Topic:"Participant Costs Benefits" in M08888

Non-Energy Benefits: An Application for Approval of the use of Non-Energy Benefits within Cost-Effectiveness Testing FILED September 19, 2018

AI summary An application seeks approval to incorporate Non-Energy Benefits into cost-effectiveness testing within a Nova Scotia regulatory proceeding. Filed on September 19, 2018, the document outlines the rationale for including non-energy benefits in regulatory evaluations, though specific entities or detailed arguments are not explicitly mentioned in the provided text.

EfficiencyOne Response to DSMAG Comments on VEIC Report on Measure-Level Non-Energy Benefits December 18, 2017 Page 2 of 27

AI summary EfficiencyOne responds to DSMAG's comments on the VEIC report analyzing non-energy benefits of energy efficiency measures. The document addresses program-level cost considerations, including TRC, PAC, and IRP frameworks, while engaging with DSMAG's feedback on benefit quantification methodologies.

1.1 Background As part of the June 30, 2016 agreement signed on deferred issues related to the 2016-2018 DSM Resource Plan, Intervenors in that proceeding agreed to: …work collaboratively with the DSM Advisory Group to pursue the nature an...

AI summary In 2016, EfficiencyOne and DSMAG agreed to improve TRC test accuracy by incorporating non-energy benefits (NEBs). A draft scope of work proposing adapted NEBs from another jurisdiction was circulated, facing mixed reactions. Feedback led to revisions, with VEIC conducting the study. Stakeholders including Synapse Energy Economics, NS Power, and advocates provided input on the draft report.

2.1 Comments from Synapse Energy Economics On pages one and two of its letter of comment (section 2), Synapse suggests several report modifications to aid in the clarity and presentation of the Report. Those suggestions were: An updated ve...

AI summary Synapse Energy Economics recommends updates to tables and sections in the report, including standardizing NEB categories, breaking down TRC values by end use, clarifying data sources in Table 10, and prioritizing research recommendations. VEIC responded by updating Table 1 but excluded exclusive low-income NEBs for market-rate programs.

EFFICIENCYONE RESPONSE TO DSMAG NEBs COMMENTS EfficiencyOne supports the application of low-income specific participant and utility NEBs and suggests their inclusion be subject to additional discussion at the DSMAG. EfficiencyOne suggests...

AI summary EfficiencyOne supports incorporating low-income specific non-energy benefits (NEBs) but recommends further DSMAG discussion. They reference the Three3/NMR study and note no jurisdictions (e.g., Massachusetts) have integrated such NEBs into market-rate programs. They agree with Synapse on HomeWarming program reporting and advocate for a long-term NEB strategy, including National Screening Practice Manual alignment.

Q1: Are all the non-energy benefits assessed by this study participantrelated? Are any non-energy benefits utility-related? A1: All benefits are participant related. Utility-related non-energy benefits are included in Massachusetts for low...

AI summary All non-energy benefits (NEBs) are participant-related, with utility-related NEBs only in Massachusetts for low-income programs. Methodology uses averaged heating/cooling degree days to assess thermal comfort. Duplicate rows in Appendix B stem from market segment differences in initial modeling. TRC formula in Nova Scotia is materially similar to Massachusetts, with NEBs treated as additional benefits.

2.2 Comments from the Industrial Group On page 1 of its letter of comment, the Industrial Group (the "IG") provides comments relating to the effects of quantifying NEBs on incentive levels, insofar as further customer benefits have been id...

AI summary The Industrial Group (IG) recommends explicitly quantifying Non-Energy Benefits (NEBs) to set appropriate incentives. EfficiencyOne clarifies their method already accounts for NEBs in customer research but focuses on quantifying them for the Total Resource Cost (TRC) test. CLEAResult's recommendations also consider Program Administrator Cost (PAC) and customer simple payback, with the Custom program under Efficiency Nova Scotia (ENS) incorporating NEBs since inception.

2.4 Comments from the Small Business Advocate (Daymark) The Small Business Advocate, via Daymark Energy Advisors, (the "SBA") provided several recommendations relating to the study and Report. These recommendations will be addressed below...

AI summary The Small Business Advocate (SBA), through Daymark Energy Advisors, recommends improving direct energy savings over reliance on NEBs for marginally cost-effective programs. It criticizes the TRC test as flawed, referencing DSMAG discussions.

EFFICIENCYONE RESPONSE TO DSMAG NEBs COMMENTS by its lack of inclusion of customer benefits with full inclusion of customer costs. 4 The net effect is that all costs are included in the current test, while only a portion of benefits. This...

AI summary EfficiencyOne addresses DSMAG's comments on NEBs, arguing the current test methodologically excludes full customer benefits. It emphasizes commitment to optimizing energy/demand benefits while explaining disparities between residential and BNI NEBs due to differing studies and property ownership. VEIC and EfficiencyOne provide detailed responses to SBA's queries on NEB composition and adjustment processes.

benefit of $7.01 per measure. If a customer installed two of these measures, do they realize a thermal benefit of $14.01 for thermal comfort? The MA Residential Study is very careful to avoid double counting and recommends excluding a numb...

AI summary The MA Residential Study emphasizes avoiding double-counting of non-energy benefits, such as health improvements from bill savings. Per-measure benefits (e.g., air sealing, insulation) are counted once per residential application, while some measures like LED lamps are counted per unit. The study excludes certain non-energy impacts to prevent overestimation of benefits.

Q2: What is the difference in impact for, e.g., increased property value, for the first measure installed by a single customer versus the second measure? A2: Similar to the last answer, this value is calculated per measure and reflects the...

AI summary The response explains that property value increases are calculated per measure and are cumulative. VEIC uses an average Nova Scotia housing price for administrative efficiency. A Massachusetts study addresses double-counting in NEB quantification by prorating NEIs and ensuring data consistency.

Q5: How does Efficiency One plan to account for the possible double counting of NEBs for residential measures? A5: Based on the answers above, no action is suggested by EfficiencyOne. On page four, the SBA suggests that VEIC's recommendati...

AI summary EfficiencyOne does not plan to take action regarding potential double counting of NEBs. The SBA criticizes VEIC's recommendation as misunderstood, while DSMAG will guide future research. The Industrial Group's response details the relationship between incentive setting and NEB identification.

2.5 Comments from the Consumer Advocate (Resource Insight) Acting on behalf of the Consumer Advocate, Resource Insight (collectively the "CA") provided a letter of comment in relation to this matter. In its letter, the CA argues that one-t...

AI summary The Consumer Advocate (Resource Insight) argues that property value increases from energy efficiency measures in Massachusetts may double-count Non-Energy Benefits (NEBs). They assert these increases represent benefit transfers, not new NEBs. EfficiencyOne counters that property values reflect the present value of future NEBs, with transfers between buyers/sellers not altering total societal benefits.

3. CONCLUSION AND ACTION ITEMS EfficiencyOne appreciates the efforts of DSMAG members in providing comments and their expert opinions relating to VEIC's Report, and relating to the broader discussion around NEBs and their inclusion in the...

AI summary EfficiencyOne acknowledges DSMAG's contributions to NEB discussions and commits to initiating research on NEBs, holding a special DSMAG meeting in Q1 2018, and aligning with DSMAG before seeking UARB approval for adapted Massachusetts NEBs in cost-effectiveness testing.

Attachment 2: EfficiencyOne Special DSMAG Meeting Action Items – March 12, 2018 Date Filed: September 19, 2018 To: DSM Advisory Group From: Cheryl Jenkins, Asa Parker, Vermont Energy Investment Corporation Date: March 12, 2018 Re: Response...

AI summary EfficiencyOne and VEIC respond to DSMAG action items regarding the Massachusetts TRC test, confirming it includes non-energy benefits (NEB) like rate discounts and utility benefits beyond avoided costs. Appendix C of the 2016-2018 Massachusetts TRM lists these benefits. The Massachusetts Energy Efficiency Guidelines define non-electric benefits for Program Participants.

Directive to develop Non-Energy Impact values In 2010, the Massachusetts Department of Public Utilities (Department) approved the use of Non-Energy Impacts in the energy efficiency three-year and annual plans of the state's energy efficien...

AI summary In 2010, Massachusetts' Department of Public Utilities (D.P.U.) mandated studies to evaluate the reliability of non-energy impacts in energy efficiency plans. Program Administrators conducted over 75 studies between 2010-2013, with findings summarized in the 2017 VEIC report. However, none of the benefits were recommended for use by EfficiencyOne.

Position of the Attorney General - "The Attorney General acknowledges that non-energy impacts are integral to energy efficiency programs and notes that a significant percentage of total program benefits are attributed to non-energy impact...

AI summary The Attorney General emphasizes the importance of non-energy benefits in energy efficiency programs and urges the Department of Public Utilities to reevaluate the TRC test's reliance on these benefits for cost-effectiveness analysis. The AG requests an investigation into whether non-energy impacts listed in the TRM should be included in such analyses.

Position of Program Administrators - "The Program Administrators, noting the Department's prior directive to evaluate the assumptions underlying the non-energy impacts incorporated in the cost-effectiveness analyses, assert that that they...

AI summary Program Administrators assert their non-energy impact assumptions align with TRC test requirements and are supported by data and expert testimony. They oppose the Attorney General's proposed investigation, calling it costly and inappropriate, and note the third-party vendor's role in developing these impacts.

Position of the Department of Economic Resources (DOER) - "DOER argues that the Department has previously approved the inclusion of non-energy impacts in the calculation of program benefits and that the Program Administrators appropriately...

AI summary DOER asserts that non-energy benefits (NEB) were properly included in program benefit calculations per prior approvals, with Program Administrators conducting studies under the Department-approved EM&V process. DOER defends the methodology used for NEB values as standard practice in the EM&V field, countering the Attorney General's objections.

Position of Environment Northeast (ENE) - "ENE argues that careful review and calibration of the treatment of non-energy impact assumptions is required to ensure that all benefits and costs of energy efficiency programs are accurately quan...

AI summary ENE emphasizes the need for accurate quantification of non-energy benefits and costs in energy efficiency programs. However, ENE contends that the current proceedings are not the appropriate forum for investigating these assumptions, as suggested by the Attorney General.

(4) That non-energy impacts for three individual benefits do not accrue specifically to program participants

AI summary The document argues that non-energy impacts (NEIs) for three specific benefits do not exclusively benefit program participants. This challenges the assumption that these impacts are directly tied to participants in efficiency programs, potentially affecting the evaluation of program effectiveness and cost-benefit analyses.

Department Analysis and Findings - "The TRC test includes only those benefits and costs that are associated with the energy system and program participants; non-energy impacts are appropriately included as a program benefit if they accrue...

AI summary The Department of Public Utilities (DPU) determines that non-energy benefits like national security, recycling from appliance turn-ins, and economic development do not specifically accrue to program participants and thus should not be included in the TRC test. Program Administrators are instructed to remove these from cost-effectiveness analyses.

Synapse Question 2: Per Table 1 of the VEIC report, a number of utility NEBs were not included in the VEIC analysis. Does E1 have plans to quantify these utility NEBs separately? If not, why not? Given the differing methodologies and signi...

AI summary EfficiencyOne excluded utility NEBs in their analysis due to differing methodologies and focus on market-rate programs, referencing a 2011 NMR study that recommends including Utility NEBs only for low-income programs.

Synapse Question 3: Is Table 4 of the VEIC report purely illustrative? If so, please clarify. Yes, Table 4 is intended to illustrate how a total NEB value for a given measure is comprised of different types of NEBs which sum to the overall...

AI summary The response confirms that Table 4 in the VEIC report is illustrative, explaining how total Non-Energy Benefits (NEB) values are composed of different types of NEBs that sum to the overall result.

Synapse Question 4: A table like Table 6 for residential NEBs would be informative. VEIC and EfficiencyOne will make this modification in the subsequent version of the report.

AI summary The text requests a table similar to Table 6 for residential Non-Energy Benefits (NEBs), which VEIC and EfficiencyOne commit to including in the next report version.

Synapse Question 5: Per p. 22 of the VEIC report, a blank cell in the treatment column indicates that the NEB value was directly applied to E1's portfolio. Some clarification is appropriate, however, as all values were apparently adjusted...

AI summary The text clarifies that NEB values in the VEIC report were adjusted for exchange rates and property value differentials. Synapse confirms exchange rate adjustments, while EfficiencyOne and VEIC note property value adjustments are indicated in Table 10 (pages 23-35) with a forthcoming footnote. Discrepancies in reporting methods are highlighted.

Synapse Question 6: Similar to the duplicate rows in Appendix B, Table 10 of the VEIC report includes rows that list the same measure but have different NEB values. Can another column be added to Table 10 to clarify how these rows are diff...

AI summary Table 10 of the VEIC report contains duplicate rows with varying NEB values. A request was made to add a column clarifying differences between these rows. VEIC and EfficiencyOne agreed to implement this modification.

Synapse Question 7: On p. 24, 4th row, the commercial clothes washer shows a negative NEB. Why is this value negative? As EfficiencyOne was already including water savings for this measure, the previous water savings value was "backed-out"...

AI summary The negative NEB for commercial clothes washers is due to replacing EfficiencyOne's water savings estimate with Massachusetts' lower estimate, resulting in a reduced value.

Attachment 3: DSMAG NEBs Presentation – June 27, 2018 Date Filed: September 19, 2018

AI summary Attachment 3 from a June 27, 2018 DSMAG NEBs presentation discusses Non-Energy Benefits (NEBs) in regulatory proceedings, likely involving programs like Efficiency Nova Scotia (ENS) and considerations of Total Resource Cost (TRC), Program Administrator Cost (PAC), and Integrated Resource Planning (IRP).

Non-Energy Benefits: DSMAG Feedback and Next Steps Presentation to DSMAG June 27, 2018

AI summary The document outlines a presentation to the DSMAG on June 27, 2018, focusing on non-energy benefits (NEBs) and next steps in the regulatory proceeding. It highlights the importance of NEBs in the evaluation process and the role of DSMAG in providing feedback.

Definition of Property Values related NEBs - From Efficiency Vermont's 2013-2015 Plan TRM - Property Value Increase Increased value of property and expected ease of selling [a] home [or multifamily building]. - Difficult to disentangle the...

AI summary The document discusses defining property value increases related to Non-Energy Benefits (NEBs), citing Efficiency Vermont's 2013-2015 Plan TRM. It highlights the difficulty in distinguishing between actual property value increases and perceived ease of selling, with the latter being based on the owner's beliefs rather than classical economic reality.

Summary of EfficiencyOne Position - True double-counting of property value does not exist in the results of the Massachusetts primary research - ENS agrees with the philosophical argument made by Research Insight, however, does not agree t...

AI summary Efficiency Nova Scotia (ENS) acknowledges Research Insight's philosophical argument but disputes its impact on Massachusetts data quantitatively. ENS argues miscategorization of NEBs via pro rata treatment requires costly new research, which is impractical. ENS recommends no changes to VEIC's report, citing no double-counting in Massachusetts primary research results.

Pro-rata Inclusion of Low-Income NEBs - Synapse recommended exploring the inclusion of low-income (LI) NEBs within market-rate programs, based on proportional participation - At the February DSMAG meeting regarding NEBs, VEIC indicated tha...

AI summary Synapse recommended proportionally including low-income NEBs in market-rate programs. VEIC argued additional NEBs would be minimal and not justify effort. Synapse requested data on LI customer participation in ENS programs. Other members had mixed support, with some conditional approval.

Analysis of the Affordable Multifamily Housing Pilot - AEC and others have submitted that the exclusion of lowincome NEBs from the analysis was inappropriate - AEC and others suggested that an initial analysis could include the Affordable...

AI summary AEC and others argue that excluding low-income non-energy benefits (NEBs) from the analysis was inappropriate and suggest including the Affordable Multifamily Housing pilot in initial assessments. Resource Insight recommends incorporating participant and utility NEBs in future evaluations of low-income programs.

Summary of ENS's Position - ENS agrees with VEIC's statement: "If Efficiency Nova Scotia offers a low-income program in the future, including NEBs values for low-income programs will ensure that the lowincome program valuation is consisten...

AI summary ENS supports including Non-Energy Benefits (NEBs) in low-income program valuations to align with its portfolio. However, insufficient data currently prevents analysis of the Affordable Multifamily Housing Pilot, though no harm is anticipated.

Summary of ENS's Position Cont. - ENS, as part of its regulatory submission regarding NEBs, will request approval to leverage the Mass. Low-Income NEI's Report2, excluding health-care system benefits (socialized in Canada), in future cost-...

AI summary ENS seeks approval to use the Mass. Low-Income NEI's Report2 (excluding Canadian healthcare benefits) in future cost-effectiveness testing for low-income programs, pending UARB acceptance. This approach will be applied during the next DSM Resource Plan evaluation.

Positive and Negative NEBs The Industrial Group expressed a desire to know whether Non-Energy Costs, in addition to benefits, were included within the Mass. data and VEIC's work

AI summary The Industrial Group questioned whether Non-Energy Costs, alongside benefits, were included in the Mass. data and VEIC's work, highlighting concerns about comprehensive evaluation of non-energy factors.

Impact of NEBs on Investment Allocation - The Industrial Group requested clarification on whether NEBs will affect the distribution of investment within programs - ENS does not anticipate the reallocation of program efforts due to the incl...

AI summary The Industrial Group seeks clarification on whether Non-Energy Benefits (NEBs) influence investment distribution. ENS asserts that program efforts will not be reallocated due to NEBs, emphasizing that meeting energy savings targets, maintaining a Balanced Portfolio, and strategic planning remain the primary factors in investment allocation.

Double Counting The Small Business Advocate requested clarification on how double counting was incorporated in the Mass studies, both with respect to interactions between measures, and different categories of NEBs

AI summary The Small Business Advocate requested clarification on how double counting was addressed in Mass studies, focusing on interactions between measures and categories of Non-Energy Benefits (NEBs). The proceeding involves Efficiency Nova Scotia (ENS) and the Department of Public Utilities (DPU).

Mass Survey Methods - For the Residential and Multifamily study two methods were used to prevent double-counting: - 1. The pro-rating of each category to the total declared value of NEBs by the respondent (refer to slide 6) - 2. The perfor...

AI summary The document outlines methods to prevent double-counting in residential and multifamily studies, including pro-rating NEBs and project-level surveys. Commercial and industrial studies do not use this method as benefits are easily monetized.

ENS Position - High degree of sensitivity to double-counting within Mass. studies - Impossible to "tweak" methodology used in Mass. without completely re-doing primary research - DSMAG consensus was for a reasonably expedited process for v...

AI summary ENS emphasizes concerns about double-counting in Massachusetts studies and the impracticality of modifying their methodology without re-doing primary research. It highlights DSMAG's consensus on expediting NEB valuation processes and notes no further action is recommended.

Summary - ENS appreciates the DSMAG discussion and comments on the topic of NEBs - ENS recommends that no further changes to VEIC's report be made at this time - Third iteration of report produced in June 2018 - ENS intends to submit VEIC'...

AI summary ENS acknowledges DSMAG's input on NEBs and recommends no further changes to VEIC's June 2018 report, intending to submit it to UARB soon.

Attachment 4: Final VEIC NEBs Report with Appendices – July 12, 2018 Date Filed: September 19, 2018

AI summary Attachment 4 presents the Final VEIC NEBs Report with Appendices dated July 12, 2018, submitted on September 19, 2018. It outlines non-energy benefits (NEBs) analysis for regulatory proceedings, involving entities like Efficiency Nova Scotia (ENS) and the Utilities and Ratepayers Board (UARB).

Measure-Level Non-Energy Benefits Study Prepared for EfficiencyOne by Vermont Energy Investment Corporation Final June 14, 2018

AI summary A Measure-Level Non-Energy Benefits Study, prepared by Vermont Energy Investment Corporation for EfficiencyOne, was finalized on June 14, 2018. The study focuses on quantifying non-energy benefits of efficiency programs, relevant to regulatory proceedings involving demand-side management and resource planning.

Section 2.0 Introduction to Non-Energy Benefits

AI summary This section introduces non-energy benefits (NEBs) within the context of regulatory proceedings, emphasizing their role in integrated resource planning (IRP) and evaluation, measurement, and verification (EM&V). It highlights the importance of quantifying NEBs alongside energy-related costs for comprehensive decision-making.

2.2 Current Status of Cost-Effectiveness Screening and NEBs in the Region States and provinces in eastern North America address non-energy benefits in energy efficiency cost-effectiveness screening using a variety of mechanisms. Figure 1 i...

AI summary Eastern North American jurisdictions use varied mechanisms to incorporate non-energy benefits (NEBs) in energy efficiency cost-effectiveness screening. Figure 1 maps these approaches, referencing the National Standard Practice Manual (NSPM) as a key guideline. New York and Rhode Island recently transitioned from TRC-based tests.

2.3 Non-Energy Benefits Research Background Research on NEBs of energy efficiency programs has evolved over the last 20 years. Early in the history of ratepayer funded efficiency programs, it quickly became evident to program administrator...

AI summary Research on non-energy benefits (NEBs) of energy efficiency programs has evolved over 20 years, identifying benefits beyond energy savings. Early studies categorized NEBs into participant, utility, and societal benefits, aligning with cost-benefit tests like the Utility Cost Test and Societal Cost Test. Over 300 studies now support incorporating NEBs into cost-effectiveness screening as a best practice.

2.3 Regulator-Approved Resources In 2010, Massachusetts' Program Administrators embarked on a comprehensive and robust series of studies identifying and valuing NEBs from their programs (see Appendix A for more details on these studies). T...

AI summary Massachusetts Program Administrators conducted extensive research on non-energy benefits (NEBs) from energy efficiency programs, leading to the Massachusetts Technical Reference Manual (MA TRM). This manual, approved by the Massachusetts Department of Public Utilities, has influenced other jurisdictions like Rhode Island and Maryland. The studies provide evidence-based NEB values used in regulatory proceedings and cost-effectiveness screenings.

Section 3.0 Methodology of NEBs Application and Adaptation VEIC was commissioned by EfficiencyOne to conduct an analysis of a full suite of non-energy benefits to be quantified for Efficiency Nova Scotia's portfolio of measures. VEIC condu...

AI summary VEIC analyzed non-energy benefits (NEBs) for Efficiency Nova Scotia's programs, using Massachusetts' research as the primary resource. Deliverables include a report, presentation to the DSM Advisory Group, and an Excel tool for future use. Massachusetts' MA TRM provides adaptable measure-level NEB values for Nova Scotia's measures.

3.1 Local Adjustments to MA TRM Values In some cases, the adaptation of NEBs directly from the MA TRM was not feasible – for example, if a measure in Nova Scotia was similar but not the same as a measure in Massachusetts. In this case, we...

AI summary The document outlines challenges in directly applying Massachusetts TRM NEB values to Nova Scotia measures due to differences in program design. When measures differ, primary research was used to assign NEB values based on technology type (e.g., commercial end-use categories). The process is categorized into six groups, emphasizing technology-based NEB allocation where direct alignment was not possible.

Section 6.0 Effects of NEBs on Total Resource Cost Test Results

AI summary This section examines how Non-Energy Benefits (NEBs) influence the Total Resource Cost (TRC) test results, a key metric in evaluating energy efficiency programs. It likely explores the integration of NEBs into TRC calculations, their quantification, and implications for regulatory decisions.

6.1 Measure-level Effects The inclusion of NEBs in cost-effectiveness testing resulted in a correction to the cost/benefit ratio for approximately two-thirds of the measures in Nova Scotia's portfolio. The research assigned NEB values to m...

AI summary Incorporating Non-Energy Benefits (NEBs) in cost-effectiveness testing altered the cost/benefit ratio for two-thirds of Nova Scotia's energy efficiency measures, while 82 measures remained unchanged. NEB values were assigned based on statistical significance, and details are documented in Appendix B and the NEB Analysis Tool spreadsheet (Appendix C).

al service providers and health and safety experts. The goal of these interviews was to review NEBs in the literature, identify additional NEBs and to understand how NEBs were treated in other states. NMR proceeded to use this information...

AI summary The study involved interviews with service providers and experts to review Non-Energy Benefits (NEBs), design surveys for households and low-income rental housing, and assess NEI (Non-Energy Impacts). Surveys included 213 low-income and 209 non-low-income households, stratified by installed measures, with questions on perceived NEI value, health changes, and demographics. The methodology details sample size and weighting.

Request IR-11: Table 1 (page 5 of 64) of the VEIC Report (Attachment 4) lists NEBs "Recommended for Inclusion in the ENS Market Rate Programs". a) Please identify which of these E1 believes are currently accounted for by customers who cons...

AI summary EfficiencyOne (E1) communicates all Non-Energy Benefits (NEBs) listed in the VEIC Report to customers through DSM marketing and direct communication, though the extent varies. Benefits are shared generally to raise awareness, not as specific dollar savings estimates, per E1's response to the Nova Scotia Utility and Review Board (UARB).

NON-CONFIDENTIAL Request IR-12: The second paragraph on page 6 of 64 of the VEIC Report (Attachment 4) discusses how NEBs were developed as a per Kwh value. Please provide an example, showing how the NEB was developed for a particular tech...

AI summary VEIC clarifies that Massachusetts, not VEIC, developed NEB per kWh values. They reference the Massachusetts C&I study, which converts NEB values to per-kWh using absolute monetary values. An example uses the Solid Door Commercial Refrigerator measure, calculating NEB as 681 kWh × $0.047/kWh = $32.00 annually.

NON-CONFIDENTIAL - 1 measures that only have property value NEIs, such as appliances and low-flow - 2 showerheads, we recommend using in the BCR calculations the property value NEIs - 3 as proxies for the individual NEIs that have not yet...

AI summary The document discusses using property value NEIs as proxies in BCR calculations for efficiency measures. PAs and EEAC applied this in their 2019-2021 filing, while VEIC revised tables and appendices to reflect removal of property value NEBs. Revisions include Attachment 1 (Tables 10-19) and Attachment 2 (Appendix C).

14 Efficiency Nova Scotia Programs and Portfolio (Plan Year 2016) Program Plan Year 2016 Total Benefits w/o NEBs Total Benefits with NEBs TRC Ratio w/o NEBs TRC Ratio with NEBs BNI – Efficient Product Rebates $23,758,752 $29,834,913 2.01 2...

AI summary The document presents Efficiency Nova Scotia's 2016 programs, showing total benefits with and without non-energy benefits (NEBs) and TRC ratios for each program. The TRC ratios range from 1.0 to 3.66, indicating varying cost-effectiveness. The total portfolio benefits increase significantly when NEBs are included.

Selected Publications and Presentations - Malmgren, Ingrid, and Cassie Powers. Volkswagen Settlement Beneficiary Mitigation Plan Toolki t. National Association for State Energy Officials, 2017. - Malmgren, Ingrid, David Roberts, and Justin...

AI summary The document lists publications and presentations by Ingrid Malmgren and colleagues on topics including electric vehicles, clean energy programs, and non-energy benefits. Key organizations involved are Sierra Club, NYSERDA, NASEO, and ACEEE. Themes focus on demand-side management, grid-interactive vehicles, and integrating non-energy benefits into policy.

Lessons from the Field: Practical Applications for Incorporating Non-Energy Benefits into Cost-Effectiveness Screening Ingrid Malmgren, Vermont Energy Investment Corporation Lisa A. Skumatz, Skumatz Economic Research Associates, Inc. (SERA)

AI summary The document discusses practical applications for integrating non-energy benefits into cost-effectiveness screening in regulatory proceedings. It highlights insights from field experiences, focusing on demand-side management and energy efficiency, with contributions from experts in the field.

ABSTRACT The literature on non-energy benefits (NEBs) has shifted in the past several years from the recognition of these benefits by regulators and program administrators to recommendations on how best to incorporate these benefits into c...

AI summary The paper discusses the evolution of non-energy benefits (NEBs) in energy efficiency programs, emphasizing their integration into cost-effectiveness screening. It highlights three NEB classifications (participant, utility, societal) and presents case studies showing practical applications across varying regulatory frameworks. The analysis underscores NEBs as a best practice for program evaluation.

Introduction For decades, researchers have recognized that a significant portion of the value of energy efficiency programs comes not only from the energy savings, but from the programs' other impacts, their non-energy benefits. Unfortunat...

AI summary The introduction highlights the undercounting of non-energy benefits (NEBs) in energy efficiency programs, emphasizing their significant value beyond energy savings. It discusses literature on NEB classification, quantification methods, and best practices for integrating NEBs into cost-effectiveness screening. Four case studies illustrate approaches to quantify NEBs and challenges encountered.

Twenty Years of Progress on NEBs Over the past 20 years, NEB research has progressed from hypothesized lists of generalized benefits that might be attributable to programs, to tentative applications in lowincome programs, to full-fledged e...

AI summary Over 20 years, NEB research evolved from hypothetical benefit lists to detailed estimation across hundreds of programs. Key steps include early low-income program applications and expanded categorization of benefits (Skumatz 2013, Skumatz et al. 2009).

The New York Case Study Included in this paper, are four case studies of how non-energy benefits became incorporated into cost-effectiveness screening. If one looks at these cases chronologically, they appear to operate like a set of domin...

AI summary New York's case study details how NYSERDA incorporated non-energy benefits (NEBs) into program evaluations through scenarios, influencing other states. While NEBs are not formally used in cost-effectiveness screening by the Department of Public Service, a 2013 Public Service Commission order initiated TRC policy review. NYSERDA's research on NEBs, though not adopted in New York, informed policies in Colorado and Vermont.

Lessons Learned Research is critically important in quantifying and validating the value of NEBs in energy efficiency programs. NYSERDA invested considerably in NEB research on all of its programs, and developed tailored, local models to e...

AI summary Research is vital for quantifying non-energy benefits (NEBs) of energy efficiency programs. NYSERDA invested in NEB research, creating local models to estimate job and economic impacts. While this research improved programs, it requires programmatic and political support to maximize benefits.

general policy matters, and addressed low-income cost-effectiveness. Special consideration was given to the TRC calculation for low-income programs (using a UCT in the event the TRC is less than 1.0). 136. For those low-income DSM programs...

AI summary The Colorado case study discusses adjustments to the Total Resource Cost (TRC) calculation for low-income Demand Side Management (DSM) programs. For programs with TRC below 1.0, a modified Utility Cost Test (UCT) is applied, considering existing public infrastructure as a 'public good.' The Colorado PUC mandated a 20% increase in benefits for low-income DSM programs, while Gas Rules require multiplying TRC by 1.05 to account for societal benefits.

The Vermont Case Study Three elements contributed to the incorporation of cost-effectiveness screening in Vermont: the quantity and nature of available research regarding NEBs, a growing number of other jurisdictions incorporating NEBs int...

AI summary Vermont integrated Non-Energy Benefits (NEBs) into cost-effectiveness screening due to research, stakeholder collaboration, and jurisdictional trends. Since 2000, Vermont operated a statewide efficiency program. The 1990 Docket 5270 established the Societal Cost-effectiveness Test with 5% and 10% adders for environmental and risk benefits. In 2009, a consensus emerged on NEB value, leading to Riley Allen's recommendation for a 5% NEB adder and research partnerships.

The District of Columbia Case Study Although the population of the District of Columbia is roughly the size of the population of Vermont, there are many differences between the energy efficiency utility operated in Vermont and the DC Susta...

AI summary The District of Columbia's energy efficiency utility (DCSEU), established in 2011 under the Clean and Affordable Energy Act of 2008, differs from Vermont's model by integrating social equity goals and using the Societal Benefit Test for cost-effectiveness. Funding comes from system benefits charges and RGGI credits, with NEBs and risk adders included in evaluations.

Lessons and Conclusions Twenty years on, it appears to be time to reconsider benefit-cost tests that better represent actual benefits and costs, and support more optimal program investment. It is clear that there has been incremental progr...

AI summary The document emphasizes the need to update benefit-cost tests to include Non-Energy Benefits (NEBs) for accurate energy efficiency program evaluations. It highlights how states like New York, Colorado, and Vermont have influenced each other's policies and stresses the importance of value-based decision-making to address biases in cost-effectiveness tests.

References Allen, R. 2009. Vermont Public Service Board Memorandum, October 30. page 16. http://psb.vermont.gov/sites/psb/files/projects/EEU/screening/VEICCommentsReAllenMemo200 9-12-04.pdf - Clean and Affordable Energy Act, Council of the...

AI summary The references include legal documents, studies, and legislation related to energy efficiency, non-energy benefits, and regulatory decisions. Key entities involve Vermont and Colorado regulatory bodies, ACEEE, and Brookings Institution. Topics focus on cost-effectiveness screening, TRC, and NEBs. Cross-references include Colorado PUC decisions and Vermont PSB memoranda.

Beyond Energy Savings?

AI summary The document text is a chunk from a Nova Scotia regulatory proceeding document titled 'Beyond Energy Savings?' containing only image placeholders. No substantive content or analysis is provided in the text, making it impossible to extract detailed arguments, topics, or cross-references.

Value of Distributed Solar Electric Generation by Location Category Value (¢/kWh) Pittsburgh, PA Harrisburg, PA Scranton, PA Philadelphia, PA Jamesburg, NY Newark, NJ Atlantic City, NJ ME NY MA CT Fuel cost savings 4.1 4.1 4.1 3.8 4.2 3.9...

AI summary The table quantifies the value of distributed solar generation across U.S. locations, showing benefits like fuel cost savings, environmental value, and economic development. Total values range from 22.6 to 33.7 cents/kWh, with Maine and Massachusetts having higher totals. Data sources include academic studies and regulatory bodies.

te that, "NEBs may reflect some of the most important effects from energy efficiency measures and programs, and may especially represent some of the most important outcomes for low-income strategies." In 2009, the Colorado Public Utility C...

AI summary The text discusses the valuation of Non-Energy Benefits (NEBs) in energy efficiency programs, highlighting Colorado's approach with different NEB adders for low-income and non-low-income programs. VEIC supports a 30% non-energy benefit adjustment, citing administrative efficiency and additional benefits for low-income programs. Colorado PUC increased the NEB adder for low-income programs to 25% in 2011.

2. Valuation of HPF Non-Energy Benefits (NEBs) in Low-Income Programs Fluctuations in Heating and Process Fuel markets disproportionately affect low income households. As a result, an increasing number of state programs are incorporating N...

AI summary The document discusses the valuation of non-energy benefits (NEBs) in low-income energy efficiency programs, emphasizing their disproportionate impact on low-income households. It references historical research (SERA, NCLC) showing NEB adders can justify 17–300% adjustments. VEIC advocates for a two-tier NEB adder, with a 15% minimum increment for low-income programs, citing energy affordability and societal benefits like reduced homelessness and utility non-payments.

NON-CONFIDENTIAL Request IR-05: Ref: Attachment 4. (a) Please confirm if average home energy use was adjusted for by VEIC in its report and, if not, why not? (b) What is the difference in the average home energy use in Massachusetts compar...

AI summary VEIC did not adjust average home energy use in its report as it was not tied to specific NEBs analyzed. Massachusetts vs. Nova Scotia comparisons were deemed irrelevant to VEIC's research. U.S. and Canadian per capita residential electricity use is comparable.

3 Outcomes/End Results Required Completion of an analysis that provides a full suite of non-energy benefits to be quantified for Efficiency Nova Scotia's portfolio of measures. These non-energy benefits are to be provided through adoption...

AI summary The analysis requires quantifying non-energy benefits for Efficiency Nova Scotia's measures using studies from jurisdictions like Massachusetts, which have explicitly quantified such benefits. Massachusetts is highlighted as a jurisdiction with prior explicit quantification efforts.

4 Scope of Work EfficiencyOne would like to quantify the NEBs of its efficiency measures in a simplified manner. Through consultation with the DSMAG, the rationale for this preference is based on more expeditious and cost-efficient impleme...

AI summary EfficiencyOne seeks to quantify Non-Energy Benefits (NEBs) of its efficiency measures using simplified methods, preferring adaptation of Massachusetts research. The approach requires measure-specific factors (percentages, per unit, or per kWh) and consideration of jurisdictional differences. Attachments provide resource plans and Massachusetts studies for reference.

4.5 Deliverables Project deliverables must include: - 1. An initial scoping document (can be in tabular format) identifying the relative difficulty of adapting NEBs from other jurisdictions. This document will be reviewed by EfficiencyOne,...

AI summary Deliverables include an initial scoping document, a draft report with methodology and findings, a final report, and a presentation. Focus areas are adapting Non-Energy Benefits (NEBs) and Total Resource Cost (TRC) test results, involving EfficiencyOne, the Research Team, and the Proponent. The draft report must include justification for NEB modifications and interim values for non-adaptable measures.

NON-CONFIDENTIAL Request IR-06: 2 1 - 3 In general, would more measures and programs pass the cost effectiveness test based on the - 4 PAC or on the TRC with NEBs included? Please elaborate. 5 6 Response IR-06: 7 - 8 In general, more measu...

AI summary The response indicates that more measures pass the cost-effectiveness test under the PAC method compared to TRC with NEBs, due to lower NEB values. Examples and calculations show PAC ratios are higher. VEIC's recommendations and the impact of NEBs on TRC are discussed, with most cases not surpassing PAC results.

NON-CONFIDENTIAL Request IR-08: Does the CE testing methodology proposed by EfficiencyOne put any limitation on how much NEBs (as a percentage of energy benefits) can be considered in the cost-effectiveness testing? Response IR-08: Efficie...

AI summary EfficiencyOne's proposed CE testing methodology uses specific NEB values from Massachusetts research rather than a direct methodology, implying a limitation on NEB percentages. Future changes would involve consultation with the DSM Advisory Group or NSUARB, as outlined in the Application.

4.1 HOME ENERGY ASSESSMENT

AI summary The section titled '4.1 HOME ENERGY ASSESSMENT' outlines regulatory considerations related to home energy evaluations. Key entities include Efficiency Nova Scotia (ENS) and Vermont Energy Investment Corporation (VEIC), with discussions on Non-Energy Benefits (NEBs) and Overall Prevalence (OP) metrics.

6.1 BUSINESS ENERGY REBATES - MAIL-IN

AI summary Section 6.1 outlines a mail-in business energy rebate program under Efficiency Nova Scotia (ENS), referencing Vermont Energy Investment Corporation (VEIC) and Non-Energy Benefits (NEBs). The section discusses Overall Prevalence (OP) metrics but lacks detailed arguments, citations, or procedural specifics.

Assumptions Actual program participants are apartment building owners. Avoided energy benefits are assumed to flow-through to tenants either a) directly, where tenants pay power bills, or b) indirectly, by means of deferred increases in re...

AI summary The assumption outlines that apartment building owners participate in the program, with avoided energy benefits reaching tenants either directly through power bill payments or indirectly via deferred rent increases.

Assumption Actual program participants are apartment building owners. Avoided energy benefits are assumed to flow-through to tenants either a) directly, where tenants pay power bills, or b) indirectly, by means of deferred increases in ren...

AI summary The assumption is that apartment building owners participate in programs, with avoided energy benefits flowing to tenants directly or indirectly. The BER-IR program's installation locations are unknown, and low-income participation is assumed similar to BER-MI.

Assumption Actual program participants are apartment building owners. Avoided energy benefits are assumed to flow-through to tenants either a) directly, where tenants pay power bills, or b) indirectly, by means of deferred increases in ren...

AI summary The assumption outlines that apartment building owners participate in the program, with avoided energy benefits flowing to tenants either directly (if tenants pay power bills) or indirectly through deferred rent increases. This addresses how benefits are distributed under the program's structure.

NON-CONFIDENTIAL Request IR-09: Please refer to the workbook titled "Attachment 4 – Appendix C", cell CK27. For this measure, does a negative NEB signify an additional cost to the customer? Response IR-09: The following response has been p...

AI summary The response to Request IR-09 clarifies that a negative NEB does not indicate an additional customer cost but reflects lower estimates by VEIC compared to EfficiencyOne, driven by differences in water savings calculations.

M08888 IN THE MATTER OF The Public Utilities Act , R.S.N.S. 1989, c. 380, as amended. - and - IN THE MATTER OF an Application by EfficiencyOne for Approval of the Use of Measure Level Non-Energy Benefits Within Cost Effectiveness Testing

AI summary Matter M08888 involves an application by EfficiencyOne under the Public Utilities Act to approve the use of Measure Level Non-Energy Benefits within cost-effectiveness testing. The proceeding examines whether such benefits should be included in evaluations of energy efficiency programs.

- On November 22, 2018, after responding to the Information Requests of the Intervenors, and having - regard to the upcoming regulatory proceedings in 2019 with respect to the 2020-22 DSM Plan - Application, EfficiencyOne requested the NEB...

AI summary EfficiencyOne requested deferral of the NEB Application in 2018, leading to the NSUARB adjourning proceedings until 2019. The NSUARB raised jurisdictional authority concerns under the Public Utilities Act, prompting EfficiencyOne to engage stakeholders and seek clarification on the Board's jurisdiction to consider Non-Energy Benefits. Stakeholders including Synapse, NSPI, and advocates raised similar concerns.

EFFICIENCYONE'S POSITION - EfficiencyOne respectfully submits that the NSUARB has full jurisdiction to take into account non-energy - impacts in cost effectiveness testing. In particular, the Utility and Review Board Act S.N.S. 1992, c. 11...

AI summary EfficiencyOne asserts the NSUARB has jurisdiction to consider non-energy impacts in cost-effectiveness testing, citing statutory authority from the Utility and Review Board Act and Public Utilities Act. It emphasizes the NSUARB's role in determining customer interests, performance requirements, and DSM plan terms.

- duty to determine what is appropriate for consideration in the assessment of a DSM plan. The PUA - provides no explicit direction to the Board in determining the best interests of customers. The PUA does - not restrict the types of matte...

AI summary The Nova Scotia Utility and Review Board (NSUARB) has broad discretion under the Public Utilities Act (PUA) to assess Demand Side Management (DSM) plans, including non-energy benefits. The PUA does not restrict considerations beyond what is 'appropriate,' allowing the Board to determine relevant factors for customers' best interests. The Board's oversight includes DSM activities and utility regulation.

The Commission stated: "…A failure on our part to consider broader societal impact stemming from the implementation of energy efficiency programs would ignore the codified intent of the General Assembly "to provide affordable, reliable, an...

AI summary The Commission emphasizes the need to consider societal and non-energy benefits in energy efficiency programs, aligning with the Public Utilities Act's mandate for affordability. They assert that cost-effectiveness alone isn't sufficient, as the Board must also evaluate rate impacts, jobs, and environmental effects. Maryland's approach supports including non-energy benefits in cost-effectiveness tests.

CONCLUSION AND RELIEF SOUGHT - Based upon the foregoing, EfficiencyOne respectfully submits that the Board's broad jurisdiction to - determine what matters are appropriate to consider in the assessment of DSM plans includes the - authority...

AI summary EfficiencyOne argues the NSUARB has jurisdiction to consider non-energy impacts in cost-effectiveness testing for DSM plans and requests approval of the NEB Application or a variation. The submission emphasizes the Board's authority to assess non-energy benefits in DSM evaluations.

M08888 IN THE MATTER OF The Public Utilities Act , R.S.N.S. 1989, c. 380, as amended. - and - IN THE MATTER OF an Application by EfficiencyOne for Approval of the Use of Measure Level Non-Energy Benefits Within Cost Effectiveness Testing

AI summary The document pertains to a regulatory proceeding under the Public Utilities Act, R.S.N.S. 1989, c. 380, involving EfficiencyOne's application to approve the use of measure-level non-energy benefits within cost-effectiveness testing.

5.1 Total Resource Cost ("TRC") [82] ENSC's application proposes to use the TRC test at the program level and not at the measure level starting in 2012: ENSC is proposing that the TRC test for the 2012 DSM Plan be applied at the program le...

AI summary ENSC proposes applying the TRC test at the program level for the 2012 DSM Plan, allowing consideration of strategic benefits beyond TRC. The CA and Province support this approach, while EAC highlights TRC's limitations in quantifying non-energy benefits. Programs in 2012 show TRC values above 1.0, indicating cost-effectiveness.

- May 1, 2012. That was because, on May 30, 1998, the Province warned Central the parcel might be expropriated and, as Central had been told of the pending expropriation, there would be no compensation for future capital improvements on th...

AI summary Central claims compensation for land expropriation, arguing the Province's 1998 warning disrupted their plans. The Board found occupation existed despite the warning, rejecting the Province's claim that Central's failure to build by 2012 disentitles them. The Court affirms the Board's interpretation of 'occupation' and legal principles against rewarding the Province's actions.

SMITH : Yes, I do. And he you know, he you know, he was being nice but he said this wasn't settled but he said that if you know, it could be changed and, you know, this is very preliminary. But he also told me that now that you know about...

AI summary Mr. Smith testified that the Province did not inform him of the expropriation process, stating he was only told that developments on the corridor would not be compensated. He had limited contact with provincial employees, only one of whom discussed expropriation. The Province's lack of clear communication left him unaware of the process.

, the benefit derived from the avoidance of CO2 emissions directly corresponds to energy reduction and cost effective delivery of electricity; the same cannot be said for the presently proposed NEBs.. By way of further contrast, the Indust...

AI summary The document contrasts CO2 emission benefits with NEBs, emphasizing the Industrial Group's reference to the Board's mandate under the Gas Distribution Act to evaluate non-gas benefits. It cites a 2003 franchise application example, highlighting socio-economic and environmental impacts of gas expansion, including GDP growth, employment, and emission reductions.

March 9, 2020 VIA EMAIL 28840 Ms. Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Dear Ms. Friis: Re: M08888 - EfficiencyOne - Approval of Use of Mea...

AI summary The Consumer Advocate supports EfficiencyOne's position that the Nova Scotia Utility and Review Board (NSUARB) may consider non-energy impacts in cost-effectiveness testing for electricity efficiency measures. The letter confirms the Board's jurisdiction to define criteria for selecting demand-side management (DSM) measures funded by ratepayers.

Nova Scotia Utility and Review Board IN THE MATTER OF The Public Utilities Act, R.S.N.S. 1989, c.380, as amended - and - IN THE MATTER OF an Application by EfficiencyOne for approval for the use of measure-level Non-Energy Benefits within...

AI summary The Nova Scotia Utility and Review Board is considering an application by EfficiencyOne to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning under the Public Utilities Act. The proceeding involves regulatory processes related to DSM and non-energy benefits.

Nova Scotia Utility and Review Board DSM Non-Energy Benefits Nova Scotia Power Book of Authorities

AI summary The document pertains to a regulatory proceeding involving Nova Scotia Power and the Nova Scotia Utility and Review Board, focusing on DSM (Demand Side Management) Non-Energy Benefits. It is part of the Book of Authorities submitted in the case.

DSM Non-Energy Benefits – Book of Authorities NON-CONFIDENTIAL

AI summary The document is titled 'DSM Non-Energy Benefits – Book of Authorities' and is marked as non-confidential. It appears to relate to regulatory proceedings involving demand-side management (DSM) non-energy benefits, though no specific content or arguments are provided in the given text.

en établi qu'une disposition législative susceptible d'avoir un effet confiscatoire doit être interprétée avec prudence afin de ne pas dépouiller les parties intéressées de leurs droits lorsque ce 79 legislation (see Sullivan, at pp. 400-4...

AI summary The text argues that legislative provisions with potentially confiscatory effects must be interpreted cautiously to protect stakeholders' rights. It references Supreme Court of Canada cases emphasizing that attaching conditions to allocate sale proceeds infringes on economic freedom. The Alberta legislature is urged to explicitly provide ratepayer benefits, as done in U.S. states like Connecticut.

E.B.R.O. 341‑I, June 30, 1976, the Ontario Energy Board considered how to deal with a real estate profit on land which was disposed of at an after-tax profit of over $2 million. The Board stated: 115 The Station "B" property was not purcha...

AI summary The Ontario Energy Board (OEB) in 1976 addressed allocating real estate profits from land sales, arguing that sharing gains between shareholders and ratepayers prevents utility-driven speculation. U.S. regulators, as in Re Boston Gas Co. , similarly advocate allocating profits to offset rate base costs, ensuring fair distribution and preventing service degradation.

012] 1 S.C.R. 5; Reference re Remuneration of Judges of the Provincial Court of Prince Edward Island , [1997] 3 S.C.R. 3; Delios v. Canada (Attorney General) , 2015 FCA 117, 472 N.R. 171; Halifax (Regional Municipality) v. Nova Scotia (Hum...

AI summary A list of cited legal cases from various jurisdictions, including Supreme Court of Canada decisions, federal and provincial court rulings, and foreign cases, relevant to legal proceedings in Nova Scotia and other regions.

M08888 IN THE MATTER OF The Public Utilities Act , R.S.N.S. 1989, c. 380, as amended. - and - IN THE MATTER OF an Application by EfficiencyOne for Approval of the Use of Measure Level Non-Energy Benefits Within Cost Effectiveness Testing

AI summary The document outlines a regulatory proceeding under the Public Utilities Act, involving EfficiencyOne's application to incorporate non-energy benefits into cost-effectiveness testing for utility measures.

Other Jurisdictions EfficiencyOne agrees with NS Power that there are important differences between the enabling legislation of Maryland and Nova Scotia. The provision cited by NS Power, §7-211(i)(1), requires that the Commission, in asses...

AI summary EfficiencyOne and NS Power debate differences between Maryland and Nova Scotia legislation regarding non-energy benefits (NEBs) in demand-side management (DSM). NS Power argues Maryland's §7-211(i)(1) explicitly requires considering job and environmental impacts, while EfficiencyOne notes Maryland law allows broader NEB considerations beyond these factors. Nova Scotia's PUA grants the NSUARB more flexible authority to account for NEBs.

REPLY TO INDUSTRIAL GROUP SUBMISSIONS The Industrial Group submitted that the NSUARB does not have jurisdiction to take into account nonenergy benefits because (1) NEBs do not bear any relevance to EfficiencyOne's statutory mandate to unde...

AI summary The Industrial Group argues that the NSUARB lacks jurisdiction over non-energy benefits (NEBs), claiming NEBs are irrelevant to EfficiencyOne's mandate and that the NSUARB's discretionary power must be confined to its defined jurisdiction.

Relevance of NEBs to EfficiencyOne's Statutory Mandate The Industrial Group submissions rely on a narrow characterization of the potential impact of including NEBs in cost-effectiveness testing, which is not supported by the materials prov...

AI summary The Industrial Group argues that NEBs should not be included in cost-effectiveness testing as they do not address electricity use, but the text counters that NEBs could reduce consumption and support EfficiencyOne's mandate. The NSUARB is urged to determine NEBs' relevance to EfficiencyOne's statutory role.

C02 Emissions The Industrial Group states "the benefit derived from the avoidance of CO2 emissions directly corresponds to energy reduction and cost effective delivery of electricity" and that "the same cannot be said for the presently pro...

AI summary The Industrial Group argues that CO2 emission avoidance is more directly tied to energy reduction and cost-effective electricity delivery than non-energy benefits (NEBs). EfficiencyOne counters that the Industrial Group's claim is unsupported by their submissions on the NEB Application, noting that NEBs' impact on energy consumption remains undetermined in the application.

Gas Distribution Act and Regulations The Industrial Group further refers to the NSUARB's explicit mandate to account for non-gas benefits when considering an application for a gas distribution franchise. The purpose of the Gas Distribution...

AI summary The Industrial Group emphasizes the NSUARB's mandate to consider non-energy benefits in gas franchise applications, underscoring the Gas Distribution Act's role in regulating Nova Scotia's gas delivery system and ensuring fair competition in natural gas consumption.

CONCLUSION Respectfully, the submissions provided by those interested parties in opposition to the position taken by EfficiencyOne attempt to conflate the jurisdictional question presently before the NSUARB with the ultimate question of th...

AI summary EfficiencyOne argues the NSUARB can consider non-energy benefits (NEBs) in cost-effectiveness testing for DSM plans under the PUA, emphasizing jurisdictional authority is distinct from NEB application merits. Opponents conflate these issues, but EfficiencyOne asserts NEB inclusion does not dictate DSM plan approval. The PUA grants broad discretion to NSUARB to weigh 'other matters' in assessments.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary This regulatory proceeding under the Public Utilities Act involves EFFICIENCYONE's application to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning. The proceeding is before a panel including Peter W. Gurnham, Roberta J. Clarke, and Steven M. Murphy.

HEARING ORDER WHEREAS by Application dated September 19, 2018, EfficiencyOne (E1) applied to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future DS...

AI summary EfficiencyOne (E1) applied for approval to use Non-Energy Benefits in DSM planning. The Board ordered a public hearing with a detailed timetable, citing the Board Regulatory Rules. The Clerk of the Board was directed to notify participants in DSM proceedings.

NOTICE OF HEARING EFFICIENCYONE (E1) has made application to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand Side Management (DSM) plann...

AI summary EfficiencyOne (E1) seeks approval from the Board to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning. The hearing is scheduled for January 8-11, 2019, in Halifax, NS.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measurelevel Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary The document outlines an application by EfficiencyOne for approval to incorporate measure-level Non-Energy Benefits into Cost-Effectiveness testing for future Demand Side Management (DSM) planning under the Public Utilities Act. The proceeding is before a panel including Peter W. Gurnham, Roberta J. Clarke, and Steven M. Murphy.

ORDER WHEREAS by Application dated September 19, 2018, EfficiencyOne applied to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future DSM planning re...

AI summary EfficiencyOne requested deferral of its application to use Non-Energy Benefits in Cost-Effectiveness testing for further consultation. The Board adjourned the hearing and established a timetable for developing an issues list, stakeholder sessions, and filing updates by December 31, 2019.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary EfficiencyOne applied to include non-energy benefits in cost-effectiveness testing for Demand Side Management (DSM) planning. The Board ruled it lacks jurisdiction to consider non-energy impacts in such testing. Intervenors included consumer, business, and environmental groups, with Nova Scotia Power opposing the application.

2.3.1 EfficiencyOne - [12] EfficiencyOne argued that the Board has jurisdiction to decide what is in the best interests of customers and the appropriate factors to consider in that assessment, including how cost-effectiveness is determined...

AI summary EfficiencyOne argues that the NSUARB has broad jurisdiction under the Public Utilities Act to assess customer best interests, including non-energy benefits, and that cost-effectiveness of DSM programs falls within the Board's authority. It cites legislative intent and references Maryland's precedent, while NSP notes differences in Maryland's DSM legislation.

here is neither an explicit power in the Public Utilities Act nor an implicit power in the Board to take into account non-energy benefits. Again, relying on the Atco Gas decision, NS Power stated: On the basis of the foregoing, despite the...

AI summary NS Power argues that the NSUARB lacks jurisdiction to consider non-energy benefits in cost-effectiveness testing, citing the Public Utilities Act and the Atco Gas decision. They assert that such considerations are not necessary for the Board's role in ensuring just rates and safe service. A Federal Court of Appeal decision on the National Energy Board's jurisdiction is referenced, emphasizing the absence of explicit or implicit authority for cost awards.

contemplated by Section 79A of the Public Utilities Act misinterprets the jurisdiction conferred by the Public Utilities Act. [40] The Board cites with approval the passage noted above in Atco: ...The Board's seemingly broad power to make...

AI summary The NSUARB argues that Section 79A of the PUA does not grant unlimited jurisdiction, emphasizing rate-setting and supply system integrity as core functions. It rejects considering non-energy benefits for EfficiencyOne's mandate, citing Atco's emphasis on statutory limits. Exhibit E-13, p.8 is referenced, with the Board aligning with the Industrial Group on statutory authority boundaries.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measurelevel Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary The document pertains to a regulatory proceeding under the Public Utilities Act, involving EfficiencyOne's application to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning. The proceeding is before a panel including Peter W. Gurnham, Q.C., Chair, oberta J. Clarke, Q.C., and Stephen T. McGrath, LL.B.

ORDER WHEREAS by Application dated September 19, 2018, EfficiencyOne applied to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future DSM planning re...

AI summary EfficiencyOne sought approval to include non-energy benefits in cost-effectiveness testing for DSM planning. The Board adjourned proceedings multiple times, with EfficiencyOne requesting deferrals and jurisdiction clarification. After submissions from multiple parties, the Board ruled it lacks jurisdiction to consider non-energy benefits in cost-effectiveness testing.

James R. Gogan Direct Dial: (902) 563-5920 E-Mail: [email protected] File No. 41736-71 September 19, 2018 Nova Scotia Utility & Review Board PO Box 1692, Unit "M" Halifax, Nova Scotia B3J 3S3 Attention: Doreen Friis, Regulatory Affair...

AI summary EfficiencyOne seeks approval to use measure-level Non-Energy Benefits (NEBs) in cost-effectiveness (CE) testing for future Demand Side Management (DSM) planning. This follows Board Matter M06733, where a Consensus Agreement required collaborative work with the DSM Advisory Group to quantify NEBs for improving CE tests. The agreement acknowledged that low-income-focused measures may fail CE tests.

isory Group's progress on this work. - c) The Parties acknowledge that specific measures and/or programs exclusively targeted toward low-income Nova Scotians may not pass a cost-effectiveness test. In its December 22, 2016, update to the B...

AI summary EfficiencyOne submitted recommendations on non-energy benefits (NEB) to the Board, noting that low-income measures may fail cost-effectiveness tests. The Board acknowledged EfficiencyOne's work on NEB methodology, pending future applications. EfficiencyOne requested to file only an electronic copy of a large attachment. The Breton Law Group is listed as counsel.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary The document outlines a regulatory proceeding under the Public Utilities Act regarding EfficiencyOne's application to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning processes. The proceeding is before a panel including Peter W. Gurnham, Roberta J. Clarke, and Steven M. Murphy.

HEARING ORDER WHEREAS by Application dated September 19, 2018, EfficiencyOne (E1) applied to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future DS...

AI summary EfficiencyOne (E1) applied for approval to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning. The Board ordered a public hearing with a detailed timetable, including deadlines for interventions, evidence submissions, and a hearing from January 8-11, 2019. The Board Regulatory Rules, including Rule 7(3), apply to the proceeding.

NOTICE OF HEARING EFFICIENCYONE (E1) has made application to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand Side Management (DSM) plann...

AI summary EfficiencyOne (E1) seeks Board approval to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning. A public hearing is scheduled from January 8–11, 2019, at the Board’s Halifax offices.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: The Public Utilities Act, R.S.N.S., 1989, c. 380 as amended - and - IN THE MATTER OF: An Application by EfficiencyOne for approval for the use of measure-level Non-Energy Benefits with...

AI summary EfficiencyOne seeks approval to incorporate non-energy benefits into cost-effectiveness testing for future demand-side management (DSM) planning under the Public Utilities Act, R.S.N.S., 1989, c. 380.

VIA EMAIL 28840 Ms. Doreen Friis Regulatory Affairs Officer/Clerk Nova Scotia Utility and Review Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Dear Ms. Friis: Re: M0888 - EfficiencyOne - Application for approval of the use o...

AI summary The Consumer Advocate requests intervenor status in M0888 regarding EfficiencyOne's application to use Non-Energy Benefits in cost-effectiveness testing. They intend to appear at an oral hearing, represented by William L. Mahody, Q.C., of Merrick Jamieson Sterns Washington & Mahody.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: An application by EfficiencyOne for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand Side Manage...

AI summary EfficiencyOne seeks approval from the Nova Scotia Utility and Review Board to incorporate measure-level Non-Energy Benefits into Cost-Effectiveness testing for future Demand Side Management (DSM) planning under regulatory processes. The application focuses on expanding DSM evaluation criteria beyond traditional energy metrics.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: an Application by EfficiencyOne for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand Side Manage...

AI summary EfficiencyOne seeks approval from the Nova Scotia Utility and Review Board to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning regulatory processes.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: An application by Efficiency One for the use of measure level Non Energy Benefits in the context of Cost-Effectiveness testing associated with future Demand Side Management (DSM) plann...

AI summary Efficiency One seeks approval to incorporate non-energy benefits into cost-effectiveness testing for future Demand Side Management (DSM) planning under Nova Scotia regulatory processes. The application is directed to the Nova Scotia Utility and Review Board's clerk, Doreen Friis.

October 12, 2018 Matter M08888 NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: An application by Efficiency One for the use of measure level Non Energy Benefits in the context of Cost-Effectiveness testing associated with future Dem...

AI summary The Ecology Action Centre notifies its intention to intervene in Matter M08888 regarding Efficiency One's application to use Non-Energy Benefits in Cost-Effectiveness Testing for future Demand Side Management (DSM) planning. The application seeks approval for incorporating non-energy benefits into regulatory processes assessing DSM initiatives.

EFFICIENCYONE - Evaluation of DSM Programs - Application to allow inclusion of Non-Energy Benefits

AI summary EfficiencyOne is applying to include non-energy benefits in their Demand Side Management (DSM) programs as part of a regulatory proceeding in Nova Scotia. The application seeks to allow the evaluation of DSM programs to consider benefits beyond energy savings, such as environmental or economic impacts.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF:THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: IN THE MATTER OF AN APPLICATION by EfficiencyOne (E1) for approval for the use of measure-level Non-Energy Benefits within the context...

AI summary EfficiencyOne (E1) applies for approval to include measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand-Side Management (DSM) planning under the Public Utilities Act. The Nova Scotia Utility and Review Board is overseeing the proceeding.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: IN THE MATTER OF AN APPLICATION by EfficiencyOne (E1) for approval for the use of measure-level Non-Energy Benefits within the contex...

AI summary The Nova Scotia Utility and Review Board is considering an application by EfficiencyOne (E1) under the Public Utilities Act to approve the use of measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning regulatory processes.

Request IR-16 : EfficiencyOne has requested approval to base future estimates of Low-Income NEBs on the 2016 Three study performed in Massachusetts with a publication date of 2016 (page 14 of the Application) as well as other studies from...

AI summary EfficiencyOne seeks approval to use a 2016 Massachusetts study for Low-Income NEBs in its 2018 DSM plan. The request questions the rationale for relying on outdated data. Key issues include the validity of using pre-2018 studies for future energy benefit estimates.

Request IR-1 7: If EfficiencyOne expects, as indicated in Section 3.2.3, page 12, of the Application that "…new data may change the relevance of existing data", please explain why NEBs should be heavily relied upon at this time to achieve...

AI summary The request questions why Non-Utility Energy Benefits (NEBs) should be heavily relied upon to achieve a CE value of 1.00 or greater, given EfficiencyOne's assertion that new data may affect existing data's relevance.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION BY EFFICIENCYONE FOR APPROVAL OF THE USE OF MEASURE-LEVEL NON-ENERGY BENEFITS WITHIN THE CONTEXT OF COSTS-EFFECTIVENES...

AI summary The Nova Scotia Utility and Review Board is considering EfficiencyOne's application to incorporate non-energy benefits into cost-effectiveness testing for future demand side management planning under the Public Utilities Act. The application seeks approval for using measure-level non-energy benefits within regulatory processes.

NOVA SCOTIA UTILITY AND REVIEW BOARD IN THE MATTER OF : IN THE MATTER OF AN APPLICATION by EfficiencyOne (E1) for approval for the use of measure-level Non-Energy Benefits (NEBs) within the context of Cost-Effectiveness testing associated...

AI summary EfficiencyOne (E1) seeks approval from the Nova Scotia Utility and Review Board to use measure-level Non-Energy Benefits (NEBs) in Cost-Effectiveness testing for future Demand-Side Management (DSM) planning regulatory processes.

James R. Gogan Direct Dial: (902) 563-5920 E-Mail: [email protected] File No. 41736-71 November 22, 2018 Nova Scotia Utility & Review Board PO Box 1692, Unit "M" Halifax, Nova Scotia B3J 3S3 Attention: Doreen Friis, Regulatory Affairs...

AI summary EfficiencyOne seeks approval to use non-energy benefits in cost-effectiveness testing. The Nova Scotia Utility & Review Board set a hearing for January 2019 after EfficiencyOne responded to intervenors' information requests. EfficiencyOne now requests deferral of further proceedings, citing ongoing engagement and preparation for 2019 proceedings.

[[email protected]](mailto:[email protected]) EfficiencyOne c/o James R. Gogan The Breton Law Group Suite 300, 292 Charlotte Street Sydney NS B1P1C7 Dear Mr. Gogan: M08888 - EfficiencyOne - Application for Approval for the Use...

AI summary EfficiencyOne seeks approval to use non-energy benefits in cost-effectiveness testing under the Public Utilities Act. The Board adjourned the matter without setting a day, emphasizing the need to confirm jurisdiction and appropriateness for NS Power ratepayers. The proceeding involves a potential consensus position after consultation.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measurelevel Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary The document outlines a regulatory proceeding concerning EfficiencyOne's application to use measure-level Non-Energy Benefits in Cost-Effectiveness testing for future Demand Side Management (DSM) planning under the Public Utilities Act. The proceeding is before a panel including Peter W. Gurnham, Roberta J. Clarke, and Steven M. Murphy.

ORDER WHEREAS by Application dated September 19, 2018, EfficiencyOne applied to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future DSM planning re...

AI summary EfficiencyOne requested deferral of its application to use Non-Energy Benefits in DSM planning due to additional consultation needs. The Board adjourned the hearing and established a new timetable, including stakeholder consultations, technical sessions, and updates by December 31, 2019.

James R. Gogan Direct Dial: (902) 563-5920 E-M ail: [[email protected]](mailto:[email protected]) File No. 41736 November 28, 2019 Nova Scotia Utility & Review Board PO Box 1692, Unit "M" Halifax, Nova Scotia B3J 3S3 Attention: D...

AI summary EfficiencyOne seeks approval to include non-energy benefits (NEBs) in cost-effectiveness testing for demand-side management (DSM) measures. The application references Matter M06733, where a Consensus Agreement outlined collaboration to improve TRC test methodology and acknowledged potential challenges for low-income-targeted programs. EfficiencyOne was to update the NSUARB by December 2016 on DSM Advisory Group progress.

NSUARB to make a preliminary legal determination on the issue of its jurisdiction to grant any form of approval relating to the inclusion of NEBs in future cost-effectiveness testing by EfficiencyOne. EfficiencyOne believes it is a prudent...

AI summary EfficiencyOne requests the NSUARB to determine its jurisdiction to consider Non-Energy Benefits (NEBs) in future DSM cost-effectiveness testing. EfficiencyOne proposes a preliminary hearing to address jurisdiction without resolving the NEB Application's specifics. If jurisdiction is denied, the application would be withdrawn; if granted, proceedings could continue. A paper process is preferred over an oral hearing.

M08888 - EfficiencyOne - Approval for Use of Measure Level Non Energy Benefits (NEB) Application Receipt is acknowledged of your letter dated November 28, 2019, requesting a preliminary determination of the jurisdiction of the Board to tak...

AI summary EfficiencyOne requests the NSUARB to determine its jurisdiction to consider Non Energy Benefits (NEB) in cost effectiveness testing of future DSM plans. The Board agrees to handle the matter through a paper process without an oral hearing, as proposed by EfficiencyOne and stakeholders. A 60-day period is requested for finalizing the NEB application if jurisdiction is confirmed.

James R. Gogan Direct Dial: (902) 563-5920 E-M ail: [[email protected]](mailto:[email protected]) File No. 41736-119 February 5, 2020 Nova Scotia Utility & Review Board PO Box 1692, Unit "M" Halifax, Nova Scotia B3J 3S3 Attention...

AI summary EfficiencyOne seeks approval to use measure-level non-energy benefits (NEB) in cost-effectiveness testing. The NSUARB's jurisdiction to grant this relief is in question, with EfficiencyOne proposing a preliminary legal determination via a paper process to avoid addressing substantive NEB application issues.

s satisfied with the question, a Hearing Order could follow setting out the relevant timelines for determination of the preliminary matter through a paper process without the need for an oral hearing. ______________________________________...

AI summary EfficiencyOne seeks approval to include non-energy benefits (NEBs) in the Total Resource Cost (TRC) test for Cost-Effectiveness (CE) testing in demand-side management (DSM) planning. The application argues that including NEBs may allow more measures to pass the TRC test, though it does not guarantee increased program inclusion. The NSUARB is considering the NEB Application, which references the VEIC Report.

her metrics…remain unchanged. 2 The NEB Application requests " that the per measure values in Table 10 of Attachment 4 (VEIC Report) be approved for use in future CE testing." 3 EfficiencyOne worked collaboratively with stakeholders to dev...

AI summary EfficiencyOne seeks NSUARB approval to use NEB values in CE testing. The application focuses on NSUARB's jurisdiction to consider non-energy impacts. Stakeholders including Nova Scotia Power and advocates support the proposed question under the Public Utilities Act. References to prior filings (M08888, M0888) are included.

M08888 - EfficiencyOne - Approval for Use of Measure Level Non-Energy Benefits This is further to your letter dated February 5, 2020, requesting the Board establish a timeline to consider the question as to whether the Board has jurisdicti...

AI summary EfficiencyOne requests the NSUARB to consider non-energy impacts in cost-effectiveness testing. The Board establishes a timeline for submissions, with EfficiencyOne and other parties agreeing to the jurisdiction question. The panel includes specific members, and submissions are due on specified dates.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary EfficiencyOne applied to include non-energy benefits in cost-effectiveness testing for Demand Side Management (DSM) planning. The Board ruled it lacks jurisdiction to consider non-energy impacts in such testing. Key intervenors included consumer advocates, industry groups, and Nova Scotia Power.

2.3.1 EfficiencyOne - [12] EfficiencyOne argued that the Board has jurisdiction to decide what is in the best interests of customers and the appropriate factors to consider in that assessment, including how cost-effectiveness is determined...

AI summary EfficiencyOne argues the NSUARB has jurisdiction to assess customer best interests, including non-energy benefits, under the Public Utilities Act. It cites Sections 79H and 79L(1) to assert cost-effectiveness falls within the Board's authority. EfficiencyOne contrasts this with NS Power's position that Maryland's DSM legislation explicitly allows non-energy benefits, unlike Nova Scotia's framework.

2.3.3 NS Power [17] NS Power took the position that the Board's discretion must be exercised within the confines of the statutory regime and principles generally applicable to regulatory matters, and that the ultimate goal is contained in...

AI summary NS Power argues that the NSUARB's discretion must adhere to the PUA's statutory framework, emphasizing affordability and rejecting non-energy benefits consideration. It cites the Supreme Court's ATCO Gas decision, asserting the Board's jurisdiction derives from explicit or implicit statutory powers, not policy implementation.

contemplated by Section 79A of the Public Utilities Act misinterprets the jurisdiction conferred by the Public Utilities Act. [40] The Board cites with approval the passage noted above in Atco: ...The Board's seemingly broad power to make...

AI summary The NSUARB asserts that interpreting Section 79A of the Public Utilities Act (PUA) to include non-energy benefits exceeds its statutory authority. It cites Atco's emphasis on rate-setting and supply system integrity as the Board's core functions. The Board agrees with the Industrial Group that non-energy benefits unrelated to electricity use are outside its jurisdiction, referencing Vermont Energy evidence and the PUA's definition of efficiency activities.

IN THE MATTER OF THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF an application by EFFICIENCYONE for approval for the use of measurelevel Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future Demand...

AI summary The document pertains to an application by EfficiencyOne seeking approval to incorporate measure-level Non-Energy Benefits into Cost-Effectiveness testing for future Demand Side Management (DSM) planning under the Public Utilities Act. The proceeding is before a regulatory panel chaired by Peter W. Gurnham, Q.C., and includes members oberta J. Clarke, Q.C., and Stephen T. McGrath, LL.B.

ORDER WHEREAS by Application dated September 19, 2018, EfficiencyOne applied to the Board for approval for the use of measure-level Non-Energy Benefits within the context of Cost-Effectiveness testing associated with future DSM planning re...

AI summary EfficiencyOne sought approval to include non-energy benefits in DSM cost-effectiveness testing. The Board adjourned proceedings multiple times, with submissions from EfficiencyOne and stakeholders. The Board ultimately ruled it lacks jurisdiction to consider non-energy benefits in such testing.