Topic:"Equity Access" in M12282

1 The More Access to Energy Act establishes the following purposes: 2 3 2 The purpose of this Act is to 4 5 (a) increase competition and innovation in the Province's energy sector; 6 7 (b) ensure the provision of a safe, secure, reliable a...

AI summary The More Access to Energy Act aims to increase competition and innovation in Nova Scotia's energy sector, ensure a reliable energy supply, and support sustainable development and prosperity as defined by the Environment Act and Environmental Goals and Climate Change Reduction Act. It also outlines a transition to an independent energy system operator.

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.

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.

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.

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.

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.

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.

and pride to zero for the purposes of the 2027–2031 DSM Plan. The Consensus Agreement also reduced the proposed proxy values for the "Building Shell", "BNI" and "Solar + Storage" measures categories. [23] The proposed BCA test will use a 2...

AI summary The proposed BCA test uses a 2% social discount rate, justified by E1 as aligning with GHG reduction objectives, legal standards, and guidance from NSPM, the U.S. Office of Management and Budget, and the Canadian Treasury Board. The Consensus Agreement adjusted proxy values for DSM measures like 'Building Shell' and 'Solar + Storage'.

tes" and that the "listed factors in section 6(2)(a-e) [of the Energy and Regulatory Boards Act ] supplement, but do not replace, the Board's primary mandate." In its closing submissions, it states: The operative phrase of section 6(2) is...

AI summary Nova Scotia Power (NS Power) argues that section 6(2) of the Energy and Regulatory Boards Act requires 'appropriate consideration' of factors without imposing prescriptive requirements. It contends that 'sustainable development' in the More Access to Energy Act does not mandate non-utility impacts in benefit-cost analysis (BCA) and asserts that E1 has failed to link host customer benefits to 'sustainable development'.

ince; - [94] "Sustainable prosperity" is defined in s. 3 of the More Access to Energy Act as having the same meaning as in the Environmental Goals and Climate Change Reduction Act , SNS 2021, c 20: "sustainable prosperity" means prosperity...

AI summary The document defines 'sustainable prosperity' under the More Access to Energy Act using the Environmental Goals and Climate Change Reduction Act (SNS 2021, c 20). It emphasizes principles including Netukulimk, sustainable development, circular economy, equity, shared responsibility, and recognizing climate change as a global emergency.

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.

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.

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.

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.

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.

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.

Discount Rate 11 ECEL Closing Submission, page 1. 12 CA Closing Submission, pdf page 12/14. 13 CA Closing Submission, pdf page 9/14. E1 submits that the 2 percent discount rate is not only appropriate and prudent, but also in the best inte...

AI summary E1 argues a 2% discount rate is appropriate and in ratepayers' best interest, while NS Power contends that using their cost of capital provides a more accurate reflection of current affordability challenges and aligns with immediate financial benefits. Both parties emphasize the importance of comparing demand and supply resource options.

- Generation System Impacts, including avoided energy production, avoided generation capacity, avoided carbon compliance costs, avoided variable O&M and generation risk and reliability impacts; - Transmission System Impacts, including avoi...

AI summary The proposed Benefit-Cost Analysis (BCA) test evaluates impacts across generation, transmission, distribution, and utility administrative systems. It also incorporates non-utility impacts from the Energy Reform Act and More Access to Energy Act , including host-customer, fuel savings, and societal benefits like GHG reductions and health improvements.

tes" and that the "listed factors in section 6(2)(a-e) [of the Energy and Regulatory Boards Act ] supplement, but do not replace, the Board's primary mandate." In its closing submissions, it states: The operative phrase of section 6(2) is...

AI summary NS Power argues that section 6(2) of the Energy and Regulatory Boards Act requires 'appropriate consideration' of factors without prescribing their weight, and that 'sustainable development' in the BCA test lacks clear linkage to non-utility impacts. It contends E1's approach misinterprets legislative intent by transforming policy language into prescriptive requirements.

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.

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.

WACC is legally and conceptually wrong, because WACC represents NS Power shareholder risk. Furthermore, because WACC is larger than 2%, the higher value will reduce the long-term benefits in the BCA. [190] The Consumer Advocate supported t...

AI summary The text debates the appropriate discount rate for Nova Scotia Power's BCA. NS Power argues WACC is preferable as it reflects shareholder risk and immediate financial benefits, while the Consumer Advocate supports a 2% social discount rate, citing Quebec's Superior Court. NS Power also disputes the 2% rate, claiming it inflates long-term savings.