E-5E1 (NSEB) RIR 1-46
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e currently measuring Host Customer "Asset Value" impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure, program or portfolio level.)
AI summary The text asks whether the current Benefit-Cost Analysis (BCA) test measures Host Customer 'Asset Value' impacts, and seeks clarification on the states involved and the level (measure, program, portfolio) at which the test is applied.
Resources Handbook](https://www.nationalenergyscreeningproject.org/resources/quantifying-impacts/) [(MTR Handbook)](https://www.nationalenergyscreeningproject.org/resources/quantifying-impacts/) . NESP is primarily funded by E4TheFuture wi...
AI summary EfficiencyOne proposes a BCA framework aligned with NSPM principles for DSM plans. The framework requires further analysis of utility system impacts, though EFG believes benefits may outweigh costs. Impact quantification will occur during DSM plan development, with the MTR handbook as a technical reference.
M portfolio and plan. The MTR handbook provides a useful technical reference for the steps and resources that will be used in quantifying individual impact categories. (d) [https://www.nationalenergyscreeningproject.org/wp-content/uploads/...
AI summary EfficiencyOne (E1) applies for approval of a new BCA test for DSM plans in Nova Scotia, referencing jurisdictional-specific tests adopted by states like Connecticut and Maine, and the societal cost test used in Arizona and Vermont. The application cites the National Standard Practice Manual (NSPM) and the Database of Screening Practices (DSPs) to support its framework.
M12282 – EfficiencyOne (E1) Application for Approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans
AI summary EfficiencyOne (E1) seeks approval for a new Benefit-Cost Analysis (BCA) test to evaluate Demand Side Management (DSM) plans under Nova Scotia regulatory proceedings. The application involves assessing DSM initiatives using updated methodologies, with implications for energy policy and regulatory frameworks.
E-8See new revised evidence submitted under E-14 (Evidence of P. Bowman, on behalf of IG)
6 passages
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.
tilities Act, s.79A(b). Specifically, the Board must determine the DSM actions to be undertaken, per s.79H(1), but must also must review the agreement, per s.79L. Public Utilities Act. s.79C(2)(a).
AI summary The Board's responsibilities under the Public Utilities Act include determining Demand Side Management (DSM) actions and reviewing agreements, as outlined in sections 79A(b), 79H(1), 79L, and 79C(2)(a). These provisions guide the regulatory process for DSM initiatives.
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.
EVALUATION OF E1'S PROPOSED BCA
AI summary The document evaluates Efficiency One's proposed Benefit-Cost Analysis (BCA) as part of a regulatory proceeding in Nova Scotia, focusing on energy efficiency programs and their alignment with jurisdiction-specific tests and societal cost considerations.
benefits). Public Utilities Act, s.79H(1). Public Utilities Act, s.79L(4). Public Utilities Act, s.79I(1). 2020 NSUARB 56 M08888, paragraph 33, pdf page 15 of 19. Public Utilities Act, s.79L(4).
AI summary The text references multiple sections of the Public Utilities Act (s.79H(1), s.79I(1), s.79L(4)) and cites a 2020 NSUARB decision (M08888, paragraph 33, pdf page 15 of 19), indicating legal and regulatory considerations in the proceeding.
BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...
AI summary Bowman Economic Consulting Inc. provides utility regulation consulting, focusing on rate design, cost of service analysis, and demand-side management. They represent industrial energy users in regulatory proceedings before Manitoba and Newfoundland boards, including General Rate Applications and resource planning hearings.
E-10-(i)Resume of Francis Wyatt
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Professional Experience December 2005 – Present Co-Founder, Green Energy Economics Group, Inc ., Cuttingsville, VT. Consultancy specializing in energy-efficiency and renewable resource portfolios investing in electricity and gas savings, c...
AI summary The individual's professional experience spans energy efficiency, renewable resources, and civil engineering. They co-founded Green Energy Economics Group, Inc., developed cost-effectiveness models for demand-side management, and worked on energy-saving analyses. Previous roles include Senior Analyst at Optimal Energy, Inc., and civil engineering positions at Enman Engineering and Nowlan Engineering. Their work includes utility regulatory proceedings and program planning.
Pennsylvania Program design, implementation planning, regulatory support, technical reference manual development and portfolio cost-effectiveness tool for Columbia Gas of Pennsylvania. Assisted - with testimony before the Pennsylvania Publ...
AI summary Activities include program design, regulatory support, and testimony preparation for energy companies in Pennsylvania before the PUC. Involves Columbia Gas, Philadelphia Gas Works, UGI Gas, and Peoples Natural Gas, with multiple docket numbers spanning 2006–2022. Focuses on energy efficiency, cost-effectiveness analysis, and portfolio design.
Louisiana Empirical costs projections and cost-effectiveness analysis of alternative energy-efficiency resource acquisition scenarios for Entergy New Orleans, prepared for the Alliance for Affordable Energy and submitted as comments to the...
AI summary Empirical cost projections and cost-effectiveness analysis of energy-efficiency resource acquisition scenarios for Entergy New Orleans were prepared by the Alliance for Affordable Energy and submitted to the City Council in April-May 2013 as part of a regulatory proceeding.
E-14Evidence of P. Bowman, on behalf of IG - Revised (Old evidence filed under E-8)
8 passages
PRE-FILED TESTIMONY OF PATRICK BOWMAN IN REGARD TO EFFICIENCY ONE ("E1") BENEFIT-COST ANALYSIS TEST ("BCA") Submitted to: The Nova Scotia Energy Board on behalf of The Industrial Group Prepared by: Bowman Economic Consulting Inc. 161 Rue H...
AI summary Patrick Bowman of Bowman Economic Consulting Inc. submitted a pre-filed testimony to the Nova Scotia Energy Board on behalf of The Industrial Group regarding the Efficiency One (E1) Benefit-Cost Analysis (BCA) test. The document outlines the submission's context, including the preparer and revision date.
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.
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 document references E1's proposal for a Benefit-Cost Analysis (BCA) within a Nova Scotia regulatory proceeding. It cites legal matter numbers, exhibits, and page references from evidence submissions, including E1's responses to information requests and related documents.
Is the E1 commentary a fair criticism of the TRC as previously applied in Nova Scotia? - Yes, from a principled perspective. In general, BCA should include all measurable and meaningful benefits - and costs at the proposed assessment scale...
AI summary The E1 commentary is considered a fair criticism of the TRC in Nova Scotia for excluding non-energy benefits. However, prior TRC application was restricted by M08888, which limited the Board’s jurisdiction. The new Energy and Regulatory Boards Act may permit non-energy considerations, though legal interpretation is pending. Technical challenges remain in revising the TRC test if jurisdiction expands.
Is the Proposed E1 BCA the only possible response to the criticism? - No. From the outset, the assessment to be conducted was to consider two alternatives to the TRC – - either relying primarily on PAC, or developing a new Nova Scotia spec...
AI summary The Proposed E1 BCA is not the only response to criticism. Alternatives include using PAC, developing a new test, or adjusting TRC to balance non-energy benefits. Legislative changes enabled a third approach. Cited sections of the Public Utilities Act and a 2020 NSUARB order (M08888) are referenced.
BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...
AI summary Bowman Economic Consulting Inc. provides regulatory consulting services for utility rate design, cost of service analysis, and demand side management (DSM) initiatives. They represent industrial energy users in Manitoba and Newfoundland and Labrador before regulatory bodies, including the Manitoba Public Utilities Board and Newfoundland Board of Commissioners of Public Utilities, on matters such as rate structures, surplus energy rates, and resource planning hearings.
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.
Sample Projects: For the Office of the Utilities Consumer Advocate of Alberta (2016 - 2024): Analysis and strategic support of Government agency representing the interests of small utility customers. Addressed matters of utility rates and...
AI summary The text details a range of regulatory and utility-related projects across Alberta, Ontario, British Columbia, Manitoba, and other jurisdictions. It covers rate design, asset depreciation, utility regulation, and energy policy, with involvement from multiple regulatory bodies and organizations.
E-24Rebuttal Evidence of E1 including Appendix A - Energy Futures Group Rebuttal Evidence
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EfficiencyOne IN THE MATTER OF The Public Utilities Act , RSNS 1989, c. 380, as amended -and- IN THE MATTER OF An Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans
AI summary The document pertains to a regulatory proceeding under the Public Utilities Act, RSNS 1989, c. 380, involving an application to approve a new benefit-cost analysis test for evaluating demand side management plans. EfficiencyOne is referenced as the subject of the proceeding.
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.
to provide justification on why any such measure falls below the 1.0 threshold when the BCA test is applied. Such information will inform decisions regarding inclusion of programs and measures, given Government of Nova Scotia, Department o...
AI summary The document discusses the need to justify measures below a 1.0 BCA threshold for inclusion in programs. It references Nova Scotia's legislative efforts to modernize its electricity system, including the Environmental Goals and Climate Change Reduction Act. The government emphasizes strategic electrification, efficiency programs for low-income households, and environmental protection as key policy goals.
2.3 NS POWER CUSTOMER INTERESTS AS PRIMARY
AI summary The section emphasizes that Nova Scotia Power (NSP) must prioritize customer interests in regulatory proceedings, aligning with obligations under the National Standard Practice Manual (NSPM) and considering non-energy benefits (NEB) and demand-side management (DSM) initiatives.
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.
E1 Response E1 supports the need for ongoing stakeholder engagement and proposes an 'evergreen' periodic review process via the DSMAG. Additional information regarding the proposed 'evergreen' process can be found in Section 3.1 of this Re...
AI summary E1 supports ongoing stakeholder engagement and proposes an 'evergreen' periodic review process through the DSMAG. This is detailed in Section 3.1 of the Rebuttal Evidence. The text also references Francis Wyatt's evidence (M12282, E-10) regarding consumer advocacy.
4.2 COST OF CARBON
AI summary The section titled '4.2 COST OF CARBON' introduces a regulatory proceeding discussion on carbon cost analysis. No detailed content is provided in the text, but the context includes relevant acronyms and entities involved in Nova Scotia's energy regulation.
5.3 QUANTIFICATION
AI summary This section outlines the quantification process in the Nova Scotia regulatory proceeding, involving Nova Scotia Power (NSP) and the Nova Scotia Utility and Review Board (NSUARB). It focuses on Benefit-Cost Analysis (BCA) and Demand Side Management (DSM), with considerations of non-energy benefits (NEB) and adherence to the National Standard Practice Manual (NSPM).
Daymark - In the alternative to the recommendation for further analysis on NEBs, Ms. Whitten suggests that the - Board "make the value assigned to the Unquantified Non-Energy Benefits Nil until the work outlined above - can be completed an...
AI summary Ms. Whitten recommends that the Board set the value of Unquantified Non-Energy Benefits (NEBs) to Nil until further analysis is completed and approved. This suggestion is part of a regulatory proceeding involving a Benefit-Cost Analysis (BCA) framework for Nova Scotia, with references to evidence and appendices from Matter M12282.
E1 Response - To assign a nil value to unquantified NEBs defaults such benefits to zero, notwithstanding the associated - benefit. Utilising this approach would lead to greater distortion of the results than employing the - conservative pr...
AI summary The response criticizes assigning nil values to unquantified Non-Energy Benefits (NEBs) in Benefit-Cost Analysis (BCA), arguing this distorts results. It advocates using E1's conservative proxy values instead, citing Francis Wyatt of Green Energy's perspective on the issue.
7.4 LOST VALUE OF THE NATURAL GAS SYSTEM RELIABILITY
AI summary This section addresses the lost value associated with the reliability of the natural gas system in Nova Scotia. Key acronyms and entities involved in the regulatory proceeding are outlined, though detailed analysis or arguments are not provided in the excerpted text.
7.5 DSMAG PARTICIPATION EASTWARD
AI summary Section 7.5 discusses DSMAG's participation in the Eastward project, emphasizing the need for Benefit-Cost Analysis (BCA) and Non-Energy Benefits (NEB) assessments. The NSUARB oversees the process, with E1 and EFG involved as key participants.
Rebuttal Evidence of Energy Futures Group Inc. M12282 IN THE MATTER OF The Public Utilities Act , RSNS 1989, c. 380, as amended -and- IN THE MATTER OF An Application for Approval of a New Benefit-Cost Analysis Test for Evaluating Demand Si...
AI summary Energy Futures Group Inc. (EFG) submits rebuttal evidence in M12282 regarding a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans under the Public Utilities Act. The proceeding involves Nova Scotia Energy Board and focuses on DSM program evaluation methodologies.
8 4. BOWMAN EVIDENCE
AI summary Section 8.4 of the regulatory proceeding document presents Bowman's evidence, which likely involves analysis related to energy efficiency, demand-side management, and benefit-cost assessments in Nova Scotia. Key entities and acronyms are referenced, including regulatory bodies and programs.
100256Board Decision
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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.
le s. 79V(1)(e) of the Public Utilities Act authorizes the Governor in Council to make regulations defining any word or expression used but not defined in the statute, there are no such regulations. [100] The NSPM is a publication of the N...
AI summary The Public Utilities Act (PUA) authorizes defining terms like 'cost-effective' through regulations, though none exist. The NSPM, a U.S.-based stakeholder publication, discusses benefit-cost analysis (BCA) for distributed energy resources. E1 submitted the NSPM as evidence. The NSUARB acknowledges BCA's use but notes disputes over relevant benefits and costs. Statutory amendments replaced 'electricity efficiency' with 'demand-side management' but retained cost-effectiveness requirements.
[146] In its closing submissions, the Industrial Group said: Where the PUA has clearly mandated the focus of DSM to be on the reduction of costs, the PAC is able to demonstrate that as a primary test; the Proposed BCA cannot. As confirmed...
AI summary The Industrial Group argues that the Program Administrator Cost (PAC) test aligns with the PUA's mandate to reduce electricity costs, unlike the Proposed BCA. NS Power proposes a modified Total Resource Cost (TRC) test to account for fuel switching benefits, while E1 criticizes both approaches, claiming they fail to meet legislative requirements or address strategic electrification mandates. The debate centers on cost-effectiveness criteria for demand-side management.
4.6.1 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 emphasizes using long-run marginal emission rates over average rates in E1's BCA modeling, citing the need for refined assumptions. E1 used average data from NS Power but acknowledges the need for improvement.
98033NSEB (E1) IR 1 to 46
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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-2: - Page 2 of 38 of EfficiencyOne's (E1) Evidence states: "Including non-utility impacts reflects both - best practice in benefit cost analysis test design, as well as recently enacted provincial legislation. - While the relati...
AI summary EfficiencyOne (E1) argues that including non-utility impacts in the BCA test framework aligns with best practices and provincial legislation like the Public Utilities Act and Energy Reform (2024) Act . The request seeks clarification on indirect benefits/costs, weight assignments, sensitivity analysis, policy alignment, and performance requirements for non-utility benefits in DSM evaluations.
Request IR-7: - On page 18 of 38 of E1's Evidence, a hyperlink to the "National Energy Screening Project (NESP), National Standard Practice Manual (NSPM) for Benefit-Cost Analysis of Distributed Energy Resource" is provided: - a) Please de...
AI summary Request IR-7 seeks information on the National Energy Screening Project (NESP), deviations from the NSPM in the proposed BCA test, use of the MTR handbook for quantifying benefits/costs, and data from the DSPs on states' adoption of NSPM, SCT, and resilience metrics in energy efficiency evaluations.
Request IR-9: - Please provide a summary of the feedback provided by the DSMAG regarding the final draft EFG - report, as referenced on page 20 of 38 of E1's Evidence. - Request IR-10: - Table 4: NSPM BCA Guiding Principles - a) Principle...
AI summary The document outlines regulatory requests related to DSM and DER BCA analyses. Key issues include clarifying the basis for comparing DER scenarios in BCA, identifying unlisted utility impacts, and evaluating the inclusion of policy goals in BCA tests. E1 is asked to confirm the Board's discretion in approving portfolios despite BCA results.
Request IR-33: - Text Box 1: Summary of Key EFG Recommendations item 8) recommends using benefit per kWh - for local non-greenhouse gas air pollutants using estimates from the US Environmental Protection - Agency for New England. - a) Plea...
AI summary Request IR-33 seeks clarification on using benefit per kWh for local non-GHG pollutants in Nova Scotia's BCA, referencing E1's programs and US EPA data from New England. It asks to identify local pollutants, explain appropriateness of local vs. New England data, and describe pollutant sources/measures.
Request IR-34: - Text Box 1: Summary of Key EFG Recommendations item 11) states that secondary tests are - not meant to be used in a sequential fashion or as a replacement of the recommended primary - test. Please elaborate on this recomme...
AI summary Request IR-34 seeks clarification on EFG's recommendation that secondary tests should not replace primary tests in BCA evaluations for demand-side management. It asks how secondary tests would function in Nova Scotia's context, particularly regarding portfolio-level cost-effectiveness assessments.
Request IR-35: - Please confirm that Table 5: Illustrative Example of Recommended Nova Scotia Test, provides - only the summary of the benefits associated with 1,000 Heat Pumps Replacements in Program - Year 2026. If the BCA test is and me...
AI summary Request IR-35 seeks clarification on Table 5's scope, which summarizes benefits of 1,000 heat pump replacements in 2026. It also asks if E1 will provide detailed BCA calculations if the Board approves the BCA test methodology.
99112Email NSEB re: Extension approved for IG to provide hearing logistics
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From: [Henwood, Crystal D](mailto:[email protected]) To: [Nancy G Rubin;](mailto:[email protected]) [Alice Napoleon](mailto:[email protected]); [Allison Coffin](mailto:[email protected]); [Angela Co...
AI summary The Board has approved an extension until August 29, 2025, for the M12282-E1 proceeding related to a new BCA Test for Demand Side Management (DSM). The email is addressed to multiple stakeholders, including legal and energy consulting professionals.
CRYSTAL HENWOOD Pronouns: She/Her Clerk of the Board Nova Scotia Energy Board T 902 424 1332 TF 1 833 809 0040
AI summary Crystal Henwood serves as the Clerk of the Board for the Nova Scotia Energy Board. The document provides contact information for the Energy Board, including a phone number and toll-free number. No specific regulatory issues, arguments, or legislation are detailed in the provided text, which appears to be an introductory or administrative section of a regulatory proceeding document.
\ \ 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.
99131E-mail IG re: Hearing Logistics
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From: [Nancy G Rubin](mailto:[email protected]) To: [Henwood, Crystal D](mailto:[email protected]); [Alice Napoleon;](mailto:[email protected]) [Allison Coffin](mailto:[email protected]); [Angela Co...
AI summary This email is part of a regulatory proceeding (M12282) concerning a new BCA test for DSM in Nova Scotia. It outlines communication logistics for a hearing, with multiple stakeholders including energy firms, consultants, and legal entities involved in the process.
Nancy G. Rubin, K.C.\ Partner She/Her Stewart McKelvey D: 902.420.3337 \ Law Corporation From: Henwood, Crystal D Sent: August 27, 2025 11:12 AM To: Nancy G Rubin ; Alice Napoleon ; Allison Coffin ; Angela Costello ; Angela Zeng ; Bill Mah...
AI summary An email from Crystal Henwood regarding hearing logistics for a new Benefit-Cost Analysis (BCA) test for Demand Side Management (DSM) under matter M12282. Recipients include legal counsel, energy consultants, and Nova Scotia Power (NSP) representatives involved in the proceeding.
[ ; Carvery, Kim [ ; Cavanaugh, Marina [ ; Chisholm, Holly A <[[email protected]](mailto:[email protected])>; Chris Conrad <[[email protected]>](mailto:[email protected]); Courtney Lane [ ; David Hill [ ;...
AI summary The document lists participants in a Nova Scotia regulatory proceeding, including government officials, consultants, and legal representatives. No substantive arguments or topics are discussed in the provided text.
\ \ 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.
99409Email IG re: Change start time of Hearing to 12:30
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From: [Nancy G Rubin](mailto:[email protected]) To: [Painting-MacLean, Kimberly](mailto:[email protected]); [MacNeil, Janet](mailto:[email protected]) Cc: [Alice Napoleon;](mailto:anapoleon@syna...
AI summary Email communication regarding the partial consensus agreement for EfficiencyOne's application for approval of a new Benefit Cost Analysis Test, with board acknowledgment. Part of regulatory proceeding M12282.
\ \ 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 Ms. Henwood, The Industrial Group was not a signato...
AI summary The Industrial Group did not sign the partial consensus agreement and requests a hearing adjournment to review its implications. They propose starting the hearing at 12:30 PM and skipping lunch to accommodate the revised schedule.
Nancy G. Rubin, K.C.\ Partner She/Her Stewart McKelvey D: 902.420.3337 \ Law Corporation From: Painting-MacLean, Kimberly Sent: September 19, 2025 3:21 PM To: MacNeil, Janet Cc: Alice Napoleon ; Allison Coffin ; Angela Costello ; Angela Ze...
AI summary Email communication regarding EfficiencyOne's application (M12282) for approval of a new Benefit Cost Analysis Test, with reference to a Partial Consensus Agreement and Board Acknowledgement. Nancy G. Rubin, K.C. is listed as a partner at Stewart McKelvey, and the email is sent by Kimberly Painting-MacLean of Nova Scotia's regulatory team.
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.
99410Email NSEB re: Hearing to start 12:30 pm On Monday September 22, 2025
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From: [Painting-MacLean, Kimberly](mailto:[email protected]) To: ["Nancy G Rubin"](mailto:[email protected]) Cc: [Alice Napoleon;](mailto:[email protected]) [Allison Coffin](mailto:acoffin@eastward...
AI summary Email correspondence regarding Matter M12282, involving EfficiencyOne's application for approval of a new Benefit Cost Analysis Test, with partial consensus achieved. The email is sent by Kimberly Painting-MacLean of Nova Scotia to multiple stakeholders, including legal counsel, energy consultants, and industry representatives.
Good afternoon, The panel has discussed and, in the circumstances, will be proceeding on Monday as proposed by counsel for the Industrial Group. Kind regards, Kim
AI summary The panel has agreed to proceed with the hearing on Monday as proposed by the Industrial Group's counsel. The message is a brief confirmation of the schedule adjustment.
Statement of Confidentiality This message (including any attachments) may contain private or protected information meant for a specific person or organization. If you received this by mistake, please let the sender know, do not communicate...
AI summary The email discusses M12282, EfficiencyOne's application for approval of a new Benefit Cost Analysis Test, involving a Partial Consensus Agreement and Board Acknowledgement. Recipients include Nova Scotia government officials, legal counsel, and energy consultants.
\ \ 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 Ms. Henwood, The Industrial Group was not a signato...
AI summary The Industrial Group requests a hearing adjournment to review a partial consensus agreement and prepare questions, proposing a 12:30 PM start time and skipping lunch to preserve Monday's hearing schedule.
Nancy G. Rubin, K.C.\ Partner She/Her Stewart McKelvey D: 902.420.3337 \ Law Corporation From: Painting-MacLean, Kimberly [ Sent: September 19, 2025 3:21 PM To: MacNeil, Janet <[[email protected]>](mailto:janet.macneil@mcinne...
AI summary Email communication from Kimberly Painting-MacLean to multiple stakeholders, including legal counsel and energy sector representatives, related to a Nova Scotia regulatory proceeding. The message lacks explicit arguments but identifies key participants and organizations involved.
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 posted as Exhibit N-32 in...
AI summary The document acknowledges receipt of EfficiencyOne's Partial Consensus Agreement in Matter No. M12282, dated September 19, 2025. It has been directed to the Board and staff and posted as Exhibit N-32 on the Board's public website.
Statement of Confidentiality This message (including any attachments) may contain private or protected information meant for a specific person or organization. If you received this by mistake, please let the sender know, do not communicate...
AI summary An email from Janet MacNeil to Crystal Henwood regarding EfficiencyOne's application for approval of a new Benefit Cost Analysis Test under matter M12282, with a partial consensus agreement. The message includes a confidentiality notice and lists multiple recipients from law firms and organizations involved in the regulatory proceeding.
\ \ 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 Dear Ms. Henwood, Please find attached corresponden...
AI summary An email from Janet MacNeil, paralegal for Jim Gogan, attaches correspondence and a Consensus Agreement between EOne and intervenors related to a regulatory proceeding. The email cautions against clicking links or opening attachments.
99638Closing Submission - E1
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Closing Submissions of EfficiencyOne M12282 Filed with the NOVA SCOTIA ENERGY BOARD October 14, 2025
AI summary EfficiencyOne submitted closing arguments to the Nova Scotia Energy Board regarding matter M12282. The document outlines the final position of EfficiencyOne in the regulatory proceeding, though specific arguments or details are not provided in the text snippet. The submission was filed on October 14, 2025.
2. CONTEXT AND USE OF THE COST EFFECTIVENESS TEST IN DSM PLAN REVIEW Cost effectiveness testing has long been utilized in the evaluation of DSM plans in Nova Scotia, serving as a foundational element in the Board's assessment process to en...
AI summary Nova Scotia's Board uses the Total Resource Cost (TRC) test for DSM plan reviews, but proposes replacing it with a jurisdiction-specific Benefit-Cost Analysis (BCA) test to address TRC's deficiencies. The BCA test aligns with NSPM principles and Nova Scotia policy, following prior Board approvals to shift TRC analysis from measure to program level starting 2012.
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.
6.4.2 IG'S PROPOSED APPROACH E1 notes that Mr. Bowman's proposed cost-effectiveness test is insufficient to address E1's legislated DSM mandate, in particular its expanded strategic electrification mandate. Mr. Bowman's proposal is to use...
AI summary E1 argues that the PAC test is insufficient for evaluating strategic electrification under its DSM mandate, as it only considers costs. E1 proposes the BCA as a more effective primary test, citing flaws in the PAC approach and complexity from using multiple tests. Experts like Dr. Hill (EFG) and Mr. Neme support this, emphasizing legislative requirements for electrification.
6.5.2 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.
99640Closing Submission - IG
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R – 6(b). [ 21 ](#page-7-5) E-5, E1 (NSEB) RIR – 6(b). [ 22 ](#page-7-7) Transcript, Day One, September 22, 2025, pages 41-42. [ 23 ](#page-7-9) Transcript, Day One, September 22, 2025, page 48. - (a) support competition and innovation in...
AI summary E1 argues the Board can consider non-energy benefits under the PUA's subsection (d), focusing on sustainable development. However, the text counters that this does not alter the Board's specific mandates under the PUA, emphasizing that 'appropriate consideration' remains subjective. The discussion references transcripts and regulatory provisions.
y refer to one or two.[48](#page-14-8) The Proposed BCA appears to be one of the most expansive and broad-ranging tests as compared to the limited States that do account for these non-energy benefits. While this approach may be used by som...
AI summary The document discusses the Proposed BCA's broad approach to non-energy benefits in DSM, contrasting it with limited US examples. E1 lacks Canadian jurisdictional support for this method, while the Industrial Group argues against including non-energy benefits without sufficient evidence. Board Member Murphy and the Chair emphasize the need for performance indicators if such benefits are included, which E1 has not committed to for the next DSM Plan.
-16. [ 62 ](#page-17-3) E-14, Evidence of P. Bowman, page 15. [ 63 ](#page-17-5) E-1, Application, Appendix A, Attachment 2, pages 69-73, pdf p 148-152. [ 64 ](#page-17-7) E-1, Application, Appendix A, Attachment 2, page 19, pdf p 98. [ 65...
AI summary The text references the Industrial Group's adherence to the Board's 2023-2025 DSM Plan directions, requiring individual justification for measures failing cost-effectiveness testing. It cites Board Order 2022 NSUARB 137 and E-24 Rebuttal Evidence, emphasizing compliance with prior regulatory mandates.
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such as GHG reductions, public health improvements, and climate resilience, are not disproportionately discounted relative to near-term costs, thereby upholding principles of intergenerational equity. [24] If NS Power's Weighted Average Co...
AI summary The proposed BCA test aims to align with Nova Scotia's legislative goals for sustainable development and GHG reductions. E1 argues using NS Power's WACC as a discount rate would misalign with these objectives. The benefit-to-cost ratio threshold remains at 1.0, and an 'evergreen' review process via DSMAG is proposed for periodic updates.
3.0 INTERVENOR POSITIONS
AI summary The section outlines intervenor positions in a Nova Scotia regulatory proceeding, though no specific arguments or content are detailed in the provided text. Key entities and acronyms related to the proceeding are listed.
strial Group argued the proposed proxy adders and host customer feelings are not reasonable and do not have sufficient evidentiary foundation to include them at this time. The Industrial Group states: The broad and subjective array of non-...
AI summary The Industrial Group opposes the inclusion of proxy adders and subjective non-energy benefits (e.g., 'pride,' 'amenity') in host customer impact calculations, arguing they lack evidentiary support and conflict with the PUA's definition of DSM. They emphasize that legislative provisions do not justify incorporating such factors into cost-effectiveness testing.
3.3 Small Business Advocate [45] The Small Business Advocate agreed to the Consensus Agreement and recommends the Board adopt the proposed BCA test as amended by the Consensus Agreement. In closing submissions, the Small Business Advocate...
AI summary The Small Business Advocate agreed to the Consensus Agreement, recommending the Board adopt the amended BCA test. Concerns were raised about quantifying non-energy benefits like amenity and empowerment, with suggestions to set unquantified benefits to zero or adopt the PAC test instead. The Advocate emphasized the need for further analysis on non-energy benefits.
4.0 DISCUSSION AND ANALYSIS
AI summary The document section '4.0 DISCUSSION AND ANALYSIS' is identified, but no substantive content is provided in the text chunk. Key entities and acronyms are listed in the context, though no arguments, topics, or cross-references are present in the given text.
ranchise holder, and upon application by the franchise holder, the Energy Board shall establish the terms and conditions of the agreement, which agreement must - (a) be for a term of five years;
AI summary The Energy Board is required to establish terms and conditions for franchise agreements upon application, with a specified five-year term.
4.2.1 Findings [151] E1 and its consultants purported to follow guidance in the NSPM in determining the proposed BCA test. However, a process that simply takes account of an inventory of energy and climate change policy goals and objective...
AI summary The Board rejects the proposed BCA test for DSM cost-effectiveness due to misalignment with the PUA's focus on reducing customer electricity costs. The TRC test is criticized for asymmetrical application. The Industrial Group supports the PAC test, which aligns with PUA's statutory requirements. The Board directs E1 to use PAC for future DSM plans.
clarified that the social discount rate reflects the time value of money. In this instance using 2% better reflects the weight to be given to long-term costs and benefits relative to near-terms ones. [183] The Board asked E1 to address Mr....
AI summary The document discusses a debate over the appropriate discount rate for benefit-cost analysis (BCA) in Nova Scotia's regulatory proceeding. Mr. Bowman argues against using a 2% social discount rate, advocating instead for NS Power's WACC or a 7% real discount rate, while Mr. Neme supports aligning DSM evaluations with NSPM Principles. The NSPM's role in guiding policy objectives is emphasized.
ill) The emissions rates that we have used for illustrative examples that were included in the BCA Application were based on information from Nova Scotia Power and represented average emissions rates. Q. Okay. A. (Neme) But may I add that...
AI summary E1 clarified that average emissions rates were used in illustrative examples within the BCA Application, acknowledging that long-run marginal emission rates are preferable but not yet finalized. The DICE method referenced in the DSM Plan Application also uses average rates. E1 emphasized that assumptions for the DSM Plan will be refined in the future.
4.6.1 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.