Topic:"Integrated Resource Plan" in M12282

ity, greenhouse gas reductions) would have better results than seen under the TRC, however this is not a comment on whether they will pass or fail. Date Filed: July 4, 2025 E1 (SBA) IR-17 Page 1 of 1 Request IR-18: Please list all the fact...

AI summary EfficiencyOne (E1) outlines factors beyond the Benefit Cost Analysis (BCA) test for determining DSM program funding, including equitable allocation, customer bill impacts, Integrated Resource Plan (IRP) requirements, historical spending, industry capacity, and emerging technology support. Responses to IR-19 are incomplete, focusing on financing arrangements and per capita funding data requests.

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

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

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

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

Strategic Electrification Eastward Energy has reviewed the evidence in this proceeding, and this Application is the first time that E1 has substantively referred to the potential for it to start strategic electrification, and it has provid...

AI summary Eastward Energy advocates for strategic electrification, proposing a BCA test to evaluate gas-to-electric conversions. The Gas Distribution Act amendment mandates hybrid peaking resources, aligning with Nova Scotia Power's IRP findings showing $2.3B savings in hybrid peak scenarios. Eastward Energy emphasizes DSMAG's role in the 2027-2031 DSM Plan.

[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.

2.5 CONSISTENCY - The submission also highlights concerns about inconsistency across distributed energy resources (DERs), - suggesting that the BCA test would require expansion to other areas and create regulatory challenges. The - IG stat...

AI summary The Industrial Group (IG) argues that the Proposed BCA test is inconsistent with Nova Scotia Power's Integrated Resource Plan (IRP) and capital asset treatment, advocating for the utility cost test (PAC). EfficiencyOne (E1) counters that the NSPM is tailored for DERs, the TRC test isn't linked to IRP, and NS Power opposes the PAC test. The debate centers on cost-effectiveness testing for DSM and DERs.

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.

hat compared and that, again, is an average emissions rate comparison. Q. Okay. That's average. Okay. Thank you. [Transcript, pp. 61-64] [203] On page 11 of its reply submissions, E1 stated: E1 maintains its position that the use of averag...

AI summary E1 argues that using average emissions rates, as opposed to generator-specific rates, aligns with NSPM guidance and provides more accurate long-term planning outcomes when IRP inputs and assumptions remain valid.

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.