Topic:"Non Energy Impacts" in M12282

set out in the National Standard Practice Manual (“NSPM”) for Distributed Energy Resources (“DER”); 3 b) Nova Scotia’s policy goals and objectives, as articulated in legislation; c) input from the DSMAG during workshops; and d) Nova Scotia...

AI summary The document outlines the proposed Best Interest of Customers (BCA) test design, incorporating non-utility system impacts like greenhouse gas emissions and air pollutants, aligned with Nova Scotia's sustainability goals. Inputs included the DSMAG's workshop feedback, policy objectives, and E1's DSM Plan performance data.

re reflective of accurate and current data, and of any changes to Nova Scotia policy objectives. This ‘evergreen’ review would be conducted in advance of the development of a new DSM Plan. 24. The utility system impacts and other fuel impa...

AI summary E1 proposes replacing the TRC test with the BCA test (1.0 ratio threshold) for assessing DSM Plans, emphasizing accurate data, evergreen reviews, and quantifying impacts via avoided costs, social cost of carbon, and societal benefits using a 2% discount rate. The BCA test is argued to align with ratepayer interests and regulatory priorities.

...............................................9 5.1 Portfolio Level Evaluation............................................................................................................ 9 5.2 Jurisdiction to Consider Non-Energy Impacts ....

AI summary The document outlines sections addressing portfolio-level evaluation, jurisdiction to consider non-energy impacts, legislative changes to the Public Utilities Act and Energy Reform Act, and E1's efforts to develop a new Best Interest of Customers (BCA) test. It includes directives for cost-effectiveness testing and updates to Nova Scotia's policy objectives.

......................................... 25 9.2 NSPM Guidelines ....................................................................................................................... 25 9.3 DSMAG Input ......................................

AI summary The document outlines a regulatory analysis comparing the current TRC test with a proposed BCA test, emphasizing non-utility system impacts like societal and host customer effects. It includes DSMAG input, NSPM guidelines, and test case runs on heat pumps, reflecting a shift toward broader impact assessments in energy efficiency programs.

1 current practice, E1 also commits to providing Program Administrator Cost (PAC) test results to 2 stakeholders in the course of DSM Plan applications, for information purposes. 3 4 5.2 JURISDICTION TO CONSIDER NON-ENERGY IMPACTS 5 The qu...

AI summary The document discusses the jurisdiction of the NSUARB to consider non-energy impacts in DSM plan evaluations, referencing a 2020 case where E1 applied for approval to use non-energy impacts in cost-effectiveness testing. The NSUARB concluded that the legislation does not grant it the authority to consider environmental factors in such evaluations, limiting cost-effectiveness to affordability and long-term electricity costs.

alled at a customer site. The demand side management programs being developed and screened by E1 for inclusion in their next plan are composed of individual measures and supporting services. Non-Energy Benefits: Many DERs provide benefits...

AI summary The text discusses the development of a Jurisdiction Specific Test (JST) for Nova Scotia to evaluate the cost-effectiveness of energy efficiency and distributed energy resources (DERs). It highlights that non-energy benefits from DERs, such as improved comfort and health, are harder to quantify and may be relatively small. The report recommends using a proxy adder approach to estimate these benefits and suggests that if not included in a jurisdictional test, host customer costs should be excluded.

sustainable development and sustainable prosperity. Table 11 summarizes the set of non-utility system impacts that could be considered appropriate based on the working group’s Policy Review. Table 11: Potential Non-Utility Impacts based on...

AI summary The text discusses non-utility system impacts related to energy efficiency (EE), demand response (DR), distributed generation (DG), demand-side management (DS), electric vehicles (EV), and building efficiency (BE). It highlights how these measures can affect fuel consumption, host customer costs, resilience, and greenhouse gas (GHG) emissions.

numerous occasions, and there was some discussion of using percent adders for different measure categories as an alternative to the adjusted measure- based values derived from Massachusetts. During the regulatory review of E1’s NEBs Applic...

AI summary The NSUARB ruled it lacks jurisdiction to consider non-energy impacts in cost-effectiveness testing. E1 included host customer costs and savings in its 2023-2025 DSM Plan, but the NSUARB directed their removal. Despite this, the BCA test in the plan still included some host customer costs.

44 measures installed through E1 initiatives. Following the NSPM’s symmetry principle, if host customer costs are counted, then host customer benefits should also be considered. During the fourth through the sixth DSMAG working group sessi...

AI summary The document discusses the inclusion of non-energy host customer impacts in the cost effectiveness screening of energy efficiency programs, based on the Energy Reform Act (ERA) and discussions from the Demand Side Management Advisory Group (DSMAG). It recommends using proxy adders, differentiated by measure category, DER type, and customer segment, and notes that 18 U.S. jurisdictions incorporate non-energy benefits into such screening.

, lists a summary of how non-energy host customer impacts are treated across the United States, indicating 18 jurisdictions incorporate non-energy benefits into cost effectiveness screening. Table 14 summarizes the set of recommended proxy...

AI summary The text discusses how non-energy host customer impacts are treated in the United States, noting that 18 jurisdictions incorporate non-energy benefits into cost-effectiveness screening. It outlines proxy values for these impacts, calculated as a percent adder of energy benefits and as a percent of non-incentivized measure costs, with recommendations varying based on project type and income qualification.

ility impacts, in comparison to market rate activities. The values in Table 14 are also considered by EFG to be broadly consistent with the level of valuation adopted by other jurisdictions. The proxy values in Table 14 recommend different...

AI summary The document discusses non-energy benefits (NEB) proxy values for different customer segments and measure types, noting that higher values are recommended for income-qualified or disadvantaged communities. These values are considered consistent with those used in other jurisdictions.

to economic constraints may not have been able to make as many demand side energy investments in the past. Table 14: Consultant Team Host Customer NEB Proxy Adder Recommendations If, over time, more research is done on the customer valuati...

AI summary The text discusses the limitations of data on non-energy impacts (NEBs) in Nova Scotia and the need for a generalized approach in the Benefit-Cost Analysis (BCA) framework. It highlights that the proposed proxy adder values for NEBs are modest compared to other benefit and cost categories, and suggests that these approximations may be acceptable due to resource constraints.

that while they should be counted are relatively small compared to other impacts. For comparison, the values of proxy adder approaches to non-energy impacts adopted elsewhere include: • Vermont – Non energy benefits of 15% adder to energy...

AI summary The text discusses proxy adder approaches to non-energy impacts in various regions, such as Vermont, Colorado, and Nevada, and notes feedback from the DSMAG working group requesting that adders be calculated per energy unit to facilitate comparisons and account for changes in avoided costs.

prices changed, the value of non-energy impacts would also change, and that having the values expressed in terms of per energy unit is also helpful for comparison and cross- referencing. 29 NV5 VT Act 18 Clean Heat Standard Potential Study...

AI summary The document discusses the importance of expressing non-energy impacts (NEI) in terms of per energy unit for comparison and cross-referencing. It references studies and examples, including a Benefit-Cost Analysis of Non-Wires Alternatives and a Clean Heat Standard Potential Study, to support this approach.

as levelized $ per kWh, are presented in Table 16. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461 – USA 802-482-5001 802-329-2143 [email protected] DATE FILED: May 16, 2025 Page 47 of 68 EfficiencyOne Benefit-Cost Anal...

AI summary The document compares non-energy impact (NEI) benefits from energy efficiency programs in Massachusetts with proxy values recommended for Nova Scotia. The NEI benefits in Massachusetts range from 2.6 to 34 cents per kWh, while the recommended proxy values for Nova Scotia range from 4.2 to 9.5 cents per kWh. The consultant team considers the proxy approach as conservative and appropriate.

ropriate balance between complexity required to estimate the NEI’s separately for each individual measure, and the past default of not counting host customer NEI benefits in the BCA test. 32 Derived from 2023 Electric Statewide Summary Rep...

AI summary The text discusses the balance between estimating non-energy impacts (NEI) separately for each measure and past practices of not counting host customer benefits in the BCA test. It also references a table on societal impacts for different types of distributed energy resources (DER).

Request IR-03: Refer to Exhibit E-1, the Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (the "Report"), Appendix B, Table 14, pages 45-46 of 68. For the "host customer" impact of the NEB category, provide a...

AI summary Energy Futures Group (EFG) responds to a request regarding the proxy adder approach for host customer non-energy benefits in a jurisdictional benefit cost analysis. They reference EfficiencyOne's (E1) response and provide a sensitivity analysis showing the impact of ±50% adjustments to the adders, noting that these changes do not significantly affect the overall benefit cost results.

Date Filed: July 4, 2025 E1 (Synapse) IR-16 Page 2 of 2 1 Request IR-17: 2 3 Page 46 of the EFG report cites the use of non-energy impacts adopted in Vermont, Colorado, 4 and Nevada. 5 6 (a) To what extent did EFG use the adders adopted in...

AI summary The response to Request IR-17 indicates that EFG based its recommendations on professional judgment, with some influence from practices in other jurisdictions, but not as a direct outcome of analyzing those practices. The question explores the use of non-energy impact adders from various jurisdictions and whether EFG considered data from similar regions.

II. SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS - Q. Please describe your conclusions. - A. My conclusions are: - E1's approach to developing the Nova Scotia Test is reasonable and follows the sound economic guidance from the National Stand...

AI summary The Nova Scotia Test is deemed an improvement over the TRC test for incorporating energy policy goals, other fuels, societal impacts, and non-energy benefits. While proxy values for non-energy benefits are reasonable, E1's justification for specific proxy values is insufficient.

Q. What is your overall assessment of the proposed Nova Scotia Test? - A. I find that the proposed Nova Scotia Test is an improvement upon the current TRC test. - Unlike the current TRC test, the Nova Scotia Test accounts for both host cus...

AI summary The proposed Nova Scotia Test is considered an improvement over the current TRC test as it accounts for host customer benefits and costs, ensuring proper valuation of DERs and avoiding biased BCA results. It aligns with Nova Scotia's energy policy goals by incorporating non-energy impacts as directed by recent legislation.

Evidence of Courtney Lane 1 Scotians" and non-utility system impacts such as GHG emissions.36 The language 2 contained in these statutes implies a broader approach to evaluating cost-effectiveness, 3 and including host customer impacts is...

AI summary Courtney Lane argues that the Nova Scotia Test should include societal impacts such as GHG emissions, resilience, and public health. She references the Environmental Goals and Climate Change Reduction Act and recommendations from Environment and Climate Change Canada to support her claim.

- Q. How would the NEBs be used within the Nova Scotia Test? - A. E1 proposes to apply the NEB proxy adders as a percentage of the net energy benefits, - except for beneficial electrification measures, which will be calculated as a percent...

AI summary The discussion centers on how Non-Energy Benefits (NEBs) are applied within the Nova Scotia Test, including the use of proxy adders and the applicability of Measure Categories to different customer segments. E1 proposes using NEB proxy adders as a percentage of net energy benefits, with exceptions for beneficial electrification measures. All Measure Categories are applied to both residential and BNI customer segments, except for BNI Custom Measures.

EFG Report page 46. EFG Report page 48. 1 The main justification provided by EFG are the notes summarized in Table 4 above and 2 statements that custom projects, which often highlight productivity or process 3 improvements, should have hig...

AI summary The witness expresses concerns about EFG's approach to determining NEB proxy values, particularly the lack of documentation for the 20% adder used for building shell measures and BNI Custom Measures. They recommend including host customer NEBs in the Nova Scotia Test, citing literature from other jurisdictions that quantify NEBs associated with DERs.

by Lawrence Berkely National Laboratory cites 27 studies across a range of 16 NEIs, Response to NSEB IR-15(a). many of which are proposed by E1, including comfort, health and safety, and productivity.[62](#page-29-0) In addition, Skumatz E...

AI summary The text discusses the monetization of non-energy benefits (NEBs) in the context of the Nova Scotia Test, citing studies from E1 and SERA. It recommends reducing NEB proxy values for the 2027-2031 DSM Plan to align with other jurisdictions and the SERA report, while allowing other values to be approved as they are within the recommended range.

values? A. E1's consultant EFG produced a report that is included as Appendix B to E1's Application. In its report, EFG provided a table listing nine host customer non-energy impacts that could be included in the BCA test, represented by p...

AI summary E1's consultant EFG prepared a report (Appendix B) listing nine non-energy impacts for the BCA test, from which E1 selected six. The selected impacts are detailed in a table from Table 8 of the Application.

Synapse Energy Economics Responses to the Industrial Group Information Requests NON-CONFIDENTIAL test to the utility function. A BCA test that only links benefits/costs to the utility function is essentially the PAC (also known as the util...

AI summary Synapse Energy Economics argues that the BCA test (PAC/UCT) does not align with Nova Scotia's policy goals, as noted in Courtney Lane's evidence. The Energy Board evaluates DSM plans at the portfolio level, not individual DER measures. Synapse contends that DER measures with cost-effective BCA results, including non-energy benefits, are 'useful' and 'used' once operational.

Table 1: Host Customer Non-Energy Impacts Asset Value O&M Costs Productivity Economic well-being Comfort Amenity Health & Safety Empowerment Pride c) The quantification of the host customer NEBs for the purposes of the 2027 – 2031 DSM Plan...

AI summary The 2027–2031 DSM Plan assumes zero quantification for non-energy benefits (NEBs) related to amenity, empowerment, and pride. Efficiency One (E1) will explore methods to quantify these values during the period between the hearing of the Application and the filing of the 2032–2036 DSM Plan.

ng of this matter, and the filing of its 2032-2036 DSM Plan, to examine methods for quantifying proxy values for amenity, empowerment and pride. The Consensus Agreement also includes a provision that: f) As an integral component of the Eve...

AI summary E1 proposes a Benefit-Cost Analysis (BCA) test for Demand-Side Management (DSM), supported by a Consensus Agreement. The BCA includes methods to quantify non-energy impacts like amenity and pride, with stakeholder engagement and validation via literature reviews and customer surveys. E1 requests the NSUARB to approve the BCA as the new DSM cost-effectiveness test.

4.1.1 Introduction [69] The Public Utilities Act requires NS Power to engage E1 to undertake "costeffective demand-side management". The Board must approve these agreements and "determine the cost-effective demand-side management that must...

AI summary The NSUARB must determine the cost-effectiveness test for demand-side management under the Public Utilities Act. E1 argues the Board now has jurisdiction to consider non-energy impacts, while some intervenors disagree. Legislative amendments since 2020, including the Energy Reform (2024) Act, expanded the Energy Board's consideration scope. The Board will assess statutory interpretation and the meaning of 'cost-effective' in DSM provisions.

4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...

AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The new definition of 'demand-side management' includes strategic electrification, and affordability requirements were removed from legislation previously considered in the 2020 NSUARB decision.

Request IR-17: - Page 46 of the EFG report cites the use of non-energy impacts adopted in Vermont, Colorado, and Nevada. - a. To what extent did EFG use the adders adopted in these jurisdictions to inform its recommended proxy adders for t...

AI summary Request IR-17 questions EFG's use of non-energy impact adders from Vermont, Colorado, Nevada, and Massachusetts, seeking clarification on their methodology, whether other jurisdictions use adders for specific DERs, and why Massachusetts wasn't cited. It also asks about consideration of data from similar jurisdictions.

- 28 (b) Please compare the new BCA test against the current TRC test for the 29 three examples provided in section 11 of E1's Evidence. 1 2 (i) In the calculation provided, do the "non-energy impacts" outweigh the "energy-related" impacts...

AI summary The text requests a comparison of the new BCA test with the current TRC test using three examples from section 11 of E1's Evidence. It also raises questions about the purpose and utility of Program Administrator Cost (PAC) test results in regulatory proceedings and whether the BCA influences spending on E1's programs.

as whether DSM activities reduce costs for NSPI customers, from a utility perspective)."[38](#page-21-1) In this application, E1 is proposing that the TRC test be replaced by the Proposed BCA test. EFG, Mr. Wyatt and Ms. Lane agree that th...

AI summary E1 proposes replacing the TRC test with a BCA test, supported by EFG, Wyatt, and Lane as aligned with NSPM and policy goals. SBA concerns were addressed via PCA, with Ms. Whitten supporting zero valuation for non-energy impacts. Ms. Lane initially advocated for lower proxy values but later acknowledged justification for proposed values.

1. THE BOARD CANNOT ACCOUNT FOR BROAD SOCIETAL IMPACTS, OR NON-ENERGY IMPACTS

AI summary The regulatory board acknowledges its inability to account for broad societal impacts or non-energy impacts in its proceedings, highlighting limitations in evaluating broader consequences beyond energy-related considerations.

2. THE BOARD SHOULD NOT TAKE INTO CONSIDERATION NON-ENERGY AND BROAD SOCIETAL IMPACTS In the alternative, if the Board determines it has the jurisdiction to incorporate non-energy and broad societal impacts into the cost-effectiveness test...

AI summary The Industrial Group argues that the Board should not consider non-energy and broad societal impacts in evaluating Demand-Side Management (DSM). They claim this would expand Benefit-Cost Analysis (BCA) beyond ratepayer-focused tests, introducing unquantifiable factors. E1's proposed BCA includes non-energy benefits and carbon costs, which the Small Business Advocate's consultant opposes, aligning with the Program Administrator Cost (PAC) test instead.

CONSENSUS AGREEMENT In the Consensus Agreement by certain parties to the proceeding, E1 has agreed to "reflect an assumed quantification of zero for …amenity, empowerment and pride". 51 However, at the same time it has not changed the Non-...

AI summary E1 agreed to set amenity, empowerment, and pride factors to zero in the Consensus Agreement but retained Non-Energy Proxy Values for Beneficial Electrification. Eastward argues this requires a downward adjustment, as the original value included seven factors, three of which are now zero. Dr. Hill and Mr. Neme defend the 10% value as conservative, while Eastward highlights its exclusion from Consensus Agreement discussions.

The Board's Jurisdiction to Take Non-energy Impacts into Account in Cost-effectiveness Testing for Demand-side Management Plans The second issue concerns the Board's jurisdiction to take non-energy impacts into account in cost-effectivenes...

AI summary The document addresses whether the Nova Scotia Utility and Review Board (UARB) can consider non-energy impacts in cost-effectiveness testing for Demand-side Management (DSM) plans. It references the Energy Reform (2024) Act and the EfficiencyOne (Re) case, where the UARB previously ruled against considering non-energy impacts. ECEL supports EfficiencyOne's argument that the new Act expanded the Board's jurisdiction to include non-energy benefits in DSM cost-effectiveness analyses.

21 A. Overview 22 23 E1's new proposed BCA Test was developed by E1 and its consultant, Energy Futures Group 24 ("EFG"), through consultation with the DSM Advisory Group ("DSMAG"). These consultations 25 were informed by recent amendments...

AI summary E1's new BCA Test, developed with Energy Futures Group and DSMAG, aligns with Nova Scotia's Energy Reform Act (2024) and incorporates non-utility impacts like environmental and host customer factors. The Consumer Advocate supports the test post-Partial Consensus Agreement, which adjusted proxy values for BCA testing in the 2027-2031 DSM Plan.

23 C. Submissions 24 25 As noted above, the Consumer Advocate has executed a Partial Consensus Agreement with E1 26 and other Parties regarding the new proposed BCA Test. The Consumer Advocate supports the 27 adoption of the terms of the A...

AI summary The Consumer Advocate supports the adoption of a new BCA Test as outlined in a Partial Consensus Agreement with E1 and other parties. The discussion highlights the need to assess whether recent legislative amendments in 2024 allow for the inclusion of non-energy impacts in cost-effectiveness testing, following a previous decision in EfficiencyOne (Re) , 2020 NSUARB 56.

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

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

4.1.2 WHY M08888 IS NO LONGER DETERMINATIVE Nova Scotia Power submits that "the Board's decision in M08888 issued April 15, 2020 holds".[38](#page-16-1) M08888, reviewed in the context of the legislative framework that existed at that time...

AI summary Nova Scotia Power argues that M08888 is no longer determinative due to legislative changes since 2020, including amendments to the PUA and new acts requiring consideration of non-energy factors like GHG reduction. The Board's previous jurisdictional limitations have been altered by these updates.

ng of this matter, and the filing of its 2032-2036 DSM Plan, to examine methods for quantifying proxy values for amenity, empowerment and pride. The Consensus Agreement also includes a provision that: f) As an integral component of the Eve...

AI summary E1 proposes a Benefit-Cost Analysis (BCA) test for demand-side management (DSM), supported by a Consensus Agreement. The agreement outlines methods to quantify non-energy impacts via literature reviews, surveys, and stakeholder engagement. E1 argues the BCA aligns with legislative direction and public interest, requesting approval as the new DSM cost-effectiveness test.

4.1.1 Introduction [69] The Public Utilities Act requires NS Power to engage E1 to undertake "costeffective demand-side management". The Board must approve these agreements and "determine the cost-effective demand-side management that must...

AI summary The NSUARB must determine the cost-effectiveness test for demand-side management under the Public Utilities Act, with parties disagreeing on whether non-energy impacts should be considered. Post-2020 jurisdictional changes and the 2024 Energy Reform Act split NSUARB into two boards, expanding the Energy Board's consideration scope. E1 argues the Board now has jurisdiction to include non-energy impacts, while some intervenors oppose this. The Board will assess statutory interpretation and decide on BCA approval if jurisdiction is confirmed.

4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...

AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The Act's definition of 'demand-side management' now includes strategic electrification, while affordability considerations were removed from evaluation criteria.