Topic:"Evidence Requirements" in M12282

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.

M12282- Evidence of P. Bowman, on behalf of IG The previously submitted Evidence of P. Bowman, on behalf of IG has been withdrawn and replaced with exhibit E-14.

AI summary The evidence submitted by P. Bowman on behalf of IG in matter M12282 has been withdrawn and replaced with exhibit E-14.

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.

as opposed to using them as a binding 2022 NSUARB 137 M10473; paragraph 72-73. Evidence, page 2; Exhibit E-1; pdf page 13 of 450. E1 responses to IRs from IG; IR-14; Exhibit E-4, pdf page 36 of 40.

AI summary The text references a Nova Scotia regulatory proceeding involving E1's responses to information requests (IR-14) and exhibits (E-1, E-4), citing case numbers and page references. It does not explicitly detail E1's proposed BCA but notes procedural context.

Utility Regulation Conducted research and analysis for regulatory and rate reviews of electric, gas and water utilities in eight Canadian provinces and territories and international. Prepared evidence and expert testimony for regulatory he...

AI summary The text details experience in utility regulation, including research and analysis for regulatory and rate reviews across Canadian provinces and territories, preparation of evidence and expert testimony, and assistance with utility capital and operations planning to evaluate rate impacts and long-term stability.

• Reliability Impacts - o Eastward is concerned that peak cost and system reliability impacts are only assumed to be reflected in NSPI's avoided cost values, and believes this should be confirmed with a clear explanation of how those costs...

AI summary Eastward argues that NSPI's avoided cost values may not fully capture peak cost and reliability impacts, requiring clarification. E1's BCA test should account for natural gas reliability losses. Eastward supports Posterity Group's evidence submission.

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.

Utility Regulation Conducted research and analysis for regulatory and rate reviews of electric, gas and water utilities in eight Canadian provinces and territories and international. Prepared evidence and expert testimony for regulatory he...

AI summary Research and analysis conducted for regulatory and rate reviews of utilities across eight Canadian provinces and territories. Expert testimony prepared for hearings, and assistance provided in utility planning to assess rate impacts and long-term stability.

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 adders should be expressed...

AI summary Daymark opposes the use of proxy adders for non-energy benefits like 'amenity,' 'empowerment,' and 'pride' in EfficiencyOne's benefit-cost analysis, arguing they are non-quantifiable. EFG defends proxy adders as assumptions representing non-energy benefits but provides no quantification. Daymark asserts EOne and EFG must prove these benefits are measurable and material.

Request IR-3: - Refer to the Evidence of Patrick Bowman at page 18, which states "A RIM test should not - be applied as a screening test for energy efficiency, as it can derive excessively narrow - metrics and fail to measure proper cost-e...

AI summary Patrick Bowman's evidence challenges the use of the RIM test for energy efficiency, arguing it produces narrow metrics. The proceeding questions why revenue changes in the PAC test are appropriate and how it differs from RIM. Key issues involve cost-effectiveness methodologies and regulatory testing frameworks.

Rebuttal Evidence of EfficiencyOne M12282 Filed with the NOVA SCOTIA ENERGY BOARD September 04, 2025

AI summary EfficiencyOne submits rebuttal evidence in a Nova Scotia Energy Board proceeding (M12282), filed on September 4, 2025. The document lacks detailed arguments or evidence specifics, indicating a procedural submission without substantive claims outlined in the provided text.

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.

3. SYNAPSE EVIDENCE - In response to Ms. Lane's concerns regarding justifying proxy adders, E1 relies on the Rebuttal Evidence of - EFG. E1 addresses Ms. Lane's suggestion for a 2029 updating process below.

AI summary E1 addresses Ms. Lane's concerns about proxy adders by relying on EFG's rebuttal evidence and plans to discuss a 2029 updating process. The response is part of a regulatory proceeding involving demand-side management and non-energy benefits considerations.

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.

3. DAYMARK EVIDENCE

AI summary The section titled 'DAYMARK EVIDENCE' is referenced, but no substantive content or analysis is provided in the given text. Further details about Daymark evidence would typically involve regulatory arguments, data, or stakeholder positions related to energy efficiency or utility proceedings.

dictional question. Nonenergy benefits stray far away from the Board's core mandate. - [45] NS Power cited Reference Re National Energy Board Act , a decision of the Federal Court of Appeal which examined Section 10(3) of the National Ener...

AI summary The NSUARB decision on non-energy benefits emphasizes their limited relevance to the Board's mandate. NS Power references a Federal Court of Appeal ruling denying the National Energy Board cost-awarding powers, contrasting with the NSUARB's focus on electricity efficiency. The Board defines 'cost-effective' under the Public Utilities Act, linking it to EfficiencyOne's activities.

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.

Request IR-3: - Refer to E1's Evidence at page 35, Table 11: Test Case Application of BCA Test (Heat Pumps). - a. Please provide all supporting analysis and workpapers in Microsoft Excel format with all cells unlocked, and formulas intact....

AI summary The request asks E1 to provide supporting analysis and workpapers in Excel format for their BCA test case on heat pumps, and inquires if they used the TRC Test methodology. It references E1's Evidence at page 35, Table 11, and seeks clarification on whether a BCA was conducted using the TRC Test.

Request IR-6: - Refer to Figure 1 and Figure 2 on pages 15 and 16 of the Evidence of David Hill. Please provide - Figure 1 and Figure 2 and all supporting analysis and workpapers in Microsoft Excel format with - all cells unlocked, and for...

AI summary Request IR-6 seeks submission of Figure 1 and Figure 2 from David Hill's evidence (pages 15-16) in Excel format with unlocked cells and intact formulas. The request emphasizes access to supporting analysis and workpapers.

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

AI summary Request IR-10 seeks clarification on non-commodity impacts in gas utility systems, including their definition, applicability to DER, required data, and EFG's methodology. The EFG Report (page 17) states non-commodity impacts are not quantified for the new jurisdictional test due to data gaps, though qualitative discussion in DSM plans and proxy adder considerations are queried.

Request IR-12: Please provide Table 5 on page 19 of the EFG Report in Microsoft Excel format with all supporting analysis and workpapers with formulas intact.

AI summary Request IR-12 seeks Table 5 from page 19 of the EFG Report in Excel format, including all supporting analysis, workpapers, and formulas. The request emphasizes preserving the integrity of the original data and calculations.

Request IR-16: - Refer to the NEB proxy adder recommendations included in Table 14 on page 45 of the EFG Report. - a. Please provide all workpapers, analysis, and sources used to develop each Non-Income Qualified proxy adder for each Measu...

AI summary Request IR-16 seeks detailed workpapers, analysis, and sources for non-income qualified proxy adders from the EFG Report, including Excel files with unlocked cells and formulas, and an explanation of differences between non-income and income-qualified proxy adders with cited sources.

INFORMATION REQUEST To: EfficiencyOne ("E1") James R. Gogan, McInnes Cooper Suite 300, 292 Charlotte Street Sydney, NS B1P 1C7 (902) 563-5920 [email protected] From: East Coast Environmental Law ("ECEL") Responses Due: July 4,...

AI summary East Coast Environmental Law (ECEL) has sent an information request to EfficiencyOne (E1), demanding responses by July 4, 2025. The request includes contact details for both parties, with ECEL's contact being Kostantina Northrup and E1's contact being James R. Gogan from McInnes Cooper.

INFORMATION REQUESTS To: EfficiencyOne James R. Gogan Counsel McInnes Cooper 300-292 Charlotte Street Sydney, NS B1P 1C7 By email: [[email protected]](mailto:[email protected]) From: Board Staff Nova Scotia Energy B...

AI summary The Nova Scotia Energy Board has issued an information request to EfficiencyOne, seeking responses by July 4, 2025. The request was sent via counsel James R. Gogan of McInnes Cooper. Contact details for Holly Chisholm, Advisor, Economics & Finance, are provided, along with the clerk's name, Crystal Henwood.

Request IR-19: - Please provide supporting empirical evidence demonstrating causation for the following Societal - Impacts: - a) energy efficiency investments and changes in medical outcomes and costs.

AI summary Request IR-19 seeks empirical evidence linking energy efficiency investments to changes in medical outcomes and costs, emphasizing the need for causation demonstration in societal impact assessments.

Request IR-22: - Page 8 of 18 of Mr. Hill's Evidence states: "For the gas system, only gas commodity costs were - considered. The gas utility system non-commodity impacts were not recommended for - quantification for the new jurisdictional...

AI summary The document requests clarification on the additional data required to quantify non-commodity gas system impacts, which were excluded from the jurisdictional test due to insufficient data on gas system costs.

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-26: - Please provide the proposed BCA in excel format with cells intact and worksheets unprotected. - Additionally, provide references for each measure, with empirical evidence that supports the link - between the benefit and as...

AI summary Request IR-26 seeks the proposed Benefit-Cost Analysis (BCA) in Excel format with intact cells and unprotected worksheets, along with empirical evidence linking each measure's benefits to costs. The request emphasizes transparency in data presentation and rigorous validation of cost-benefit claims.

Request IR-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.

Please refer to: David Roberts Email: [[email protected]](mailto:[email protected]) Assistant: McKayla Cameron Assistant's email: [[email protected]](mailto:[email protected]) July 17, 2025 VIA EMAIL Crystal Henwood...

AI summary The Consumer Advocate submits evidence from Francis Wyatt of Green Energy Economics Group, requesting the Nova Scotia Energy Board to qualify him as an expert witness on energy efficiency programs. This is Wyatt's first expert testimony to the Board. The proceeding relates to Matter M12282, concerning a new benefit-cost analysis test.

In Reference to DIRECT EVIDENCE OF MELISSA WHITTEN

AI summary The document references direct evidence provided by Melissa Whitten in a Nova Scotia regulatory proceeding, though specific details of the evidence or its implications are not included in the provided text.

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.

Request IR-3: - Refer to the Evidence of Patrick Bowman at page 18, which states "A RIM test should not be applied as a screening test for energy efficiency, as it can derive excessively narrow metrics and fail to measure proper cost-effec...

AI summary Patrick Bowman argues against using the RIM test as a screening tool for energy efficiency due to its narrow metrics. The proceeding questions why revenue changes should be considered in the PAC test and how this differs from the RIM test's approach.

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.

\ \ EXTERNAL EMAIL / COURRIEL EXTERNE \ \ Exercise caution when opening attachments or clicking on links / Faites preuve de prudence si vous ouvrez une pièce jointe ou cliquez sur un lien Good morning, Ms. Henwood, I will be appearing as c...

AI summary Nancy Rubin, counsel for the Industrial Group, along with Brianne Rudderham, is preparing for proceedings involving expert Patrick Bowman. They seek an extension to decide on virtual appearance after cross-examination.

\ \ EXTERNAL EMAIL / COURRIEL EXTERNE \ \ Exercise caution when opening attachments or clicking on links / Faites preuve de prudence si vous ouvrez une pièce jointe ou cliquez sur un lien Good morning, Ms. Henwood, I will be appearing as c...

AI summary Nancy Rubin, counsel for the Industrial Group, informs Crystal Henwood of appearing with Brianne Rudderham and expert Patrick Bowman. They seek time to decide if Bowman may testify virtually after cross-examination, requesting a brief extension.

This is an external email. Good afternoon, This will acknowledge receipt of EfficiencyOne's Partial Consensus Agreement regarding the above matter received by the Board on September 19, 2025. It has been directed to the Board and staff and...

AI summary The email acknowledges receipt of EfficiencyOne's Partial Consensus Agreement, dated September 19, 2025, which has been directed to the Board and staff and posted as Exhibit N-32 in Matter No. M12282.

Wyatt, page 3, line 6 and page 4, lines 5 – 7; E-7, Evidence of Courtney Lane, page 17, lines 16 – 18, & page 9, lines 4 – 6. M12282, E-14, Evidence of Patrick Bowman, Revised, page 20, lines 5 – 7. M12282, E-1, E1 Evidence and Application...

AI summary The document discusses concerns raised about the lack of documentation for proxies in the Nova Scotia BCA, with Mr. Neme providing justification for proxy values. The PCA addresses these concerns by proposing lower proxy values. Courtney Lane and others testified about evidence and recommendations related to proxy adders and BCA methodology.

n and necessity for the enactment; (b) the circumstances existing at the time it was passed; (c) the mischief to be remedied; (d) the object to be attained; DATE FILED: October 14, 2025 Page 24 of 42 A portion of which is cited in Dow Chem...

AI summary The text discusses statutory interpretation principles, emphasizing context in analyzing laws like the Public Utilities Act . It references Supreme Court of Canada cases (Dow Chemical, Bell ExpressVu) and the Interpretation Act (RSNS 1989, c 235), highlighting the need to consider legislative history, mischief, and consequences of interpretations.

lue," but that the ultimate amounts concluded would have been negotiated, and not a "re-quantification or adding up of the individual components" of the measure categories referenced.[42](#page-13-10) It is difficult, then, to understand t...

AI summary The document critiques E1 and EFG's handling of non-energy benefits in the Proposed BCA, noting that proxy adders were not re-quantified and relied on American state evidence rather than Nova Scotia data. E1 argues the figures are negotiated, not re-quantified, while EFG claims they are conservative. The Partial Consensus Agreement's Appendix A is questioned for lacking clear justification.

are "other fuel impacts, host customer impacts(all costs and benefits), greenhouse gas impacts, and criteria air pollutant impacts"[6](#page-2-2) to be calculated or quantified in the following ways: - The utility system impacts and other...

AI summary EfficiencyOne (E1) proposes quantifying impacts like fuel costs, greenhouse gas emissions, and societal effects using methods such as avoided costs, social cost of carbon, and proxy adders. A 2% discount rate aligns with the Energy Reform Act (ERA) and sustainable development goals. E1 advocates for an 'evergreen' periodic review via the Demand Side Management Advisory Group (DSMAG) to ensure alignment with evolving Nova Scotia policy objectives.

7 b. Summary of Evidence 8 9 An extensive amount of written and oral evidence has been provided in this matter. The Consumer 10 Advocate does not intend to summarize all of the evidence provided in this matter, but summarizes 11 some of th...

AI summary The Consumer Advocate acknowledges an extensive amount of written and oral evidence submitted but focuses on summarizing key relevant points rather than providing a comprehensive overview of all evidence presented.

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.

dered but did not approve of the application filed by Newfoundland Power and 30 Newfoundland Hydro to use a modified test which would have accounted for beneficial electrification.[50](#page-13-12) 31 32 33 The Consumer Advocate remains of...

AI summary The Consumer Advocate supports E1's BCA test over the modified PAC test proposed by Mr. Bowman, arguing it aligns better with Nova Scotia's policy goals. They acknowledge the traditional PAC test could serve as a secondary measure. The application by Newfoundland Power and Hydro for a modified test was not approved.

line 10. 4 M12282, Exhibit E-1, E13 Evidence of Melissa Whitten, July 17, 2025, subsection VI. Conclusions and Recommendations, Answer regarding Observations, page 16 of 17, at lines 3-13.

AI summary Evidence from Melissa Whitten in matter M12282, discussing conclusions and recommendations in response to observations, as part of Exhibit E-1, E13, dated July 17, 2025, referencing page 16 of 17, lines 3-13.

Board to do anything about them. Yet this is contrary to the principle of legislative interpretation that legislation is assumed to have meaning: "the legislator does not speak in vain".[8](#page-4-2) Third, E1 agrees that the Board must g...

AI summary E1 argues that the Proposed BCA test is the appropriate tool for the Board to consider sustainable development and prosperity, citing its alignment with the National Standard Practice Manual (NSPM) and endorsements from experts including the SBA and IG. The test is seen as a consistent, transparent framework for cost-effectiveness screening in DSM decisions.

2.2 CRITIQUE OF HOST CUSTOMER NON-ENERGY IMPACTS AND SOCIETAL IMPACTS The IG critiques the inclusion of non-energy impacts and broad societal costs, which are characterized as vague, subjective, and unsupported by evidence. E1 disagrees. T...

AI summary The IG criticizes non-energy and societal impacts as vague and unsupported, while E1 argues they are backed by academic literature and regulatory precedent, citing multiple experts and noting Mr. Bowman's dissent. E1 emphasizes expert consensus and ongoing evidence development.

[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.