Topic:"Forecasting Methodology" in M12282

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AI summary The text discusses the importance of regulatory compliance and the need for accurate forecasting methodologies in utility proceedings. It references a variety of regulatory processes, including benefit-cost analyses and prudence reviews, and highlights the role of entities such as Nova Scotia Power and the Office of People’s Counsel in these matters.

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AI summary The document discusses the impact of regulatory mechanisms on energy costs and the need for adjustments in billing practices. It references the importance of aligning base rates with actual costs and the role of fuel-cost-adjustment mechanisms in creating incentives. The text also highlights the need for accurate forecasting and the evaluation of programs.

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AI summary The document discusses the importance of aligning base rates with actual costs to avoid perverse incentives, referencing the Board's fuel-cost-adjustment mechanism in 2020. It also touches on the role of distributed energy resources and the need for accurate forecasting in regulatory proceedings.

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AI summary The text discusses the implications of the fuel-cost-adjustment mechanism and its impact on cost recovery and rate design, highlighting concerns about delayed rate adjustments and the need for alignment between base rates and actual costs. It also touches on the role of regulatory oversight and the importance of accurate forecasting and prudence reviews.

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AI summary The text discusses the challenges and considerations in setting rates and managing costs, including the use of mechanisms like fuel-cost-adjustment and the impact of delayed base rates on incentives. It also touches on the importance of accurate forecasting and the role of regulatory oversight in ensuring fair and effective energy management.

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AI summary The document discusses the impact of the fuel-cost-adjustment mechanism on rate structures, the need for aligning base rates with actual costs, and the implications for cost recovery. It mentions the role of regulatory oversight, prudency reviews, and the importance of accurate forecasting in energy regulation.

1 Request IR-14: 2 3 With regards to Table 7 on page 30 of 38 of E1's Evidence: 4 5 (a) Please describe the environmental compliance costs that are embedded in the 6 commodity price. 7 8 (b) Please describe the non-embedded environment and...

AI summary The text details a regulatory proceeding involving questions about environmental compliance costs and proxy values used in assessing host customer non-energy impacts. E1 and EFG provide responses outlining how compliance costs are embedded in commodity prices and how proxy values are developed and applied in performance requirements.

[3](#page-48-0) M12282, E1 BCA Test Application, May 16, 2025, Appendix A, Attachment 2: National Standard Practice Manual, page 276 of 302. i) EFG did not conduct a review of discount rates used in cost effectiveness testing in Canadian j...

AI summary The document references a BCA Test Application and discusses the lack of a review of discount rates used in cost effectiveness testing in Canadian jurisdictions. It highlights the importance of developing a jurisdiction-specific BCA test that aligns with Nova Scotia's policy goals and objectives, and references the Database of State Screening Practices for American discount rates.

ded by NS Power on August 23, 2024[1](#page-68-0) in M12249, E1 2026 DSM Extension Application, Exhibit 8(i), E1 Response to Synapse, RIR-05, Attachment 1, June 25, 2025. which NS Power applied a 9% unforced capacity (UCAP) PRM adjustment;...

AI summary E1 responds to NS Power's avoided cost methodologies, using system-wide T&D costs for DSM calculations. E1 advocates for forward-looking T&D cost analysis per NSPM Principle 5, considering future electrification and infrastructure costs. NS Power's PRM adjustment and constrained-system costs are noted, though locational-specific DSM remains under development.

What is E1 proposing as a BCA? - E1 has proposed that its current reliance on the Total Resource Cost ("TRC") screening test for cost- - effectiveness (and to a lesser degree, the Program Administrator Cost ("PAC") test) be replaced by a n...

AI summary E1 proposes replacing the Total Resource Cost (TRC) and Program Administrator Cost (PAC) tests with a new Benefit-Cost Analysis (BCA) tailored to Nova Scotia, incorporating societal impacts. The BCA would apply at the Portfolio level to assess public interest, with a 2% discount rate and proxy adders for non-energy benefits. E1 seeks Board approval for these changes.

OTHER BCA CONSIDERATIONS - E1's Application relies on the National Standard Practice Manual for Benefit-Cost Analysis of - Distributed Energy Resources ("NSPM"), produced by the National Energy Screening Project. - Does E1 appropriately in...

AI summary The NSUARB found E1's BCA methodology inconsistent with the NSPM's principles, particularly Principle 1, which requires treating DERs as utility system resources. E1's approach uses non-standard discount rates and unbalanced plan design, potentially biasing resource investment decisions against residential and business interests.

OTHER BCA CONSIDERATIONS - E1's Application relies on the National Standard Practice Manual for Benefit-Cost Analysis of - Distributed Energy Resources ("NSPM"), produced by the National Energy Screening Project. - Does E1 appropriately in...

AI summary E1's Benefit-Cost Analysis (BCA) approach is criticized for violating Principle 1 of the National Standard Practice Manual (NSPM) for DERs, which mandates treating DERs as utility system resources and comparing them with other resources using consistent methods. The NSUARB argues E1's BCA uses inconsistent inputs like discount rates and unbalanced plan design.

Discount rate Using the weighted average cost of capital (WACC) as a discount rate on the cost-effectiveness test appears particularly ill-suited to Nova Scotia. The WACC represents a discount rate associated with the goal of maximizing ut...

AI summary The text argues that using the weighted average cost of capital (WACC) as a discount rate in Nova Scotia's cost-effectiveness test prioritizes utility investor returns over public and provincial interests. It advocates for a social discount rate aligned with sustainable development and intergenerational equity, citing the Energy Reform Acts. EfficiencyOne's localized energy poverty data is recommended for consideration.

Response: (a) and (b) Generally, yes. Mr. Bowman understands the Board is required to assess NS Power capital expenditures that exceed $1 million in value, primarily through the Annual Capital Expenditure (ACE) process or through special c...

AI summary NSP evaluates the WTI project using a 6.72% WACC, aligning with prior proceedings. Mr. Bowman argues that the E1 discount rate proposal for Energy Efficiency uses an arbitrarily low rate, conflicting with NSPM manual Principle 1, which requires consistent evaluation of DERs as utility resources. The WTI project is part of Integrated Resource Planning, incorporating Energy Efficiency and transmission resources.

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

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

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).

E1 Response E1's position is that the use of proxy values for certain non-energy benefits is both reasonable and appropriate and consistent with jurisdiction specific studies. The NSPM for screening energy efficiency and distributed energy...

AI summary E1 argues that using proxy values for non-energy benefits (NEBs) in BCA is reasonable and aligns with the NSPM, supported by EFG and Synapse Energy Economics. E1 rejects claims of bias, emphasizing symmetric treatment of impacts. Daymark's Melissa Whitten counters, requesting third-party validation of NEB quantification (amenity, empowerment, pride).

Q. SHOULD ONLY THOSE BENEFITS THAT CAN BE PRECISELY QUANTIFIED BE INCLUDED IN THE NEW BENEFIT COST TEST? A. No. If one excludes all benefits that are difficult to quantify precisely, then those values are by default assigned a value of zer...

AI summary The answer argues against excluding non-quantifiable benefits from the new benefit-cost test, stating that assigning them a zero value is inappropriate if they are known to exist. It references the NSPM principles, which emphasize accounting for relevant and material benefits, even if difficult to quantify.

Synapse Courtney Lane of Synapse states: - The use of proxy values is a reasonable approach to estimate host customer non energy benefits (NEB) in cost-effectiveness analysis. However E1 has not sufficiently justified its proposal for NEB...

AI summary Courtney Lane of Synapse argues that while proxy values are reasonable for estimating non-energy benefits (NEB) in cost-effectiveness analysis, EfficiencyOne (E1) has not adequately justified its proposed NEB proxy values. She emphasizes the need for proxies to be grounded in literature, other jurisdictions' practices, and jurisdictional differences rather than arbitrary choices.

EFG Response The approach of using proxy values was deliberate and not arbitrary. The approach was reviewed and discussed with the Demand Side Management Advisory Group ("DSMAG") in two workshop sessions, and open to written review and com...

AI summary EFG defends using proxy values for non-energy impacts (NEIs), citing discussions with DSMAG and referencing the ACEEE database. They argue that adopting values from other jurisdictions is imprecise and that proxy adders, though small, require regular review to remain accurate. EFG recommends adopting their proposed values with an ongoing 'evergreening' process.

4.2 2% DISCOUNT RATE

AI summary This section discusses the application of a 2% discount rate in the Benefit-Cost Analysis (BCA) for regulatory proceedings in Nova Scotia. The analysis involves considerations by Nova Scotia Power (NSP) and the Nova Scotia Utility and Review Board (NSUARB), focusing on the implications of this rate for energy and non-energy benefits.

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

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

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

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

cost of carbon, reductions in air pollutants (NOx, SO₂, particulates) with associated health and environmental benefits, and societal-level resilience (continuity of critical services during outages). [20] In the BCA test, E1 has proposed...

AI summary E1 proposes a BCA test quantifying utility impacts via avoided costs and commodity costs, using the social cost of carbon for GHG emissions and a 2% discount rate aligned with the Energy Reform Act . Non-energy benefits, like comfort and maintenance savings, are valued via proxy adders applied to energy benefits or measure costs, ensuring these impacts are monetized and discounted consistently.

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.

tend to all the Board mandates. It argued that the use of a global social cost of carbon in integrated resource and capital planning would fundamentally skew these processes leading to absurd results. [42] In terms of the discount rate, th...

AI summary The Industrial Group opposes using a global social cost of carbon in planning, arguing it skews results. It rejects the 2% social discount rate, advocating for WACC instead, and opposes including non-energy benefits in DSM cost-effectiveness testing, deeming them inappropriate and lacking evidentiary support.

e included in the BCA test (comfort, amenity, health and safety, empowerment, and pride) and non-energy benefit factors are adequately linked to "sustainable development" and "sustainable prosperity". [53] NS Power agrees with Mr. Bowman's...

AI summary NS Power agrees with Mr. Bowman's discount rate stance, rejects a 2% social discount rate, and emphasizes the need for a sound, evidence-based regulatory framework. It opposes the Industrial Group's PAC test, favoring its modified TRC test that accounts for broader fuel impacts. NS Power also criticizes the procedural risks of adopting unproven 'evergreen' processes.

at best supports those requirements, and the level of appropriate consideration required in that regard." [68] Eastward commented on the 2% social discount rate in its closing submissions. It stated: The driver for the 2% discount rate was...

AI summary Eastward Energy critiques the 2% social discount rate used by EFG, arguing it overemphasizes sustainability at the expense of balanced DSM policy objectives. Eastward urges the NSUARB to reconsider this rate during proceedings.

4.5 Discount Rate [169] Benefit-cost analysis involves comparing all the costs and benefits of a program over a period of time. There will be a stream of costs and benefits that are usually spread over several years, and in some cases, dec...

AI summary The section discusses the role of discount rates in Benefit-Cost Analysis (BCA) for distributed energy resources. It explains that discount rates determine the present value of future costs and benefits, with the NSPM outlining three categories: WACC, customer-focused rates, and societal discount rates. Higher rates prioritize near-term costs, while lower rates balance long-term considerations.

s. 7.1 about the discount rate to be used: The discount rate is the rate at which future costs and benefits are converted to their present equivalents. Discounting accounts for the fact that: - there is a time preference for current consum...

AI summary The NSUARB mandates using the opportunity cost of capital (WACC) as the discount rate for DSM programs, aligning with Treasury Board guidelines. This reflects the alternative investment returns of funds from NS Power ratepayers. The Board rejects social discount rates except for long-term regulatory proposals, emphasizing WACC's consistency with NS Power's IRP and PAC test requirements.

Request IR-20: EFG states that the "consultant team developed two quantitative examples to translate proxy values into impacts per kWh and per MMBtu NEI values" on page 47 of the EFG report. Please provide all associated workpapers in Micr...

AI summary EFG states that their consultant team developed two quantitative examples to translate proxy values into impacts per kWh and per MMBtu NEI values on page 47 of the EFG report. The request is for all associated Excel workpapers with unlocked cells and intact formulas.

Request IR-20: - a) Please cite the source for the cost of carbon used in the BCA. - b) Please explain how the proxy for the host customer was selected and measured. - i. Please describe how the proxy is estimated and applied in the BCA. -...

AI summary Request IR-20 seeks clarification on the BCA's carbon cost source, proxy selection methodology, discount rate justification, and use of Canadian vs. American rates in NSPM. Questions focus on transparency, methodology, and regional applicability of economic assumptions.

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-31: - Text Box 1: Summary of Key EFG Recommendations item 3) states that actual avoided capacity - cost stream should have a planning reserve margin adjustment. It also states that constrained - and unconstrained locations can b...

AI summary Request IR-31 seeks explanations on three aspects of E1's costing methodology: (a) avoided capacity adjustment and data sources, (b) constrained/unconstrained transmission/distribution locations influenced by E1 programs, and (c) basis for estimating transmission/distribution cost growth.

Request IR-15: - Referring to Exhibit E-1, the Report, Page 45 of 68, Table 14, please explain how the - percentages in columns 2 and 3 are created what are the data points that are used to create the - percentage? - a) Please explain how...

AI summary Request IR-15 seeks clarification on the methodology used to calculate percentages in Table 14 of Exhibit E-1 and how this aligns with EOne's commitment to using reliable data for benefit estimation.

17 Request IR-14: - 18 Reference: E-1, Appendix B. - 19 Does the requested approval of a new BCA include the following as approved values, or are they 20 inputs that would be considered at each future DSM Plan review: - 21 (a) use of a 2%...

AI summary The document questions whether the approval of a new BCA includes specific values (2% social discount rate and NEB proxy adders) as fixed approvals or if they are inputs for future DSM Plan reviews, referencing E-1, Appendix B.

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.

Host Customer Non-Energy Benefits The proposed BCA test suggests that the Board should weigh a number of unquantifiable proposed benefits, including customer pride, empowerment, economic well-being, comfort, amenity, and health and safety....

AI summary The proposed BCA test includes subjective non-energy benefits like customer pride and health, valued via proxy percentages of energy benefits. Critics argue these are vague and unsupported, conflicting with PUA's DSM definition. E1 clarified non-energy impacts, but the Industrial Group opposes proxy adders for intangible benefits. Synapse's consultant Courtney Lane raised concerns about proxy value arbitrariness.

n. And if you consider the revenue they're going to get from selling that power, it's more than 13 million. So that would pass a PAC test and lower net cost to customers. It would pass 79I of the Act. We've run an electrification program,...

AI summary The text discusses revenue from power sales passing a PAC test and lowering customer costs, aligning with 79I of the Act. Electrification programs, while incurring costs, generate more revenue. Bowman argues E1 (EfficiencyOne) must consider broader cost savings beyond BCA metrics. Eastward highlights the value of Eastward's potential DSMAG involvement in advising E1's 2027-2031 plan.

espect to Nova Scotia Power's capital expenditure justification criteria when an element of capital budgeting is related to identification of least-cost alternatives for meeting needs.[62](#page-14-0) Eastward submits that the use of the s...

AI summary Eastward challenges the use of social cost of carbon in IRP analysis, warns against overemphasizing sustainability in discount rate calculations, and highlights high costs of meeting 2030 renewable energy targets. It stresses the need for balanced policy considerations and stakeholder input.

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.

Discount Rate NS Power agrees with the submission by Mr. Bowman that it is inappropriate to use a low discount rate as proposed by E1 when assessing utility resources that are complementary to, or alternatives to, bulk power projects. The...

AI summary NS Power opposes E1's proposal to use a 2% discount rate for assessing utility resources, arguing it's inappropriate for utility spending decisions. They emphasize that the cited references apply to government policy, not utility projects, and warn that a lower rate inflates long-term savings while ignoring current affordability challenges. NS Power advocates using their cost of capital to prioritize immediate financial benefits for rate payers.

RIR 1 (a) and 1(a)(i}, page 2 of 2, at lines 4-9. 11 M12282, Exhibit E-16, SBA (IG) RIR 2(a}, page 1 of 2. 12 M12282, Exhibit E-17, SBA {IG) RIR 2(b), page 2 of 2, at lines 4-9. - 1 In the interest of obtaining access to the measures and b...

AI summary The Small Business Advocate (SBA) agrees to the Consensus Agreement, which reduces proxy values for certain measures and commits EfficiencyOne to an Evergreen process for reviewing the BCA framework. The SBA recommends adopting the amended BCA Test for 2027-2031, emphasizing progress on DSM while addressing concerns about quantifying non-monetary benefits like empowerment.

p and Immigration) v. Vavilov , 2019 SCC 65 at para 44. [ 4 ](#page-1-3) Efficiencyone (Re) , 2020 NSUARB 56, at paras 4, referenced at page 7 of the Industrial Group's closing submissions. 5 [P](#page-1-5)ages 3-4 of the Industrial Group'...

AI summary The Consumer Advocate argues the 2% discount rate aligns with Nova Scotia's legislative context and Canadian/American guidance, while the Industrial Group and Eastward Energy support using NSPI's WACC. The Consumer Advocate also cites Quebec's comparable legislation and the Superior Court of Quebec's ruling on sustainability concerns.

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.

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.

5. REQUESTED BOARD ORDER Based the evidence and analysis before the Board in this matter, including as set out in these Reply Submissions, E1 respectfully requests the Board approve the Proposed BCA as supplemented by the PCA, specifically...

AI summary E1 requests the Board to approve the Proposed BCA supplemented by the PCA, including a 2% discount rate, proxy values for the 2027-2031 DSM Plan, and the evergreen process for future DSM applications. The request aligns with PUA 79H(2) and references prior submissions (M12282).

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.

The Modified PAC test for Electrification The IG presents a secondary test called the "Modified PAC test for Electrification" for consideration to address this requirement which accounts for increased utility revenues as a benefit with res...

AI summary The IG proposes a 'Modified PAC test for Electrification' that includes increased utility revenues as a benefit of electrification. NS Power supports this but argues for incorporating 'other fuel impacts' to align with a Total Resource Cost (TRC) test. Both agree that a 2% discount rate is inappropriate, advocating for NS Power's cost of capital instead.

Response to Eastward Energy (EE) Closing Submissions Here, too, NS Power does not intend to summarize the entirety of EE's closing submission but offers the following comments. On EE's first request, NS Power takes no position on Eastward...

AI summary NS Power does not take a position on Eastward Energy's (EE) request to join DSMAG and confirms that peak demand, ancillary services, and reliability are considered in avoided cost modelling, which is based on the Integrated Resource Plan (IRP) model. NS Power emphasizes ongoing discussions through DSMAG and IRP-related work.

cost of carbon, reductions in air pollutants (NOx, SO₂, particulates) with associated health and environmental benefits, and societal-level resilience (continuity of critical services during outages). [20] In the BCA test, E1 has proposed...

AI summary E1 proposes a BCA test quantifying utility impacts via avoided costs and commodity costs, using the social cost of carbon and a 2% discount rate aligned with the Energy Reform Act . Non-energy benefits (e.g., comfort, maintenance) are valued via proxy adders applied to net energy benefits or measure costs, discounted over the measure's lifespan to ensure transparency and avoid understating societal impacts.

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.

tend to all the Board mandates. It argued that the use of a global social cost of carbon in integrated resource and capital planning would fundamentally skew these processes leading to absurd results. [42] In terms of the discount rate, th...

AI summary The Industrial Group opposes using a global social cost of carbon and a 2% discount rate in benefit-cost analysis, arguing they skew planning processes and lack legislative basis. It also rejects including non-energy benefits in cost-effectiveness testing for demand-side management, citing insufficient evidence and inappropriate focus on customer feelings.

e included in the BCA test (comfort, amenity, health and safety, empowerment, and pride) and non-energy benefit factors are adequately linked to "sustainable development" and "sustainable prosperity". [53] NS Power agrees with Mr. Bowman's...

AI summary NS Power agrees with Mr. Bowman's discount rate conclusion, opposes adopting new approaches without defined mechanics, and prefers its modified TRC test over the Industrial Group's PAC test. It emphasizes the need for a sound, evidence-based regulatory framework aligned with legislative requirements.

4.5 Discount Rate [169] Benefit-cost analysis involves comparing all the costs and benefits of a program over a period of time. There will be a stream of costs and benefits that are usually spread over several years, and in some cases, dec...

AI summary The section explains the role of discount rates in Benefit-Cost Analysis (BCA), emphasizing their importance in reflecting time preference and opportunity costs. It outlines three categories of discount rates from the National Standard Practice Manual (NSPM): WACC, customer-focused rates, and societal discount rates, each serving different purposes in evaluating distributed energy resources.

4.5.1 Findings [192] Discounting is a fundamental component of BCA. Applying a social discount rate places greater emphasis on future benefits than a standard discount rate typically would. Environment and Climate Change Canada's SC – GHGs...

AI summary The text discusses the use of social discount rates in Benefit-Cost Analysis (BCA), noting that Environment and Climate Change Canada's SC-GHG guidance employs a lower discount rate to prioritize future benefits. It criticizes E1 for not following the Treasury Board's policy on when to apply a social discount rate, as outlined in the Policy on Cost-Benefit Analysis .

s. 7.1 about the discount rate to be used: The discount rate is the rate at which future costs and benefits are converted to their present equivalents. Discounting accounts for the fact that: - there is a time preference for current consum...

AI summary The document establishes that the discount rate for regulatory analyses should be based on the opportunity cost of capital (WACC), as per Treasury Board guidelines. It emphasizes alignment with NS Power's IRP and the Public Utilities Act, rejecting social discount rates except for specific long-term cases. The NSUARB mandates WACC for cost-effectiveness testing of DSM programs, citing NS Power's funding source and the need for comparable evaluations.

4.6.1 Findings [204] The Board considers the issue regarding average versus marginal generation emission rates to be worthy of further consideration. During crossexamination, E1's witnesses stated that, for expediency, average emission rat...

AI summary The Board recommends using long-run marginal generation emission rates over average rates in E1's modelling, citing the need for accuracy. E1 used average data from NS Power for expediency but acknowledges the need for refinement.