E-1Notice of Application and Evidence
8 passages
on behalf of customers, can include calculation of line losses Capacity The generation capacity (kW) required to meet the forecasted system peak load Environmental Actions to comply with environmental Generation Compliance regulations...
AI summary The text discusses various aspects of utility system impacts, including capacity requirements, environmental compliance, renewable portfolio standards, and ancillary services. It outlines how these factors are considered in the context of DERs and the BCA process.
atisfaction from ability to control energy consumption and bills Pride Satisfaction from contribution to addressing environmental concerns 1 2 1 0 . 3 .3 SOCIETAL IMPACTS 3 Societal impact sub-categories quantify economic and environme...
AI summary The text discusses societal impacts of energy efficiency and fuel switching measures, focusing on resilience, greenhouse gas emissions, other environmental impacts, and public health. It mentions the calculation of net emissions and the application of the Federal social cost of carbon to avoid double counting.
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.
Utility Gas Emissions emissions System Other Estimated health impacts from Societal Environmental PM, SO2 and NOx air pollutants Embedded in other Public Health E Environmental and GHG Economic Should be addressed outside of Developmen...
AI summary The text discusses the categorization of impacts related to gas emissions, public health, and environmental considerations, emphasizing the need for separate studies outside the BCA framework. It references the structure of these categories and their sub-elements described in the report.
ollection Need to be developed Risk Need to be developed Should be reflected in Reliability Avoided Costs 0 0 0 Resilience NM NM NM NM Sub Total Electric Impacts ($26.08) ($26.08) $20.16 Other Fuels Avoided Heating Oil/Natural Gas Fuel cos...
AI summary The text presents a table summarizing various impacts related to energy projects, including reliability, resilience, avoided costs, fuel costs, health impacts, and greenhouse gas emissions. It highlights financial figures and environmental considerations associated with different energy sources and initiatives.
uncil. The ERA has major implications for the structure and regulatory authority of the newly created NSEB, as well as for the categories of impacts to be included in a new Nova Scotia test. 1. The Energy Reform Act The ERA as passed makes...
AI summary The Energy Reform Act (ERA) introduces significant changes to the Public Utilities Act, expanding the regulatory oversight Board's consideration to include sustainable development and prosperity. The ERA also impacts the structure and regulatory authority of the newly created NSEB and the categories of impacts included in a new Nova Scotia test.
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.
et, which is negative due to the lower value of the pipeline gas savings. Table 23 illustrates the estimated greenhouse gas impacts from 1,000 residential heat pumps displacing pipeline gas.
AI summary The text discusses the negative impact of lower pipeline gas savings and provides an illustration of estimated greenhouse gas impacts from 1,000 residential heat pumps displacing pipeline gas.
E-8See new revised evidence submitted under E-14 (Evidence of P. Bowman, on behalf of IG)
4 passages
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.
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.
ro system resiliency study in response to Snare River drought. For New World Dairy (2015-2017): Assist in negotiations regarding Non-Utility Generation and interconnection with Newfoundland Hydro For Yukon Energy Corporation (2005 - 2015):...
AI summary The text outlines past involvement in energy-related projects across Canada, including resource planning, environmental assessments, and regulatory interactions. Key activities include project management for hydroelectric developments, expert testimony before regulatory bodies, and negotiations with utility providers in Newfoundland, Yukon, Northwest Territories, and Manitoba.
GOVERNMENT OF NORTHWEST TERRITORIES, YELLOWKNIFE, NORTHWEST TERRITORIES 1996 – 1998 Land Use Policy Analyst Conducted research into protected area legislation in Canada and potential for application in the NWT. Primary focus was on balanci...
AI summary The Land Use Policy Analyst (1996–1998) researched protected area legislation in Canada, focusing on balancing mining/mineral exploration with conservation principles in the Northwest Territories (NWT). The work emphasized reconciling multiple-use objectives with environmental protection goals.
E-9Evidence and Resume of Courtney Lane - Synapse
4 passages
3 As shown in [Table 2,](#page-16-0) the electric utility system impacts in the proposed Nova Scotia Test 4 are the same as those currently included in E1's TRC test. The new non-utility impact 5 categories proposed for inclusion in the te...
AI summary The proposed Nova Scotia Test 4 includes the same electric utility system impacts as E1's TRC test, with additions such as other fuel impacts, host customer impacts, societal greenhouse gas impacts, and other environmental impacts, including public health impacts from air pollutants.
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.
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.
E-14Evidence of P. Bowman, on behalf of IG - Revised (Old evidence filed under E-8)
4 passages
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 line with earlier determinations. It emphasizes that the Board must prioritize the best interests of NSPI customers while adhering to the Energy and Regulatory Boards Act and other legislation promoting competition, innovation, and sustainable development.
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.
ro system resiliency study in response to Snare River drought. For New World Dairy (2015-2017): Assist in negotiations regarding Non-Utility Generation and interconnection with Newfoundland Hydro For Yukon Energy Corporation (2005 - 2015):...
AI summary The text outlines involvement in energy-related projects across multiple jurisdictions, including resource planning, environmental assessments, and regulatory reviews for organizations like Yukon Energy Corporation, Northwest Territories Power Corporation, and Tolko Manitoba. Activities include project management, expert testimony, and interconnection negotiations.
GOVERNMENT OF NORTHWEST TERRITORIES, YELLOWKNIFE, NORTHWEST TERRITORIES 1996 – 1998 Land Use Policy Analyst Conducted research into protected area legislation in Canada and potential for application in the NWT. Primary focus was on balanci...
AI summary The Government of Northwest Territories' Land Use Policy Analyst (1996–1998) researched protected area legislation in Canada, focusing on balancing mining/mineral exploration with conservation principles in the NWT.
E-23CV - Chris Pulfer, P.Eng. - EE
3 passages
Energy Efficiency Program Design, Administration and Support - Custom Efficiency Program (CEP) Update: FortisBC (Nov. 2023-ongoing) - Achievable Potential Study (Ad Hoc) Support: Enbridge Gas (September 2023 ongoing) - Resource Plan and Lo...
AI summary The document lists energy efficiency programs and initiatives undertaken by various organizations from 2010 to 2023, focusing on program design, administration, and support. Key participants include FortisBC, Enbridge Gas, FCM, CMHC, and IESO, with projects spanning residential, commercial, industrial, and municipal sectors. Efforts include DSM planning, retrofit programs, GHG accounting, and incentive development.
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).
Transportation Energy Efficiency Technology and Market Research - Environmental and Health Impacts of Small Gasoline Powered versus Electric Powered Mobile Outdoor Equipment in Canada: Environment and Climate Change Canada (Feb. 2021-May 2...
AI summary The document lists studies on transportation energy efficiency in Canada, including environmental impacts of outdoor equipment, fuel-saving measures in heavy-duty vehicles, EnerGuide label accuracy, and vehicle technology assessments. Research was conducted by Environment and Climate Change Canada, Transport Canada, and Natural Resources Canada's Office of Energy Efficiency between 2012 and 2021.
E-24Rebuttal Evidence of E1 including Appendix A - Energy Futures Group Rebuttal Evidence
10 passages
ment that it consider NSPI customer interests in the same metric as - the E1 program screening."[7](#page-7-3) [emphasis added] - E1 Response - E1 addresses these two arguments separately, below. - 2.2.1 PEER UTILITIES - Nova Scotia legisl...
AI summary E1 argues that Nova Scotia legislation, not peer utility practices, determines the BCA test for DSM. It aligns the test with the Energy Reform (2024) Act and Public Utilities Act , emphasizing strategic electrification and sustainability. The customized test, modeled on the NSPM, incorporates environmental/social impacts, citing Efficiency Canada and a 2022 NSUARB decision.
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.
Board ("NSUARB") accepted the Framework for use in future DSM Plan applications. [14](#page-10-3) Since acceptance by the NSUARB in 2016, E1 has followed the Framework in its DSM Plan applications. M07543, E-3, EfficiencyOne Application fo...
AI summary The NSUARB accepted the Standardized Filing Framework for future DSM Plan applications, which E1 followed since 2016. A deferred matter (M07543) relates to the 2016 DSM Resource Plan. Critics argue adopting Bowman's approach would eliminate low-income programs and equity considerations, while Bowman contends GHG emissions must be directly tied to DSM, not external factors like caps.
Green Energy Mr. Wyatt raised the following concern: I support the addition of externalized cost of carbon in the new test, but ask that the internalized cost of carbon be kept separate from the externalized cost of carbon for use with the...
AI summary Mr. Wyatt supports including externalized carbon costs in the new test but advocates keeping internalized carbon costs separate for use with the Program Administrator Cost (PAC) test, as noted in footnote 21.
Eastward Eastward Energy addresses emissions rates, stating: [...T]he use of average versus marginal emissions rates is not appropriate given that going forward, incremental generation will be served by coal and later by heavy fuel oil and...
AI summary Eastward Energy argues that using average emissions rates is inappropriate because future incremental generation will rely on inefficient coal, heavy fuel oil, and natural gas/fuel oil combustion turbines. They advocate for marginal emissions rates, noting hybrid natural gas systems operate at over 90% efficiency. [35](#page-19-2)
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.
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.
100256Board Decision
18 passages
- [4] In response to this evidence, E1 submitted that a broad review of costeffectiveness testing methodologies may be appropriate given recent legislative changes, and the advancement in demand response and electrification initiatives. E1...
AI summary E1 proposes a jurisdiction-specific cost-effectiveness test for DSM, citing legislative changes and advancements in demand response. The NSUARB found E1's approach reasonable, but the Board argues the test may conflict with the PUA's requirement to reduce electricity costs. E1 claims legislative updates allow broader consideration of non-energy benefits and sustainability.
ns broadened the Board's mandate to include sustainable development, sustainable prosperity, and climate goals aligned with the Environmental Goals and Climate Change Reduction Act ., SNS 2021, c 20. - [14] In accordance with the NSUARB's...
AI summary Nova Scotia expanded the NSUARB's mandate to include sustainability and climate goals under the Environmental Goals and Climate Change Reduction Act. E1, working with DSMAG and Energy Futures Group, proposed replacing the TRC test with a new BCA test to address its narrow scope and exclude environmental benefits, aligning with modern legislation and best 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 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.
impacts E1's programming and planning, is the addition of strategic electrification as part of the definition of DSM." It said the Public Utilities Act focus remained on reducing electricity costs. [37] The addition of strategic electrific...
AI summary The Industrial Group argues that adding strategic electrification to DSM under the Public Utilities Act should not expand the NSUARB's jurisdiction to consider non-energy benefits. It emphasizes the Act's focus on reducing electricity costs and maintains the Board's existing discretion in evaluating DSM plans. The Group also clarifies that 'sustainable development' considerations under the Energy and Regulatory Boards Act do not grant the Board authority over societal 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.
ustification that would be required to possibly justify a measure that would have such a negative benefit and a benefit cost ratio substantially below 1.0. [Eastward Energy Closing Submissions, p. 9] [66] In terms of reliability impacts, E...
AI summary Eastward Energy argues that benefit-cost analyses for natural gas must account for reliability impacts and ancillary service costs, requesting explicit confirmation from Nova Scotia Power. It emphasizes balancing legislative requirements in determining cost tests and highlights the need for a 2% social discount rate consideration.
- [85] While acknowledging that it had an over-arching public interest mandate in everything it does, the NSUARB noted its principal responsibilities in regulating utilities were to ensure safe and adequate service, just and reasonable rat...
AI summary The NSUARB emphasized its statutory duty to ensure just rates and lowest long-term costs, rejecting non-energy benefits consideration. EfficiencyOne argued for broader environmental and customer interests, while the Industrial Group opposed open-ended interpretations, citing statutory definitions.
with the goal of approving rates, tolls, charges, tariffs, capital applications or other matters that are consistent with the purpose of this Act, the More Access to Energy Act and the regulations. [90] To follow through the threads in s....
AI summary The text discusses statutory changes under the More Access to Energy Act and Energy and Regulatory Boards Act , emphasizing objectives like increasing energy sector competition, ensuring reliable energy supply, and transitioning to an independent system operator. It outlines the establishment of regulatory boards and their roles, while aligning with sustainability goals from the Environmental Goals and Climate Change Reduction Act .
Sustainable prosperity long-term objective - 5 (1) The long-term objective of the Government is to achieve sustainable prosperity. - (2) To achieve its objective of sustainable prosperity, the Government shall - (a) establish, adopt, suppo...
AI summary The Government of Nova Scotia aims to achieve sustainable prosperity through integrated environmental and economic goals, raising awareness of climate change, promoting the clean economy, supporting well-being, enabling innovation, and improving social, environmental, and economic indicators.
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.
reduce electricity costs for customers. NS Power is satisfying this obligation by entering into a supply agreement with E1. It is this purpose that frames the Board's assessment of cost-effectiveness. [135] E1 appears to suggest that if on...
AI summary NS Power aims to reduce electricity costs via a supply agreement with E1. The Board assesses cost-effectiveness, disagreeing with E1's claim that statutory interpretations limit sustainable development considerations. The Board emphasizes statutory requirements over general factors, agreeing with E1's screening test for demand-side management but focusing on electricity cost impacts.
4.2 Benefit-Cost Test Alternatives [143] No party in this proceeding argued that the existing TRC test should be maintained in its present form. [144] As discussed in more detail previously, E1's proposed BCA test includes utility system a...
AI summary No party supports maintaining the existing TRC test. E1 proposes a BCA test incorporating utility and non-utility system impacts, aligning with Nova Scotia's legislative changes and sustainability goals. Table 5 compares the existing TRC and proposed BCA tests.
[160] Eastward made similar comments in its submissions: In this regard the IG has noted that the approach proposed by Mr. Bowman to costeffectiveness testing for E1 for strategic electrification – running the PAC test with the additional...
AI summary Eastward supports Mr. Bowman's modified PAC test for strategic electrification, aligning with Posterity Group's recommendations to ensure cost-effective programs. E1 argues the test assesses rate impacts, not cost-effectiveness, and has focused on GHG emissions rather than electricity cost reductions in its BCA.
sed as borrowing costs or the opportunity cost of alternative investments. - 3. Societal discount rate: A lower rate intended to account for intergenerational equity or broader societal consideration. [172] In the application, Energy Futur...
AI summary Energy Futures Group (EFG) recommends a 2% social discount rate for BCA tests, aligning with Canadian government guidance. E1 supports this, emphasizing societal and environmental considerations, and notes reliance on U.S. screening practices rather than Canadian jurisdictional reviews. The Board references EFG's alignment with the Social Cost of Greenhouse Gas Estimates guidance and Treasury Board Secretariat regulations.
[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.
5.0 SUMMARY OF BOARD FINDINGS [217] The Board finds it does not have the authority to approve E1's proposed BCA because the Public Utilities Act restricts the Board's ability to consider non-energy and societal benefits in assessing the co...
AI summary The Board cannot approve E1's proposed BCA due to Public Utilities Act restrictions on non-energy benefits. E1 must use PAC test and NS Power's WACC for DSM plan assessments. Strategic electrification must meet GHG and cost reduction criteria. Eastward is added to DSMAG. Portfolio-level evaluation allows overall cost-effective DSM plans despite individual measure failures.
98033NSEB (E1) IR 1 to 46
5 passages
Request IR-14: - With regards to Table 7 on page 30 of 38 of E1's Evidence: - a) Please describe the environmental compliance costs that are embedded in the commodity price. - b) Please describe the non-embedded environment and economic im...
AI summary Request IR-14 asks E1 to clarify environmental compliance costs embedded in commodity prices and non-embedded environmental/economic impacts in the Social Cost of Carbon, as detailed in Table 7 of their evidence.
Request IR-18: - Table 9: Societal Impacts, please elaborate on the following terms and definitions relating to - energy efficiency: - a) Resilience - b) Other Environmental - i. Please differentiate between Greenhouse Gas Emissions - c) P...
AI summary Request IR-18 seeks clarification on societal impact terms in Table 9, focusing on energy efficiency aspects like resilience, greenhouse gas emissions, public health, and energy security. It requests differentiation between greenhouse gas emissions and other environmental factors.
Request IR-25: - Table 3 on Page 12 of 18 of Mr. Hill's Evidence: Data Sources and Application in Developing Recommended Nova Scotia Test: - a) For the Utility System Impact "Program Administration and Incentives", the Application in Repor...
AI summary Request IR-25 seeks clarification on assumptions in the BCA related to program administration, fuel price adjustments, placeholder cost assumptions, and proxy values for non-energy benefits. Questions focus on EFG's assumptions, carbon price removal rationale, US Energy Information Administration fuel cost data, and adjustments to avoid double-counting energy benefits.
Request IR-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-42: - In reference to Table 14, please provide empirical evidence demonstrating cause between the - measure type and the customer segment. - Request IR-43: - With regards to Table 15 on page 47 of 68 of EFG's report, please expl...
AI summary The document contains five requests (IR-42 to IR-46) seeking clarifications on empirical evidence, definitions (e.g., weatherization), energy security linkages, air quality benefit comparisons between Nova Scotia and New England, and implications of Canada's carbon tax abolition on E1's cost calculations. Key entities include E1, Nova Scotia Power, and Environment Canada.
99638Closing Submission - E1
10 passages
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.
4.3 APPLICABLE DISCOUNT RATE E1, relying on expert analysis provided by EFG, submits that the adoption of a 2% real discount rate for evaluating impacts under the Proposed BCA test is both reasonable and legally sound. It reflects a societ...
AI summary E1, supported by EFG, argues that a 2% real discount rate is legally sound and aligns with NSPM and Nova Scotia legislation, including GHG mitigation and sustainable development. They oppose using WACC, claiming it misrepresents long-term benefits and legislative goals, with support from Efficiency Canada.
4.4 EVERGREEN PROCESS - E1's proposed evergreen process represents a foundational commitment to maintaining the integrity, - relevance, and adaptability of its Proposed BCA framework. This process ensures that the BCA test remains - aligne...
AI summary E1's evergreen process ensures the BCA framework remains aligned with evolving legislation, policy, and market conditions in Nova Scotia. It involves periodic reviews, stakeholder engagement, and collaboration with DSMAG to quantify non-energy impacts. E1 claims no opposition to the process.
5. SUMMARY OF EVIDENCE AND HEARING RECORD Cost-effectiveness testing is not new in Nova Scotia. Section 79H(1) of the Public Utilities Act requires that the Board "determine the cost-effective demand-side management that must be undertaken...
AI summary The Nova Scotia Utility and Review Board is evaluating the replacement of the Total Resource Cost (TRC) test with a Benefit-Cost Analysis (BCA) for demand-side management (DSM) cost-effectiveness. Critics, including EfficiencyOne and the Consumer Advocate, argue the TRC test is asymmetrical and fails to incorporate new legislative priorities like sustainable development. E1 proposes the BCA test as a more comprehensive alternative.
6.1 INTRODUCTION - It is E1's position that the Proposed BCA satisfies the legislative requirements for cost-effectiveness testing, - including new or amended legislative requirements. More specifically, E1 submits that the Proposed BCA -...
AI summary E1 argues that their proposed BCA meets legislative requirements for cost-effectiveness testing, including portfolio-level DSM assessment and sustainable development considerations. They also claim Mr. Bowman's approach fails to satisfy statutory requirements.
id="page-31-1"> Ibid , p age 451 , line 9 – page 452, line 12 . 66 M12282, E-14, Evidence of Patrick Bowman, Revised, page 20, lines 14 – 2 7. a. The primary energy efficiency test should be the PAC test, applied at the measure and program...
AI summary The IG proposes using the PAC test for energy efficiency and electrification, alongside the E1 BCA test for broader benefits. Mr. Bowman critiques this approach as cumbersome, misaligned with cost-effectiveness analysis, and overly focused on energy efficiency, ignoring other DSM resources like demand response. He argues rate impacts should not be used as screening criteria and emphasizes the need for alignment with legislative purposes.
Public Utilities Act , RSNS 1989, c 380, s 79L(5). 1 (a) support competition and innovation in the provision of energy resources 25 (a) increase competition and innovation in the Province's energy sector; 26 (b) ensure the provision of a s...
AI summary The document outlines the objectives of the Public Utilities Act, emphasizing the promotion of competition and innovation in energy provision, ensuring reliable and economical energy supply, and supporting sustainable development and greenhouse gas emissions reduction goals as defined by the Environmental Goals and Climate Change Reduction Act.
Building on the provisions outlined above, E1's position is that the legislative framework not only empowers the Board to consider issues of sustainable prosperity and sustainable development, but in fact obliges it to do so as part of its...
AI summary E1 argues that the legislative framework empowers and obliges the Board to prioritize sustainable development and prosperity, as defined in statutes like the Environment Act and the Energy and Regulatory Boards Act . These laws require the Board to consider long-term societal outcomes, including energy efficiency and emissions reduction, when evaluating DSM plan applications and cost-effectiveness.
6.5.2 IG'S PROPOSED APPROACH The evidence presented to the Board supports the finding that the Proposed BCA is the test which best addresses these policy concerns. In fact, the IG's expert, Mr. Bowman, indicates that in order to address br...
AI summary The IG's expert, Mr. Bowman, advocates for the Proposed BCA as a societal test to address sustainable development and GHG reductions. However, his primary PAC test fails to incorporate legislative policy goals outlined in the NSPM, which mandates integrating DER-related policy considerations into cost-effectiveness analyses. The Proposed BCA allows the Board to consider societal factors within a cost-effective framework.
9 7. REQUESTED BOARD ORDER - Based the evidence and analysis before the Board in this matter, including as set out in this Closing - Submission, E1 respectfully requests the Board approve the Proposed BCA as supplemented by the PCA, - spec...
AI summary E1 requests the NSUARB to approve the Proposed BCA with PCA modifications, including a 2% discount rate and evergreen process. It aligns with PUA, supports decarbonization goals, and reflects stakeholder input via DSMAG. The BCA is deemed evidence-based, consistent with legislation, and in the public interest.
99640Closing Submission - IG
6 passages
ee also paras 36-37, and 47. the legislation and the meaning of the words used in the PUA . This interpretive exercise falls within the Board's general oversight over electricity utility regulation. In the Board's most recent ACE decision,...
AI summary The Board discusses statutory interpretation principles, referencing Sullivan's questions and past decisions, emphasizing the inclusion of broader policy factors like sustainability and innovation in regulating electricity utilities under the PUA.
e: societal impact, or direct costs to the utility and ratepayers. The focus for E1, based specifically on the language of the PUA , should first and foremost be the reduction of costs for customers. The main change to the PUA since the la...
AI summary The Public Utilities Act (PUA) mandates that Efficiency One (E1) prioritize cost reduction for customers through demand-side management (DSM), including strategic electrification that reduces both greenhouse gas emissions and electricity costs. The PUA now requires the Energy Board to evaluate DSM plans at the portfolio level, while retaining discretion to approve plans not meeting program-level cost-effectiveness criteria.
Prior Interpretation of the Board's Jurisdiction Up until this application, the predecessor Board made clear that it did "not have the jurisdiction to take into account non-energy impacts in cost-effectiveness testing" in relation to DSM.[...
AI summary The Board clarified its jurisdiction excludes non-energy impacts in DSM cost-effectiveness testing, focusing solely on energy-based costs and benefits. EfficiencyOne argued for broader environmental considerations under the PUA, but the Board rejected this, citing statutory definitions. The Board emphasized 'cost-effective' means evaluating electricity efficiency activities for affordability and long-term cost reduction, acknowledging limited environmental benefits.
The Board Still Cannot Account for Non-energy Benefits The Industrial Group recognizes that certain recent legislative amendments may impact the ongoing interpretation of the PUA provisions. However, the additional factors provide guidance...
AI summary The Industrial Group acknowledges recent legislative changes but argues they don't alter the PUA's focus on reducing electricity costs. E1's environmental goals must align with PUA provisions, not override them. The Board must adhere to statutory mandates, and non-energy benefits aren't within the legislative framework for cost-effectiveness evaluation.
use of the social cost of carbon within that context is with respect to cost-benefit analyses in the introduction of a piece of legislation; it is not a tool that impacts costs charged to ratepayers. Of particular concern is how far this e...
AI summary The document discusses concerns over the broad interpretation of section 6(2) of the ERBA, which mandates consideration of sustainability in regulatory decisions. It highlights E1's reliance on sustainability factors and EFG's argument for a broad societal test in energy regulation. The use of social cost of carbon in legislation is noted as not directly impacting ratepayer costs, but consistency in regulatory oversight remains a concern.
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.
99641Closing Submission - EE
3 passages
STRATEGIC ELECTRIFICATION With respect to the recently added definition of strategic electrification in section 79A(b)(iv) of the Public Utilities Act , Ms. Thompson confirmed that strategic electrification requires both a reduction in ove...
AI summary The definition of strategic electrification under the Public Utilities Act requires reducing both greenhouse gas emissions and electricity costs. Ms. Thompson notes E1 has not advanced work on demonstrating cost reductions. Mr. Bowman argues the PAC test must include revenue benefits for electrification to pass, emphasizing that avoiding peak demand increases makes the test mathematically feasible.
SUSTAINABLE DEVELOPMENT AND SUSTAINABLE PROSPERITY CONSIDERATIONS Considerable weight has been given by E1 and EFG in this process to the recent addition of sustainable development and sustainable prosperity as a factor which the Board is...
AI summary E1 and EFG emphasized the Board's mandate under the Energy and Regulatory Boards Act to consider sustainable development and prosperity, defined via existing legislation like the Environment Act and Environmental Goals and Climate Change Reduction Act . These concepts require balancing economic growth, environmental stewardship, and social responsibility, with the Board's interpretation of 'appropriate consideration' remaining discretionary.
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.
99643Closing Submission - NSPI
4 passages
impact view become the dominant perspective. E1 determined that two legislative changes have significant implications to be recognized in the new BCA test that reflect Nova Scotia's policy objectives: - 1. On November 9, 2022, the Nova Sco...
AI summary EfficiencyOne highlights two legislative changes impacting Nova Scotia's BCA test: a 2022 PUA amendment shifting cost-effectiveness testing to the portfolio level and expanding DSM definitions, and the 2024 Energy Reform Act adding factors like energy efficiency, sustainable development, and GHG emissions to the Energy Board's considerations.
lly alter the core objectives of DSM under the PUA. Such activities remain the "means" to an "end" of reduced overall electricity costs or of reducing the cost of electricity for NS Power's customers. Regarding subsection (iv), the legisla...
AI summary The text discusses the legislative framework under the PUA, emphasizing that strategic electrification must reduce both GHG emissions and customer costs. The TRC test currently includes GHG emissions in cost calculations, but the amendment focuses solely on emissions reductions. NS Power agrees that programs must achieve both emission and cost reductions to be approved by the Board.
proach to s. 67 of the PUA used in the Dalhousie Legal Aid decision." There, as here, the link between the factors a party seeks to introduce and those explicitly accounted for in the ERBA is lacking. In short, E1 has not demonstrated how...
AI summary E1 argues that host customer benefits under the JST are not adequately linked to 'sustainable development' and 'sustainable prosperity' under the ERBA, so the Board should not change its interpretation of DSM under the PUA. Cites the Dalhousie Legal Aid decision and references M12171.
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.
99732Reply Submission - E1
5 passages
2.1 LEGISLATIVE INTERPRETATION & JURISDICTIONAL LIMITS The IG contends that the Board, under the Public Utilities Act (" PUA "), is not empowered to consider broad societal impacts or non-energy benefits when evaluating the cost-effectiven...
AI summary The Industrial Group (IG) argues that the Board under the Public Utilities Act (PUA) cannot consider societal impacts or non-energy benefits when evaluating demand-side management (DSM) cost-effectiveness, emphasizing ratepayer cost reduction. They claim the new strategic electrification provision in the Energy Efficiency and Renewable Energy Act (ERBA) allows EfficiencyOne (E1) to expand programs but still requires adherence to cost-effectiveness, with sustainability limited to specific proposals.
2.4 BROAD INTERPRETATION AND SOCIAL COST OF CARBON - The IG warns that adopting a broad societal test could have unintended consequences for other utilities, - potentially leading to inconsistent and unreasonable outcomes. Specifically, th...
AI summary The Industrial Group (IG) warns that using a broad societal test for evaluating E1's programming could lead to inconsistent outcomes, arguing the social cost of carbon (SCC) is not reflected in Nova Scotia energy prices. However, the text counters that SCC represents real societal costs affecting Nova Scotians, even if not directly priced.
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.
ons 79 L (8) and (9):[40](#page-17-1) M08888, NSUARB Decision, April 15, 2020, page 7, para 10. Ibid , page 13, para 26 and page 15, para 35. Sections 79L (8) and (9) guide the Board's assessment of these activities. The Board must be sati...
AI summary M08888 is no longer determinative due to legislative changes, including repealed affordability instructions, expanded DSM definitions, and new environmental considerations under the ERBA and More Access To Energy Act. The Board previously rejected an environmental mandate under the PUA, but current legislation now requires broader considerations.
4.3 APPROPRIATE DISCOUNT RATE NS Power asserts that the WACC should be the discount rate for DSM cost-effectiveness screening. NS Power's reliance on WACC as the appropriate discount rate is both legally and conceptually flawed for several...
AI summary NS Power argues for using WACC as the discount rate for DSM cost-effectiveness screening, but opponents claim it is legally and conceptually flawed. They argue WACC misapplies NSPM principles, ignores sustainability and long-term GHG benefits, and undervalues DSM programs. A 2% social discount rate is recommended, aligning with federal guidance and legislative mandates.
100256Board Decision
16 passages
- [4] In response to this evidence, E1 submitted that a broad review of costeffectiveness testing methodologies may be appropriate given recent legislative changes, and the advancement in demand response and electrification initiatives. E1...
AI summary E1 proposes a jurisdiction-specific cost-effectiveness test for DSM plans, citing legislative changes and advancements in demand response and electrification. The NSUARB found E1's approach reasonable, but the Board emphasized that legislative changes do not override the PUA's mandate to reduce electricity costs. E1's test includes non-energy benefits and sustainability factors, though critics argue it may increase customer costs.
herefore, directed E1 to work with the Demand-side Management Advisory Group (DSMAG) before the 2026- 2028 DSM Plan application to assess and develop an optimal DSM cost-effective testing methodology. [13] After the NSUARB's decision in M1...
AI summary Legislative changes in Nova Scotia, including amendments to the Public Utilities Act and the Energy Reform Act (2024), have expanded the NSUARB's mandate to include climate goals and sustainable development. These changes affect demand-side management (DSM) evaluation methods, shifting analysis to the portfolio level and incorporating strategic electrification.
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.
impacts E1's programming and planning, is the addition of strategic electrification as part of the definition of DSM." It said the Public Utilities Act focus remained on reducing electricity costs. [37] The addition of strategic electrific...
AI summary The Industrial Group argues that adding strategic electrification to DSM does not expand the NSUARB's jurisdiction to consider non-energy benefits, emphasizing the Public Utilities Act 's focus on reducing electricity costs. It highlights the Board's retained discretion in evaluating DSM plans and clarifies that sustainable development considerations under the Energy and Regulatory Boards Act do not grant authority over 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 NS Power opposes E1's proposed BCA test, advocating for TRC modifications that include GHG emissions reductions (net tonnage basis) and electricity cost reductions, alongside other fuel impacts. It emphasizes that subsection 79A(b)(iv) of the PUA mandates GHG reductions for strategic electrification but argues this does not override the core objective of reducing electricity costs. NS Power asserts the Board's mandate to ensure 'just and reasonable rates' remains central.
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.
ustification that would be required to possibly justify a measure that would have such a negative benefit and a benefit cost ratio substantially below 1.0. [Eastward Energy Closing Submissions, p. 9] [66] In terms of reliability impacts, E...
AI summary Eastward Energy argues that benefit-cost analyses for natural gas projects must account for reliability impacts and ancillary service costs, seeking clarification from NS Power. It emphasizes balancing legislative requirements for sustainable development and critiques the 2% social discount rate. The Board is urged to ensure reliability value is captured in avoided costs.
om the text in s. 79L(9) (much of which is now included in s. 79L(5)). E1 submitted this affordability requirement featured in the NSUARB's reasons in reaching its conclusions in its decision in 2020: Section 79L(9) has been repealed, ther...
AI summary Section 79L(9) of the PUA was repealed, removing affordability as a statutory requirement for electricity efficiency activities. E1 acknowledges the NSUARB's continued focus on affordability but notes its removal from statutory obligations. The Energy Reform (2024) Act now mandates the Board to consider factors like competition, innovation, and sustainable development in regulatory decisions, aligning with broader energy legislation.
Sustainable prosperity long-term objective - 5 (1) The long-term objective of the Government is to achieve sustainable prosperity. - (2) To achieve its objective of sustainable prosperity, the Government shall - (a) establish, adopt, suppo...
AI summary The Government of Nova Scotia aims to achieve sustainable prosperity through integrated environmental and economic goals, public awareness campaigns, clean economy growth, well-being initiatives, supportive regulation, and continuous improvement in social, environmental, and economic indicators.
The current version is: (iv) strategic electrification of energy end uses currently powered by fossil fuels in a manner that reduces overall greenhouse gas emissions and electricity costs [108] E1 submits that strategic electrification can...
AI summary E1 argues that strategic electrification cannot be evaluated using traditional PAC or TRC tests, as utility impacts are primary costs and non-utility impacts (e.g., fuel savings, GHG reductions) are primary benefits. The 2022 PUA amendment defines strategic electrification as reducing GHG emissions and electricity costs, requiring expanded cost-effectiveness analysis to include non-utility benefits.
[124] Eastward expressed similar comments in its reply submissions: E1 has continued in its Closing Submissions to put considerable emphasis on the Board's requirement at section 6(2)(d) of the Energy and Regulatory Boards Act to give "app...
AI summary Eastward's reply submissions emphasize E1's focus on the Board's duty under the Energy and Regulatory Boards Act to prioritize sustainable development in DSM plans. E1 argues that the Board must explicitly address sustainable development, while East Coast Environmental Law notes this responsibility does not override other statutory considerations like affordable energy rates. NSPI aligns with E1's BCA approach, and E1 disputes the Industrial Group's interpretation of legislative changes.
osts. As noted already, strategic electrification may only be undertaken if, in addition to reducing greenhouse gas emissions, it reduces electricity costs. This is explicitly stated in s. 79A(b)(iv). [130] While the NSUARB's 2020 decision...
AI summary The NSUARB examines legislative requirements for demand-side management, emphasizing cost reduction and alignment with sections 79A(b)(iv), 79I(1), and 79H(2) of the PUA. The Board agrees with the Industrial Group and NS Power that cost reduction remains central, rejecting broader interpretations of sustainable development overriding specific cost mandates. References to Matter M12171 highlight tensions between general and specific legislative provisions.
4.2 Benefit-Cost Test Alternatives [143] No party in this proceeding argued that the existing TRC test should be maintained in its present form. [144] As discussed in more detail previously, E1's proposed BCA test includes utility system a...
AI summary No party supports maintaining the current TRC test. E1's proposed BCA test includes utility and non-utility system impacts, informed by Nova Scotia's legislative changes, with objectives of sustainability, GHG reduction, and equitable access. Table 5 compares the existing TRC test and the proposed BCA test.
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.
sed as borrowing costs or the opportunity cost of alternative investments. - 3. Societal discount rate: A lower rate intended to account for intergenerational equity or broader societal consideration. [172] In the application, Energy Futur...
AI summary The document discusses the recommendation of a 2% social discount rate for BCA tests by Energy Futures Group (EFG), aligning with Canadian government guidance. EFG argues this rate reflects societal and environmental priorities, citing intergenerational equity and the Province's policy goals. The NSUARB requested justification, with EFG referencing U.S. screening practices and the SC-GHG guidance.
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.