Topic:"Infrastructure Planning" in M12282

s required to maintain electric  grid stability and power quality Transmission Capacity Maintaining the availability of the transmission system to transport  Transmission electricity safely and reliably Transmission System Electricity lo...

AI summary The text outlines key performance indicators related to the transmission and distribution systems, including grid stability, power quality, transmission and distribution capacity, system losses, and voltage levels. These metrics are essential for maintaining reliable electricity delivery.

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AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on rate-setting, emphasizing the need for alignment between base rates and actual costs. It highlights the importance of regulatory oversight and the evaluation of mechanisms to ensure fair cost recovery and effective resource planning.

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AI summary The text contains technical and regulatory content related to energy management, fuel adjustment mechanisms, and infrastructure planning in Nova Scotia. It references various regulatory processes, programs, and entities involved in energy policy and compliance.

generator s t Distribution Capacity Updated NSP Avoided e Costs, Not based on historic ($1.86) ($1.86) 1.86 Should reflect marginal m Distribution System Losses Distribution losses from generator Should be reflected in I Distribution O&M A...

AI summary The text discusses distribution capacity costs, distribution system losses, and financial incentives related to DERs. It highlights the need for updated avoided costs, proper reflection of losses, and development of credit and collection risk strategies.

Maintaining the availability of the transmission system to transport Transmission Capacity Transmission electricity safely and reliably Transmission System Losses Electricity lost through the transmission system Maintaining the availabilit...

AI summary The text outlines key aspects of transmission and distribution systems, including capacity, losses, voltage management, and financial incentives for DERs. It also mentions utility direct investment in DERs and program administration efforts.

Page 65 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 66 E. Electric Emissions Intensity: Estimated electric system emissions intensities are based on the difference in carbon emissions estima...

AI summary This document discusses the electric emissions intensity based on the 2023-2025 Plan and an alternative estimate from an updated Integrated Resource Plan (IRP). It also references the National Energy Screening Project, which identifies 18 states and regions that include host customer non-energy or non-water impacts in their screening practices.

E1 Responses to Eastward Energy Inc. (Eastward Energy) Information Requests NON-CONFIDENTIAL - (b) E1 was directed by the Nova Scotia Utility and Review Board in their Board Order on E1's 2023-2025 DSM Plan "To provide specific justificati...

AI summary E1 is responding to information requests by the Nova Scotia Utility and Review Board (NSUARB), explaining that it will justify DSM measures failing cost-effectiveness testing in future resource plans, including the 2027-2031 DSM Plan. E1 engages with the DSMAG, sharing modelling details and seeking input during plan development.

regulator, and stakeholders, to gain insights and knowledge about the cost effectiveness of the DSM Plan. E1 understands the results may be used to inform, guide discussion, and support recommendations as opposed to using them as a binding...

AI summary E1 explains that the PAC test results are for informational purposes and not for determining funding levels or approving the DSM Plan. The Public Utilities Act mandates cost-effective demand-side management, and E1 must determine the appropriate investment level through the DSM Plan development process, considering factors like the Integrated Resource Plan and historical performance.

impact of generation changes and distributed energy resources on the T&D system; and escalating costs of T&D infrastructure. E1 has not proposed a specific methodology for M12282, E1 BCA Test Application, May 16, 2025, Appendix A, Attachme...

AI summary E1 has not proposed a specific methodology for assessing the impact of generation changes and distributed energy resources (DER) on transmission and distribution (T&D) systems, while noting escalating T&D infrastructure costs. The text references the National Standard Practice Manual (NSPM) and cites matter M12282.

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.

Why is the E1 proposal on discount rates inconsistent with utility system resources? - In conducting Integrated Resource Planning ("IRP"), utilities typically compare alternative new energy - generation resources using their Weighted Avera...

AI summary The E1 proposal to use a 2% social discount rate for DSM evaluation conflicts with NSPM's requirement for consistent methods, as WACC is standard for utility IRP. Treasury Board guidance cited by E1 applies to regulatory proposals, not infrastructure investments. NSPM mandates equal footing for DSM with other resources using WACC, not lower social rates.

Why is E1's approach of using balanced plan design problematic? - E1 indicates that in addition to cost-effectiveness, its proposals are designed to reflect balance, such as - equitable allocation of investment and savings between resident...

AI summary E1's balanced plan design prioritizes equity and access over cost-effectiveness, conflicting with NSPM Principle 1 and Nova Scotia IRP principles (safety, reliability, least cost, decarbonization, robustness). The NSPM allows balance criteria only with explicit policy, while utility resources are typically evaluated economically, not by equity. Examples like PPA allocation illustrate potential inequities in applying balance without policy mandates.

Are there other concerns with E1's BCA inputs? - Yes. However, this concern may be more appropriately addressed as part of a specific DSM Plan review, - rather than a BCA review. - E1 has proposed to estimate the benefits of DSM measures u...

AI summary The analysis highlights three concerns with E1's BCA inputs: (1) using inflationary adders instead of evolving baseline conditions for avoided generation costs, (2) misrepresenting GHG emission impacts via average NSPI intensity, and (3) uncertainty about DSM's emission avoidance under fixed emission caps. These issues may require revisiting during DSM plan reviews.

AREAS OF EXPERIENCE: - Utility Regulation and Rates, including Depreciation - Project Development and Planning - Utility Resource Planning

AI summary The document outlines key areas of experience related to utility regulation, project development, and resource planning. It emphasizes expertise in depreciation, utility rate design, and strategic planning for energy resources.

ustrial energy users. For Industrial Gas Users Association of Manitoba (2020 - present): Support for cost of service and rate design matters. Testimony before the Manitoba Public Utilities Board. For Northwest Territories Power Corporation...

AI summary Bowman Economic Consulting Inc. provides regulatory support to industrial and utility organizations across Canada, focusing on rate design, revenue requirements, cost of service, and system planning. Engagements include testimony before regulatory bodies, technical analysis for rate applications, and project development assistance.

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.

ro system resiliency study in response to Snare River drought. For New World Dairy (2015-2017): Assist in negotiations regarding Non-Utility Generation and interconnection with Newfoundland Hydro For Yukon Energy Corporation (2005 - 2015):...

AI summary The text outlines past involvement in energy-related projects across Canada, including resource planning, environmental assessments, and regulatory interactions. Key activities include project management for hydroelectric developments, expert testimony before regulatory bodies, and negotiations with utility providers in Newfoundland, Yukon, Northwest Territories, and Manitoba.

Utility Proceeding Work Performed Before Client Year Oral Testimony BC Hydro 2021 Intergrated Resource Plan Analysis, Preparation of Intervenor Evidence BCUC AMPCBC 2023 Yes Utility Proceeding Work Performed Before Client Year Oral Testimo...

AI summary The document lists various utility proceedings, including integrated resource plans, rate design applications, and transmission line valuations. It outlines the work performed, the regulatory bodies involved, and the clients for each proceeding, with some cases involving oral testimony and others settled through negotiation.

egarding the application of Potomac Electric Company for a Multi‐Year Plan and Performance Incentive Mechanisms. On behalf of the Maryland Office of People's Counsel. March 3, 2021 and April 20, 2021. Pennsylvania Public Utility Commission...

AI summary Testimonies by Alice Napoleon and Courtney Lane on energy efficiency, multi-year plans, and energy storage programs for utilities in Maryland, Pennsylvania, and the District of Columbia. Testimonies were submitted on behalf of the Maryland Office of People's Counsel, Natural Resources Defense Council, and National Grid, addressing regulatory applications and energy policies.

People's Republic of China - Developed portfolio and project economic and financial analysis tools for use in China, and provided remote and in-person training sessions on use. For Natural Resources Defense Council and Institute for Sustai...

AI summary The text details work on energy efficiency projects in China, including economic analysis tools for the Natural Resources Defense Council, efficiency retrofits for Guangdong's Economic and Trade Commission, and prefeasibility studies for an Asian Development Bank loan. Projects involved Jiangsu province, Shanghai municipality, and Efficiency Power Plant assessments.

Introduction Eastward Energy Inc. ("Eastward") is the incumbent natural gas supplier in the Province of Nova Scotia. As this is the first Application by EfficiencyOne ("E1") to substantively raise the issue of potential strategic electrifi...

AI summary Eastward Energy Inc., Nova Scotia's incumbent natural gas supplier, opposes EfficiencyOne's (E1) first application regarding strategic electrification initiatives, arguing the proceeding could impact the provincial energy landscape. Eastward addresses concerns raised by E1's application and information request responses.

2-4) . Eastward previously - submitted in response to NSUARB Staff IR-2 in Eastward's Mains Feasibility Test Review - proceeding (NSUARB Matter No. M10960), that the Company believes the majority of newly - constructed dwelling units in th...

AI summary Eastward argues that new construction in HRM will be near existing infrastructure, making hybrid heating systems cost-effective. EfficiencyOne seeks approval for a new benefit-cost analysis test for DSM plans. References include the Gas Distribution Act and related matters.

TOPICS OF INTEREST Resource procurement, short & long term purchase agreements for both electric & natural gas commodity, transmission, distribution, storage. Wholesale and retail market design and analysis, BTM resources. Natural gas mark...

AI summary The document outlines key topics including resource procurement, market design for electricity and natural gas, economic analysis, FERC policy issues, battery storage, integrated resource planning, and infrastructure replacement programs. It emphasizes both short-term and long-term procurement strategies, renewable fuels, and regulatory considerations.

Managing Consultant Melissa Whitten joined Daymark Energy Advisors in 2009 with more than 25 years of experience in energy management and energy and financial consulting. Her work experience includes six years as Director of Gas Supply, Tr...

AI summary Melissa Whitten, with over 25 years of experience in energy management and consulting, joined Daymark Energy Advisors in 2009. She has expertise in natural gas and electric utilities, including supply, transportation, storage, LNG, RNG, and renewable diesel procurement.

SELECTED EXPERIENCE - Conduct annual renegotiation of natural gas supply contract for basis and commodity pricing plus terms of service, and assist with review of renewable diesel procurement. for a major governmental authority; - Conducte...

AI summary Experience includes managing natural gas contracts, rate cases, infrastructure audits, and evaluations of utility strategies. Activities involve optimizing portfolios, negotiating supply agreements, and ensuring compliance with regulations like NERC. Work spans utilities, regulatory boards, and evaluations of LNG facilities and merger reviews.

EXPERT TESTIMONY FORUM ON BEHALF OF MATTERS Nova Scotia Utilities and Review Board Nova Scotia Small Business Advocate M11692 Nova Scotia Power Storm Cost Recovery Rider M11458 Nova Scotia Power 2024 Annual Capital Expenditure Plan M11220...

AI summary The expert testimony section lists multiple matters before the Nova Scotia Utilities and Review Board and the Ohio Public Utilities Commission, including cost recovery riders, capital expenditure plans, decarbonization deferral accounts, fuel adjustment mechanisms, and infrastructure replacement programs.

Why is the E1 proposal on discount rates inconsistent with utility system resources? - In conducting Integrated Resource Planning ("IRP"), utilities typically compare alternative new energy - generation resources using their Weighted Avera...

AI summary The E1 proposal to use a 2% social discount rate for DSM evaluation conflicts with NSPM principles requiring consistent methods with utility IRP (using WACC). Treasury Board guidance cited by E1 applies to regulatory proposals, not infrastructure investments, and emphasizes uniform discount rates for cost-benefit analysis.

Why is E1's approach of using balanced plan design problematic? - E1 indicates that in addition to cost-effectiveness, its proposals are designed to reflect balance, such as - equitable allocation of investment and savings between resident...

AI summary E1's balanced plan design approach is criticized for prioritizing equity and access over cost-effectiveness, conflicting with NSPM Principle 1. The NSPM emphasizes cost-effectiveness as the primary DSM test unless explicitly mandated by policy. Nova Scotia's IRP principles (safety, reliability, least cost, decarbonization, robustness) are highlighted as the foundation for resource planning, with balance not typically justified in rate-funded DSM programs.

Are there other concerns with E1's BCA inputs? - Yes. However, this concern may be more appropriately addressed as part of a specific DSM Plan review, - rather than a BCA review. - E1 has proposed to estimate the benefits of DSM measures u...

AI summary Concerns exist with E1's BCA inputs, particularly its use of inflation-adjusted long-term avoided generation costs and average GHG intensity metrics. These approaches may not align with utility planning standards or Treasury Board guidelines, as they fail to account for evolving baseline conditions, incremental GHG impacts, and fixed emission caps. The analysis should inform future DSM plan justifications.

AREAS OF EXPERIENCE: - Utility Regulation and Rates, including Depreciation - Project Development and Planning - Utility Resource Planning

AI summary The document outlines key areas of experience in utility regulation, including depreciation, project development, planning, and resource planning. These areas reflect expertise relevant to regulatory proceedings in Nova Scotia's energy sector.

ustrial energy users. For Industrial Gas Users Association of Manitoba (2020 - present): Support for cost of service and rate design matters. Testimony before the Manitoba Public Utilities Board. For Northwest Territories Power Corporation...

AI summary Bowman Economic Consulting Inc. provides regulatory support to industrial and energy organizations on cost-of-service, rate design, revenue requirements, and technical analysis. Services include testimony before regulatory bodies, evidence preparation, and expert guidance on depreciation, return on investment, and system planning.

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.

ro system resiliency study in response to Snare River drought. For New World Dairy (2015-2017): Assist in negotiations regarding Non-Utility Generation and interconnection with Newfoundland Hydro For Yukon Energy Corporation (2005 - 2015):...

AI summary The text outlines involvement in energy-related projects across multiple jurisdictions, including resource planning, environmental assessments, and regulatory reviews for organizations like Yukon Energy Corporation, Northwest Territories Power Corporation, and Tolko Manitoba. Activities include project management, expert testimony, and interconnection negotiations.

Utility Proceeding Work Performed Before Client Year Oral Testimony DERS 2023 DRT and RRT Application Analysis, Support of Consumer Advocate during Negotiated Settlement Process AUC UCA 2023 No - Negotiated Settlement and written process E...

AI summary The document outlines various regulatory proceedings involving utilities and their clients, detailing the work performed, the regulatory bodies involved, and the nature of the interventions. It includes cases related to rate design, revenue requirements, and integrated resource planning.

Request IR-2: - Refer to the Evidence of Patrick Bowman at page 15, which states that "E1 has proposed - its BCA include multiple specific inputs that are not consistent with methods and - assumptions for alternative resource investments"....

AI summary The Board questions whether 'alternative resource investments' are approved like the E1 DSM Plan and if a BCA is required for them, citing Patrick Bowman's evidence that E1's BCA methodology differs from standard practices for alternative investments.

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.

Selected Projects - Natural Resources Defense Council (Illinois, Michigan and Ohio). Critically review energy efficiency, demand response, electrification, distribution system investment and integrated resource plans filed by IL, MI and OH...

AI summary The document outlines two key projects: Natural Resources Defense Council (NRDC) engaging in energy efficiency reviews, regulatory testimony, and legislative support in Illinois, Michigan, and Ohio from 2010 to present. E4TheFuture co-authored the National Standard Practice Manual (NSPM) for distributed energy resources (DERs) and conducted training from 2016 to present, with updates expected in 2025.

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.

Brian Purcell and Judy Simon) - National Standard Practice Manual for Assessing Cost-Effectiveness of Energy Efficiency Resources , Edition 1, Spring 2017 (with Tim Woolf, Marty Kushler, Steven Schiller and Tom Eckman) - The Next Quantum L...

AI summary The document lists publications by Brian Purcell and Judy Simon on energy efficiency, cost-effectiveness, and regulatory strategies. Key works include the National Standard Practice Manual, studies on efficiency goals, and reports on using energy efficiency to defer transmission and distribution investments. These publications address topics like demand-side management, integrated resource planning, and compliance with EPA regulations.

Energy Efficiency Technology and Market Research - Year 8 Building Energy Benchmarking: City of Edmonton (Nov. 2024 ongoing) - Building Controls Program Design Support: FortisBC (Jun. 2024 November 2024) - 2024 Conservation Potential Revie...

AI summary The document outlines multiple energy efficiency and market research initiatives underway in 2023-2025, involving organizations like FortisBC, Fortis Energy Inc., Natural Resources Canada, and others. Projects include building benchmarking, conservation reviews, retrofit studies, and grid integration analyses, spanning provinces and focusing on residential, commercial, and transportation sectors.

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).

Regulatory Experience - G-215-24 2024 Consolidated Resource Plan: Pacific Northern Gas - EB-2021-0002 Multi-Year Natural Gas DSM Plan: Enbridge Gas Inc. - G-371-22 2023- 2027 Demand-Side Management Expenditures Plan: Fortis BC Inc. (Electr...

AI summary The document lists regulatory filings related to energy plans in Nova Scotia, including demand-side management, long-term gas resource plans, and energy conservation initiatives by companies such as FortisBC Energy Inc., Enbridge Gas Inc., and Pacific Northern Gas. Multiple matter numbers and plan years are referenced.

ication. Similarly, Nova Scotia Power's most recent Integrated Resource Plan (IRP) modelling analysis shows potential savings of $2.3 Billion for a hybrid peak scenario compared to the IRP baseline. In response to the Board's IR-06(b) E1 s...

AI summary Nova Scotia Power's IRP analysis highlights potential $2.3B savings from hybrid peak scenarios. Eastward Energy emphasizes the need to include hybrid peaking resources in the upcoming 2027-2031 DSM Plan and urges immediate collaboration with E1 and DSMAG to analyze opportunities, given the Plan's development timeline and anticipated urban growth in Halifax.

with the goal of approving rates, tolls, charges, tariffs, capital applications or other matters that are consistent with the purpose of this Act, the More Access to Energy Act and the regulations. [90] To follow through the threads in s....

AI summary The text discusses statutory changes under the More Access to Energy Act and Energy and Regulatory Boards Act , emphasizing objectives like increasing energy sector competition, ensuring reliable energy supply, and transitioning to an independent system operator. It outlines the establishment of regulatory boards and their roles, while aligning with sustainability goals from the Environmental Goals and Climate Change Reduction Act .

(2) A franchise (a) gives the franchise holder the exclusive right to supply Nova Scotia Power Incorporated with reasonably available, cost-effective demand-side management for the purpose of this Act; … - 79K (1) Nova Scotia Power Incorpo...

AI summary The franchise agreement outlines Nova Scotia Power Incorporated's (NSP) obligations to provide information for demand-side management (DSM) activities, emphasizing cost-effectiveness and availability. The IESO's role in integrated resource planning and avoided cost calculations is highlighted, with references to the Energy Reform Act 2024. E1 argues for broader benefit-cost analysis beyond utility impacts, while the NSUARB reinforces cost-effectiveness requirements.

[201] In its response, E1 stated: The approach E1 is proposing in the 'evergreen' process for calculating the emissions intensity of DSM savings for the purposes of benefit cost analyses is the Difference in Carbon Emissions (DICE) method....

AI summary E1 proposes using the Difference in Carbon Emissions (DICE) method for calculating emissions intensity in DSM savings, aligning with NSPM and IRP for long-term planning. They argue this is more accurate than using marginal generator emissions, especially for significant load changes. In BCA, they use average emissions rates for illustrative examples.

4.8 Avoided Costs [212] Eastward raised concern about NS Power's avoided cost values and requested confirmation that ancillary service costs, peak costs and system reliability are embedded in the avoided cost values. Eastward also requeste...

AI summary Eastward questioned NS Power's avoided cost values, seeking confirmation that ancillary service costs, peak costs, and system reliability are included. NS Power explained that peak demand, ancillary services, and reliability are factored into avoided cost modeling, using the latest IRP model and ongoing DSMAG discussions. The Board accepted this response as adequate.

Eastward Energy Incorporated TAKE NOTICE that Eastward Energy ("Eastward") hereby requests to intervene in this proceeding. Eastward is a Nova Scotia-based company, formed for the purpose of providing natural gas distribution service to No...

AI summary Eastward Energy Incorporated requests intervention in a Nova Scotia Energy Board proceeding. The company provides natural gas distribution in Nova Scotia and lists contact details for representatives and counsel. The proceeding addresses issues established by the Nova Scotia Energy Board (NSEB).

Reference: General - (a) How does the benefit-cost test capture the cost of additional pressure on meeting the increased electric utility peak demand caused by any "strategic electrification", such as required electric system infrastructur...

AI summary The text raises questions about how the benefit-cost test accounts for infrastructure upgrades due to strategic electrification, coordination between E1 and the electric utility's planning department, and whether hybrid peaking or dual fuel opportunities were evaluated in the application.

Request IR-20: - Please comment on whether a test similar to the proposed BCA Test should be used by the following: - a) Natural Gas Utilities for customer programs and resource planning. - b) Water Utilities for customer programs and reso...

AI summary Request IR-20 seeks input on applying a BCA Test to Natural Gas and Water Utilities, the Province of Nova Scotia's budgeting, and NSPI's resource planning and capital expenditure criteria. The proposal aims to standardize evaluation methods for customer programs, resource planning, and infrastructure decisions.

Request IR-2: - Refer to the Evidence of Patrick Bowman at page 15, which states that "E1 has proposed its BCA include multiple specific inputs that are not consistent with methods and assumptions for alternative resource investments". - a...

AI summary The document references Patrick Bowman's evidence that E1's BCA includes inputs inconsistent with alternative resource investment methods. The Board seeks clarification on whether alternative resource investments are approved similarly to the E1 DSM Plan and if a BCA is required for such investments, specifying the test used.

t Mr. Bowman's approach to cost-effectiveness testing does not satisfy the relevant statutory requirements and, as such, is not appropriate for application within Nova Scotia's legislative framework. It is E1's position that the Proposed B...

AI summary E1 argues that its Proposed BCA test aligns with the Public Utilities Act (PUA) 's requirements for portfolio-level cost-effectiveness screening, ensuring compliance with DSM legislative goals. In contrast, Mr. Bowman's PAC test is deemed too narrow, failing to capture broader policy objectives. E1 acknowledges PAC's utility for granular analysis but asserts it should not be the primary screening tool.

iciency test", suggesting he is focusing on the PAC test to achieve something other than "cost-effectiveness" or "benefit-cost" test. Indeed, in his oral evidence, Mr. Bowman emphasized that the Board can, and should, use the cost-effectiv...

AI summary Mr. Bowman argues that using the PAC test, rather than BCA, signals to E1 its obligations to NS Power customers, emphasizing conservation's role in IRP. He contends PAC is not optimal for cost-effectiveness but serves as a directional tool. Critics assert this is an inappropriate use of the cost-effectiveness test.

r broad societal impacts and host customer impacts.[29](#page-10-6) Mr. Neme testified: [ 26 ](#page-10-1) Transcript, Day Two, September 23, 2025, pages 512-513. [ 27 ](#page-10-3) See[:https://www.canada.ca/en/environment-climate-change/...

AI summary Mr. Neme argues that applying cost-effectiveness tests inconsistently would lead to absurd outcomes in energy planning. Incorporating the global social cost of carbon would skew Integrated Resource Plan and capital planning processes, though these aspects are beyond the proceeding's scope. This highlights risks of broad PUA interpretation.

y – Opening Statement, page 1. 11 Transcript page 45, lines 5-9. 12 Exhibit E-1, Application of EfficiencyOne, Appendix A. 13 Transcript page 55, line 6 to page 56, line 16. 14 Transcript page 57, line 4 to page 58, line 8. with an expecte...

AI summary Eastward requests early DSMAG membership to contribute to E1's 2027-2031 plan development, emphasizing that delayed input could miss a six-year window for cost-effective hybrid heating DSM opportunities. Eastward urges the Board to make an early decision to ensure timely collaboration.

RELIABILITY IMPACTS In its Rebuttal Evidence E1 stated that "NS Power's avoided cost of capacity implicitly includes reliability impacts through a planning reserve margin adjustment" 44 , and "If reliability differs between modelled scenar...

AI summary The document discusses reliability impacts in energy planning, noting that E1 claims avoided costs include reliability adjustments. Experts confirm adding capacity increases reserve margins and system impacts should be considered. EFG assumes ancillary service costs are embedded in avoided costs. Eastward argues reliability differences must be assessed explicitly, opposing deferral to future reviews and requesting NS Power to clarify ancillary service inclusion.

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.

fs pursuant to this Act or any other enactment, the Energy Board may adopt any method or technique that it considers appropriate, including an alternative form of energy regulation.17 [emphasis added] Notably, before the changes introduced...

AI summary The Energy Reform (2024) Act expanded EfficiencyOne's DSM responsibilities to include cooperation with the IESO under the Public Utilities Act. Previously, EfficiencyOne's role was limited to supporting NSPI's legislated duty to provide cost-effective DSM. The Board's jurisdiction now includes considering non-energy impacts in cost-effectiveness testing, per the Energy and Regulatory Boards Act.

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.

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.

with the goal of approving rates, tolls, charges, tariffs, capital applications or other matters that are consistent with the purpose of this Act, the More Access to Energy Act and the regulations. [90] To follow through the threads in s....

AI summary The text discusses statutory changes under Nova Scotia's energy regulation, focusing on the More Access to Energy Act and Energy and Regulatory Boards Act . Key objectives include fostering competition, ensuring reliable energy supply, and transitioning to an independent system operator. The More Access to Energy Act defines sustainable development and outlines procurement practices and energy planning goals.

(2) A franchise (a) gives the franchise holder the exclusive right to supply Nova Scotia Power Incorporated with reasonably available, cost-effective demand-side management for the purpose of this Act; … - 79K (1) Nova Scotia Power Incorpo...

AI summary The franchise grants exclusive rights to Nova Scotia Power Incorporated (NSPI) for cost-effective demand-side management. NSPI must share customer data with franchise holders and cooperate with the IESO on integrated resource planning. Provisions emphasize cost-effectiveness and 'reasonably available' demand-side management, with E1 arguing for a broader benefits-costs test beyond utility impacts.

pdated SC-GHG guidance is to be used in accordance with the Treasury Board Secretariat's regulatory guidance on cost-benefit analysis, Canada's Cost-Benefit Analysis Guide for Regulatory Proposals ." [175] In response to Board IR-5(h) aski...

AI summary The document discusses the use of discount rates in regulatory analysis, with E1 proposing a 2% social discount rate and Mr. Bowman criticizing this approach. He argues that Integrated Resource Planning (IRP) should use WACC instead, aligning with NSPM Principles. The Treasury Board guidelines are noted as applicable to regulatory proposals, not infrastructure investments.

[201] In its response, E1 stated: The approach E1 is proposing in the 'evergreen' process for calculating the emissions intensity of DSM savings for the purposes of benefit cost analyses is the Difference in Carbon Emissions (DICE) method....

AI summary E1 proposes using the Difference in Carbon Emissions (DICE) method for calculating emissions intensity in benefit-cost analyses, aligning with NSPM guidance and IRP modeling. This method considers long-term generation resource mix impacts, contrasting with short-term marginal emissions approaches. E1 also notes average emissions rates are used for illustrative BCA examples.

4.8 Avoided Costs [212] Eastward raised concern about NS Power's avoided cost values and requested confirmation that ancillary service costs, peak costs and system reliability are embedded in the avoided cost values. Eastward also requeste...

AI summary Eastward questioned NS Power's avoided cost values, specifically regarding ancillary services, peak costs, and reliability. NS Power responded that these factors are included in their avoided cost modeling, particularly with DSM programs like electrification of transportation, and referenced the IRP model and DSMAG. The Board accepted NS Power's response.