets for energy efficiency programming while prioritizing equitable access and benefits for low income and marginalized Nova Scotians. While...

AI summary The text emphasizes supporting energy efficiency programs with equitable access for low-income and marginalized communities while reaffirming the statutory requirement for Demand Side Management (DSM) programming to remain cost-effective. It clarifies that these goals do not override existing cost-effectiveness mandates.

NS POWER'S POSITION This initiative overall has made great progress throughout the DSMAG; however, more work is required to eliminate the potential for unintended consequences and to ensure alignment with the current and existing legislati...

AI summary NS Power emphasizes the need for careful evaluation of DSM programs to avoid increasing customer costs and align with legislative frameworks. It recommends modifying the TRC test to include greenhouse gas emissions reductions, electricity cost savings, and displaced fuel impacts. The NSEB's regulatory regime and strategic electrification under the PUA are highlighted as key considerations.

Mechanics of the BCA

AI summary The section outlines the mechanics of the Benefit Cost Analysis (BCA) process, likely detailing its application in regulatory proceedings. Key entities involved include Nova Scotia Power, the Nova Scotia Energy Board, and related legislation such as the Public Utilities Act and Energy Reform (2024) Act.

Avoided Cost Series NS Power submits that the current avoided cost series is primarily intended to inform analysis of traditional energy efficiency measures that reduce both energy and peak demand, or contribute to demand response. In the...

AI summary NS Power proposes updating the avoided cost series for DSM and Demand Response to reflect new programming, including strategic electrification. They emphasize the need for tailored cost curves and collaboration with E1 and DSMAG. The BCA test focuses on demand-side resources, not supply-side.

CONCLUSION DSM remains a vital tool for managing system costs, advancing electrification, and supporting the energy transition. However, its primary purpose must remain clear: to deliver measurable, economically sound benefits to customers...

AI summary DSM is essential for managing costs and energy transition but must prioritize customer benefits without unnecessary burdens. NS Power's recommendations are seen as balanced and transparent, allowing the Board to incorporate evolving policy considerations while maintaining cost-effectiveness and affordability.

APPENDIX A Category PAC (Program Administrator Cost) Current TRC (Total Resource Cost) NS Power Recommendatio ns E1's Proposed BCA (Nova Scotia Jurisdictional Test) Perspective Utility-centric Utility (costs and benefits) + Participant 9co...

AI summary The table compares different approaches to calculating Program Administrator Cost (PAC) and Total Resource Cost (TRC) under various perspectives and benefit-cost analysis (BCA) frameworks. It highlights differences in included benefits, costs, and non-energy benefits (NEBs) across utility-centric, participant-focused, and societal perspectives.

1 M12282 2 3 NOVA SCOTIA ENERGY BOARD 4 5 6 IN THE MATTER OF: The Public Utilities Act 7 8 and 9 10 IN THE MATTER OF: An Application by EfficiencyOne for approval of a new 11 Benefit-Cost Analysis Test for Evaluating Demand-Side 12 Managem...

AI summary This document outlines an application by EfficiencyOne for approval of a new Benefit-Cost Analysis Test for Evaluating Demand-Side Management Plans under the Public Utilities Act. The Consumer Advocate is submitting closing remarks on the matter.

16 17 Please accept these as the closing submissions on behalf of the Consumer Advocate regarding the 18 Application filed by EfficiencyOne ("E1") for approval of a New Benefit-Cost Analysis ("BCA") 19 Test for Evaluating Demand Side Manag...

AI summary The Consumer Advocate submits closing remarks on behalf of EfficiencyOne's application for approval of a new benefit-cost analysis test for evaluating demand side management plans.

6 a. The Legislative Context for this Application 8 This Application occurs in the context of recent legislative amendments, which have impacted 9 energy regulation in Nova Scotia. 11 Specifically, the Energy Reform Act (2024) , c 2, Bill...

AI summary The legislative context includes the Energy Reform Act (2024) and related statutes, establishing the Energy Board and emphasizing sustainable development, competition, and energy efficiency. Amendments to the PUA require evaluating demand-side management at the portfolio level, including strategic electrification.

ge-2-5)ages 10 and 11 of Dr. Hill's evidence, Appendix A to Exhibit E-1, lines 7-10; see also page 12, lines 4-6. 4 [P](#page-2-7)age 14 of Dr. Hill's evidence, Appendix A to Exhibit E-1. - 4 - 5 E1's rebuttal evidence critiques the eviden...

AI summary EfficiencyOne (E1) submits rebuttal evidence addressing critiques from multiple parties, including Patrick Bowman (Industrial Group), Courtney Lane (Synapse), Melissa Whitten (Daymark Energy Advisors), and others. E1 defends its BCA test, critiques the PAC Test, and responds to arguments about proxy values, non-energy benefits, demand-side management, and discount rate usage. The rebuttal also engages with evidence from the Consumer Advocate, Small Business Advocate, and Eastward Energy.

13 vi. Eastward Energy 14 15 Eastward Energy filed evidence by Posterity Group Consulting Inc. In this evidence, Posterity 16 Group requested "that E1 specifically recognize the benefits of hybrid heating to reduce peak load impacts as par...

AI summary Eastward Energy submitted evidence by Posterity Group Consulting Inc., urging EfficiencyOne (E1) to include hybrid heating benefits in the 2027-2031 DSM Plan. Posterity Group provided examples showing net benefits under the BCA test. Christopher Pulfer of Posterity Group testified as an expert witness.

1 2 3 BEFORE THE NOVA SCOTIA ENERGY BOARD 4 IN THE MATTER OF AN APPLICATION BY EFFICIENCYONE for approval of a New 5 Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans - Ml2282 6 CLOSING ARGUMENT OF THE SMALL BUSINESS A...

AI summary EfficiencyOne seeks approval for a new Benefit-Cost Analysis (BCA) Test to evaluate Demand Side Management (DSM) plans, following stakeholder consultations. The Small Business Advocate (SBA) emphasizes cost-effectiveness and inclusion of low-income programs despite potential cost inefficiencies. The SBA supports proposed Utility System impacts but highlights ongoing discussions about Non-Utility System impacts.

mpacts, 24 which are grouped together as Non-Utility System impacts3. These impacts generated a lot of 25 discussion, as they are, in many cases, new additions from the previous tests used by EfficiencyOne 26 and are not consistently used...

AI summary The document discusses Non-Utility System impacts from EfficiencyOne's new Benefit-Cost Analysis (BCA) test for Demand Side Management (DSM) plans, which have sparked debate due to their novelty compared to previous tests. Melissa Whitten of Daymark Energy Advisors raised concerns about proxy values for non-energy benefits and challenges in measuring/verifying them.

- 1 energy benefits. She identified the non-energy benefits of amenity, empowerment and pride as - 2 being of the most concern and recommended more work be done to quantify them, with the results - 3 of that work being presented to the mem...

AI summary Ms. Whitten recommends quantifying non-energy benefits (amenity, empowerment, pride) or setting their value to Nil until approved by the Board. She prefers the PAC test over quantifying these benefits. The SBA expresses concerns about unquantified non-energy benefits impacting ratepayers. The discussion involves Benefit-Cost Analysis (BCA) and Demand Side Management (DSM).

nquantified and difficult to quantify - 21 non-energy benefits with EfficiencyOne on several occasions. The SBA's concern stems from the - 22 fact that ratepayers are required to pay for a DSM plan on the basis that there will be benefits...

AI summary The Service Board of Appeals (SBA) raises concerns about quantifying non-energy benefits in Demand Side Management (DSM) plans, emphasizing the need for benefits to be broadly beneficial to ratepayers, not just participants. Melissa Whitten's evidence and exhibits highlight challenges in ensuring fair cost allocation and proper Benefit-Cost Analysis (BCA) framework application.

RIR 1 (a) and 1(a)(i}, page 2 of 2, at lines 4-9. 11 M12282, Exhibit E-16, SBA (IG) RIR 2(a}, page 1 of 2. 12 M12282, Exhibit E-17, SBA {IG) RIR 2(b), page 2 of 2, at lines 4-9. - 1 In the interest of obtaining access to the measures and b...

AI summary The Small Business Advocate (SBA) agrees to the Consensus Agreement, which reduces proxy values for certain measures and commits EfficiencyOne to an Evergreen process for reviewing the BCA framework. The SBA recommends adopting the amended BCA Test for 2027-2031, emphasizing progress on DSM while addressing concerns about quantifying non-monetary benefits like empowerment.

3 NOVA SCOTIA ENERGY BOARD 4 5 IN THE MATTER OF: The Public Utilities Act 6 7 and 8 9 IN THE MATTER OF: An Application by EfficiencyOne for approval of a new 10 Benefit-Cost Analysis Test for Evaluating Demand-Side 11 Management Plans 12

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne under the Public Utilities Act to approve a new Benefit-Cost Analysis Test for evaluating Demand-Side Management Plans. The proceeding involves assessing the methodology for evaluating energy efficiency initiatives.

13 Reply Submissions of the Consumer Advocate 14 15 Please accept these as the reply submissions on behalf of the Consumer Advocate regarding the 16 Application filed by EfficiencyOne ("E1") for approval of a New Benefit-Cost Analysis ("BC...

AI summary The Consumer Advocate's reply submissions challenge EfficiencyOne's proposed BCA test for Demand Side Management Plans, emphasizing legislative integration between the Energy and Regulatory Boards Act, More Access to Energy Act, and Environmental Goals and Climate Change Reduction Act. The Industrial Group disputes EfficiencyOne's interpretation of these statutes.

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 The Industrial Group submits reply comments opposing Nova Scotia Power (NSPI) and EfficiencyOne (E1)'s closing brief in M12282, maintaining its statutory interpretation position regarding a new benefit-cost analysis test for evaluating demand-side management (DSM) plans.

Response to NSPI The Industrial Group is supportive of the analytical approach to legislative interpretation of the Public Utilities Act (" PUA ") outlined by NSPI. The new policy goals contained in the Energy and Regulatory Boards Act and...

AI summary The Industrial Group supports NSPI's legislative interpretation of the Public Utilities Act (PUA) and agrees that new policy goals from the Energy and Regulatory Boards Act and More Access to Energy Act should not override demand-side management (DSM) program requirements. Both parties align on the need to prioritize cost-effective programs over sustainability goals.

i. PAC vs TRC Where the Industrial Group diverges from NSPI is with respect to the proposed primary test to be adopted for DSM going forward. In contrast to NSPI, the Industrial Group does not view the Total Resource Cost (" TRC ") test as...

AI summary The Industrial Group opposes NSPI's proposed use of the Total Resource Cost (TRC) test for demand-side management (DSM), arguing it inaccurately measures costs and benefits for utilities and customers. They advocate for the PAC test, which accounts for customer incentives and aligns with Nova Scotia's high electricity prices, aiming to lower ratepayer costs. The Public Utilities Act (section 79L(4)) mandates consideration of customer interests.

Response to E1 Unsurprisingly, E1 takes a vastly different approach to statutory interpretation which has largely been addressed in the Industrial Group's initial submissions. Without repeating those, the Industrial Group will address some...

AI summary The Industrial Group addresses E1's differing statutory interpretation approach, focusing on critiques of Mr. Bowman's endorsement of PAC and DSM application review methods. References include prior submissions, diagrams, and cross-examination testimony confirming GHG inclusion in social cost of carbon calculations.

i. PAC is Not "Too Narrow" and Suite of Tests is not "Cumbersome" and "Complex" E1 claims the PAC test "is too narrow to serve as the main assessment for portfolio-level decisionmaking["](#page-2-0) 5 . The Industrial Group emphasizes that...

AI summary E1 argues the PAC test is too narrow and the proposed tests are complex, while the Industrial Group counters that PAC is foundational and targeted. E1 focuses on environmental goals, whereas PUA mandates cost reduction for NSPI customers. The combination of tests proposed by Mr. Bowman is deemed balanced and not overly burdensome.

ii. Misstatement of Approach to Evaluation of Strategic Electrification While misstating the evidence of Mr. Bowman, E1 again pleads "complexity" to argue against the use of different tests to be applied to different resources. Its submiss...

AI summary E1 argues against using different cost-effectiveness tests for DSM resources, claiming complexity and misrepresenting Mr. Bowman's evidence. The Industrial Group supports Mr. Bowman's proposal to use the PAC test for all DSM, with adjustments for strategic electrification. Critics argue E1's uniform test fails to address electrification's unique benefits and costs, while the Proposed BCA overlooks utility revenue impacts and inadequate evaluation criteria.

iii. The Proposed BCA Could Be Used as a Supplementary Test but is Not Supported in its Current Form and is Not Required E1's submissions imply endorsement of the Proposed BCA by Mr. Bowman: In fact, the IG's expert, Mr. Bowman, indicates...

AI summary E1 argues the Proposed BCA is necessary for addressing societal concerns, but Mr. Bowman clarifies it is not required and should only be a supplementary tool. The Industrial Group supports using the PAC as the primary cost-effectiveness test, with BCA serving as a secondary, non-essential complement. Broader societal costs are deemed unnecessary for lowering electricity costs.

Conclusion The Industrial Group maintains its position that the legislation, as currently drafted, does not allow for a broad societal test to be used for primary cost-effectiveness testing of DSM, and that the PAC should be used as the pr...

AI summary The Industrial Group argues that current legislation does not permit a broad societal test for DSM cost-effectiveness, advocating for PAC as the primary test. Mr. Bowman's proposed tests are deemed manageable for E1 and should guide the DSM Plan application. The submission is signed by Nancy G. Rubin and Brianne Rudderham, with a carbon copy to participants.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act, RSNS 1989, c. 380 as amended IN THE MATTER OF: An Application by EfficiencyOne for Approval of a New Benefit Cost Analysis Test for Evaluating Demand Side Management (DSM...

AI summary The Nova Scotia Energy Board is considering EfficiencyOne's application for a new Benefit Cost Analysis Test for Demand Side Management (DSM) plans under the Public Utilities Act. Eastward Energy Inc. submitted a rebuttal argument opposing the approval of this test as part of Matter M12282.

DEMAND SIDE MANAGENMENT ADVISORY GROUP ("DSMAG") It remains clear from the Closing Submissions of E1 that the DSMAG is intended to continue as the principle vehicle by which E1 will gain input on its DSM plans and programs, and that E1's p...

AI summary Eastward seeks DSMAG membership to contribute to E1's 2027-2031 DSM plan. E1 opposes this without providing reasons, while NSPI rejects E1's BCA test, proposing an alternative. Other DSMAG members, including the IG, support Eastward's inclusion. Eastward argues there is no valid reason to exclude it from DSMAG.

SUSTAINABLE DEVELOPMENT AND SUSTAINABLE PROSPERITY 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 "appropriate consider...

AI summary E1 emphasizes the Board's duty under the Energy and Regulatory Boards Act to consider sustainable development and prosperity in DSM plans. E1's BCA proposal is framed as aligning with these goals, though NSPI and East Coast Environmental Law caution against overriding other legislative priorities like affordable energy rates. The Board's decision may set a precedent for future cases, with Mr. Bowman's approach avoiding global carbon cost methodologies.

AVOIDED COSTS NSPI states that it intends to "update the avoided cost series of DSM and Demand Response ("DR") to reflect an updated planning scenario"[21](#page-6-0) , and that in its view "some types of DSM programming may require altern...

AI summary NSPI plans to update avoided cost data for DSM and DR programs, collaborating with E1 and DSMAG. Eastward offers expertise on hybrid heating technologies and emphasizes the need for DSMAG participation to ensure accurate avoided cost valuations.

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.

mework.[9](#page-4-3) Therefore, E1 submits the Proposed BCA test is the appropriate tool for the Board to use to give "appropriate consideration" to matters of sustainable development and prosperity. For example, the Board has accepted th...

AI summary EfficiencyOne (E1) argues the Proposed BCA test is appropriate for the Board to consider sustainable development and prosperity. E1 references past matters (M07543, M10437) and disputes the Industrial Group's (IG) claim that the Board must set aside sustainability considerations under the Public Utilities Act (PUA).

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.

3.1 MEMBERSHIP IN THE DSMAG - 27 In Eastward Energy's submission, the question of membership in the Demand Side Management Advisory - 28 Group (DSMAG) is raised. Eastward Energy asserts that it should be accepted as a full member, arguing...

AI summary Eastward Energy seeks DSMAG membership, arguing it would enhance collaborative energy planning. E1 opposes this, stating DSMAG members broadly represent electricity ratepayers, while Eastward Energy focuses only on strategic electrification. E1 offers one-on-one discussions instead.

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.

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.

city efficiency and conservation activities that are the subject of the agreement, is in the best interests of Nova Scotia Power Incorporated's customers and satisfies the requirements of Section 79J. (9) The Board's assessment of the prop...

AI summary The repeal of Section 79L(9) removes affordability as a specific statutory consideration for electricity efficiency programs, though E1 notes the Board still prioritizes affordability. NS Power conflates cost-effectiveness with broader 'best interests' criteria for DSM plans. The Board's M08888 decision relied on now-repealed sections 79L(8) and (9).

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.

5. REQUESTED BOARD ORDER Based the evidence and analysis before the Board in this matter, including as set out in these Reply Submissions, E1 respectfully requests the Board approve the Proposed BCA as supplemented by the PCA, specifically...

AI summary E1 requests the Board to approve the Proposed BCA supplemented by the PCA, including a 2% discount rate, proxy values for the 2027-2031 DSM Plan, and the evergreen process for future DSM applications. The request aligns with PUA 79H(2) and references prior submissions (M12282).

James R. Gogan Direct +1 (902) 563 5920 [[email protected]](mailto:[email protected]) 1969 Upper Water St., Suite 1300 McInnes Cooper Tower - Purdy's Wharf Halifax, NS B3J 3R7 TEL: 902.425.6500 FAX: 902.425.6350 Our...

AI summary EfficiencyOne submits reply submissions to the Nova Scotia Energy Board regarding a new Benefit-Cost Analysis Test for evaluating Demand Side Management Plans in regulatory proceeding M12282.

October 21, 2025 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M12282 Demand Side Management (DSM) Benefit Cost Analysis Test (BCAT) Rebuttal Submission Dear Ms. Henw...

AI summary Nova Scotia Power Incorporated (NS Power) submits a rebuttal to EfficiencyOne's (E1) proposed Benefit Cost Analysis Test (BCAT) for Demand Side Management (DSM) Plans, emphasizing the need for consensus aligned with legislative intent and cost-effectiveness frameworks. NS Power argues the Nova Scotia Energy Board (NSEB) cannot consider host customer non-energy impacts or societal impacts post- Energy Reform Act (ERA) enactment, citing the Public Utilities Act (PUA) as the governing legislation.

Response to the Closing Arguments of E1, the Consumer Advocate (CA), the Small Business Advocate (SBA), and East Coast Environmental Law (ECEL) NS Power does not intend to summarize the entirety of the parties' closing submissions but will...

AI summary NS Power responds to E1, CA, SBA, and ECEL's closing arguments, opposing E1's proposed BCAT framework and PCA terms. NS Power highlights disagreements on legislative interpretation post-M08888, noting only five of eight intervenors supported the PCA. E1 argues the BCAT aligns with ratepayer interests and has broad intervenor support.

Asset Value New equipment, latest technologies improve asset value Water cost impacts Some efficiency measures also reduce water consumption O&M Costs Energy Efficiency (EE) and Electric Vehicles (EV) typically decrease. Demand Response (D...

AI summary The text discusses the impact of energy efficiency (EE) measures and other programs on asset value, water consumption, operational costs, productivity, economic well-being, comfort, amenity, health and safety, empowerment, and pride. It also critiques the relevance of individual benefits to sustainability goals outlined in legislative amendments, emphasizing the need for empirical support to link these benefits to broader sustainability outcomes.

Consideration of greenhouse gas emissions ECEL is particularly supportive of the inclusion of the social cost of carbon among non-utility system benefits in E1's proposed BCAT.[11](#page-4-0) Additionally, the CA agrees with E1 that the le...

AI summary ECEL supports including the social cost of carbon in E1's BCAT. The CA agrees with E1 that legislative changes expand the Board's mandate to consider greenhouse gas emissions. NS Power argues for quantifying emissions reductions alongside cost savings for strategic electrification, aligning with EGCCRA's 2030 and 2050 emission targets.

Response to the Industrial Group's (IG) Closing Submissions Similarly to the above, NS Power does not intend to summarize the entirety of the IG's closing submissions but will address differences in the IG's proposed PAC and Modified PAC t...

AI summary NS Power agrees with the Industrial Group (IG) on the need for alternative cost-effectiveness tests for demand-side management (DSM) and strategic electrification under the PUA. Both parties emphasize evaluating greenhouse gas reductions and electricity cost savings, though NS Power insists on measure-level proof for strategic electrification. NS Power also supports IG's stance on primary and secondary testing for DSM analyses.

November 4, 2025 [[email protected]](mailto:[email protected]) James R. Gogan McInnes Cooper McInnes Cooper Tower – Purdy's Wharf 1969 Upper Water Street, Suite 1300 Halifax, NS B3J 3R7 Dear Mr. Gogan: M12282 – Effi...

AI summary The Board has cancelled a hearing in M12282 regarding EfficiencyOne's proposed DSM Plan. Eastward Energy seeks DSM Advisory Group (DSMAG) membership, but EfficiencyOne opposes it, citing potential conflicts. The Industrial Group supports broader DSMAG participation, while the Board acknowledges Eastward's value but has not yet ruled on its request.

omed. The Board agrees that Eastward has a valuable perspective that would benefit the DSMAG and does not share EfficiencyOne's concerns that this benefit would be outweighed by any Document: 325547 conflict. The Board's reasons will be ad...

AI summary The Board supports Eastward's inclusion in the DSMAG, dismissing EfficiencyOne's concerns about potential conflicts. It directs EfficiencyOne to add Eastward as a member, with full reasoning to follow in the decision. The Clerk of the Board, Crystal Henwood, and Board Counsel William L. Mahody are involved in the proceeding.

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.

3.5 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 Demand-side Management Legislation and Policies in Nova Scotia

AI summary The section introduces demand-side management legislation and policies in Nova Scotia, referencing key entities and acronyms related to utility regulation and cost analysis frameworks.

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.

n the present tense, it shall be applied to the circumstances as they arise, so that effect may be given to each enactment, and every part thereof, according to its spirit, true intent, and meaning … - (5) Every enactment shall be deemed r...

AI summary The text outlines statutory interpretation principles, emphasizing remedial enactments and factors like mischief, objects, and history. It mandates the Board to consider the text, context, and purpose of the Public Utilities Act's provisions on demand-side management cost-effectiveness.

4.1.3 Board Approval of Demand-side Management [78] Before 2010, NS Power undertook its own demand-side management programs. In 2009, responding to growing concerns over the potential inherent conflict between selling electricity and takin...

AI summary Before 2010, NS Power managed its own demand-side programs. In 2009, the Legislature enacted the Efficiency Nova Scotia Corporation Act, creating a not-for-profit to administer demand-side management and energy efficiency programs, funded by utility assessments. The NSUARB approved expenditures from the fund, effective January 2010.

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.

4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...

AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The Act's definition of 'demand-side management' now includes strategic electrification, while affordability considerations were removed from evaluation criteria.

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.

nges in Nova Scotia results in the Board doing nothing more than it has always done by taking relevant policy goals into consideration when making discreet demand-side management decisions. It states: …This approach effectively suggests th...

AI summary The text critiques the perceived lack of impact from legislative amendments, such as replacing the Utility and Review Board Act with the Energy and Regulatory Boards Act, on demand-side management regulation. It argues that these changes are seen as superfluous, not granting new powers but merely reflecting environmental goals. The Consumer Advocate challenges the Industrial Group's stance that legislative objectives cannot override statutory language.

4.1.6.1 Findings [128] Considering the text, context and purpose of the legislation, the Board finds that the purpose of the demand-side management provisions in the Public Utilities Act is to reduce electricity costs for customers. Demand...

AI summary The Board finds that demand-side management under the Public Utilities Act aims to reduce electricity costs, with NS Power responsible for implementation. Strategic electrification must also reduce electricity costs, as per s. 79A(b)(iv). The removal of 'affordability' from the Act suggests a focus on electricity cost reduction rather than broader affordability considerations.

[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.

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).

clarified that the social discount rate reflects the time value of money. In this instance using 2% better reflects the weight to be given to long-term costs and benefits relative to near-terms ones. [183] The Board asked E1 to address Mr....

AI summary The document discusses a debate over the appropriate discount rate for benefit-cost analysis (BCA) in Nova Scotia's regulatory proceeding. Mr. Bowman argues against using a 2% social discount rate, advocating instead for NS Power's WACC or a 7% real discount rate, while Mr. Neme supports aligning DSM evaluations with NSPM Principles. The NSPM's role in guiding policy objectives is emphasized.

ill) The emissions rates that we have used for illustrative examples that were included in the BCA Application were based on information from Nova Scotia Power and represented average emissions rates. Q. Okay. A. (Neme) But may I add that...

AI summary E1 clarified that average emissions rates were used in illustrative examples within the BCA Application, acknowledging that long-run marginal emission rates are preferable but not yet finalized. The DICE method referenced in the DSM Plan Application also uses average rates. E1 emphasized that assumptions for the DSM Plan will be refined in the future.

4.7 Eastward Energy on DSM Advisory Group [206] Eastward Energy requested the Board order that it be added as a full member of the DSMAG. Although E1 acknowledged Eastward's valuable information and perspectives regarding natural gas hybri...

AI summary Eastward Energy seeks full membership in the DSMAG, arguing its expertise in hybrid peaking resources and gas distribution is critical for strategic electrification. E1 opposes, citing potential conflicts, while Eastward cites the Gas Distribution Act to support its mandate and ongoing pilot projects.

4.7.1 Findings [209] Noting that E1 is currently preparing its 2027-2031 DSM Plan, Eastward asked the Board to make an early finding about its membership in the DSMAG before its input may be too late to be incorporated into the new plan. [...

AI summary Eastward requested early inclusion in the DSMAG to contribute to the 2027-2031 DSM Plan. E1 opposed, arguing Eastward's narrow focus conflicts with DSMAG's purpose. The Board rejected E1's concerns, citing Eastward's valuable input and directed E1 to include Eastward as a DSMAG member.

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.

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 seeks approval for a new benefit-cost analysis test to evaluate demand side management plans under the Public Utilities Act. The proceeding is before a panel including Stephen T. McGrath, Steven M. Murphy, and Darlene Willcott.

ORDER EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans. The Board issued its Decision on December 10, 2025....

AI summary EfficiencyOne (E1) sought approval for a new BCA test for DSM plans, but the Nova Scotia Energy Board rejected it, directing E1 to use the PAC test instead. The Board mandated NS Power's WACC as the discount rate, required strategic electrification to reduce emissions and costs, and included Eastward in the DSM advisory group. E1 must comply with the Public Utilities Act and provide specific data for DSM plan assessments.