Topic:"Participant Costs Benefits" in M12282

, as reflected in the EFG Report and in discussions and presentations with the DSMAG was that relying on the gas commodity cost to represent gas system impacts was an appropriate and efficient method. Request IR-11: Refer to the EFG Report...

AI summary EFG recommends using proxy adders over a jurisdiction-specific study for estimating non-energy benefits in Nova Scotia's BCA test. Discussions with DSMAG confirmed this approach, with EFG sharing rationale and values in workshops. The EFG Report (page 17) supports proxy adders for host customer impacts.

What is E1 proposing as a BCA? - E1 has proposed that its current reliance on the Total Resource Cost ("TRC") screening test for cost- - effectiveness (and to a lesser degree, the Program Administrator Cost ("PAC") test) be replaced by a n...

AI summary E1 proposes replacing the Total Resource Cost (TRC) and Program Administrator Cost (PAC) tests with a new Benefit-Cost Analysis (BCA) tailored to Nova Scotia, incorporating societal impacts. The BCA would apply at the Portfolio level to assess public interest, with a 2% discount rate and proxy adders for non-energy benefits. E1 seeks Board approval for these changes.

Is the E1 commentary a fair criticism of the TRC as previously applied in Nova Scotia? - Yes, from a principled perspective. In general, BCA should include all measurable and meaningful benefits - and costs at the proposed assessment scale...

AI summary The E1 commentary criticizes the TRC for excluding non-energy benefits, but the NSUARB previously limited jurisdiction to energy impacts per M08888. The new Energy and Regulatory Boards Act may permit non-energy considerations, though legal interpretation is pending. Technical challenges remain in revising TRC to meet updated requirements.

VI. HOST CUSTOMER BENEFITS AND COSTS SHOULD BE INCLUDED IN THE

AI summary The section emphasizes the need to include host customer benefits and costs in regulatory decisions, ensuring comprehensive analysis for equitable outcomes. It aligns with Nova Scotia's energy regulatory framework.

Evidence of Courtney Lane states that the long-term objective of the Government is to achieve sustainable prosperity, which includes supporting "the well-being and quality of life for all Nova Scotians" and working towards "continues impro...

AI summary Courtney Lane argues the Nova Scotia Energy Board (NSEB) should reconsider its authority to include Non-Energy Benefits (NEBs) in cost-effectiveness screening. E1 proposes quantifying NEBs like asset value, productivity, and health using proxy adders from EFG. The analysis references the Environmental Goals and Climate Change Reduction Act (SNS 2021, c 20) and cites matter M12282.

in Table 4 are already within that range and can be approved without modification. Should E1 want to include the higher NEB values, it should provide justification in its upcoming 2027-2031 DSM Plan. Sutter, M., J. Mitchell-Jackson, S. Sch...

AI summary The document states that values in Table 4 are within an approved range and can be accepted without changes. However, if E1 wishes to use higher NEB values, it must justify this in its 2027-2031 DSM Plan. References to studies on non-energy benefits and cost-benefit analyses are provided.

Is the E1 commentary a fair criticism of the TRC as previously applied in Nova Scotia? - Yes, from a principled perspective. In general, BCA should include all measurable and meaningful benefits - and costs at the proposed assessment scale...

AI summary The E1 commentary is considered a fair criticism of the TRC in Nova Scotia for excluding non-energy benefits. However, prior TRC application was restricted by M08888, which limited the Board’s jurisdiction. The new Energy and Regulatory Boards Act may permit non-energy considerations, though legal interpretation is pending. Technical challenges remain in revising the TRC test if jurisdiction expands.

ulates benefits that can be highly delinked from the program costs paid by utilities and their customers. For example, by using a Social Cost of Carbon estimate (as proposed by E1) the benefits of GHG - emission reductions encompass all gl...

AI summary The text critiques E1's BCA for linking global GHG benefits to local costs, highlights non-participant customer burden from DSM programs, and notes TRC's imbalance. E1 and Synapse argue TRC's unbalanced approach can be addressed through three methods, emphasizing the need for comprehensive cost-benefit analysis.

The multiple benefits of energy efficiency The International Energy Agency has highlighted that energy efficiency improvements produce multiple benefits for customers, society, and the environment.4 It does not make sense to have a cost-ef...

AI summary Energy efficiency offers multifaceted benefits, including non-financial advantages for customers and society. Nova Scotia's cost-effectiveness tests must account for these benefits, not just customer costs. E1's framework is praised for focusing on specific benefits, allowing alignment with policy goals. Low-income households and resilience are highlighted as priority areas, with recommendations to adjust benefit quantification as technologies evolve.

Katharine Turner Policy Research Associate, Energy Poverty Efficiency Canada August 26, 2025 Nova Scotia Energy Board 3rd Floor, Summit Place 1601 Lower Water Street Halifax, Nova Scotia B3J 3P6 ATTN: Crystal Henwood Clerk of the Board E-m...

AI summary Katharine Turner, acting on behalf of the Kwilmu'kw Maw-klusuaqn Negotiation Office and the Assembly of Nova Scotia Mi'kmaw Chiefs, supports EfficiencyOne's proposed DSM plan with a Benefit-Cost Analysis (BCA) test. They emphasize the inclusion of non-energy benefits as a positive policy development, highlighting its potential to benefit Mi'kmaq communities by reflecting broader impacts beyond utility savings.

Potential Effects on Mi'kmaq Communities The consideration of non-energy benefits means that DSM programs may be more effective in supporting Mi'kmaq communities, particularly those in remote or underserved areas. Programs that account for...

AI summary The text highlights that incorporating non-energy benefits (NEB) into Demand Side Management (DSM) programs can better support Mi'kmaq communities, especially in remote areas, by improving home comfort, affordability, and resilience. It also emphasizes potential community-level benefits like green jobs and local capacity-building through partnerships with Mi'kmaq groups.

EfficiencyOne's Application for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans (NSEB M12282) SBA Responses to NSEB Board Staff Information Requests NON-CONFIDENTIAL adders should be expressed...

AI summary Daymark opposes the use of proxy adders for non-energy benefits like 'amenity,' 'empowerment,' and 'pride' in EfficiencyOne's benefit-cost analysis, arguing they are non-quantifiable. EFG defends proxy adders as assumptions representing non-energy benefits but provides no quantification. Daymark asserts EOne and EFG must prove these benefits are measurable and material.

Response to IR-2: a) No, the only reason why I discussed the non-energy benefits in my evidence was to provide my opinion for the Board's consideration, in the event that the Board decides that it will include non-energy benefits in its de...

AI summary The respondent clarifies that discussing non-energy benefits was to inform the Board's potential inclusion of such benefits in decisions, but considers quantifying them premature. They advocate for using the PAC test over the proposed BCA test to avoid quantifying hard-to-measure benefits like amenity and pride, while suggesting PAC could be supplemented with other data.

1 Request IR-2: - 2 Please provide versions of the two tables on page 14 that also include a column for the - 3 total resource cost test, adjusted to include non-energy benefits, as contemplated in - 4 "Option 1" described on page 12.

AI summary Request IR-2 seeks updated versions of two tables on page 14, requiring an additional column for the total resource cost test adjusted to include non-energy benefits as outlined in 'Option 1' on page 12.

1 1. INTRODUCTION - On May 16, 2025, EfficiencyOne ("E1") submitted an Application for Approval of a New Benefit-Cost - Analysis ("BCA") Test for Evaluating Demand Side Management ("DSM") Plans before the Nova Scotia - Energy Board (the "B...

AI summary EfficiencyOne submitted a new BCA test for DSM plans to the Nova Scotia Energy Board in Matter 12282. Multiple intervenors, including Synapse and the Industrial Group, provided evidence, with E1 rebutting claims about alternative BCA tests, portfolio-level cost-effectiveness, proxy values for non-energy benefits, and discount rates. The Industrial Group opposed E1's proposed framework, prompting E1's detailed rebuttal.

2.3 NS POWER CUSTOMER INTERESTS AS PRIMARY

AI summary The section emphasizes that Nova Scotia Power (NSP) must prioritize customer interests in regulatory proceedings, aligning with obligations under the National Standard Practice Manual (NSPM) and considering non-energy benefits (NEB) and demand-side management (DSM) initiatives.

3.1 2029 UPDATING PROCESS - Synapse - Ms. Lane suggests that "[t]he Board should direct E1 to launch a process for updating the NEB proxies in - 2029 for use in the next DSM Plan." [19](#page-12-4)

AI summary Ms. Lane recommends that the Board direct EfficiencyOne (E1) to initiate a process in 2029 for updating non-energy benefits (NEB) proxies, which will be used in the subsequent Demand Side Management (DSM) Plan. This suggestion is part of the 2029 updating process discussion.

E1 Response - E1 supports this recommendation with the addition of a review and update for all impacts—not solely - those related to NEB proxies—commencing prior to the development of the next DSM Plan via the - proposed 'evergreen' proces...

AI summary E1 supports a recommendation to review all impacts, not just non-energy benefits (NEB) proxies, via an 'evergreen' process before developing the next DSM Plan. Engagement with DSMAG is expected to begin in 2029. E1 proposes a multi-step process to ensure the BCA test remains current, including quantifying impacts using jurisdictional data and customer surveys, with DSMAG input.

Daymark - Melissa Whitten of Daymark Energy Advisors, Inc. ("Daymark") provides the following observations and - conclusions regarding the Application: - The proposed BCA test framework relies on proxy values for certain non-energy - benef...

AI summary Daymark Energy Advisors criticizes the proposed BCA test framework for relying on unquantifiable proxy values for non-energy benefits, warning that this could introduce bias and lead to suboptimal DSM Plan decisions. They argue that plans derived from biased frameworks should not be prioritized for customers.

E1 Response E1's position is that the use of proxy values for certain non-energy benefits is both reasonable and appropriate and consistent with jurisdiction specific studies. The NSPM for screening energy efficiency and distributed energy...

AI summary E1 argues that using proxy values for non-energy benefits (NEBs) in BCA is reasonable and aligns with the NSPM, supported by EFG and Synapse Energy Economics. E1 rejects claims of bias, emphasizing symmetric treatment of impacts. Daymark's Melissa Whitten counters, requesting third-party validation of NEB quantification (amenity, empowerment, pride).

Daymark - In the alternative to the recommendation for further analysis on NEBs, Ms. Whitten suggests that the - Board "make the value assigned to the Unquantified Non-Energy Benefits Nil until the work outlined above - can be completed an...

AI summary Ms. Whitten recommends that the Board set the value of Unquantified Non-Energy Benefits (NEBs) to Nil until further analysis is completed and approved. This suggestion is part of a regulatory proceeding involving a Benefit-Cost Analysis (BCA) framework for Nova Scotia, with references to evidence and appendices from Matter M12282.

E1 Response - To assign a nil value to unquantified NEBs defaults such benefits to zero, notwithstanding the associated - benefit. Utilising this approach would lead to greater distortion of the results than employing the - conservative pr...

AI summary The response criticizes assigning nil values to unquantified Non-Energy Benefits (NEBs) in Benefit-Cost Analysis (BCA), arguing this distorts results. It advocates using E1's conservative proxy values instead, citing Francis Wyatt of Green Energy's perspective on the issue.

Q. SHOULD ONLY THOSE BENEFITS THAT CAN BE PRECISELY QUANTIFIED BE INCLUDED IN THE NEW BENEFIT COST TEST? A. No. If one excludes all benefits that are difficult to quantify precisely, then those values are by default assigned a value of zer...

AI summary The answer argues against excluding non-quantifiable benefits from the new benefit-cost test, stating that assigning them a zero value is inappropriate if they are known to exist. It references the NSPM principles, which emphasize accounting for relevant and material benefits, even if difficult to quantify.

7.5 DSMAG PARTICIPATION EASTWARD

AI summary Section 7.5 discusses DSMAG's participation in the Eastward project, emphasizing the need for Benefit-Cost Analysis (BCA) and Non-Energy Benefits (NEB) assessments. The NSUARB oversees the process, with E1 and EFG involved as key participants.

Synapse Courtney Lane of Synapse states: - The use of proxy values is a reasonable approach to estimate host customer non energy benefits (NEB) in cost-effectiveness analysis. However E1 has not sufficiently justified its proposal for NEB...

AI summary Courtney Lane of Synapse argues that while proxy values are reasonable for estimating non-energy benefits (NEB) in cost-effectiveness analysis, EfficiencyOne (E1) has not adequately justified its proposed NEB proxy values. She emphasizes the need for proxies to be grounded in literature, other jurisdictions' practices, and jurisdictional differences rather than arbitrary choices.

EFG Response The approach of using proxy values was deliberate and not arbitrary. The approach was reviewed and discussed with the Demand Side Management Advisory Group ("DSMAG") in two workshop sessions, and open to written review and com...

AI summary EFG defends using proxy values for non-energy impacts (NEIs), citing discussions with DSMAG and referencing the ACEEE database. They argue that adopting values from other jurisdictions is imprecise and that proxy adders, though small, require regular review to remain accurate. EFG recommends adopting their proposed values with an ongoing 'evergreening' process.

EFG Response - To make the value assigned to the unquantified NEBs nil would result in bias the result which Ms. Whitten - is seeking to avoid. E1 notes that completely excluding known, but hard-to-quantify benefits would default - such be...

AI summary EFG argues against setting unquantified non-energy benefits (NEBs) to zero in benefit-cost analysis (BCA), stating it would bias results. They suggest using conservative proxy values instead, as proposed by E1, to avoid distorting BCA outcomes.

2.0 PROPOSED BENEFIT-COST ANALYSIS TEST - [8] E1 is the holder of a franchise issued by the Minister of Energy to provide demand-side management activities to NS Power. Under the Public Utilities Act , E1 must develop a demand-side managem...

AI summary E1, a franchise holder under the Public Utilities Act, must develop demand-side management (DSM) plans for NS Power, subject to Nova Scotia Utility and Review Board approval. The DSM framework uses a tiered structure (measure, program, portfolio levels) and cost-effectiveness testing to evaluate plans, ensuring measurable benefits for ratepayers.

tend to all the Board mandates. It argued that the use of a global social cost of carbon in integrated resource and capital planning would fundamentally skew these processes leading to absurd results. [42] In terms of the discount rate, th...

AI summary The Industrial Group opposes using a global social cost of carbon in planning, arguing it skews results. It rejects the 2% social discount rate, advocating for WACC instead, and opposes including non-energy benefits in DSM cost-effectiveness testing, deeming them inappropriate and lacking evidentiary support.

3.3 Small Business Advocate [45] The Small Business Advocate agreed to the Consensus Agreement and recommends the Board adopt the proposed BCA test as amended by the Consensus Agreement. In closing submissions, the Small Business Advocate...

AI summary The Small Business Advocate agreed to the Consensus Agreement, recommending the Board adopt the amended BCA test. Concerns were raised about quantifying non-energy benefits like amenity and empowerment, with recommendations to set unquantified benefits to zero or adopt the PAC test instead. The Advocate emphasized the need for further work on quantifying non-energy benefits.

4.1.4 The 2020 Non-energy Benefits Decision - [83] The NSUARB determined it did not have the jurisdiction to consider nonenergy benefits in the cost-effectiveness testing for demand-side management in Re EfficiencyOne , 2020 NSUARB 56. In...

AI summary The NSUARB ruled it lacked jurisdiction to consider non-energy benefits in DSM cost-effectiveness testing in Re EfficiencyOne , 2020 NSUARB 56. E1 argued that the Public Utilities Act grants the NSUARB broad discretion to assess factors like thermal comfort and property value impacts as part of customers' best interests, beyond mere electricity savings.

ficiency and conservation activities". However, the requirement that what is undertaken is "cost-effective" and done to try to "reduce costs for customers" is the same as it was before the amendments. [103] It is reasonable that the refere...

AI summary The document clarifies that 'cost-effective' under the Public Utilities Act refers to reducing customer costs, not utility costs. It emphasizes that the requirement for cost-effectiveness remains unchanged post-amendments, with references to sections 79I, 79H, and 79C. The NSUARB's 2020 decision focuses on customer costs, though the interpretation of 'costs for customers' beyond electricity costs is not explicitly addressed.

ams, and the specific role for E1 to address energy-based efficiency and conservation. This provision has not expanded E1's mandate beyond energy impacts. [Industrial Group Closing Submissions, p. 5] [120] The Industrial Group argued that...

AI summary The Industrial Group argues that cost-effectiveness testing for demand-side management (DSM) must prioritize reducing electricity costs for customers, not broader non-energy benefits like GHG reductions. They warn that expanding DSM's scope under the Public Utilities Act or Energy and Regulatory Boards Act would create inconsistent regulatory outcomes.

reduce electricity costs for customers. NS Power is satisfying this obligation by entering into a supply agreement with E1. It is this purpose that frames the Board's assessment of cost-effectiveness. [135] E1 appears to suggest that if on...

AI summary NS Power aims to reduce electricity costs via a supply agreement with E1. The Board assesses cost-effectiveness, disagreeing with E1's claim that statutory interpretations limit sustainable development considerations. The Board emphasizes statutory requirements over general factors, agreeing with E1's screening test for demand-side management but focusing on electricity cost impacts.

4.3 Strategic Electrification [158] Strategic electrification that reduces overall GHG emissions and electricity costs is included in the definition of "demand-side management" in s. 79A(b)(iv) of the Public Utilities Act . The PAC test, a...

AI summary The document discusses challenges in applying the traditional PAC test to strategic electrification programs under the Public Utilities Act. Mr. Bowman proposes modifying the PAC test to include increased revenues from electrification as a benefit, ensuring cost-effective programs. The Industrial Group supports this approach, aligning with E1's mandate to reduce electricity costs for NSPI customers.

Request IR-11: - Refer to the EFG Report on page 17, which states "For host customer impacts the new - jurisdictional test should include both measure costs and non-energy benefits. EFG recommends - a proxy adder approach to estimate the c...

AI summary The EFG Report recommends using proxy adders to estimate non-energy benefits for host customers, varying by DER type and segment. It suggests this approach addresses harder-to-quantify benefits, with rationale in Section V and Appendix F. Questions ask if DSMAG or EFG discussed jurisdiction-specific studies for NEB and whether proxy adders are preferred over such studies.

Request IR-19: - Refer to the statement on page 44 of the EFG Report, which states that the recommended proxy values are "calculated as a percent adder of the estimated energy benefits for efficiency measures and as a percent of non-incent...

AI summary Request IR-19 seeks clarification on E1's use of proxy adders for energy benefits versus net energy benefits, alignment of 'energy benefits' with the Nova Scotia Test's Electric Utility System Impacts, rationale for applying adders to non-incentivized beneficial electrification costs, and the impact of reducing incentives on NEB (Net Energy Benefits).

Request IR-22: - Table 14 on page 45 of the EFG Report indicates that Host Customer Non-Energy Benefit Impacts from Building Shell Measures and Beneficial Electrification measures have impacts on indoor air quality and health. Page 51 of t...

AI summary The EFG Report highlights health impacts from energy efficiency measures and air pollutants. Questions arise about potential double-counting of health benefits between host customer Non-Energy Benefits (NEBs) and air pollution emission impacts, and whether health-related NEBs should be subtracted from air pollution calculations.

Request IR-25: - Table 3 on Page 12 of 18 of Mr. Hill's Evidence: Data Sources and Application in Developing Recommended Nova Scotia Test: - a) For the Utility System Impact "Program Administration and Incentives", the Application in Repor...

AI summary Request IR-25 seeks clarification on assumptions in the BCA related to program administration, fuel price adjustments, placeholder cost assumptions, and proxy values for non-energy benefits. Questions focus on EFG's assumptions, carbon price removal rationale, US Energy Information Administration fuel cost data, and adjustments to avoid double-counting energy benefits.

Request IR-27: - Page 8, under Non-Energy benefits states "If host customer benefits are not included in a jurisdictional test, then the host customer costs should be excluded." - a) Please describe the host customer costs and if they incl...

AI summary Request IR-27 seeks clarification on host customer costs and benefits related to E1 programs, specifically whether E1's costs are included and if benefits are uniform across programs. It references a rule excluding host customer costs if benefits are not included in jurisdictional tests.

R – 6(b). [ 21 ](#page-7-5) E-5, E1 (NSEB) RIR – 6(b). [ 22 ](#page-7-7) Transcript, Day One, September 22, 2025, pages 41-42. [ 23 ](#page-7-9) Transcript, Day One, September 22, 2025, page 48. - (a) support competition and innovation in...

AI summary E1 argues the Board can consider non-energy benefits under the PUA's subsection (d), focusing on sustainable development. However, the text counters that this does not alter the Board's specific mandates under the PUA, emphasizing that 'appropriate consideration' remains subjective. The discussion references transcripts and regulatory provisions.

The Board Still Cannot Account for Non-energy Benefits The Industrial Group recognizes that certain recent legislative amendments may impact the ongoing interpretation of the PUA provisions. However, the additional factors provide guidance...

AI summary The Industrial Group acknowledges recent legislative changes but argues they don't alter the PUA's focus on reducing electricity costs. E1's environmental goals must align with PUA provisions, not override them. The Board must adhere to statutory mandates, and non-energy benefits aren't within the legislative framework for cost-effectiveness evaluation.

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.

Host Customer Non-Energy Benefits The proposed BCA test suggests that the Board should weigh a number of unquantifiable proposed benefits, including customer pride, empowerment, economic well-being, comfort, amenity, and health and safety....

AI summary The proposed BCA test includes subjective non-energy benefits like customer pride and health, valued via proxy percentages of energy benefits. Critics argue these are vague and unsupported, conflicting with PUA's DSM definition. E1 clarified non-energy impacts, but the Industrial Group opposes proxy adders for intangible benefits. Synapse's consultant Courtney Lane raised concerns about proxy value arbitrariness.

023- 2025 DSM Plan proceeding, including: (e)to provide specific justification, on an individual basis, for each measure that fails cost-effectiveness testing in future resource plan applications; (f) to include payback information in its...

AI summary Patrick Bowman argues that the Program Administrator Cost (PAC) is the appropriate test for evaluating Demand-Side Management (DSM) under the Public Utilities Act (PUA), as it focuses on reducing customer costs. He contrasts this with the Proposed Benefit-Cost Analysis (BCA), which he claims is overly broad and emphasizes societal impacts over ratepayer costs. EFG supports the PAC's effectiveness in signaling cost reductions.

DSMAG CONSULTATION While the purpose and role for the DSMAG is not currently an issue before the Board, the Industrial Group wishes to reiterate its concerns with respect to E1's overreliance on the DSMAG consultations within E1's and EFG'...

AI summary The Industrial Group criticizes E1's reliance on DSMAG consultations as implicit support for the Proposed BCA, emphasizing that DSMAG discussions do not endorse the BCA or its non-energy benefits. They note DSMAG's confidentiality and lack of consensus on the BCA, while welcoming Eastward Energy's potential DSMAG membership.

e it even more so by empowering the Board to regulate creatively, beyond the confines of traditional regulatory practices, to support the achievement of Nova Scotia's environmental policies and goals. The legislative intention behind the E...

AI summary The document discusses the Board's authority to consider non-energy benefits in cost-effectiveness testing for DSM plans under the Energy Reform (2024) Act . It references legislative intent, statutory interpretation approaches, and statements from Honourable Tory Rushton emphasizing modernizing Nova Scotia's electricity system to achieve environmental goals.

emissions were avoided due to demand-20 side management, and Mr. Bowman's critique of E1's use of a 2% social discount rate within its proposed BCA.[14](#page-3-18) 21 - 22 23 Notably, E1's proposed BCA Test was modified subsequent to the...

AI summary EfficiencyOne (E1) modified its proposed BCA Test via a Partial Consensus Agreement, adjusting non-energy benefit quantification and proxy values. E1 agreed to conduct research and share results with DSMAG. At the hearing, E1's witnesses discussed the BCA Test and alternatives (PAC, TRC Tests), with EFG's Mr. Neme noting secondary tests' potential. Mr. Bowman critiqued E1's 2% social discount rate use.

20 iii. Board Counsel 22 Counsel to the Nova Scotia Energy Board filed evidence from Courtney Lane of Synapse Energy 23 Economics. 25 Ms. Lane's conclusions in her evidence were as follows: - 27 E1's approach to developing the Nova Scotia...

AI summary Board Counsel submitted evidence from Courtney Lane of Synapse Energy Economics, supporting E1's Nova Scotia Test as an improvement over the TRC test by incorporating energy policy goals and non-energy impacts. Lane recommended approving the BCA test with modifications but noted E1's insufficient justification for NEB proxy values. The Partial Consensus Agreement's zero quantification of certain impacts was also mentioned.

15 iv. Small Business Advocate 16 17 The Small Business Advocate filed evidence in this matter from Consultant Melissa Whitten of 18 Daymark Energy Advisors, Inc. In her evidence, Ms. Whitten presented concerns regarding E1's 19 proposed B...

AI summary The Small Business Advocate raised concerns about E1's proposed BCA test, citing difficulties in quantifying non-energy benefits like amenity, empowerment, and pride. Melissa Whitten of Daymark Energy Advisors supported the Partial Consensus Agreement's zero quantification for these benefits but expressed ongoing concerns about their inclusion in future proceedings.

mpacts, 24 which are grouped together as Non-Utility System impacts3. These impacts generated a lot of 25 discussion, as they are, in many cases, new additions from the previous tests used by EfficiencyOne 26 and are not consistently used...

AI summary The document discusses Non-Utility System impacts from EfficiencyOne's new Benefit-Cost Analysis (BCA) test for Demand Side Management (DSM) plans, which have sparked debate due to their novelty compared to previous tests. Melissa Whitten of Daymark Energy Advisors raised concerns about proxy values for non-energy benefits and challenges in measuring/verifying them.

- 1 energy benefits. She identified the non-energy benefits of amenity, empowerment and pride as - 2 being of the most concern and recommended more work be done to quantify them, with the results - 3 of that work being presented to the mem...

AI summary Ms. Whitten recommends quantifying non-energy benefits (amenity, empowerment, pride) or setting their value to Nil until approved by the Board. She prefers the PAC test over quantifying these benefits. The SBA expresses concerns about unquantified non-energy benefits impacting ratepayers. The discussion involves Benefit-Cost Analysis (BCA) and Demand Side Management (DSM).

nquantified and difficult to quantify - 21 non-energy benefits with EfficiencyOne on several occasions. The SBA's concern stems from the - 22 fact that ratepayers are required to pay for a DSM plan on the basis that there will be benefits...

AI summary The Service Board of Appeals (SBA) raises concerns about quantifying non-energy benefits in Demand Side Management (DSM) plans, emphasizing the need for benefits to be broadly beneficial to ratepayers, not just participants. Melissa Whitten's evidence and exhibits highlight challenges in ensuring fair cost allocation and proper Benefit-Cost Analysis (BCA) framework application.

med to be consistent between the Energy and Regulatory Boards Act , the Environmental 6 Goals and Climate Change Reduction Act, and the More Access to Energy Act . 7 8 The Industrial Group relies upon a predecessor Board decision from 2020...

AI summary The Industrial Group argues that a 2020 Board decision limiting jurisdiction to energy impacts in DSM cost-effectiveness testing remains valid, despite 2024 legislative amendments. They assert that adding 'strategic electrification' to DSM's definition does not expand the Board's authority to consider non-energy benefits, emphasizing statutory interpretation principles from the Vavilov decision.

erations above other costs and benefits being analysed in the test. In fact, the effect of the host customer benefits is expected to be minor. As noted by Dr. Hill (EFG) in the hearing: [5](#page-3-2) We also think, though, that the scale...

AI summary The text argues that non-energy benefits are minor compared to other impacts like fuel savings and GHG reductions. It critiques the Industrial Group's (IG) interpretation of legislative changes as overly narrow, allowing the Board to do what it has always done. References include Dr. Hill's testimony and matter number M12282.

cost of carbon, reductions in air pollutants (NOx, SO₂, particulates) with associated health and environmental benefits, and societal-level resilience (continuity of critical services during outages). [20] In the BCA test, E1 has proposed...

AI summary E1 proposes a BCA test quantifying utility impacts via avoided costs and commodity costs, using the social cost of carbon and a 2% discount rate aligned with the Energy Reform Act . Non-energy benefits (e.g., comfort, maintenance) are valued via proxy adders applied to net energy benefits or measure costs, discounted over the measure's lifespan to ensure transparency and avoid understating societal impacts.

tend to all the Board mandates. It argued that the use of a global social cost of carbon in integrated resource and capital planning would fundamentally skew these processes leading to absurd results. [42] In terms of the discount rate, th...

AI summary The Industrial Group opposes using a global social cost of carbon and a 2% discount rate in benefit-cost analysis, arguing they skew planning processes and lack legislative basis. It also rejects including non-energy benefits in cost-effectiveness testing for demand-side management, citing insufficient evidence and inappropriate focus on customer feelings.

3.3 Small Business Advocate [45] The Small Business Advocate agreed to the Consensus Agreement and recommends the Board adopt the proposed BCA test as amended by the Consensus Agreement. In closing submissions, the Small Business Advocate...

AI summary The Small Business Advocate agreed to the Consensus Agreement, recommending the Board adopt the amended BCA test. Concerns were raised about quantifying non-energy benefits like amenity and empowerment, with suggestions to set unquantified benefits to zero or adopt the PAC test instead. The Advocate emphasized the need for further analysis on non-energy benefits.

4.1.4 The 2020 Non-energy Benefits Decision - [83] The NSUARB determined it did not have the jurisdiction to consider nonenergy benefits in the cost-effectiveness testing for demand-side management in Re EfficiencyOne , 2020 NSUARB 56. In...

AI summary The NSUARB ruled in Re EfficiencyOne (2020 NSUARB 56) that it lacked jurisdiction to consider non-energy benefits in cost-effectiveness testing for demand-side management. E1 argued that the NSUARB's duty to act in customers' best interests, under the Public Utilities Act , allowed consideration of factors like thermal comfort and property value impacts beyond electricity savings.

ams, and the specific role for E1 to address energy-based efficiency and conservation. This provision has not expanded E1's mandate beyond energy impacts. [Industrial Group Closing Submissions, p. 5] [120] The Industrial Group argued that...

AI summary The Industrial Group argues that the cost-effectiveness test under the Public Utilities Act must prioritize reducing customer electricity costs, not GHG emissions. They warn against expanding demand-side management (DSM) benefits to include non-energy impacts, citing s. 6(2) of the Energy and Regulatory Boards Act could lead to inconsistent regulatory decisions.