Topic:"Rate Design" in M12249

3 1.5 RATE CLASS ALLOCATIONS 4 Rate class spending estimates for 2026 are largely aligned with expectations for 2025. The planned 5 expenditures under each rate class forecasted for the 2026 DSM Extension are reflected i[n Table 2,](#page-...

AI summary Rate class spending estimates for 2026 are largely aligned with 2025 expectations. The planned expenditures under each rate class for the 2026 DSM Extension are reflected in Table 2.

To develop the 2026 rate class spending estimates E1 used the available data from 2022, 2023 and 2024. In the NSUARB's decision on NS Power's Application for the 2025 DSM Cost Recovery Rider (DCRR), E1 was directed to "take notice of the c...

AI summary E1 used data from 2022 to 2024 to develop 2026 rate class spending estimates. The NSUARB directed E1 to address concerns from the Industrial Group in its pending 2025 DSM program application. E1 is committed to transparency and will provide quarterly and annual reports on rate class spending and variances.

3.1 OVERVIEW In support of the 2026 DSM Extension Application, E1 has conducted a fulsome modelling process. An overarching objective of E1 in its modelling process for the 2026 DSM Extension was to adopt learnings drawn from the actual re...

AI summary E1's 2026 DSM Extension Application uses 2023-2025 data and 2025 forecasts to inform targets, noting no alternate scenarios were modelled. The NSUARB required alternative scenarios in past applications, with future submissions needing DSM budget scenarios and NSPI rate impact analysis.

8 Table 4: Program Component Comparison of 2025 Forecast and 2026 DSM Extension Year Program Component Comparison of 2025 Forecast and 2026 DSM Extension Year Instant Savings • Further reduction in energy savings and increase in unit cost...

AI summary The document compares energy savings and costs for various program components between the 2025 forecast and the 2026 DSM extension year. Key factors include the removal of LED lighting, changes in provincial rebates, budget constraints, and program restructuring.

20 Table 2: Key Global Model Input & Assumptions in 2026 DSM Extension Development Item Description of Key Global Model Inputs & Assumptions EE DR • Avoided cost of carbon are embedded in the avoided costs of energy that NS Power calculate...

AI summary The document outlines key input assumptions for the 2026 DSM Extension Development, including avoided costs of carbon, line loss factors, and incentive development for energy efficiency and demand response programs. It references the Evergreen IRP, NS Power's 2014 Cost of Service Study, and E1's Incentive Setting Methodology.

7 Table 3: 2023-2026 DSM Extension Portfolio Level Insights Insights 2023-2025 Plan as Approved 2026 DSM Extension 2023-2026 Carbon Emissions Avoided First-Year CO₂e Savings (kt) 326 26 352 Lifetime CO₂e Savings (kt) 1,742 134 1,877 Portfo...

AI summary Table 3 provides insights into the 2023-2026 DSM Extension Portfolio, including carbon emissions avoided, energy and demand savings, investment breakdowns, and cost and benefit analyses. It highlights the split of investments between residential and BNI programs and the net benefits of energy efficiency and demand response initiatives.

3.6 RATE CLASS ALLOCATIONS Rate class expenditures for the 2026 DSM Extension are provided in [Table 8,](#page-62-0) below. Rate class spending for 2026 is largely consistent with E1's 2025 forecast by rate class.[25](#page-61-1) E1's 2026...

AI summary The 2026 DSM Extension rate class expenditures align with E1's 2025 forecast, using 2022–2024 data. A cross-reference to M12186 (E1's 2024 Annual Progress Report) is cited for detailed rate class results.

C. Rate and Bill Impact Analysis E1 also used the actual annual stream of avoided costs of capacity as calculated by NS Power and provided to the DSMAG on August 23, 2024 for the E1 RBIA. These values are outlined in Table 4 above.

AI summary E1 utilized actual annual avoided capacity costs calculated by NS Power and shared with DSMAG on August 23, 2024, for the E1 RBIA. These values are detailed in Table 4.

A. Energy Efficiency ProCESS Model - E1 understands from NS Power that the avoided costs of carbon (electric utility compliance costs) are - embedded in the avoided costs of energy that NS Power calculated for the Evergreen IRP No Atlantic...

AI summary E1 used avoided energy costs (including embedded carbon costs) from NS Power for the 2026 DSM Extension, without modeling separate carbon costs. Avoided energy costs were not included in demand response cost-effectiveness testing. The same RBIA approach as energy efficiency programs was applied for the 2026 DSM Extension.

1 3.2 DSM REPORTING ASSUMPTIONS: INCIDENTAL IMPACTS - 2 [Table 3](#page-104-1) provides the assumptions and calculations for incidental low-income and equity impacts - 3 for DSM reporting from E1's non-targeted program components.

AI summary The section discusses DSM reporting assumptions related to incidental low-income and equity impacts from E1's non-targeted program components, with Table 3 providing the relevant calculations.

Filed Electronically

AI summary The document is an electronically filed submission in a Nova Scotia regulatory proceeding involving Demand-Side Management (DSM) programs, cost recovery mechanisms, and utility rate structures. Key entities include Nova Scotia Power (NSP), the Nova Scotia Utility and Review Board (NSUARB), and EfficiencyOne (E1). Topics focus on DSM cost recovery, energy efficiency, and regulatory analysis.

Filed Electronically

AI summary The document is an electronically filed submission in a Nova Scotia regulatory proceeding involving Demand-Side Management (DSM) programs, cost recovery mechanisms, and utility rate structures. Key entities include Nova Scotia Power (NSP), the Nova Scotia Utility and Review Board (NSUARB), and EfficiencyOne (E1). Topics focus on DSM cost recovery, energy efficiency, and regulatory analysis.

Appendix B Rate and Bill Impact Analysis of the 2026 DSM Extension

AI summary This appendix outlines the Rate and Bill Impact Analysis (RBIA) for the 2026 extension of Demand-Side Management (DSM) programs in Nova Scotia. The analysis evaluates financial implications for consumers and utilities, focusing on cost recovery and program effectiveness.

1. EXECUTIVE SUMMARY EfficiencyOne (E1) delivers demand side management (DSM) programs that offer benefits to customers and the electric utility. While DSM is a key resource option for delivering clean, affordable, reliable and safe energy...

AI summary EfficiencyOne (E1) implements demand-side management (DSM) programs that reduce customer bills despite potential rate increases, addressing equity concerns. E1's Rate and Bill Impact Analysis (RBIA) evaluates long-term rate and bill impacts of DSM activities, providing insights for balancing benefits across customers.

2. INTRODUCTION The forward-looking RBIA is an analysis of the rate and bill impacts associated with the proposed DSM investment only. The forward-looking rate and bill impact analysis associated with a DSM Plan or Extension Application co...

AI summary The document discusses forward-looking and historical Rate and Bill Impact Analysis (RBIA) for Demand-Side Management (DSM) investments. It outlines E1's proposed elimination of historical RBIA filings except during DSM Plan Application years, with the NSUARB accepting this approach. The next historical RBIA is scheduled for the 2027-2031 DSM Resource Plan Application.

3. 2026 DSM EXTENSION RBIA RESULTS - The results in this section are for the 2026 DSM Extension. All impacts are calculated relative to a scenario - where no DSM is conducted in 2026. Results are summarized in Attachment 1, and have been p...

AI summary This section presents the 2026 DSM Extension RBIA results, comparing scenarios with and without DSM implementation. Impacts are calculated relative to a no-DSM baseline, with energy efficiency and demand response analyzed separately and combined. Attachments 1 and 2 summarize results, including rate and bill impacts by rate class, and model outputs.

3.1 OVERALL RATE IMPACTS - DSM can lower rates by avoiding different types of electricity system costs (avoided energy, capacity, - transmission and distribution). DSM may also increase rates, a result of recovering program costs as well -...

AI summary The 2026 DSM Extension RBIA analyzes rate impacts of Demand-Side Management (DSM) programs, showing average rate changes ranging from +0.08% to +0.45% over 2026-2041. Initial cost recovery in 2026 causes higher impacts (+2.1% to +4.9%), but long-term effects (2027-2041) show smaller or negative impacts (-0.14% to +0.15%). These figures reflect long-term trends, not annual fluctuations.

14 Table 1: Average Rate Impact compared to No-DSM Scenario, 2023-2025 Plan to 2026 DSM Extension Results 15 Comparison Rate Class 2023-2025 Plan RBIA Result (average rate impact over 2023-2039) 2026 DSM Extension RBIA Result (average rate...

AI summary The table compares the average rate impact of the 2023-2025 Demand-Side Management (DSM) Plan and the 2026 DSM Extension on various rate classes. The results show a decrease in rate impact for most classes under the 2026 DSM Extension compared to the 2023-2025 Plan, with the exception of Large Industrial, which saw a negative impact under the 2023-2025 Plan and a positive impact under the 2026 Extension.

3.2 OVERALL BILL IMPACTS Generally speaking, ratepayers that participate in DSM programs directly benefit by reducing their electricity consumption and thereby lowering their electricity bills. Together, the level of reduced consumption (o...

AI summary DSM programs reduce electricity bills for participants by 0.1-8.8% (2026-2041), while non-participants see minimal increases (+0.1-0.4%). Total customer savings range from -1.1 to -0.1%. Net savings for Nova Scotia ratepayers are $74 million due to reduced revenue requirements from DSM programs implemented in 2026.

3.3 RESULTS BY RATE CLASS This section highlights results in more detail by individual rate class for the 2026 DSM Extension.

AI summary This section details results by rate class for the 2026 DSM Extension, focusing on analysis by individual rate classes under Nova Scotia's Demand-Side Management initiatives.

3.3.1 RESID EN TIAL - As modelled, the Residential class includes Rate Codes 2, 3, 6, 9 and 16 (Domestic), as well as 4 - and 5 (Charitable). - The average rate impact over the study period is an increase of 0.3 - percent, or 0.05 cents/kW...

AI summary The Residential class in Nova Scotia's regulatory proceeding includes specific rate codes (2, 3, 6, 9, 16 for Domestic and 4, 5 for Charitable). The average rate impact is a 0.3% increase (0.05 cents/kWh), but participants see a 1.2% bill decrease, while non-participants face a 0.2% increase. Overall, the class experiences a 0.1% bill decrease.

3.3.2 SM ALL GEN ERAL - As modelled, the Small General class includes Rate Code 10 only. - The average rate impact over the study period is an increase of 0.4 percent, or 0.08 cents/kWh.

AI summary The Small General class (Rate Code 10) is modeled with an average rate impact increase of 0.4% (0.08 cents/kWh) over the study period. This reflects the projected cost implications for this specific rate category within the regulatory proceeding.

Small General Residential ↑ 0.4% Rates ↑ 0.3% Rates ↓ 1.2% Participant Bills ↑ 0.2% Non-Participant Bills ↓ 0.1% Total Customer Bills - ↓ 8.8% Participant Bills - ↑ 0.4% Non-Participant Bills - ↓ 0.9% Total Customer Bills - Participants in...

AI summary The Small General class in Nova Scotia sees a 0.4% rate increase, with participants experiencing an 8.8% average bill decrease, non-participants facing a 0.4% increase, and overall customer bills decreasing by 0.9% over the study period.

3.3.3 GEN ERAL - As modelled, the General class includes Rate Code 11 only. - The average rate impact over the study period is an increase of 0.2 percent, or 0.03 cents/kWh. General - ↑ 0.2% Rates - ↓ 4.8% Participant Bills - ↑ 0.2% Non-Pa...

AI summary The General class under Rate Code 11 experiences a 0.2% rate increase, but participants see a 4.8% average bill decrease, while non-participants face a 0.2% increase. Overall, total customer bills decrease by 1.1% over the study period.

3.3.4 LARGE GENERAL - As modelled, the Large General class includes Rate Code 12 only. - The average rate impact over the study period is an increase of 0.1 percent, or 0.01 cents/kWh. - Participants in the Large General class see an avera...

AI summary The Large General rate class experiences a 0.1% rate increase and 0.9% average bill decrease for participants over the study period. Non-participants see a 0.1% bill increase, though all customers are assumed to participate in BER-IR by 2026. This results in total customer bill reductions despite non-participant line inclusion.

3.3.5 SM ALL IN D USTRIAL - As modelled, the Small Industrial class includes Rate Code 21 only. - The average rate impact over the study period is an increase of 0.3 percent, or 0.05 cents/kWh. - Participants in the Small Industrial class...

AI summary The analysis details rate and bill impacts for Small, Medium, and Large Industrial classes under Nova Scotia's regulatory proceeding. Small Industrial sees a 0.3% rate increase but 5.8% lower bills for participants. Medium Industrial has a 0.1% rate increase with 0.7% lower participant bills. Large Industrial shows a 0.1% rate increase and 0.9% lower participant bills, with all customers assumed to participate in BER-IR by 2026.

3.3.8 M UN ICIPAL - As modelled, the Municipal class includes Rate Code 24 only. - The average rate impact over the study period is an increase of 0.2 percent, or 0.01 cents/kWh. Municipal ↑ 0.2% Rates ↓ 0.1% Average Bills - Municipal util...

AI summary The Municipal class (Rate Code 24) experiences a 0.2% rate increase and 0.1% average bill decrease. E1 program participation by all Municipal Electric Utilities results in identical bill impacts for participants and total customers, though individual participation is not modeled. This simplification affects rate and bill effect analysis for MEU customers.

4. UPDATE ON MODEL EVOLUTION - In 2024-2025, E1 worked with Elenchus, its RBIA consultant, to update the E1 RBIA model and NS Power rate model. Updates include the following: - Integration of historical and forward-looking RBIA models. Bot...

AI summary In 2024-2025, E1 and NS Power updated their RBIA and rate models with historical/forward-looking integration, expanded resource options (including strategic electrification), refined participation methodology, revised data display, added change logs, and enhanced transparency through new model tabs. These updates support the 2026 DSM Extension RBIA and future DSM planning.

4.1 INTEGRATION OF HISTORICAL AND DSM PLAN RBIA MODELS - Both the NS Power rate model and E1 RBIA model were adjusted so they have the functionality to provide - either historical RBIA results (DSM delivered since 2011) or forward-looking...

AI summary The NS Power rate model and E1 RBIA model have been adjusted to provide both historical RBIA results (DSM since 2011) and forward-looking RBIA results for future measures. This integration allows for a comprehensive analysis of past and future DSM impacts.

4.2 ADDITIONAL DSM RESOURCES - In the planning for E1's first five-year DSM Plan (2027-2031) it was identified that in addition to energy - efficiency and demand response, additional resources may need to be included in future DSM Plan RBI...

AI summary The planning for E1's first five-year DSM Plan (2027-2031) identified the need to include additional resources beyond energy efficiency and demand response. The NS Power rate model and E1 RBIA model were updated to allow for up to five resources to be modeled simultaneously, as detailed in Table 2.

4.3.1 ACTIVE PARTICIPATION M ETHOD OLOGY - Previously, participant estimates were calculated using a 'cumulative' methodology. This did not account - for the measure life of savings, resulting in the potential for the number of cumulative...

AI summary The document discusses a shift from a cumulative to an annual/active participation methodology in DSM programs to address overestimation of participants and underestimation of savings. E1's new approach tracks active participation yearly with weighted-average measure life, improving accuracy in RBIA models. Program-level participation data will no longer be included in RBIA but will remain in E1's reports.

4.4 MODEL CHANGE LOG - During the 2022 Historical Rate and Bill Impact Analysis proceeding, Synapse requested that E1 document - any formula changes in the RBIA model and in its Decision Letter dated February 24, 2023, the Board - directed...

AI summary During the 2022 Historical Rate and Bill Impact Analysis proceeding, Synapse requested E1 to document formula changes in the RBIA model. The Board directed E1 to create a change log for the E1 RBIA model and NS Power rate model to track updates, with a change log tab added to both models.

4.5 NS POWER RATE MODEL SCENARIOS - In the 2022 Historical Rate and Bill Impact Analysis proceeding, Synapse recommended that E1 continue - to improve transparency in the RBIA models, and E1 committed to working with NS Power to add M10830...

AI summary NS Power updated its rate model to improve transparency in DSM scenarios following Synapse's 2022 recommendations. E1 and Elenchus collaborated with NS Power to clarify DSM/No-DSM scenarios, adjusting the model without altering RBIA results. The model includes historical DSM costs, planned programs, and calculates revenue requirements by adding avoided costs to the 'DSM Benchmark' scenario.

4.6 DEMAND RESPONSE ASSESSMENT In the 2022 Rate and Bill Impact proceeding, Synapse recommended that E1 monitor for models used in other jurisdictions that they may adopt to enhance the demand response assessment in the RBIA and E1 indicat...

AI summary In the 2022 Rate and Bill Impact proceeding, Synapse advised E1 to adopt models from other jurisdictions to improve demand response assessments. E1 committed to refining models with its consultant Elenchus but has not identified necessary changes yet. The NSUARB directed E1 to report on model developments in its next report.

5. METHODOLOGY AND ASSUMPTIONS - Attachment 3 describes the overall modelling and key assumptions that apply to the 2026 DSM Extension - RBIA (forward looking). M10830, E1 2022 RBIA, E1 Reply Comments, January 19, 2023, page 5 M10830, E1 2...

AI summary Attachment 3 outlines modeling and assumptions for the 2026 DSM Extension and references RBIA as forward-looking. It cites M10830, E1's 2022 RBIA, and the NSUARB Decision dated February 24, 2023, page 5.

6. FUTURE CONSIDERATIONS - E1 understands that NS Power is currently developing an updated Cost of Service Study. Once concluded, - E1 will work with stakeholders to consider any potential implications to the RBIA as a result of this updat...

AI summary E1 acknowledges NS Power's updated Cost of Service Study and plans to collaborate with stakeholders on RBIA implications. The next RBIA applications will cover 2026-2031, part of E1's DSM Resource Plan filing in winter 2026.

7. CONCLUSION - Highlights from the 2026 DSM Extension RBIA analysis include: - Over the 16 years of the study period, participants in DSM programs see average annual bill reductions ranging from a low of 0.1 percent (typical Municipal par...

AI summary The 2026 DSM Extension RBIA analysis highlights that DSM programs lead to significant bill savings for participants, with Nova Scotian ratepayers expected to save $74 million over 16 years. Non-participants experience minimal rate increases, while higher participation reduces the number of customers facing rate hikes without bill savings. The analysis also notes that societal benefits like reduced emissions and local economic investment are not fully captured in the RBIA model.

his graph shows estimated rate impacts of DSM by individual DSM resource, all relative to the no-DSM scenario. 23 This graph shows bill impacts of all DSM resources combined, as percentage differences relative to the no-DSM scenario. 'Part...

AI summary The text includes several figures illustrating the estimated rate and bill impacts of Demand-Side Management (DSM) resources relative to a no-DSM scenario. It also describes participation metrics for DSM resources, distinguishing between 'Annual' and 'Active' participation. The document was filed on April 30, 2025.

his graph shows estimated rate impacts of DSM by individual DSM resource, all relative to the no-DSM scenario. This graph shows bill impacts of all DSM resources combined, as percentage differences relative to the no-DSM scenario. 'Partici...

AI summary The document presents graphical analyses of the estimated rate and bill impacts of Demand-Side Management (DSM) resources relative to a no-DSM scenario. It also includes participation rates for different DSM resources, distinguishing between 'Annual' and 'Active' participation, and highlights the potential for double-counting of participants across resources.

his graph shows estimated rate impacts of DSM by individual DSM resource, all relative to the no-DSM scenario. This graph shows bill impacts of all DSM resources combined, as percentage differences relative to the no-DSM scenario. 'Partici...

AI summary The document includes figures illustrating the estimated rate and bill impacts of Demand-Side Management (DSM) resources relative to a no-DSM scenario, as well as participation rates for different DSM resources. The analysis includes both annual and active participation metrics, accounting for potential overlaps in customer participation across resources.

his graph shows estimated rate impacts of DSM by individual DSM resource, all relative to the no-DSM scenario. This graph shows bill impacts of all DSM resources combined, as percentage differences relative to the no-DSM scenario. 'Partici...

AI summary The document presents graphical analyses of the estimated rate and bill impacts of Demand-Side Management (DSM) resources, relative to a no-DSM scenario. It includes participation rates for different DSM resources, distinguishing between 'Annual' and 'Active' participation, and highlights the impact of DSM on customer energy use and costs.

his graph shows estimated rate impacts of DSM by individual DSM resource, all relative to the no-DSM scenario. This graph shows bill impacts of all DSM resources combined, as percentage differences relative to the no-DSM scenario. 'Partici...

AI summary The text presents graphical data on the estimated rate and bill impacts of Demand-Side Management (DSM) resources, comparing scenarios with and without DSM. It also includes information on participation rates and active participation by DSM resource, highlighting the impact of DSM on customer energy use and billing.

his graph shows estimated rate impacts of DSM by individual DSM resource, all relative to the no-DSM scenario. This graph shows bill impacts of all DSM resources combined, as percentage differences relative to the no-DSM scenario. 'Partici...

AI summary The text discusses the estimated rate and bill impacts of Demand-Side Management (DSM) resources, comparing them to a no-DSM scenario. It also includes graphs showing participation rates for different DSM resources, distinguishing between 'Annual' and 'Active' participation, and highlights potential overlaps in customer participation across resources.

his graph shows estimated rate impacts of DSM by individual DSM resource, all relative to the no-DSM scenario. This graph shows bill impacts of all DSM resources combined, as percentage differences relative to the no-DSM scenario. 'Partici...

AI summary The text discusses the estimated rate and bill impacts of Demand-Side Management (DSM) resources, relative to a no-DSM scenario. It also provides visual representations of annual and active participation rates for different DSM resources within a class, highlighting potential overlaps and double-counting.

1. GENERAL APPROACH - E1 has used the "snapshot" approach recommended by Synapse, in which the impacts of specific - program years are analyzed (in this case 2026 programs for the forward-looking DSM RBIA) rather - than incorporating an as...

AI summary E1 employed Synapse's 'snapshot' approach, analyzing 2026 DSM programs for the forward-looking DSM RBIA instead of a long-term assessment.

2. RESOURCES AND SCENARIOS - The 2026 DSM Extension Analysis includes the NS Power rate model and the E1 RBIA model, filed - in Attachments 5 and 6 respectively. The analysis compares two scenarios: a DSM scenario and a - no-DSM scenario....

AI summary The 2026 DSM Extension Analysis compares DSM and no-DSM scenarios using NS Power's rate model and E1's RBIA model. It evaluates energy efficiency and demand response impacts, isolating 2026 DSM effects on rates and bills. Alternative scenarios include Energy Efficiency Only and Demand Response Only, with results summarized in Attachment 1.

2.1 ENERGY EFFICIENCY INPUTS - For 2026, first-year energy, lifetime energy and demand savings developed at the program - component level were allocated to rate classes in proportion with the actual rate class allocation - of energy and de...

AI summary The document outlines methods for allocating 2026 energy and demand savings to rate classes based on 2022-2024 program component data. Weighted-average measure lives (WAMLs) are calculated using ratios of lifetime to first-year energy savings per rate class.

2.2 DEMAND RESPONSE INPUTS - Demand response costs, savings, measure life, and customer incentives are calculated and - entered separately in the model from energy efficiency inputs. Demand response inputs are - determined separately from...

AI summary Demand response (DR) inputs are modeled separately from energy efficiency (EE) to enable scenario analysis, including DSM, EE-only, and DR-only cases. DR programs affect demand, not energy, with one-year measure life and continuous participant engagement. Data for the 2026 DSM Extension RBIA comes from Guidehouse's DRSim™ model and historical forecasts.

4. TIME PERIOD DEFINITIONS - The following time periods apply to the RBIA analysis: - DSM delivery period: the timeframe over which DSM programs are delivered. - The DSM delivery period included in the 2026 DSM Extension RBIA is 2026. - Co...

AI summary The text defines time periods for the RBIA analysis, including the DSM delivery period (2026), cost recovery period (2026), and study period (2026-2041). The study period ends when all average rate class DSM impacts expire, with impacts modeled over the full timeframe.

5. AVOIDED COSTS - Avoided costs are calculated at the system level using evaluated DSM savings and avoided cost - rates in four categories: generation, transmission, distribution, and energy. Avoided costs used - for the 2026 Extension an...

AI summary Avoided costs are calculated system-wide using DSM savings and rates across generation, transmission, distribution, and energy categories. Data for the 2026 Extension and RBIA are detailed in Appendix A, Attachment 1.

6. RATE CLASSES INCLUDED - E1's RBIA model presents results by rate class for the following NS Power customer classes: - Residential (rate codes 2, 3, 4, 5, 6, 9 and 16); - Small General (rate code 10); - General (rate code 11); - Large Ge...

AI summary E1's RBIA model analyzes NS Power rate classes including Residential, Small/General/Large Industrial, and Municipal, but excludes Unmetered, GRLF, Shore Power, and ELIADC classes. E1 does not offer programs for excluded classes.

7. CALCULATION OF PARTICIPATION This section describes the development of participation figures, which are used for the participant bill impact calculations.

AI summary This section outlines the methodology for calculating participation figures, which are essential for determining the financial impact on participants in the regulatory proceeding. It forms part of the NSUARB's analysis under the PUA.

7.1 PARTICIPATION COUNTS BY CLASS Participation estimates used in the RBIA model are different than participation estimates used in development of DSM plans, since the RBIA tracks participating accounts , rather than the number of products...

AI summary The document explains how the RBIA model calculates participation counts by distinguishing between annual and active participants, using de-duplicated account data across programs and years. It details three participant categories: tracked, untracked, and Residential Behaviour participants, with totals capped at the number of customers in each rate class.

7.2.1 ANN UAL TRACKED EN ERGY EFFICIEN CY PARTICIPA TION - For 2026, annual tracked participation was first estimated at the program component level. For - some program components this was done directly using inputs to Guidehouse's ProCESS...

AI summary The 2026 annual tracked participation for energy efficiency programs was estimated using Guidehouse's ProCESS model and scaled 2023 RBIA data with energy and unit factors. Results were allocated to rate classes based on historical 2023 participation patterns.

7.2.2 ACTIVE TRACKED ENERGY EFFICIEN C Y PARTICIPATION - For 2026, in the forward-looking RBIA, all annual participants are considered to be active - participants, as the forward-looking RBIA does not account for any impacts prior to 2026....

AI summary The forward-looking RBIA assumes all annual participants are active in 2026 and remains flat until their energy savings expire, after which participation drops to zero. This approach does not account for pre-2026 impacts.

7.3 UNTRACKED (POINT-OF-SALE PROGRAM) PARTICIPATION - E1 operates two program components that offer rebates at the point-of-sale: residential Instant - Savings and the Instant Rebates portion of Business Energy Rebates (BER-IR). These prog...

AI summary E1's Untracked Point-of-Sale Program includes residential and business rebate components (BER-IR) with participation estimated via transaction records and assumptions about rate class participation. For 2026, annual and active participants are estimated using forward-looking RBIA methods, with assumptions about flat participation until energy savings expire. Residential Behaviour and Demand Response participation methods are also detailed, including cross-participation rates and DRSim™ model inputs.

7.6 MUNICIPAL RATE CLASS PARTICIPATION - Municipal customers within the NS Power model are Municipal account numbers that take - service under the Municipal tariff. The number of customers within the NS Power model - fluctuates from year-t...

AI summary The NS Power model's municipal customer count fluctuates yearly between 1 and 8. E1's RBIA model aggregates all municipal customers as one utility, adjusting participant numbers but facing uncertainty due to data volatility in the municipal rate class.

8. CALCULATION OF RATE IMPACTS - Rate impacts are calculated in NS Power's Rate Model (Attachment 5) to reflect NS Power's Cost - of Service in a more precise manner. NS Power's Rate Model methodology is described in - Attachment 4. - to a...

AI summary NS Power's Rate Model calculates rate impacts by blending DSM energy and demand effects into a single energy rate, while E1's RBIA Model uses these inputs. Demand charges are excluded from bill savings calculations as they are already incorporated into the blended rate. All rate effects are assumed to apply to energy rates, with customer and demand charges remaining unchanged between DSM scenarios.

9. CALCULATION OF BILL IMPACTS This section describes key elements of the bill impact calculations.

AI summary This section outlines the methodology for calculating bill impacts as part of the Nova Scotia Utility and Review Board (NSUARB) proceeding. It focuses on the Rate and Bill Impact Analysis (RBIA) process, which evaluates the financial effects of demand-side management programs on customer bills.

9.1 NO-DSM BILL IMPACTS - In the no-DSM scenario, for each rate class, and for each year, the total class energy consumption - is divided by the number of customers to produce an estimate of the average customer's - consumption. This avera...

AI summary The no-DSM scenario calculates average customer energy consumption by dividing total class energy consumption by the number of customers. These averages, combined with no-DSM rates, are used to estimate average bills for each rate class and year.

9.2 NON-PARTICIPANT BILL IMPACTS - In the DSM scenario, non-participants in DSM programs are assumed to use the same amount of - energy as they do in the no-DSM scenario. Their bill impacts are therefore driven only by changes - in rates u...

AI summary In the DSM scenario, non-participants' bill impacts are driven by rate changes rather than energy use, with fixed charges affecting the percentage differences between bill and rate impacts.

9.3 PARTICIPANT BILL IMPACTS - For the DSM scenario, within each rate class in each year, total annual savings (i.e., current-year - savings plus persistent savings from past years, note that this is not applicable for the 2026 - forward-l...

AI summary The DSM scenario assumes equal annual savings distribution among participants, ignoring participation depth variations. E1's RBIA includes free-riders but uses net savings, leading to lower average savings estimates. The model does not account for past-year savings in the 2026 forward-looking RBIA.

9.4 TOTAL CUSTOMER BILL IMPACTS - The RBIA also includes a third category of participants, called Total Customers. Impacts for this - category are determined by allocating DSM savings for the class equally among all customers in - the clas...

AI summary The RBIA includes a Total Customers category, where DSM savings are equally allocated among all customers in the class. Average savings and DSM scenario rates are used to calculate average bill savings, providing an estimate without differentiating between participants and non-participants.

Methodology for determination of changes in NS Power's base cost rates as a result of DSM-induced changes in class usage and total system costs November 27, 2020

AI summary The Nova Scotia Utility and Review Board (NSUARB) outlines a methodology to assess changes in Nova Scotia Power's (NSP) base cost rates caused by Demand-Side Management (DSM)-induced shifts in class usage and total system costs. The analysis focuses on evaluating DSM's impact on cost recovery, rate design, and system-wide cost implications.

1.0. Introduction In an effort to more precisely and accurately align EfficiencyOne's (E1) RBIA Model with the methodological process used by NS Power in setting of its base cost rates, all rate setting functionality from E1's RBIA model h...

AI summary NS Power is taking over rate-setting functionality from E1's RBIA model, aligning with COSS methodology. NS Power will provide annual inputs for RBIA under DSM scenarios, including revenue forecasts, sales, and customer data.

2.0. Background The regulated base cost rate setting process involves the following three sequential analytical steps: - Determination of total annual revenue requirement; - COSS concerned with apportionment of total costs among rate class...

AI summary The regulated base cost rate setting process involves three steps: determining total annual revenue requirement, conducting a Cost-of-Service Study (COSS) for cost apportionment among rate classes, and establishing class rates and revenue responsibilities.

Revenue Requirement Ordinarily, the base cost rate setting process used in rate case applications requires a great amount of detailed cost inputs to determine revenue requirement. Annual rate base data needs to be collected on a variety of...

AI summary The document explains that the RBIA does not require detailed annual cost data for rate base calculations, as it only assesses DSM-induced changes while keeping other costs constant. This avoids the need for a full rate case analysis, focusing instead on directional and relative rate/bill changes due to DSM programs.

Cost of Service Studies COSS provides the most insight into class cost causation as based on changes in its energy and demand usage. It shows in a transparent way how rate class usage of demand and energy services within each functional ar...

AI summary COSS (Cost-of-Service Study) is critical for analyzing class cost causation by leveraging NS Power's Load Forecast Report and E1's long-term usage forecasts. This approach simplifies pricing adjustments by utilizing existing data rather than future investment details, ensuring transparency in rate class changes due to DSM.

Rates and Revenues There is little that can be inferred about the cost causation process from the rate structures used by the utility to generate customers' bills. The rates are bundled and therefore do not allow tracking of cost recovery...

AI summary The document critiques NS Power's bundled rate structures, which obscure cost recovery tracking by functional areas (generation, transmission, distribution). Residential and small general classes recover demand-related costs via energy charges, while other classes use combinations of demand and energy charges. Misalignments exist between revenue streams and cost categories for customer and demand charges, as noted in the Cost-of-Service Study (COSS).

Conclusions Bypassing the detailed COSS ratemaking step, which is intended to show how DSM-induced, cost causative changes in usage affects rates will produce misleading results and create difficulties in interpretation. Any such rate anal...

AI summary Bypassing the COSS ratemaking step for DSM leads to misleading rate analyses by failing to account for reallocation of embedded system costs. A simplified COSS process is recommended to accurately reflect how DSM-induced usage changes affect class-specific costs and rates.

3.0. Applied Approach The relative changes in rates due to DSM are determined by conducting two separate rate setting analyses under the "With DSM" and "No DSM" scenarios. The rate setting process under each scenario is broken out by two s...

AI summary The rate impact of Demand-Side Management (DSM) is analyzed through two scenarios ('With DSM' and 'No DSM'), each divided into subprocesses for FAM-related and non-FAM-related cost calculations to assess relative rate changes.

3.1 Revenue Requirement The annual revenue requirements under the "With DSM" scenario are kept consistent with the test year information from the preceding rate cases. The non-FAM costs in the years following the 2014 test year from the 20...

AI summary The document outlines revenue requirements for 'With DSM' and 'No DSM' scenarios, adjusting FAM and non-FAM costs with inflation and DSM impacts. Historic cost true-ups are excluded due to minimal rate effects, lack of COSS rigor, and complexity. E1 provides avoided fuel cost data for post-2022 adjustments.

3.2 Cost of Service Studies Cost of service Studies consist of an application of the following three sequential steps: - functionalization of revenue requirement to the four areas: generation, transmission, distribution and retail; - class...

AI summary The Cost of Service Study (COSS) by NS Power involves three steps: functionalizing revenue requirements, classifying costs, and apportioning them among rate classes. Most costs are shared, except streetlight fixture costs assigned to unmetered customers.

3.2.3 Allocation of Costs to Rate Classes Annual cost requirements within each service of each functional area are apportioned to rate classes based on class share in the underlying usage both in the "With DSM" and "No DSM" case.

AI summary Annual costs in each service area are allocated to rate classes based on their share of underlying usage in both 'With DSM' and 'No DSM' scenarios, ensuring proportional cost distribution across different customer classes.

FAM-related Costs The FAM-related costs are allocated to rate classes using the following two-step process: • Annual class energy usage is multiplied by the benchmark unit cost $/MWh - o In the "With DSM" case the benchmark unit costs come...

AI summary FAM-related costs are allocated to rate classes using a two-step process involving benchmark unit costs from past rate cases. The method does not differentiate between energy and demand-related costs due to historical insignificance of demand costs, though recent Maritime Link Costs have increased demand-related costs to 15% of FAM totals. This allocation method may be remodeled in future RBIA applications.

DSM Costs The annual DSM-related costs incurred by individual rate classes, as provided by E1, are apportioned to rate classes based on the 25/75 rule. 75 percent of the costs incurred by each class is treated as direct responsibility of e...

AI summary DSM costs are apportioned to rate classes using a 25/75 rule, with 75% of costs directly attributed to each class and 25% distributed based on energy and demand usage. Energy-related costs are allocated by system generation share, while demand-related costs are based on winter peak contributions.

3.2.4 Generic COSS Results The actual results from the above cost allocation process under the "With DSM" and "No DSM" scenarios are presented in the "COSS Outputs" tab within NS Power's rate model, where the long-term trends in annual rel...

AI summary The COSS Results compare 'With DSM' and 'No DSM' scenarios, showing long-term unit cost trends by rate class. Historic periods show higher DSM cost impacts, while out-years show reduced differentials. Fuel-cost-heavy classes (e.g., Large Industrial) benefit more from DSM savings, whereas fixed-cost-heavy classes (e.g., Domestic) see less benefit. Differences arise from DSM spend, usage changes, and cost allocation methods.

3.3 Unit Revenue Determination For the directional purposes of the RBIA model, it is not considered necessary to develop annual rates with all charges under the "With DSM" and "No DSM" cases. Rather, it is sufficient for NS Power to provid...

AI summary NS Power determines class unit blended revenues for residential and small general rate classes without customer charges, adjusted for line losses. Factors like fuel cost true-ups and rate smoothing are excluded, as they have no material effect on relative unit revenue changes between 'With DSM' and 'No DSM' cases.

Overview of Spreadsheet Calculations

AI summary The document outlines spreadsheet calculations related to Demand-Side Management (DSM) programs, involving the Nova Scotia Utility and Review Board (NSUARB) and EfficiencyOne (E1). Key considerations include benefit/cost ratios (TRC, PAC), regulatory frameworks (PUA), and cost recovery mechanisms (DCRR). The analysis supports NSUARB's evaluation of DSM initiatives under the Public Utilities Act.

Data Inputs

AI summary The 'Data Inputs' section lists acronyms and their expansions relevant to a Nova Scotia regulatory proceeding, including organizations, legislation, and programs involved in energy efficiency, demand-side management, and utility regulation.

"COSS Data Inputs" tab This tab includes all annual test year class usage and embedded costs from the COSS and BCF COSS filed in GRA and BCF proceedings as well as a forecast of annual usage by class per the most recent ten-year Load Forec...

AI summary The 'COSS Data Inputs' tab contains annual test year data from COSS and BCF COSS filings, load forecasts, and DSM expenditures, used to determine class unit costs and revenues. It includes data from regulatory proceedings and forecasts for usage by rate class.

Savings in energy and demand usage by rate class Savings in energy and demand usage arising from DSM programs for each class are tracked in the following class tabs: R-Savings, SG-Savings, G-Savings, LG-savings, SI-Savings, MI-Savings, LI-...

AI summary The document outlines how energy and demand savings from DSM programs are tracked by rate class, using data from 2011 to 2022. Savings are calculated by E1's RBIA Reports and adjusted using COSS data on energy and demand losses.

Cost of Service Studies Apportionment of costs to rate classes is done separately for the "With DSM" and "No DSM" cases" in the tabs bearing the same names.

AI summary The document outlines the apportionment of costs to rate classes under two scenarios: 'With DSM' and 'No DSM', as part of the Cost of Service Study. This analysis is conducted separately in tabs named accordingly.

"With DSM" tab The "With DSM" tab provides annual cost allocation to rate classes based on long-term usage as included in NS Power's most recent Annual ten-year Load Forecast Report. This usage already reflects inclusion of DSM Program eff...

AI summary The 'With DSM' tab outlines annual cost allocation to rate classes using NS Power's ten-year load forecast, incorporating DSM program effects. FAM costs for 2023-2035 are adjusted via a two-step process: calculating class costs using 2022 blended FAM rates, then scaling to match annual totals. The formula combines previous year costs with energy requirement changes and avoided FAM costs.

Comments The applied process is a simplification of a more elaborate cost allocation process from the COSS where some FAM costs, such as fuel costs, are allocated to rate classes based on their shares in monthly energy requirements; some o...

AI summary The text describes a simplified cost allocation process for FAM costs based on the COSS, allocating different FAM costs using factors like energy requirements and load factors, carrying forward 2022 unit costs, and adjusting non-FAM costs for inflation.

"COSS Outputs" tab The "COSS Outputs" tab provides two sets of bar graphs of percentage change in class rates due to DSM over the period 2011–2035 calculated as either arithmetic or load-weighted rate changes. The graphs within each set ar...

AI summary The 'COSS Outputs' tab presents bar graphs illustrating percentage changes in class rates due to DSM (Demand-Side Management) from 2011 to 2035, calculated using arithmetic or load-weighted methods. It includes scenarios analyzing changes in unit base cost revenues, considering DSM costs, and a control panel to test inflation and avoided cost impacts on rate changes.

"NSPI Inputs into RBIA" tab "NSPI Inputs into RBIA" provides pricing inputs requested by E1. It includes the following annual class data in years 201-2035 broken out by "With DSM" and "No DSM" scenarios: - Forecast Unit Revenues Before DSM...

AI summary The 'NSPI Inputs into RBIA' tab provides annual pricing data from 201-2035, comparing 'With DSM' and 'No DSM' scenarios, including revenue forecasts, DSM program charges, sales forecasts, demand forecasts, and customer counts, submitted by E1 for the Rate and Bill Impact Analysis.

Filed Electronically

AI summary The document is an electronically filed submission in a Nova Scotia regulatory proceeding involving Demand-Side Management (DSM) programs, cost recovery mechanisms, and utility rate structures. Key entities include Nova Scotia Power (NSP), the Nova Scotia Utility and Review Board (NSUARB), and EfficiencyOne (E1). Topics focus on DSM cost recovery, energy efficiency, and regulatory analysis.

Filed Electronically

AI summary The document is an electronically filed submission in a Nova Scotia regulatory proceeding involving Demand-Side Management (DSM) programs, cost recovery mechanisms, and utility rate structures. Key entities include Nova Scotia Power (NSP), the Nova Scotia Utility and Review Board (NSUARB), and EfficiencyOne (E1). Topics focus on DSM cost recovery, energy efficiency, and regulatory analysis.

The figure below identifies the Contract Price to be paid by NSPI allocated for each year of the Term. 2023 2024 2025 2026 Total UARB /NSEB Approved Investment Amount 53,000,000 57,500,000 62,500,000 63,750,000 236,750,000 173,000,000 Refu...

AI summary The document outlines the Contract Price to be paid by Nova Scotia Power Inc. (NSPI) for each year of the Term, including approved investment amounts, refunds, and net contract amounts. It also mentions that any surplus realized by EfficiencyOne in meeting Performance Targets will be refunded to NSPI, with a reference to a 2019 surplus to be refunded in 2023.

ate to decrease, and here it does not. This may be a function of special conditions at the site, since this does not occur at other sites, but it is something the Evaluator should examine and explain.

AI summary The text notes that a rate of decrease is not occurring as expected, potentially due to site-specific conditions. The Evaluator is advised to investigate and explain this discrepancy, as it differs from other sites.

2. BNI DR For BNI, the Evaluator first reviewed Efficiency Nova Scotia BNI tracking sheets to ensure consistency, resulting in a small correction (magnitude 2%-3%) to Efficiency Nova Scotia tracking values. By agreement between Efficiency...

AI summary BNI DR capacity calculation involves corrections to Efficiency Nova Scotia tracking sheets, event-based capacity determination (Dec-Feb, excluding weekends/holidays), participant classification for morning/evening events, and whole-house AMI data analysis. Evaluated results show 8.034 MW for BNI DR and 0.057 MW for Residential DR, with methodologies deemed logical and complete.

Date Filed: June 25, 2025 IG IR-04, Attachment 1, Page 1 of 1 Plan As Approved Expenditures ($ million) Actual Expenditures ($ million) Variances (Actual Expenditures to Plan as Approved) ($million) 2 3 (a) Please define quantitatively wha...

AI summary The document includes a request for EfficiencyOne (E1) to define what constitutes a 'substantial change to any customer class on an annual basis' and to explain efforts to avoid such changes and rate impacts during the true-up process for the four-year plan. E1 responds that it has not yet quantitatively defined 'substantial change' and is evaluating the issue further, considering both total expenditures and the number of customers in each rate class.

Date Filed: June 25, 2025 E1 (IG) IR-07 Page 2 of 2 1 Request IR-08: 2 3 Preamble: At page 6, E1 states it was directed to "take notice of the concerns raised by the 4 Industrial Group and be prepared to address them in its pending applica...

AI summary The Industrial Group raised concerns about unanticipated cost impacts from variances in EfficiencyOne's DSM expenditures by customer class, potentially affecting rate classes. E1 responded by addressing these concerns through strategies developed after reviewing the causality of the issue, particularly in the context of the 2025 DSM Cost Recovery Rider (DCRR) and the 2026-2030 DSM Plan.

1) The Impact of New Initiatives Prior to 2019, expenditures for both the medium and large industrial rate classes were lower than what E1 had estimated in the DSM Plans for those years and as a result in 2019, E1 engaged Dunsky Energy Con...

AI summary E1 engaged Dunsky Energy Consulting in 2019 to address low industrial customer participation in DSM programs. By 2020, E1 developed an industrial strategy with energy management support, relationship building, and expanded incentives. Implementation grew from 3 to 15 participants by 2023, though E1's 2021 estimates underestimated the program's popularity in the 2023-2025 DSM Plan.

2) Provide enhanced reporting in the Quarterly and Annual Reports E1 understands the importance of transparency in reporting on rate class spending variances and is committed to enhancing the rate class spending reporting. In 2025, E1 enha...

AI summary E1 acknowledges the need for transparent reporting on rate class spending variances and plans to enhance reporting in 2026 by adding year-end forecasts in quarterly DSM reports and expanding annual reports to include projected rate class expenditures and variances for the entire Plan period.

3) Continue to Manage Program Expenditures E1 will continue to provide explanations for program spending variances compared to the DSM Plan that are greater than 25% in its Quarterly and Annual Progress Report. In the development of the DS...

AI summary E1 will continue managing program expenditures in line with the DSM Plan, providing explanations for variances exceeding 25% in its reports. Flexibility in reallocating funds between programs is emphasized to meet performance targets, while considering rate class spending and potential impacts on customer participation and future DSM Plan success.

(d) Please refer to part (b) of this IR response. (e) The residential DR program component was introduced in the 2023-2025 DSM Plan. Delivering programs in 2023-2025 has provided E1 valuable insights into the actual costs and capacity from...

AI summary EfficiencyOne (E1) has introduced a residential demand response (DR) program as part of the 2023-2025 DSM Plan, acknowledging early cost-effectiveness challenges but emphasizing its role in equity and alignment with provincial clean energy goals, including the 2030 Clean Power Plan and decarbonization targets.

& lt;sup>c Weighted average measure life for Q1 2025 actuals was calculated by dividing the lifetime energy savings by the first year energy savings. 1 Request IR-14: 2 3 Reference: Appendix A, page 27. 4 5 In the 2025 DCRR matter, the Ind...

AI summary The text discusses concerns raised by the Industrial Group in the 2025 DCRR matter regarding DSM costs and spending variations by customer class. E1 explains that actual spending by rate class is reported for the DSM rider and that mid-course adjustments are not used for this purpose. Questions are raised about true-up processes and their impact on programming and spending.

14 Description of TRC and PAC costs and benefits as applied within DRSim model: 15 • The TRC test (as utilized in Nova Scotia) is a ratio of the utility benefits divided by 16 the utility costs + customer costs. 17 • The PAC test is a rati...

AI summary The TRC and PAC tests are described as ratios used to evaluate demand response programs in Nova Scotia. TRC includes both utility and customer costs, while PAC only considers utility costs. Both tests levelize upfront costs over ten years, following Guidehouse's recommendation.

24 Table 1: Summary of benefits and costs used for the TRC and PAC tests as applied in the DRSim model for 25 demand response TRC PAC Benefits • Avoided generation capacity costs • Avoided T&D capacity costs • Avoided energy purchases • Av...

AI summary The table outlines the benefits and costs considered in the TRC and PAC tests for demand response as modeled in the DRSim model. Benefits include avoided generation and transmission/distribution capacity costs and energy purchases. Costs include program delivery, customer costs, and participant costs, with some streams noted as zero.

Date Filed: June 25, 2025 E1 (IG) IR-23 Page 3 of 3 1 Request IR-24: 20 over the 2026 DSM Extension period compared to the rate impacts from the 2023-2025 Plan 21 RBIA.1 1 Request IR-26: 2 3 Reference: Appendix B, page 13 of 24, and pages...

AI summary The document outlines requests related to the 2026 DSM Extension period and non-participant bill impacts, focusing on participation rates in EE and DR programs across various industrial rate classes. It emphasizes the broad reach of E1's rebate programs and the assumption that participation is widespread.

As stated on page 13 of Appendix A, the RBIA participation forecasting methodology assumes each customer in larger classes participates in DSM every year, either directly or indirectly through contractors. As a result, there are no non-par...

AI summary The text discusses the RBIA participation forecasting methodology, assuming all customers in larger classes participate in DSM every year. It also outlines the average bill impact for non-participants in the 2026 DSM Extension, which is driven by rate class rate impacts and shows minimal increases for small, medium, and large industrial classes.

E1 Responses to Municipal Electric Utilities (MEUs) Information Requests NON-CONFIDENTIAL Request IR-01: Reference: Evidence, page 14 of 25: "E1 intends to utilize the intervening time between now and the anticipated 2027-2031 DSM Plan fil...

AI summary E1 (EfficiencyOne) states it does not currently have estimated DSM expenditure ranges for the 2027-2031 plan but anticipates sharing them after fall 2025 modelling. Consultations with the DSMAG on the DSM Plan are ongoing, with a planned Q1 2026 filing.

M12249 – EfficiencyOne (E1) Application for Approval of the 2026 DSM Extension 1 Request IR-07: 2 3 The Board's Decision in Matter M10473 approved the 2023-2025 DSM Plan with specific annual 4 expenditures and performance targets. Amended...

AI summary The document outlines a request (IR-07) from the Nova Scotia Energy Board regarding the 2026 extension of the 2023-2025 DSM Plan, asking EfficiencyOne (E1) to explain the rationale for combining 2026 targets with previous ones, the benefits of such a combination, and whether new performance standards can be established for 2026.

E1 Responses to Nova Scotia Energy Board (NSEB) Information Requests NON-CONFIDENTIAL 1 programming including investment in new multi-year technologies; and reducing 2 administrative and regulatory costs associated with single year approva...

AI summary E1 is seeking to extend the 2023–2025 DSM Plan to include 2026, arguing that cumulative performance targets should be considered over the entire plan period rather than individually for each year. This approach aims to reduce administrative and regulatory costs and provide flexibility for program performance.

Table 2 : NS Power summary of the season definitions for energy used in the June 12, 2024 and August 23, 2024 deliverables. Season definitions used in Updated season definitions June 12, 2024 analysis Winter On-Peak Months: Months: Jan, Fe...

AI summary The table outlines updated season definitions for energy use in NS Power's June 12, 2024 and August 23, 2024 deliverables. The updated definitions show that November and March are now classified as non-winter months, with no on-peak/off-peak differentiation. The request for rationale seeks an explanation for this shift.

Observations: - There are some years where the on-peak winter avoided cost of energy is lower than the offpeak winter avoided costs (2031, 2032, 2034, 2035, 2036, 2037, 2041, 2042, 2047). The difference is as much as $43/MWh (2036). - Ther...

AI summary The text highlights years where on-peak winter avoided energy costs are lower than off-peak winter costs and non-winter periods, with a maximum difference of $43/MWh in 2036. Such discrepancies occur in multiple years, including 2029, 2031, and others, indicating irregularities in cost patterns across seasons and times.

Discussion: The goal of time-differentiated avoided costs is to better understand and value the marginal impact to the system of removing energy during different time periods (i.e. what is the value of removing a kWh of energy during winte...

AI summary The discussion focuses on time-differentiated avoided costs for DSM resources, emphasizing their value during varying periods (e.g., winter on-peak vs. summer). E1 criticizes NS Power's categorization of non-winter periods without time differentiation, arguing it oversimplifies system costs and misrepresents price signals. E1 recommends at least four avoided cost categories for accurate system planning and DSM effectiveness.

Request IR-01: Refer to Exhibit E-1 EfficiencyOne 2026 DSM Extension Application ("Application"), Appendix B, Figure 1, Average Rate and Bill Impacts (2026-2041) as a Result of DSM Activities in 2026, page 4 of 24, line 1. EfficiencyOne ex...

AI summary The document requests clarification on EfficiencyOne's 2026 DSM Extension Application, focusing on two figures analyzing rate and bill impacts. It questions whether including the incremental DSM investment reduces negative impacts, if Figure 2 reflects this inclusion, and whether Small General/Industrial rate classes show the highest average rate impacts over 2026-2041.

of 2026 DSM Activities, shows that the Small General and Small Industrial rate classes are expected to have the highest average rate impact over the 2026-2041 period, of all the rate classes shown. (d) Please confirm that the results shown...

AI summary The text questions the consistency of DSM impact figures for Small General and Small Industrial rate classes between Figure 2 and Table 1, and asks EOne to justify disproportionate impacts on these classes despite DSM benefits being supposed to be universal. EOne clarifies that the RBIA only compares 2026 DSM Extension investment to no DSM investment, not existing DSM programs, and that the purple rate impacts in Figure 1 match Table 1's data.

and bills. (b) The average rate impacts shown in purple in Figure 1: Average Rate and Bill Impacts (2026- 2041) as a Result of DSM Activities in 2026 of Appendix B, are equivalent to the rate impacts shown in Figure 2: Average Rate Impacts...

AI summary The document confirms that the 2026 DSM Extension results in average rate increases of 0.45% and 0.34% for Small General and Small Industrial rate classes, but customer bills decrease by 8.8% and 5.8% respectively. EfficiencyOne argues that these rate impacts do not hinder DSM participation as the bill savings offset the rate increases.

(d) Please refer to part (b) of this IR response. 1 Request IR-04: 2 3 Refer to the Application, Appendix B, Section 7. Conclusion, page 23 of 24 at line 21, where 4 EOne states that "Maximizing customer participation in DSM programs mitig...

AI summary EOne asserts that participation in DSM programs will lead to positive bill impacts for small businesses and outlines marketing strategies to increase participation. The 2026 DSM Extension investment is legislatively set, and maximizing participation does not reduce overall rate impacts but increases the number of customers with net bill reductions.

E1 Responses to Synapse Energy Economics (Synapse) Information Requests NON-CONFIDENTIAL Request IR-10: Please refer to Table 5: 2026 Program Savings and Investment on page 23 of the Evidence. (a) Under the Demand Response (DR) Program sub...

AI summary The response to Request IR-10 asks for an updated version of Table 5 with a breakdown of Lifetime Benefits for the Residential Demand Response and BNI Demand Response program components and confirms that Lifetime Benefits represent the net present value of total benefits associated with the TRC.

(a) The lifetime benefits of Demand Response for the year 2026 by program component are as follows: Demand Response (DR) Program Lifetime Benefits ($ million) Residential Demand Response $0.9M BNI Demand Response $2.3M DR Program Total $3....

AI summary The lifetime benefits of Demand Response (DR) programs in 2026 are outlined, with residential and BNI DR programs contributing $0.9M and $2.3M respectively. These benefits are expressed as avoided costs, including capacity, transmission, and distribution, consistent with the Total Resource Cost Test (TRC) and Program Administrator Cost Test (PAC) in Nova Scotia.

In 2024 for business, non-profit and institutional (BNI) customers, E1 continued with the Commercial and Industrial Aggregator and introduced domestic hot water direct load control, smart thermostat direct load control, and EV telematics a...

AI summary In 2024, E1 introduced new demand response and energy efficiency programs for BNI customers. However, Mr. Peach's recommendation regarding the practicality of demand response savings may lead to the elimination of these programs in the 2026 DSM Extension, affecting E1's ability to support NS Power in managing demand.

EfficiencyOne (E1) Responses to Small Business Advocate (SBA) Information Requests NON-CONFIDENTIAL - 1 resulted in a change to unitary energy savings for LED lighting measures and updated the - 2 free-ridership level for LED lamps and fix...

AI summary EfficiencyOne (E1) applied 2024 evaluation findings to adjust 2025 tracked energy savings, noting a 7.7% decline in BER evaluated savings due to reduced LED Linear Lamp sales. The 2024 Peach Report recommended updating BER baselines to reflect current DesignLights Consortium standards, with no further study deemed necessary.

1 jurisdictional scan of programs across provinces to better assess the state of 2 demand flexibility in Canada. 3 Q. What do you recommend? 4 I recommend that NSEB approve the demand response offering. Participation in 5 2023 and 2024 was...

AI summary The text discusses a recommendation to approve a demand response offering by NSEB, with a focus on improving participation and formalizing it in the 2027-2031 DSM Plan. It also addresses the updated avoided transmission and distribution costs for the constrained system provided by NSPI in 2024.

PROFESSIONAL EXPERIENCE Synapse Energy Economics, Inc. , Cambridge, MA. Principal Associate , April 2023 – Present; Senior Associate , June 2013 – April 2023; Associate, July 2008 – June 2013; Research Associate , January 2007 – July 2008....

AI summary The document outlines 18 years of professional experience in demand-side management (DSM) analysis, including work with jurisdictions across the US and Canada. Key activities include evaluating utility energy efficiency plans, assessing DSM program effectiveness, and conducting cost-effectiveness and rate impact analyses. The individual has provided testimony in New Brunswick, Rhode Island, and New Mexico, and supported the Rhode Island Division of Ratepayer Advocate since 2012.

Efficiency and Building Electrification Portfolios Through 2025: A Brief on the New York Public Service Commission's Recent Order. Synapse Energy Economics for the Natural Resources Defense Council. Kallay, J., A. Hopkins, J. Frost, A. Nap...

AI summary The document lists various energy efficiency and building electrification studies, comments, and reports by Synapse Energy Economics and partners. Key entities include Nova Scotia Utility and Review Board, Natural Resources Defense Council, and Bloom Energy. Topics cover energy efficiency initiatives, low-income energy burden, fuel cell cost-effectiveness, and rate model enhancements. Cross-references include New York Public Service Commission Case 18-M-0084.

Energy Efficiency Potential in Oklahoma Sierra Club, Oklahoma (April 2011 – November 2011, December 2013 – January 2014) - Provided updated report for energy efficiency in Oklahoma and additional comments on PUC rulemaking for electric and...

AI summary Sierra Club provided an updated energy efficiency report for Oklahoma, assisted with PUC rulemaking comments, worked on the US regional haze plan, and gave expert testimony for Oklahoma Gas & Electric's rate case before the Corporation Commission of Oklahoma.

Testimony and Proceeding Participation Forum On Behalf Of Docket/Matter Date Issues Addressed Massachusetts Department of Public Utilities Massachusetts Office of the Attorney General D.P.U. 24-140 through D.P.U. 24-149 - 2025-2027 Three-Y...

AI summary This section lists various regulatory proceedings and testimonies from different states, focusing on energy efficiency plans, rate cases, and wildfire mitigation costs. Key issues addressed include policy design, incentive structures, cost-effectiveness, and plan development.

Econoler Response: Econoler rejects the assertion that program savings are not meaningful. As previously detailed in this evidence, the effect of the program on energy consumption is real, was demonstrated with real metering data and shoul...

AI summary Econoler defends the validity of energy savings from the E1 Residential Behaviour program, citing real metering data and RCT methodology. They argue that savings percentages are within expected ranges and that partitioning data would create bias. The program's RCT design ensures group equivalence and robust results.

5.5 Mid-course Adjustments [67] The Industrial Group expressed concerns about E1's discretion to reallocate spending between programs and customer classes through "mid-course adjustments". The Industrial Group said E1 was granted this disc...

AI summary The Industrial Group criticizes E1's lack of definition for 'substantial change' in mid-course adjustments, arguing a 25% spending shift violates Board guidelines. E1 defends flexibility but commits to improved reporting. Proposed 2026 spending increases for industrial classes face scrutiny over customer cost impacts.

5.6 DSM Supply Agreement [74] This application includes amendments to the schedules in E1's existing Supply Agreement with NS Power. E1 said if changes to the Supply Agreement are required because of the outcome of NS Power's pending gener...

AI summary E1 seeks amendments to its Supply Agreement with NS Power, contingent on the outcome of NS Power's pending general rate application. E1 committed to collaborating with NS Power to revise the agreement, which would then be submitted to the Board for approval.

DSM Resource Plan. The 2026 Extension maintains programming continuity with the 2025 program offerings, ensuring DSM program accessibility for customers and consistency with service delivery partners. EOne proposes to follow the same DSM r...

AI summary EfficiencyOne submits the 2026 DSM Extension Plan, maintaining continuity with prior programs and including appendices with reports, analyses, and technical tables. The plan includes stakeholder engagement acknowledgments and details on rate impacts, equity considerations, and supply agreements.

NOTICE OF INTERVENTION OF: K + S Windsor Salt Ltd. CKF Inc. Crown Fibre Tube Inc. Irving Shipbuilding Inc. Maritime Paper Products Ltd. Michelin North America (Canada) Inc. Oxford Frozen Foods Limited Compass Minerals Canada Corp. Farnell...

AI summary The Industrial Group, comprising multiple large and medium industrial companies, seeks to intervene in the proceeding. They are customers of NSPI, and the outcome will affect their costs and rates. The issues may relate to those established by the NSEB.

NOTICE OF INTERVENTION OF: CONSUMER ADVOCATE TAKE NOTICE that the Consumer Advocate hereby intervenes in the above Application and proceeding. The Consumer Advocate represents the interests of residential ratepayers, who may be impacted by...

AI summary The Consumer Advocate intervenes in the proceeding on behalf of residential ratepayers, addressing issues raised by the Nova Scotia Energy Board. They are represented by Pink Larkin and consult with Green Energy Economics Group Inc. The notice is dated May 20, 2025.

NOTICE OF INTERVENTION TO: The Nova Scotia Energy Board ("Board") AND TO: EfficiencyOne 1. The BERWICK ELECTRIC COMMISSION, the RIVERPORT ELECTRIC COMMISSION, the TOWN OF MAHONE BAY, and the TOWN OF ANTIGONISH (collectively, the "MEUs") pu...

AI summary The MEUs (Berwick Electric Commission, Riverport Electric Commission, Town of Mahone Bay, Town of Antigonish) are intervening in a proceeding before the Nova Scotia Energy Board. They purchase power from Nova Scotia Power Inc. under the Municipal and BUTU rates and are affected by the Spill Tariff. They request intervenor status.

Request IR-6: Regarding E1's annual expenditures: Document: 321929 Date Filed: June 4/25 NSEB (E1) Page 2 of 6 - a) What dollar amount was spent on salaries and benefits during each of the past 5 years? - b) Did any employees receive bonus...

AI summary Request IR-6 seeks detailed information about E1's annual expenditures, focusing on salaries and benefits over the past five years, bonus distribution policies, employee eligibility for bonuses, and the criteria used to determine bonus awards. The request also asks for documentation outlining bonus policies.

Request IR-10: With regards to Table 1 on Page 3 of 25 of E1's Evidence: - a) Under "Energy and Demand Savings", please identify the "% of Energy Non-Lighting Savings" for 2026 and 2023-2026. - b) Under "Energy and Demand Savings", please...

AI summary Request IR-10 seeks clarification on Table 1 from E1's Evidence, specifically asking for data on energy non-lighting savings, demand response as a percentage of NS Power peak load, and the 10-year levelized cost of demand response investments for 2026 and the 2023-2026 period.

Request IR-12: - Please provide a version of Table 2 on page 6 of 25 of E1's Evidence to show a) expected 2025 - DSM rate class expenditures from the 2023-2025 DSM plan, b) expected 2024 DSM rate class - expenditures from the 2023-2025 DSM...

AI summary Request IR-12 seeks specific data from Table 2 in E1's Evidence, focusing on 2023-2025 DSM plan expenditures for 2025, 2024, and final 2024 figures. The request aims to clarify DSM rate class spending details.

Request IR-14: - Page 15 of 25 of E1's Evidence states: "E1 notes that while the August 2024 avoided costs - provided by NS Power have been used for purposes of 2026 Extension benefits calculations, - further work remains to be done in thi...

AI summary E1's evidence indicates that while August 2024 avoided costs from NS Power were used for 2026 Extension benefits calculations, further work remains. The request seeks clarification on current deficiencies, responsible parties, and timelines for completion.

Request IR-1: Page 1 of the Evidence of EfficiencyOne ("the Evidence") states, "2023 and 2024 together saw energy savings of 304.3 GWh and demand savings of 58.3 GWh." a. Should the demand savings be GW? b. Does the demand savings include...

AI summary The document outlines four non-confidential information requests related to EfficiencyOne's Demand-Side Management (DSM) program. Requests include clarifying unit measurements (GW vs. GWh), restructuring a table, providing annual progress reports, and detailing DSMAG engagement timelines. The proceeding involves questions about demand savings, reporting requirements, and legislative timelines.

- Cost Test (TRC), and Program Administrator Cost Test (PAC) for lighting measures in the 1 Efficiency Product Installation program component over time. Please include 2023 25 In each of the five worksheets, please keep all the row heading...

AI summary The text outlines requests for detailed tables related to the Cost Test (TRC) and Program Administrator Cost Test (PAC) for lighting measures in the Efficiency Product Installation program, and also requests for breakdowns of low-income and equity customer participation in residential and BNI programs.

- Request IR-24: Table 20: 2026 Summary of the Residential Demand Response Program Component and Table 21: 2026 Summary of the BNI Demand Response Program Component on pages 43 and 44 of Appendix A respectively include New Capacity and Ava...

AI summary The document includes three information requests related to Nova Scotia's Demand Response (DR) programs. IR-24 seeks definitions of 'New Capacity' and 'Available Capacity' and their relation to E1's 2025 forecasts. IR-25 asks for the proposed start date of enrollments. IR-26 inquires about data-driven marketing strategies using AMI data for personalized customer outreach. The NSUARB is involved in regulating these programs.

Application by E1 for Approval of the 2026 DSM Extension - (NSUARB M12249) Non-Confidential MEU Information Requests to E1 1 IR-1 2 Reference: Evidence, page 14 of 25: "E1 intends to utilize the intervening time between 3 now and the antic...

AI summary E1 seeks approval for the 2026 DSM Extension, detailing plans to accelerate consultations on the 2027-2031 DSM Plan by Q4 2025. The MEU requests expenditure ranges for the Municipal Rate Class (24) and detailed breakdowns of forecast and actual expenditures for municipal utilities, including energy and demand savings. E1 must confirm assumptions about Demand Response participation.

Refer to Exhibit E-1 EfficiencyOne 2026 DSM Extension Application ("Application"), Appendix B, Figure 1, Average Rate and Bill Impacts (2026-2041) as a Result of DSM Activities in 2026 , page 4 of 24, line 1. EfficiencyOne explains Figure...

AI summary The text references a DSM Extension Application and requests clarifications about the impact of DSM investments on average rates and customer bills. It specifically asks about the interpretation of a forward-looking RBIA, the comparison between figures and tables, and the justification for higher rate impacts on certain rate classes.

Request IR-2: Refer to the Application, Appendix B, Figure 5: Average Bill Impact (2026-2041 as a Result of 2026 DSM Extension Activities on page 12 of 24, line 13. used to achieve this goal? - a) Please confirm that Figure 5 shows that th...

AI summary Request IR-2 seeks clarification on Figure 5 from Appendix B, which projects average bill impact reductions for SBA customer classes (Small General, General, Small Industrial) from 2026-2041. Questions address confirmation of projected decreases, EOne's methods to achieve investment/participation rates, a revised figure for 2025-2026, and the role of non-energy benefits in the projected savings.

Refer to the Application, Appendix B, Section 7. Conclusion, page 23 of 24 at line 21, where EOne states that "Maximizing customer participation in DSM programs mitigates rate impacts by increasing the number of customers who experience ne...

AI summary EOne asserts that maximizing customer participation in Demand-Side Management (DSM) programs reduces rate impacts by increasing net bill reductions. The proceeding questions EOne's confidence in achieving small business participation and whether other cost-reduction strategies beyond participation rates are being pursued.

23 Request IR-10: - 24 Please provide particulars of all changes to the modelling inputs referenced on page 16 (including - 25 lines losses, avoided costs, discount rates, annual energy savings, peak demand savings,

AI summary Request IR-10 asks for details on changes to modelling inputs, including line losses, avoided costs, discount rates, annual energy savings, and peak demand savings, referenced on page 16.

11 Reference: Appendix A, page 27, Table 8: 2026 DSM Extension Rate Class Expenditures. - 12 (a) Please provide a breakdown by program component of the proposed 13 expenditures for each of the Large Industrial and Medium Industrial 14 Clas...

AI summary The Nova Scotia Utility and Review Board requests detailed breakdowns of proposed and actual 2026 DSM expenditures for Large and Medium Industrial rate classes, including forecasted and actual costs, energy savings, and demand savings from 2023 to 2025.

21 Reference: Appendix A, page 28. Each year, spending by rate class is influenced by the mix of participating customers or program activity, particularly in the BNI sector, where the exact timing of project completions can be difficult to...

AI summary Annual spending by rate class is influenced by customer participation and project timing, especially in the BNI sector. E1 acknowledges the importance of reporting spending variances and is committed to improving reporting and ensuring program equity and access for all Nova Scotians.

- 25 (b) Please explain the "LED baseline changes in 2025" and why increased 26 rebates were required. 1 2 (c) Did E1 have data or information that suggested that consumers would not purchase LEDs absent higher incentives? If so, please pr...

AI summary The text requests explanations regarding the 'LED baseline changes in 2025' and the need for increased rebates, as well as data on consumer behavior, calculations for cost ratios, societal cost test values, and forecasted avoided costs for energy in the context of the DSM Plan.

7 Request IR-26: - 8 Reference: Appendix B, page 13 of 24, and pages 15-16 of 24. - 9 On page 13 of Appendix B, E1 states that: When examining non-participant bill impacts, it is important to note the broad reach of E1's point-of-sale reba...

AI summary Request IR-26 seeks data on participation rates in energy efficiency (EE) and demand response (DR) programs for industrial rate classes under the 2023–2025 and 2026 DSM Plans. It emphasizes that E1's rebate programs (Instant Savings, BER-IR) likely result in near-universal participation, affecting non-participant bill calculations (0.1–0.3% increases).

1 M12249 2 3 NOVA SCOTIA ENERGY BOARD 4 5 6 IN THE MATTER OF: The Public Utilities Act 7 8 – and – 9 10 IN THE MATTER OF an application by EFFICIENCYONE for approval of the 2026 11 DSM Extension for Demand-Side Management Activities 12 bet...

AI summary The Nova Scotia Energy Board is processing an application by EfficiencyOne for approval of the 2026 DSM Extension and amendment to a 2023-2025 Demand-Side Management Purchase Agreement with Nova Scotia Power Inc. under the Public Utilities Act. The Consumer Advocate has issued information requests to EfficiencyOne and their counsel, James Gogan, with responses due by June 25, 2025.

September 18, 2025 VIA EMAIL Ms. Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax NS B3J 3S3 Dear Ms. Henwood: Re: Ml2249 Application by EfficiencyOne for approval of the 2026 DSM Exten...

AI summary The Small Business Advocate (SBA) supports EfficiencyOne's (EOne) application to extend its 2023-2025 Demand-Side Management (DSM) plan through 2026, aligning with Nova Scotia Power's processes and recent legislative amendments to the Public Utilities Act . The SBA emphasizes the application's narrow scope, focusing solely on the 2026 extension rather than broader reforms.

Delivered by Email Crystal Henwood Regulatory Affairs Officer/Clerk Nova Scotia Energy Board 3rd Floor, 1601 Lower Water Street PO Box 1692, Unit "M" Halifax NS B3J 3S3 Dear Ms. Henwood: Re: M12249 - EfficiencyOne - 2026 DSM Extension Appl...

AI summary EfficiencyOne (E1) seeks approval to extend its 2023-2025 Demand Side Management (DSM) Plan to 2026 under amended Public Utilities Act provisions. The Industrial Group submits that while the legislative investment amount is fixed, the Board must still assess the plan's cost-effectiveness, savings targets, and spending allocation. E1 requests exemptions from Board directives requiring detailed cost-justifications and payback information for certain measures.

Rate Class Expenditures Below are the planned rate class expenditures for 2026:[3](#page-1-2) 2 Exhibit E-1, Evidence, page 5, line 19-21. 3 Exhibit E-1, Evidence, page 6. Rate Class 2026 ($ million) Residential/Charitable (2,3,4) 33.9 Sma...

AI summary The document outlines 2026 rate class expenditures across residential, industrial, and municipal sectors, totaling $63.75 million. E1 used 2022-2024 data and addressed concerns raised by the Industrial Group per the Board's direction. Key allocations include $33.9M for residential/charitable and $17M for general demand.

General The Industrial Group submits that while this application has been filed as a one-year "extension plan", it lacks the full consultative approach generally employed by E1 and E1 did not fulfill all the standardized filing requirement...

AI summary The Industrial Group criticizes E1's extension plan for lacking consultative approach and failing to comply with NSUARB directives on cost-effectiveness testing and data disclosure. E1's 'balanced plan' spending (51% residential, 49% BNI) contrasts with unbalanced energy savings (35% residential, 65% BNI). The Industrial Group supports E1's adoption of updated census data for equity spending but calls for DSMAG review of E1's planning framework.

Mid-Course Adjustments and True-Ups The Industrial Group has been expressing concerns with respect to E1's so-called "mid-course adjustments" by which E1 retains the discretion to shuffle spending between programs and customer classes. Whe...

AI summary The Industrial Group criticizes E1's mid-course adjustments for allowing program spending shifts between customer classes without quantifying 'substantial changes' or providing advance notice, despite Board-imposed 25% variance limits and commitments. E1 acknowledges shortcomings but outlines strategies to address concerns, citing historical data reliance and future allocation plans.

Conclusion The Industrial Group recommends that the Board: - 1. Take into consideration the cost-effectiveness results provided in relation to the program and/or measure level, in addition to the portfolio level, considering the requiremen...

AI summary The Industrial Group recommends the NSUARB consider cost-effectiveness at program and portfolio levels, engage DSMAG pre-2027-2031 plan filing, reject Mr. Peach's savings exclusion, mandate E1's comprehensive DR analysis, coordinate with NSPI on overlapping programs, and manage budgeted spending. E1 must address cybersecurity breach impacts and clarify Supply Agreement amendments.

4.7 INTRA-TERM VARIANCES - 23 The Industrial Group characterizes a 25% change in planned spending by program and customer class as a - 24 "substantial change" and asks the Board to direct tighter within-class controls. While E1 agrees that...

AI summary The Industrial Group argues a 25% spending variance in DSM programs requires tighter controls, but E1 (NS Power) warns this could hinder DSM portfolio management. E1 responded to concerns with enhanced reporting, including quarterly/year-end forecasts, variance explanations, and stakeholder engagement. The Board previously acknowledged E1's concerns about overly restrictive caps.

4.8 NS POWER AMENDMENTS TO SUPPLY AGREEMENT - 2 The extent to which any modifications to the existing Supply Agreement between E1 and NS Power are - 3 required due to changes to NS Power's DSM Rate Rider recovery period will be informed by...

AI summary NS Power may need to amend its Supply Agreement with E1 based on changes to the DSM Rate Rider recovery period, pending the Nova Scotia Energy Board's (NSEB) decision on the General Rate Application (GRA). E1 will collaborate with NS Power to revise the agreement if required, with the revised version submitted to the NSEB for approval. Until then, the agreement will remain unchanged for 2026 except for specific amendments requested in this application.

4.0 POSITION OF THE INTERVENORS

AI summary The section outlines the positions of intervenors in the regulatory proceeding. Key arguments focus on Demand-Side Management (DSM), Total Resource Cost (TRC), and Program Administrator Cost (PAC), with emphasis on rate design and cost methodologies. NS Power's role and program cost structures are central to the discussion.

4.1 Industrial Group [28] The Industrial Group argues that although the specific investment amount for the 2026 DSM extension has been prescribed by the legislation, the Board must still consider whether the proposed 2026 DSM Plan is in th...

AI summary The Industrial Group argues the Board must evaluate the 2026 DSM Plan's cost-effectiveness, ensure E1 manages spending reasonably, and address overlapping programs and cybersecurity impacts. It recommends engaging DSMAG, rejecting certain savings exclusions, and requiring detailed analysis for demand response programming. The group also urges E1 to address impacts from the NSPI cybersecurity breach and clarify tariff amendments.

4.2 Consumer Advocate [31] Green Energy Economics Group (Green Energy), the Consumer Advocate's Consultant, recommended the 2026 DSM extension be granted with the following modifications: • To ensure the same sector budget allocation is us...

AI summary The Consumer Advocate recommends granting the 2026 DSM extension with adjustments, including reallocating funds to the residential sector and ensuring proper cost-effectiveness and low-income participation in programs. Green Energy Economics Group supports these recommendations and advises against discontinuing savings verification for the Efficiency Insights program.

5.5 Mid-course Adjustments [67] The Industrial Group expressed concerns about E1's discretion to reallocate spending between programs and customer classes through "mid-course adjustments". The Industrial Group said E1 was granted this disc...

AI summary The Industrial Group raised concerns about E1's authority to make mid-course adjustments to DSM program spending, arguing that a 25% variance constitutes a 'substantial change' and requesting stricter budget management. E1 acknowledged not defining 'substantial change' but emphasized the need for flexibility, proposing enhanced reporting and spending management strategies. The Industrial Group opposed unfettered cost shifting between customer classes, citing impacts on customer rates.

5.5.1 Findings [73] The concerns raised by the Industrial Group are serious. The potential for E1 to proceed with relatively unrestrained changes to ensure it meets its own performance targets and objectives at the cost of hardship and pre...

AI summary The Board acknowledges concerns from the Industrial Group about E1's potential to prioritize its performance targets over ratepayer interests, particularly with DSM Plans reviewed every five years. The Board finds the current process unbalanced, requiring E1 to engage DSMAG and revise mid-course adjustment procedures in its DSM Plan application.

5.6 DSM Supply Agreement [74] This application includes amendments to the schedules in E1's existing Supply Agreement with NS Power. E1 said if changes to the Supply Agreement are required because of the outcome of NS Power's pending gener...

AI summary The application proposes amendments to E1's Supply Agreement with NS Power, contingent on the outcome of NS Power's pending general rate application. E1 committed to collaborating with NS Power to revise the agreement, which would then be submitted to the Board for approval.