Topic:"Rate Design" in M12282

1 Overall, the cost-effectiveness test is the primary assessment of a DSM Plan. A benefit-cost ratio threshold 2 of 1.0 or greater of a DSM Plan must always be satisfied at the portfolio level. While measures that do not 3 meet the ratio t...

AI summary The cost-effectiveness test is central to evaluating DSM Plans, requiring a benefit-cost ratio of 1.0 or higher at the portfolio level. While measures failing the TRC test may be included, E1 must justify their inclusion to align with the Balanced Plan Approach. The Board's 2022 Decision emphasizes that measure-level TRC tests could hinder future market development and equitable access, but measures failing TRC should be justified for strategic or long-term benefits.

Page 10 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence

AI summary The document presents the EfficiencyOne Benefit-Cost Analysis Test Application and includes evidence related to the proceeding. It outlines the analysis and evaluation of the EfficiencyOne program's benefits and costs.

smission • Distribution • General Gas Only Commodity Costs Not Included Non-Utility System Other Fuels All Not Included Host Customer All (costs and benefits) Costs Only Societal Resilience Not Included GHG Emissions Avoided Cost of Carbon...

AI summary The text outlines categories of costs and benefits considered in the EfficiencyOne Benefit-Cost Analysis Test Application, including distribution, gas commodity costs, host customer impacts, societal resilience, GHG emissions, and public health, with some categories included and others excluded from the analysis.

Page 29 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 • societal impacts (i.e., resilience, greenhouse gas emissions, other environmental and public 2 health). 3 4 These categories of N-USIs are further explained in...

AI summary The text discusses the societal impacts of EfficiencyOne's activities, including resilience, greenhouse gas emissions, and other environmental and public health factors. It also outlines the impact of changes in pipeline gas consumption, fuel oil, propane, and other fuels, based on commodity prices and their inclusion in the new BCA proposed by E1.

le 7: Other Fuel Impacts Other Fuel Description and Examples Inclusion in Discussion Notes Impacts new BCA Primarily electrification or efficiency displacing fossil fuels. Fuel and related O&M Commodity  Distributed Storage can be used costs...

AI summary The document discusses other fuel impacts, including the displacement of fossil fuels by electrification and efficiency, compliance costs for environmental regulations, and the market price effects of other fuels. These impacts are considered in the new BCA framework, with some factors deemed not material.

1 2. Review and discuss the consideration of utility system impacts in the Nova Scotia test. One 2 of the core principles of the NSPM is that to provide an accurate comparison of demand side 3 and supply side options, all utility system im...

AI summary The document discusses the consideration of utility system impacts and non-utility system impacts in the Nova Scotia test. It highlights the inclusion of avoided costs for energy, capacity, transmission, and distribution for the electric system, while gas system non-commodity impacts are not quantified. Non-utility impacts such as greenhouse gas emissions, air pollutants, and host customer costs are also addressed.

2024 Appearances on behalf of Conservation Law Foundation before the Rhode Island Public Utilities Commission and Energy Facilities Siting Board in regards Rhode Island Energy’s proposed portable liquified natural gas vaporization project...

AI summary The text outlines various legal and regulatory appearances and interventions by organizations and entities in different states, focusing on energy-related matters such as rate adjustments, project approvals, and merger reviews.

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AI summary The text discusses the regulation of energy and utility services in Nova Scotia, focusing on topics such as cost recovery, fuel adjustment mechanisms, and stakeholder engagement. It references various regulatory processes and considerations for energy efficiency and affordability.

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AI summary The text discusses the impact of a fuel-cost-adjustment mechanism on rate structures and the need for adjustments in rate design to account for delayed cost reflections. It also references the BCD and its influence on energy efficiency programs and policy considerations.

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AI summary The text discusses the impact of the fuel-cost-adjustment mechanism on rate structures and the need for adjustments in pricing models. It references the EfficiencyOne Benefit-Cost Analysis and mentions Nova Scotia Power and the Building Code Division as entities involved in the proceedings. The document highlights the importance of aligning base rates with actual costs and the role of regulatory oversight.

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AI summary The text discusses the analysis of fuel-cost-adjustment mechanisms and their impact on rate structures, including the role of efficiency programs and regulatory considerations. It references regulatory proceedings, cost recovery, and the evaluation of energy efficiency initiatives.

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AI summary The text discusses the regulation of energy efficiency programs and the analysis of cost-benefit for such initiatives, involving entities like EfficiencyOne and Nova Scotia Power. It references various regulatory proceedings and mechanisms, including fuel-cost-adjustment and rate-related considerations.

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AI summary The text discusses regulatory proceedings related to energy efficiency programs, cost recovery mechanisms, and the implementation of energy efficiency initiatives. It references the EfficiencyOne Benefit-Cost Analysis and Nova Scotia Power, emphasizing the importance of cost-effectiveness and program evaluation in the regulatory process.

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AI summary The text discusses the impact of the O75 mechanism on fuel-cost-adjustment and its influence on rate structures, including concerns about incentives and cost recovery. It also mentions regulatory considerations related to efficiency programs and compliance with standards.

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AI summary The text discusses the implementation and evaluation of the 456 program, including the use of benefit-cost analysis, efficiency measures, and regulatory considerations. It references the DEFG and mentions the role of Nova Scotia Power in the proceedings.

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AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on rate-setting, emphasizing the need for alignment between base rates and actual costs. It highlights the importance of regulatory oversight and the evaluation of mechanisms to ensure fair cost recovery and effective resource planning.

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AI summary The text discusses regulatory proceedings related to energy efficiency and cost recovery mechanisms, including the implementation and evaluation of fuel-cost-adjustment mechanisms and their impact on rate structures. It references the role of the Board in managing these processes and the importance of aligning cost structures with actual expenses.

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AI summary The document discusses the implementation of the fuel-cost-adjustment mechanism and its impact on rate structures, including concerns about incentives and the need for adjustments in the rate design. It also references the need for a review of the mechanism and related regulatory considerations.

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AI summary The text discusses the regulatory process, including the Board's fuel-cost-adjustment mechanism, the evaluation of energy efficiency programs, and the use of HIJ (a term possibly referring to a specific regulatory framework or initiative). It also touches on the impact of these mechanisms on affordability and the need for cost recovery.

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AI summary The document discusses the regulatory proceedings related to Nova Scotia Power's (NOP) fuel-cost-adjustment mechanism, including the evaluation of its impact on rates and the need for adjustments. It outlines the Board's consideration of PBQ (possibly a program or regulation) and its implications on cost recovery, stakeholder engagement, and the need for prudence reviews.

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AI summary The text discusses the implementation and impact of the ["] mechanism, emphasizing its role in energy regulation and cost management. It highlights concerns about delayed base rates and the need for adjustments to align with actual costs. The discussion also touches on the integration of various regulatory processes and the evaluation of energy efficiency programs.

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AI summary The text discusses various aspects of regulatory proceedings related to energy and utility management, including fuel cost adjustments, rate structures, and the impact of policies on energy efficiency and affordability. It also references legal and procedural matters within the regulatory framework.

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AI summary The text discusses the regulation of electricity rates and the management of energy efficiency programs in Nova Scotia. It highlights concerns about the alignment of base rates with actual costs, the role of the Board in managing fuel cost adjustments, and the evaluation of energy efficiency initiatives. The document also touches on the importance of stakeholder engagement and the impact of regulatory decisions on customers.

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AI summary The text discusses the regulation of fuel-cost-adjustment mechanisms, emphasizing the need for alignment between base rates and actual costs. It highlights the role of the ABC mechanism in addressing inefficiencies and ensuring fair cost recovery. The discussion includes the impact of regulatory decisions on utility operations and customer affordability.

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AI summary The text discusses the regulation of utility costs and the impact of mechanisms such as fuel-cost-adjustment and rate-setting processes. It references the role of entities like Nova Scotia Power and Affordable Bill Cap, and mentions topics such as cost recovery, rate design, and regulatory compliance. It also references specific regulatory matters and the need for alignment between cost structures and service delivery.

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AI summary The document discusses the implementation and implications of BCD (likely a regulatory measure or program), focusing on its impact on cost structures, program design, and compliance with regulatory standards. It highlights concerns about alignment with energy efficiency goals and the need for adjustments in program design and oversight.

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AI summary The document discusses the implementation and evaluation of the ST+ program, including its impact on energy efficiency, cost-effectiveness, and regulatory considerations. It highlights challenges in program design, such as ensuring fair cost distribution and addressing potential inefficiencies. The ST+ program is evaluated in relation to broader energy management goals and regulatory frameworks.

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AI summary The text discusses the implementation of the Affordable Bill Cap (ABC) and its implications for rate structures and customer affordability. It highlights concerns about the impact of delayed rate adjustments and the need for mechanisms that align with actual costs.

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AI summary The document discusses regulatory proceedings related to Nova Scotia Power (NSP) and the implementation of the Affordable Bill Cap (ABC). It addresses the need for adjustments in billing practices and the potential impacts on customers, including the use of standard test units (STU) and standard practice manuals (567). The text also outlines the importance of compliance with regulatory standards and the evaluation of energy efficiency programs.

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AI summary The document discusses the implementation of the LMN (likely a regulatory or energy-related initiative) and its impact on cost recovery and rate structures. It emphasizes the importance of aligning base rates with actual costs and the challenges posed by delayed rate adjustments. The text also touches on the role of stakeholder engagement and the need for effective regulatory oversight.

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AI summary The document discusses the regulation of energy costs, specifically addressing the implementation of fuel-cost-adjustment mechanisms and their impact on rate structures. It highlights the need for alignment between base rates and actual costs, as well as the role of regulatory oversight in ensuring fair pricing and compliance with energy efficiency standards.

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AI summary The document discusses the implementation and evaluation of the HIJ (likely a regulatory mechanism) by Nova Scotia Power (NSP) and its impact on rate structures, affordability, and compliance with regulatory standards. It also highlights concerns about the alignment of fuel costs with base rates and the need for prudence reviews.

5ÿ53@=D<ÿ766@=C9ÿA@;ÿ93:ÿ9:E8@;7Dÿ7C<ÿE7;L4C7DÿHIJÿ4E87695ÿ4Cÿ75ÿ E=63ÿ<:974Dÿ75ÿC:6:557;?ÿ9@ÿ;:AD:69ÿ93:5:ÿ:AA:695Oÿ _ÿa868ÿcb ÿÿ766 ÿbc fÿ23:;:ÿ7;:ÿ5@E:ÿ549=794@C5ÿ4CÿHIJÿoFp5ÿh3:;:ÿ7ÿHIJÿ B:C:A49ÿ:u8:;4:C6:<ÿB?ÿ@C:ÿ87;9?ÿ45ÿ:...

AI summary The text discusses the implementation and evaluation of HIJ mechanisms, including the impact of fuel-cost-adjustment and the role of HIJ in managing energy costs. It highlights concerns about the alignment of base rates with actual costs and the need for adjustments in energy pricing models.

tNXSTÿVOPSWXYÿ [+#'43ÿ4#+#'%)/!+ÿ i,#"ÿ%+1ÿ %'/%2"#ÿ†„ÿ \/$(ÿ ƒ‡ƒÿ#&/$$/!+$ÿ ƒ#+#'%)/!+ÿ0%.%0/)3ÿ <%.%0/)3ÿ #"/%2/"/)3ÿ )#'ÿ#+ /'!+&#+)%"ÿÿ [+ /'!+&#+)%"ÿ0!&."/%+0#ÿ [+ /'!+&#+)%"ÿ0!&."/%+0#ÿ #$/"/#+0#ÿ ˆ,2"/0ÿ#%")ÿÿ „%'(#)ÿ.'/0#ÿ#::#0)$ÿ...

AI summary The text discusses the implementation of various regulatory mechanisms, including the fuel-cost-adjustment, 9†Z, and ƒ‡ƒ, in the context of rate proceedings. It highlights concerns about the alignment of base rates with actual costs and the impact of these mechanisms on pricing and customer affordability.

?ÿ@GKD<ÿABACDEÿE;<=>?;@ÿFGACAÿ;?Jÿ@GKD<ÿ;LG>JDJÿFGACAZPÿO>CIÿD?GR=IÿAG@;<ÿ JDU@GBED?CTÿCI>AÿDHHDFCÿFGR@JÿWDÿ@;<=DÿD?GR=IÿCGÿAI>HCÿCIDÿUD;NÿUD<>GJÿH ?=ÿKID?ÿCIDÿAG@;<ÿ=D?D<;C>G?ÿJ>AA>U;CDAPÿ̀Aÿ;ÿ AÿUID?GED?G?TÿCIDÿ>EU;FCÿGCID<ÿ F>D?Cÿ;><ÿFG...

AI summary The text discusses the Fuel Adjustment Mechanism (FGH) and its role in Nova Scotia Power's (NSP) operations. It highlights concerns about the mechanism's impact on cost recovery and the need for adjustments to align base rates with actual costs. The discussion also touches on regulatory proceedings, including the evaluation of cost recovery mechanisms and the implications for rate design and affordability.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 107 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !ÿ"#$%"ÿ$"ÿ&''"($ÿ)" ÿ$+%,...

AI summary The text discusses the application of the EfficiencyOne Benefit-Cost Analysis Test and references the National Standard Practice Manual. It includes a review of the Fuel Adjustment Mechanism and its impact on cost recovery and affordability, as well as the role of Nova Scotia Power in regulatory proceedings.

ÿ"#"$%&ÿ"(() )"# &ÿ$"+,-$ "+ÿ ./01ÿ2/34567ÿ861270961ÿ5/6ÿ96:6;051ÿ3:8ÿ2<151ÿ=<15ÿ76>6?3:5ÿ5<ÿ6:67@Aÿ6;;0206:2AÿBCCDÿ761 >6:@61ÿI05/ÿCCÿ2<15J6;;6250?6:611ÿ3:3>A161Fÿÿ Kÿ+LMMNOPÿQRÿSTPÿUQVWXYÿÿ ZÿCCÿ761 E86ÿ562/:<><@061\ÿ167?0261\ÿ=631E761\ÿ...

AI summary The document discusses the Nova Scotia Power Fuel Adjustment Mechanism (FGH) and its impact on rate-setting and cost recovery. It highlights concerns about the mechanism's ability to accurately reflect fuel costs, the need for adjustments in rate design, and the implications for affordability and cost deferral. The text also mentions regulatory considerations and stakeholder engagement in the process.

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AI summary The document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the Fuel Adjustment Mechanism (FGH) and its implications, including the evaluation of efficiency programs and cost-benefit analyses within a regulatory context.

9?;2ÿD2:2/907.:Rÿ/9837:Dÿ52/B7A2ÿ0.ÿ8707D902ÿ/937@J509/0ÿ /2S47/282:05ÿ.:ÿD2:2/90./5<ÿ:.:JA.7:A7@2:0ÿ329Kÿ/2@4A07.:<ÿ;.A907.:9;ÿ329Kÿ/2@4A07.:5<ÿ9:@ÿ.012/5Fÿÿ T12ÿ64:@982:09;ÿUVLÿ3/7:A73;25ÿ@25A/7?2@ÿ7:ÿV19302/ÿWÿA9:ÿ?2ÿ452@ÿ0.ÿ7@2:076Cÿ01...

AI summary The text discusses the Fuel Adjustment Mechanism (FGH) and its role in adjusting fuel costs for Nova Scotia Power (NSP). It emphasizes the importance of aligning base rates with actual costs, the impact of the mechanism on rate structures, and the need for proper alignment of incentives and cost recovery. It also touches on the need for prudence in managing fuel costs and ensuring fair cost distribution.

KPLJÿJGÿ O=J=FHA>=ÿJ<=ÿKGP>J=FM?KJP?LÿW?@=LA>=ÿMGFÿ=@JAH?JA>BÿCDÿ@?RA>B@Sÿÿ _A@JGFAK?LÿKP@JGH=FÿLG?OÿE?JJ=F>@ÿK?>ÿW=ÿP@=OÿJGÿMGF=K?@Jÿ?ÿW?@=LA>=IÿWPJÿ AMAK?>JÿK<?>B=@ÿJGÿJ<=AFÿWPALOA>B@ÿGFÿM?KALAJA=@ÿJ<?Jÿ ?MM=KJÿLG?OÿE?JJ=F>@cÿKP@JGH=F@ÿH...

AI summary The text discusses the regulation of utility companies, focusing on the implementation of cost recovery mechanisms and the evaluation of rate structures. It outlines the importance of aligning base rates with actual costs, addressing issues such as fuel-cost-adjustment mechanisms and the need for prudence reviews to ensure fair and reasonable rates for customers.

!(= 'ÿ) ÿ,! &$'ÿ%+)=0'ÿ ÿ&'' %%'ÿ)!ÿ&ÿ(=/=0&$#-ÿ &%#%ÿ$)ÿ'$ /#!ÿ)- &00ÿ ()%$A""($#-!%%;ÿ M;ÿN0($ÿ&ÿ()!%#%$!$ÿ&!'ÿ 0#& 0ÿ/ $+)'ÿ") ÿ&00)(&$#!,ÿ1 ), &/ÿ()%$%;ÿN)/ ÿ !"#$%ÿ&!'ÿ ()%$%ÿ/&>ÿ ÿ'# ($0>ÿ&00)(& 0;ÿO) ÿP&/10.ÿ(&1&(#$>ÿ/& Q$ÿ % -&$#)!...

AI summary The text discusses regulatory proceedings related to energy efficiency and cost recovery mechanisms, referencing specific programs and regulatory frameworks. It outlines the role of energy efficiency initiatives, cost recovery, and the evaluation of programs such as DSM plans and energy efficiency resource standards.

ÿ"#$%&#'(%)"ÿ+),)&-%#.,ÿ&)$.(&/)$ÿ 0123ÿ4156789ÿ:83492;83ÿ718ÿ;8<8=273ÿ5<:ÿ4>373ÿ?>37ÿ98@8A5<7ÿ7>ÿ:23792;B78:ÿC8<89572><ÿDEFGÿ983>B9483HÿI7ÿ 2:8<72=283ÿJ8Kÿ=547>93ÿ7157ÿ5==847ÿEFÿ;8<8=273ÿ5<:ÿ4>373ÿ5<:ÿ69>A2:83ÿCB2:5<48ÿ><ÿ5::98332 ??><ÿ 4...

AI summary The document discusses the Board of Commissioners (BC) and the Board of Fuel Costs (BFC) in the context of a regulatory proceeding involving demand-side management (DSM) and energy standards (ES). It outlines the evaluation of fuel-cost-adjustment mechanisms, the role of energy efficiency programs, and the impact of these policies on rate structures and cost recovery.

G>ÿGQG=>MGÿ<:AÿG?MJK=:A>IJGKQÿ:K=>;A:=>ÿE>=L>>Aÿ=9>G>ÿMIH>Gÿ?AG=:A=:A>IJGKQUÿ[9?Gÿ FK>O?E?K?=QÿM:a>Gÿ?=ÿH?FF? =L>>Aÿ A>F?=GSÿ:AHÿKIG=ÿ;>P>AJ>GUÿC?FF>;>A=ÿCDÿ=:;?FFGÿ =;>:=ÿKI:Hÿ;>HJ<=?IAÿP>;GJGÿ>K><=;?<?=QÿB>A>;:=?IAÿH?FF>;>A=KQbÿ=9>;>FI;>...

AI summary The text discusses the Board of Commissioners' (BC) and Board of Fuel Costs (BFC) handling of fuel cost adjustments, including the use of CYZ and the implementation of various mechanisms for managing fuel costs and ensuring equitable distribution of expenses among stakeholders.

$0"%"ÿ$'-ÿ-,/"&%#$)-&ÿ!#$"%ÿ') ÿ3"ÿ$0"ÿ%#,"6ÿ3($ÿ4-!ÿ-$0"!ÿ4-!,%ÿ-4ÿ&"$ÿ 3) )&5ÿ$0"+ÿ') ÿ3"ÿ.)44"!"&$7ÿ :ÿ<-%$ÿ!"="&("%ÿ4!-,ÿ12ÿ!"%-(!"%ÿ') ÿ&-$ÿ"C"".ÿ$0"ÿ0-%$ÿ(%$-,"!ÿ-(&$"!4#$(# ÿ3) %ÿ-="!ÿ$0"ÿ 12ÿ$#!)44ÿ&"$$)&5ÿ/"!)-.7ÿ :ÿD4ÿ#ÿ12ÿ!"%-(!...

AI summary The text discusses the Board of Commissioners' (BC) evaluation of the 12th Demand Side Management (DSM) Plan and its implications on rate design and cost recovery. It highlights concerns about the alignment of base rates with actual costs, the impact of the fuel-cost-adjustment mechanism, and the need for a comprehensive review of the DSM Plan's effectiveness and fairness.

1(-%&ÿ=+-"+ÿ"#0)%ÿ -2G'" ÿ- .ÿ'/-)- 3ÿ #ÿG(#4-%!ÿ"!( '-$ÿ'$"-))'(3ÿ.!(4-"!.ÿ +' ÿ(!\0-(!ÿ-$[!" -#$.ÿ#,ÿ!$!(13ÿ(' +!(ÿ +'$ÿ=- +%('=')6ÿ XÿZ..02G -#$.ÿ(!1'(%-$1ÿ+#=ÿ +!ÿ-$ !("#$$!" -#$ÿG(#"!..ÿ'))#=.ÿ%-. (-/0 !%ÿ. #('1!ÿ #ÿ0 -)-]!ÿ 0$0.!%ÿ-$...

AI summary The text discusses the implementation and evaluation of a fuel-cost-adjustment mechanism and its impact on rate structures, including the need for adjustments to align base rates with actual costs, and mentions regulatory considerations and stakeholder engagement in the process.

ÿN= ÿBGÿBJAÿMK;PHÿA?A>BK;S;>=B;G<ÿI;??ÿPA>KA=DAÿA?A>BK;>ÿDRDBANÿ Bÿ>=<ÿTAÿKAPU>APÿBJKGUMJÿ^Y_ÿ;Bÿ>=<ÿ TAÿA?;N;<=BAPÿGKÿN=PAÿ =Z=T;?;BRÿGSÿ abÿc Dÿ;DÿUB;?;dAPXÿ[eAAÿFJ=ZBAKDÿfÿ= Aÿ c?A>BK;S;APÿTU;?P; BÿA?A>BK;>ÿDRDBANÿKAD;?;A<>A_ÿc Dÿ hÿ S[...

AI summary The text appears to be a portion of a regulatory proceeding document, likely involving discussions on energy efficiency, cost recovery, and regulatory processes. Key terms such as 'affordability' and 'rate-design' are referenced, suggesting the document deals with regulatory decisions and policies in the energy sector.

!+ÿ!ÿ $+5#-ÿ/1ÿ 3- 0103!-0/,ÿj0##ÿ#/j$ ÿ7! m$-ÿ3#$! 0,4ÿ) 03$+ÿj.$ $ÿ-.$ $ÿ! $ÿ $-0-0n$ÿj./#$+!#$ÿ7! m$-+8ÿ c0,!,30!#ÿt,3$,-0n$+ÿp$848:ÿ $"!-$+qÿ hÿ r /4 !7ÿi270,0+- !-0/,ÿk/+-+ÿ hÿ pi$ÿ834/8+ÿ1-/ÿ- /ÿ,ÿ/! .5$ ! ÿ#1ÿ45!$+#ÿÿ+,6/+,-$')7+ ÿ/...

AI summary The text discusses regulatory proceedings related to energy and utility matters, focusing on the analysis of fuel-cost-adjustment mechanisms and their impact on rate structures and affordability. It also touches on the evaluation of programs and customer-related initiatives.

;6<>@7Pÿ !"!"ÿ_3 abÿcda)ÿef2'g3hÿ X:9;<=>?>;6<>@7ÿA967BÿBCDB<> 7EÿI>P9PVÿ>7;=96B>7EKÿ9:9;<=>;><8ÿ ;@7BCAJ<>@7ÿ?@=ÿ @7ÿ@?ÿ@ ::ÿ X:>l:99;:8<=ÿ><?@>;ÿD69<>ÿ@F79ÿ9A9 6BC=9Bÿ6=9ÿ >7;=96B9ÿ9:9;<=>;ÿB8B<9Aÿ;@B D:9ÿ9i;9J<>@7ÿ@?ÿXYBÿ 9??9;<>O9ÿ@7:8...

AI summary The text discusses regulatory proceedings related to rate-setting and cost-recovery mechanisms, referencing specific processes and evaluations involving fuel-cost-adjustment and energy-efficiency programs. It highlights challenges with base rates lagging actual costs and the need for regulatory oversight and prudence reviews.

-.!&7ÿ%#ÿ-" 1&ÿ 8ÿ#5#4,!4ÿ#&#,7@ÿ%-ÿ&##:.ÿ ÿ9#ÿ+, :14#:ÿ -&:ÿ9@ÿ-::!&7ÿ ÿ#5#4,!4ÿ.@.#"ÿ-&: ,ÿ?a'ÿ.@.#"ÿ+#-Gÿ:#"-&:./ÿÿ ?%#ÿ#H#&ÿ ÿ$%!4%ÿ!&4,#-.#:ÿ4 &.1"+! &ÿ 8ÿ#5#4,!4ÿ#&#,7@ÿ-::.ÿ4 .ÿ ÿ%#ÿ.@.#"ÿ$!55ÿ9#ÿ:,!;#&ÿ9@ÿ-ÿ ;-,!#@ÿ 8ÿ8-4 ,.ÿ!&451:...

AI summary The document discusses the regulatory proceedings related to Nova Scotia Power's (NSP) fuel-cost-adjustment mechanism and its implications. It addresses the need for aligning base rates with actual costs, the impact of the mechanism on incentives, and the evaluation of cost recovery and rate design.

efit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ ÿ"#$ÿÿ &'(')" +,-ÿ ( ./-"-ÿ ), ÿ01." .'ÿ2' ÿ/ '-ÿ 34564758ÿÿ 9:;<ÿ=>?@ÿABÿ@:CÿD>EF>Gÿ;EHGFIC<ÿBAF?ÿH:>=@C?<ÿ>II?C<<;EJÿI;BBC?CE@ÿK>L<ÿABÿHADM;E;EJÿDFG@;=...

AI summary This document discusses the National Standard Practice Manual in the context of a cost analysis test application. It outlines various aspects of cost analysis, including fuel-cost-adjustment mechanisms, rate design, and the application of standard practices in regulatory proceedings. The text references different scenarios and considerations relevant to energy regulation and cost management.

ÿ!"#$%&#'ÿ) +,%$'ÿ-'.,ÿÿ /0ÿ1234ÿ561417ÿ89:;:9:417ÿ5819234<17ÿ60=>2<ÿ9?:<=@A6<9:41ÿ36Bÿ144Cÿ92ÿ:0196;;ÿ38;9:A;4ÿ20@1:94ÿDEF17ÿG?:5?ÿ 36Bÿ96C4ÿH2<3ÿ69ÿ9?4ÿI8:;=:0J7ÿH65:;:9B7ÿ563A817ÿ2<ÿ04:J?I2<?22=ÿ;4K4;LÿM?:1ÿ5?6A94<ÿ=415<:I41ÿ?2Gÿ92ÿ ?2;...

AI summary The document discusses the regulatory considerations surrounding the implementation of DEF (Demand-side Management) programs, including their impact on utility operations, cost recovery, and the need for stakeholder engagement. It highlights the importance of aligning rate structures with program objectives and ensuring that these programs are effectively managed and evaluated.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 183 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"#$%&ÿ'()$ +%ÿ ,-.ÿ'(/%01...

AI summary The text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the methodology for evaluating benefit-cost analysis, including the use of standard practices and the importance of proper application of these methods in regulatory proceedings.

ÿ23ÿ/4%ÿ#%!Gÿ+%"!(+ÿ2(ÿ/4%ÿ01'+6ÿ'(+')!/'(0ÿ/4!/ÿ/4%'1ÿ '(/%1)2((%)/'2(ÿ!(+ÿ'(/%1!)/'2(ÿ9'/4ÿ/4%ÿ01'+ÿ'&ÿ(2/ÿ2($8ÿ'"#21/!(/ÿ7 /ÿ#2/%(/'!$$8ÿ"21%ÿ)2&/5%33%)/'@%ÿ /4!(ÿ1%&'+%(/'!$ÿ- .ÿ'(/%01!/'2(ÿ+ %ÿ/2ÿ/4%ÿ&)!$%ÿ23ÿ01'+ÿ& ##21/ÿ/4!/ÿ/4%8ÿ)2...

AI summary The text discusses the regulatory challenges and considerations related to the fuel-cost-adjustment mechanism and its impact on rate structures and financial planning. It references proceedings and evaluations concerning the alignment of base rates with actual costs and the implications for stakeholders.

ÿ+-ÿ1'+'4($,%ÿ(+ÿ ($("+ÿ$"ÿ0)'$(+/ÿ+'9ÿ5 #'ÿ,$)'?,ÿ+-b")ÿ5 #'ÿ )" ",($("+,3ÿÿ B",$:'44'0$(5'+',,ÿ+ !,(,ÿ,&"# -ÿ0"+,(-')ÿ9&'$&')ÿ?# $( 'ÿ"+:,($'ÿ;=>,ÿ)'ÿ1,'-ÿ"+ÿ'.(,$(+/ÿ )',"#)0',ÿ")ÿ )"/)?,%ÿ9&')'ÿ(+0)'?'+$ ÿ1'+'4($,ÿ+-ÿ0",$,ÿ0+ÿ1'ÿ '5')/...

AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on incentives and costs. It outlines various aspects of the mechanism, including its structure, objectives, and implications for stakeholders. It also references regulatory proceedings and related entities.

=QP=77ÿ7@K>JÿŸkÿ:=9=J>;8@9ÿIJ@Gÿ ;<=ÿ?F8KE89:Oÿ>9EÿE87P<>J:=7ÿEFJ89:ÿ7S7;=GÿH=>ŒTÿ žÿ efÿ7<8I;7ÿK@>EÿIJ@Gÿ@9VH=>Œÿ7S7;=Gÿ<@FJ7ÿ;@ÿ@IIVH=>Œÿ7S7;=Gÿ<@FJ7Tÿÿ žÿ C@K>Jÿ<=KH7ÿG==;ÿ@9V78;=ÿPF7;@G=JÿK@>EOÿR8;<ÿ>9Sÿ=QP=77ÿ:=9=J>;8@9ÿ?=89:ÿF7=Eÿ;@ÿ...

AI summary The document discusses the regulation of energy costs and the mechanisms in place for adjusting fuel costs, including the impact of these mechanisms on pricing and the need for alignment between base rates and actual costs. It also outlines various proceedings and reports related to energy regulation and policy.

!ÿ#$#%&'() ÿ $,-.'$# ÿ /01210134ÿ567ÿ8093:4ÿ48;301;34ÿ433<ÿ08ÿ1640522ÿ;=201>23ÿ?@Aÿ0B>34ÿ16ÿ5ÿ4>3C1D1CÿE38E:5>91Cÿ5:35ÿD8:ÿ093ÿ >=:>843ÿ8Dÿ73D3::16Eÿ8:ÿ5F81716Eÿ63Gÿ16F340;3604ÿ16ÿ7140:1H=0186ÿ8:ÿ0:564;144186ÿ4B403;4IÿJ914ÿC95>03:ÿ 734C:1H...

AI summary The text discusses the role of MNO in Nova Scotia's energy regulatory process, including its function in cost recovery, fuel cost adjustment mechanisms, and the impact of regulatory decisions on energy pricing and customer affordability. It also highlights the importance of stakeholder engagement and the evaluation of energy efficiency programs.

!"ÿ)$!5ÿ,%(,ÿ-"-$(3ÿ!+#ÿ,!'$+ÿ#!ÿ2!^-$ÿ!+#ÿ,!'$+8ÿ~#,-$ÿVkl+ÿ+',ÿ +ÿkkÿ "4ÿV‚ÿ "ÿ 2+!ÿ 6$!7%4-ÿ-"-$(3ÿ&-"-)%#+.ÿ%"ÿ 44%#%!"ÿ#!ÿTUVÿ "4ÿ+3+#-5ÿ6- dÿ+ 7%"(+8ÿÿ ]"ÿ/01ÿ "ÿ%"2'4-ÿ ÿ+%"(2-ÿVkl.ÿ&'#ÿ/01+ÿ5!$-ÿ!55!"23ÿ%"2'4-ÿ5'2#%62-ÿVkl+8ÿ]"ÿ/01...

AI summary The text discusses the implementation and impact of the fuel-cost-adjustment mechanism and the TUV (Test User Value) mechanism in Nova Scotia's regulatory proceedings. It highlights concerns about the alignment of base rates with actual costs and the influence of these mechanisms on pricing and incentives.

,ÿ a7 %,$̀ ÿ9"ÿ , ÿ f4":ÿ+!ÿ 0"& ÿ a$,+$%&ÿ+0"$% #ÿ1!%+0"1+!0,ÿ6$+)ÿ+ 1)%!!&=ÿ"%#ÿ14,+!2 0ÿ a7 0+$, 5ÿ0 "+$!%,)$7,ÿ6$+)ÿ+0"# ÿ"$ ,5ÿ2"0g +$%&ÿ2"+ 0$",5ÿ +1'5ÿ+!ÿ840+) 0ÿ0 104$+ÿ14,+!2 0,ÿ$%+!ÿ"%ÿ a$,+$%&ÿ70!&0"2'ÿh!6 05ÿ$+ÿ$,ÿ",!ÿ$27!0+"%+...

AI summary The text discusses regulatory proceedings related to energy efficiency and cost recovery mechanisms, including the role of the E(> in managing fuel costs and the impact of the -./ on utility operations. It references various regulatory frameworks and processes for energy management and compliance.

%#"!&,ÿ'%.ÿ ),&,ÿ)"ÿGH?,ÿ,+)10.ÿ=#ÿ#,&!6'&#.ÿ1,!%2ÿ,1""! !#%&ÿ0) '&!)%'0ÿ'%.ÿ&#6()$'0ÿ .#&'!0ÿ&)ÿ'.#I1'&#0/ÿ$#($#,#%&ÿ&+#ÿ:;ÿ)(#$'&!%2ÿ('&&#$%,ÿ'%.ÿ )%,#I1#%&ÿ=#%#"!&,ÿ'%.ÿ ),&,8ÿÿ JKLMLKÿOPPQRSTUSVÿXQYÿZ[TUQSÿ]^R_ÿ]S ÿa_T_YbUSUSVÿcYQd_PTÿ...

AI summary The text discusses the regulation of energy costs and the role of the Nova Scotia Power (NSP) in managing fuel costs and ensuring equitable distribution of energy resources. It highlights the importance of adjusting rates to reflect actual costs and the need for proper oversight in energy management.

ÿ@#)N &'$@#&#ÿFGHÿ#(=)?0#%&ÿ!% $#',#,ÿI!==ÿ-#ÿ0#',.$#ÿ")$ÿ ),&,5ÿÿ K)$ÿ#/'0(=#<ÿ )%,!#$ÿ'ÿ,.-,&'&!)%ÿ.(@$'#ÿ&+'&ÿI',ÿ")$# ',&ÿ&)ÿ-#ÿ%###ÿ"!1#ÿ?#'$,ÿ"$)0ÿ%)I5ÿJ+#ÿ ")$# ',&ÿI',ÿ-',#ÿ)%ÿ+!,&)$! '=ÿ=) '=!l#ÿ=)'ÿ@$)I&+ÿ.$!%@ÿ'ÿ&!0#ÿI+#%ÿ,?,&#0...

AI summary The text discusses the implementation and implications of the fuel-cost-adjustment mechanism in Nova Scotia, focusing on its impact on rate structures, cost recovery, and regulatory proceedings. It references the role of the Board in evaluating cost-effectiveness and prudence reviews, as well as the use of efficiency programs and regulatory oversight.

!ÿ)(#$'&)$ÿ'%ÿ&+#ÿ .,&)0#$,ÿ ,#$1#5ÿJ+#ÿ1'$!'-!=!&?ÿ'%ÿ!%&#$0!&&#%&ÿ%'&.$#ÿ)"ÿFGH,ÿ '%ÿ' ÿ@$#'&#$ÿ.% #$&'!%&?ÿ!%&)ÿ=)'ÿ")$# ',&!%@ÿ '%ÿ)(#$'&!)%ÿ)"ÿ&+#ÿ,?,&#05ÿx&!=!&!#,ÿ0'?ÿ&+.,ÿ(#$ #!1#ÿ'ÿ$!,>ÿI+#%ÿ$#=?!%@ÿ.()%ÿFGH,ÿ&)ÿ0##&ÿ'ÿ,?,&#0ÿ %##...

AI summary The text discusses the application of the FGH mechanism and its implications on cost recovery and rate design, highlighting the need for alignment between base rates and actual costs to avoid perverse incentives.

&'"ÿ /,)+)-7ÿ0&'/$'%,-&ÿ'&9!)'&%&-#"ÿ,'&ÿ )//)!+#ÿ#$ÿ0'& )#ÿ,- ÿ9!,-#)/.2ÿZ$'ÿ&S,%0+&6ÿ!"#$%&'"ÿ 0,'#))0,#)-7ÿ)-ÿ?Aÿ0'$7',%"ÿ,'&ÿ$/#&-ÿ)-&-#)1)[& ÿ#$ÿ0,'#))0,#&6ÿ58)+&ÿ-$#ÿ,"ÿ%,-.ÿ!"#$%&'"ÿ'&&)1&ÿ 0&-,+#)&"ÿ/$'ÿ/,)+)-7ÿ#$ÿ%&&#ÿ$%%)#%&-#"2ÿ...

AI summary The text discusses the implementation of the :;< and QRG in Nova Scotia, highlighting their role in energy efficiency and cost management. It references the ?@A and its impact on fuel-cost-adjustment mechanisms and rate design, emphasizing the need for alignment between policy and operational practices.

!ÿ#$#%&'() +&ÿ+&-ÿ./-%0/1 /#ÿ 2345ÿ63789:;ÿ8;<=4>:5ÿ?@4>7A6:ÿ 4A?ÿ?@4>7A6:ÿ ÿF<;ÿ7CCÿHIJÿ9D8:5Lÿÿ Zÿ\Aÿ7A7CDE4A?ÿ8<;9F 4A?ÿ:A7]C4A?ÿ:FF:695Kÿ57=4A?5ÿ:FF:695Kÿ7A>ÿ7=<4>:>ÿ6<59ÿ :FF:695Lÿ Zÿ\Aÿ7A7CDE4A?ÿ8<;9F 4=:;5:ÿ;7A?:ÿ ÿ7=<4>ÿ @A;:75 ÿ]D...

AI summary The text discusses the implementation and evaluation of the HIJ (Demand-Side Management) program by Nova Scotia Power (NSP), including its impact on cost recovery, program design, and regulatory considerations. It highlights concerns about program effectiveness, compliance, and alignment with regulatory standards.

Vÿ!&ÿ!"# /'+;ÿ '+ÿZ# .##+<ÿc]##ÿ]#) '!+ÿd ?mÿnCFGopLFEMGÿJKKGLFDÿ S'RR#&#+ ÿSTUÿ -9#ÿ),+ÿ/,:#ÿ'+ #&,) ':#ÿ#RR#) ÿ!+ÿ#,)/ÿ! /#&Vÿ'+)P%('+;ÿ#RR#) ÿ!+ÿ,:!'(#(ÿ)! ÿ,+(ÿ #RR#) ÿ!+ÿYO/ÿ!&ÿYOÿ'"9,) Vÿ,+(ÿ#+,ZP'+;ÿ! /#&ÿSTU<ÿ8/##ÿ'+ #&,) ':#ÿ#RR#)...

AI summary The text discusses the STU (possibly a regulatory body or process) and its role in managing demand-side management (DSM) programs, including the evaluation of benefit-cost analysis tests and the impact of STU on energy efficiency initiatives. It highlights the need for proper alignment between rates and costs, as well as the evaluation of DSM programs.

7ÿ$4ÿ!77%77ÿ( \ÿZ!69%bÿ5#869&5#;ÿ !#!6@757ÿ4:ÿ648!$54#^7>%85:58ÿ( \ÿZ!69%ÿ!#&ÿ84#75&%"!$54#ÿ4:ÿ&5::%"%#$ÿ( \ÿ749"85#;ÿ<%8A!#57<70ÿÿ gQKTLJÿBChBDÿiUjkMLQRUHÿUlÿmLMNQIQUHMWÿPQRILQSTIQUHÿVWMHHQHKÿIUÿGHIJKLMIJNÿPQRILQSTIQUHÿVWMHHQHKÿ ÿ 278 nÿ...

AI summary The text discusses fuel-cost-adjustment mechanisms and their impact on rate structures, highlighting the need for alignment between base rates and actual costs. It also touches on the importance of regulatory oversight and prudence reviews in managing energy resources and ensuring fair pricing for customers.

GH@ ÿ#"2ÿ#"ÿ%"-&$1ÿ&+ !$ÿ! &$+ ÿ%"(32%")ÿ'$&)$#1ÿ2! %)"ÿ#"2ÿ1&$!ÿ# 3$#+!ÿ'$%%")ÿ %)"#( 5ÿ 6ÿ278 ÿ387Iÿ28I :ÿJ+%(%+%! ÿ#"ÿ &3$!ÿ !$4%! ÿ-$&1ÿ./0 ÿ+ $&3) ÿ#ÿ&1,%"#+%&"ÿ &-ÿ1! #"% 1 ÿ%"(32%")ÿ'$&)$#1 Kÿ'$&3$!1!"+Kÿ#"2ÿ'$%%")5ÿL&#+%&"...

AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on rate structures, including the need for adjustments to align base rates with actual costs. It also references the EfficiencyOne Benefit-Cost Analysis Test Application and the National Standard Practice Manual as supporting documents.

@79D?:ÿ7ME?@QÿX8?:?C9:?OÿB7ÿDAMÿP?ÿ=?G?@@A:Mÿ 79ÿA=AFMt?ÿ78?ÿ:A7?ÿBDEAG7@ÿC9:ÿ>BCC?:?=7ÿG;@79D?:ÿ@?G79:@Qÿu9=>;G7B=<ÿAÿ:A7?ÿBDEAG7ÿA=AFM@B@ÿC9:ÿ?a?:Mÿ G;@79D?:ÿGFA@@ÿB@ÿE:9PAPFMÿ799ÿP;:>?=@9D?ÿA=>ÿ=97ÿ=?G?@@A:MQÿZ=@7?A>OÿA=AFM@?@ÿGA=ÿP?ÿG9...

AI summary The text discusses the analysis of a regulatory proceeding in Nova Scotia, focusing on topics such as fuel-cost-adjustment mechanisms, rate design, and cost recovery. It emphasizes the importance of aligning base rates with actual costs and the implications of delayed rate adjustments.

53ÿ45A716145?79Bÿ^5A71614571;?ÿA5789ÿ65?ÿ529;ÿ >8ÿ<98=ÿ7;ÿ6;345A8ÿ45A71614571;?ÿ56A;99ÿHIJÿ1?171571E89GÿHIJÿ7D489Gÿ56A;99ÿ<71217189Gÿ5?=ÿ56A;99ÿ _ 8ÿ89713578=ÿ@;Aÿ856:ÿD85Aÿ;@ÿHIJÿ1342838?7571;?Bÿ̀:8Dÿ9:;<2=ÿ>8ÿ6;345A8=ÿ 56A;99ÿ35?DÿD85A9ÿ...

AI summary The document discusses the role of HIJ in the context of rate-setting and regulatory processes, focusing on the implementation of fuel-cost-adjustment mechanisms and their impact on cost recovery and affordability. It also touches on the evaluation of programs and the importance of transparency and stakeholder engagement in regulatory decisions.

!"#$ÿ&'ÿ) +,-ÿ./01ÿ),2+3ÿ 4567ÿ899:;<6=ÿ9>?@6<:7ÿ:=8A9B:ÿC:A9B8C:ÿC8DB:7ÿC58CÿEF>67<6GC6?;7ÿG8;ÿF7:ÿC?ÿC8H:ÿ6;@:;C?>Iÿ?JÿC5:6>ÿ 899B6G8DB:ÿ9?B6G6:7ÿK?8B7ÿ8;<ÿ?DE:GC6@:7ÿ8;<ÿC?ÿ5:B9ÿ6<:;C6JIÿ>:B:@8;CÿD:;:J6C7ÿ8;<ÿG?7C7ÿC?ÿ6;J?>Aÿ <:@:B?9A:;...

AI summary The text discusses the regulatory proceedings related to energy efficiency and cost recovery mechanisms, including fuel-cost-adjustment, rate-design, and the impact of these policies on affordability and customer service. It references the Nova Scotia Power (NSP) and the role of the regulatory board in overseeing these processes.

0Gÿ4,-ÿG?440-0C.ÿA0D0A3ÿ,4ÿ<11A?E<.?,C;ÿ- ÿD ÿD ÿ.,ÿ<ÿ1-,=>;ÿ./0-0ÿ@<>ÿF0ÿ<ÿ.- ÿ IÿJ-,=?03ÿ./<.ÿ<-0ÿ@,-0ÿG0.<?A0Gÿ<-0ÿA?N0A>ÿ.,ÿ@,-0ÿ ÿ-01-030C.ÿ./0ÿ@ ÿ.,ÿ-0B2?-0ÿ@,-0ÿ ?C4,-@<.?,Cÿ ÿ<-0ÿ@,-0ÿ.- ÿ32E/ÿ<3ÿ?@1-,D0Gÿ/0 ;ÿ<11A?0Gÿ .,ÿ-03?G0C.?...

AI summary The text discusses the implications of the fuel-cost-adjustment mechanism and its impact on cost recovery and rate design, highlighting concerns about delayed rate adjustments and the need for alignment between base rates and actual costs. It also touches on the role of regulatory oversight and the importance of accurate forecasting and prudence reviews.

PÿfWTVUTÿq\VQUÙVUp̀TÿeVUVÿvPWÿv\U\WTÿVQV[X]T]ÿ w)/-0?+ÿ3::)-ÿ ÿI, 5/0/ /04)ÿD Eÿ/3ÿ ++)++ÿ/9)ÿ)8/)5/ÿ3:ÿ ÿ>)5):0/ÿ3-ÿ?3+/Fÿ05ÿ/9)ÿ >+)5?)ÿ3:ÿ(35)/ -Eÿ 4 .,)+ÿ:3-ÿ/90+ÿ1,-13+)Cÿr3-ÿ)8 (1.)Fÿ0:ÿ/9)ÿ,/0.0/Eÿ=3)+ÿ53/ÿ(35)/0<)ÿ+ :)/EFÿ-)+0.0)5...

AI summary The text discusses the need for adjusting fuel costs and the implications of base rates lagging behind actual costs. It highlights the importance of aligning rates with current fuel costs and mentions the role of regulatory processes in addressing these issues.

ÿ) ;' .% )1>ÿ( $,<&.3 )1>ÿ."/ÿ %2 )ÿ 1%.3 2 / )1ÿ 1%$&. % ÿ."/ÿ/ ,'& "%ÿ7'."%$#$ /ÿ$&(.,%1ÿ #ÿZ[:ÿ() ;).&1>ÿ( $,$ 1>ÿ."/ÿ$" 1%& "%1ÿ$"ÿ %2 $)ÿ\')$1/$,%$ "15ÿÿ ]^ LMNKOPGÿEJÿ_NFMOQFPÿ̀SaGÿ b 1%ÿ) 1 .),2ÿ "ÿ$&(.,%ÿ7'."%$#$,.%$ "ÿ% ÿ/.% ÿ Y$1...

AI summary The text discusses regulatory proceedings related to Nova Scotia Power's energy and utility practices, including fuel-cost-adjustment mechanisms, demand-side management, and the impact of regulatory decisions on cost recovery and affordability. It also references specific regulatory frameworks and stakeholder engagement in the process.

!"#$ÿ&'ÿ) +!,#!-ÿ./ ÿ0 +12,+ÿ 3456ÿ7889:;5<ÿ8=>?5;96ÿ@A5;7:B9ÿ>:ÿ4>CÿD>ÿ8=969:Dÿ=96AED6ÿ5:ÿC7F6ÿD47Dÿ7=9ÿG>6Dÿ5:H>=G7D5?9ÿ7:;ÿG>6Dÿ A69HAEÿ5:ÿG7I5:@ÿB>6DJ9HH9BD5?9:966ÿ;9B565>:6KÿLDÿ7E6>ÿ8=>?5;96ÿ@A5;7:B9ÿ>:ÿ4>CÿD>ÿ8=969:Dÿ=96AED6ÿD>ÿ 6A88...

AI summary The text discusses the regulation of Nova Scotia Power (NSP) and the challenges related to the NOP (likely a regulatory mechanism or program), including the impact of fuel cost adjustments and the need for aligning rates with actual costs. It also touches on the importance of ensuring fair and effective energy efficiency programs and regulatory oversight.

ÿ,# ÿ+.%$%ÿ,"!ÿ #+-/ ! ÿ #ÿ$)!ÿ+.%$%ÿ."ÿ.#!ÿ234ÿ$90!6ÿ$)!#ÿ$)!9ÿ%)./- ÿ7!ÿ #+-/ ! ÿ."ÿ, ÿ234ÿ$90!%'ÿ BCDEFGÿIJKLÿMNOPQRGÿSFGTGUVOVCWUÿWXÿYGUGXCVJZWTVÿ[OVCWT\ÿ]^QWV_GVC̀ORÿaERVCQRGÿIM[Tÿ ÿ ()!ÿbc4ÿ !$" +ÿ0".8 !%ÿ 0."$,#$ÿ #." ,$ .#ÿ$),$ÿ %ÿ...

AI summary The text discusses the challenges and considerations in setting rates and managing costs, including the use of mechanisms like fuel-cost-adjustment and the impact of delayed base rates on incentives. It also touches on the importance of accurate forecasting and the role of regulatory oversight in ensuring fair and effective energy management.

S>ÿ5YY>7??BTcÿB6VSQ?>ÿSTAÿUC7TÿB?ÿB>ÿT5?aÿbC7ÿ>7Q?B5T>ÿSY?7Dÿ?CS?ÿAB>Q@>>ÿ>7h7DSeÿ7XS6Ve7>ÿ5YÿB6VSQ?>ÿ?CS?ÿ SD7ÿ>567?B67>ÿQ5T>BA7D7Aÿ5YY>7??BTcÿB6VSQ?>ÿSTAÿVD5hBA7ÿc@BASTQ7ÿ5TÿC5Uÿ?5ÿA7?7D6BT7ÿUC7?C7Dÿ?C7Wÿ >C5@eAÿR7ÿBTQe@A7Aÿ5Dÿ7XQe@A7AÿB...

AI summary The text discusses regulatory proceedings involving energy programs and policies, including the Yukon Energy Program (YBZ), Low-Income Energy Assistance Program (LML), and Benefit-Cost Analysis (BCD). It references the Clean Energy (CDE) initiative and Nova Scotia Power (NSP), highlighting topics such as mandatory net output (MNO) and regulatory processes related to energy programs.

!(%!(#ÿ""$(ÿ($H%!$#ÿ(ÿ!'$(ÿ", % &,%1ÿ, 70&$+$ !#ÿ!ÿ 6%(!,&,6%!$ÿ, ÿ cdÿ6(-(%+#)ÿJ++ ÿ$e%+61$#ÿ, &107$ÿ, &$ !,E$#ÿ"(ÿ$"",&,$ &Cÿ+$%#0($#ÿ(ÿ"(ÿ %-($$+$ !#ÿ!ÿ6%(!,&,6%!$ÿ, ÿ dÿ6(-(%+#)ÿfg$$ÿJ'%6!$(ÿh)iÿ j'$ÿ&#!ÿ"ÿ%ÿ", % &,%1ÿ, &$ !,E$ÿ,#ÿ$e6$...

AI summary The text discusses the implementation and evaluation of the cd mechanism, focusing on its impact on rate structures and cost recovery. It highlights concerns about misalignment between base rates and actual costs, and the need for adjustments to ensure fairness and accuracy in billing practices.

mÿiFGÿMQRJRHQJNÿQRHGREQXGÿDFIPNYÿZGÿQRHNPYGYÿQRÿEFGÿjfdÿEGDEÿJDÿJÿPEQNQE[ÿD[DEG^ÿHIDEAÿiFGÿ FIDEÿHPDEI^GLÿQ^KJHEDÿDFIPNYÿQRHNPYGÿIRN[ÿEFGÿKILEQIRÿIMÿEFGÿ^GJDPLGÿHIDEÿKJQYÿZ[ÿEFGÿFIDEÿHPDEI^GLAÿ %(oÿ456ÿ1#2q028 +#ÿ, +# -).#/ÿ rI^GÿPEQNQEQGD...

AI summary This text discusses the analysis and evaluation of various energy programs and regulatory considerations, including cost recovery mechanisms, program effectiveness, and the impact of regulatory decisions on energy efficiency and affordability. It references specific programs and regulatory processes.

ÿ 78ÿ\ÿ]^_ÿQ'ÿ-$("$%-6"#ÿ0"ÿ$&%ÿ&//#"%%-$5ÿ- M(%#ÿ."( #"ÿ,&#%ÿ( #%& "0#ÿ$+ÿ%'M4"0#ÿ0"ÿ $&%ÿ-$() +"+ÿ-$ÿ%,-#ÿ%"#%7ÿ Zÿ 78ÿ\ÿ^ÿ^_ÿQ'ÿ-$("$%-6"#ÿ0"ÿ$&%ÿ&//#"%%-$5ÿ- M(%#ÿ."( #"ÿ%,"ÿM0%4ÿ-$( 00-$5ÿ%,"ÿ(&#%ÿ N%'M4"0#Pÿ0"ÿ& %#-+"ÿ%,"ÿ#(&M"ÿ&...

AI summary The text discusses regulatory proceedings related to energy policies and mechanisms, including fuel-cost-adjustment, affordability, and the impact of various programs and regulations on energy efficiency and customer service. It touches on topics such as energy efficiency, cost recovery, and the role of regulatory oversight.

.$"ÿ.00ÿ%.' $-ÿ 2. ÿ.%%"' ÿ 2"ÿ !"ÿ#$"%"$"&'"ÿ$"0"3.& ÿ ÿ 2"ÿ' - X"%%"' 3"&" ÿ.&.05 (ÿ Z2-ÿ# & ÿ 2. ÿ.ÿ+-' 4& ÿ$. "ÿ4-"+ÿ% $ÿ' - X"%%"' 3"&" ÿ.&.05 ÿ' 40+ÿ$"%0"' ÿ! $"ÿ 2.&ÿW4- ÿ 2"ÿ' - ÿ %ÿ'.# .0ÿ-ÿ. ÿ0".- ÿ &"ÿ/. ÿ% $ÿ 2"ÿ.##0'. &ÿ %ÿ 2"...

AI summary The document discusses the impact of the fuel-cost-adjustment mechanism on rate structures, the need for aligning base rates with actual costs, and the implications for cost recovery. It mentions the role of regulatory oversight, prudency reviews, and the importance of accurate forecasting in energy regulation.

<9ÿ>5<9DÿD9A>BD=9AÿI96CEÿ8AA9AA9@rÿd?ÿ 5<9ÿ8CAF9Dÿ5>ÿ8C:ÿ>?ÿ5<9A9ÿbB9A56>CAÿ6Aÿsnmtuÿ5<9Cÿ8459DC856G9ÿ@6A=>BC5ÿD859AÿA<>B4@ÿI9ÿB5646v9@;ÿ AB=<ÿ8Aÿ5<>A9ÿI8A9@ÿ>Cÿ=BA5>79Dÿ>DÿA>=69584ÿL9DAL9=56G9AJÿ Q%$Rÿ[Tÿ[/)-($&ÿ%,$ÿS_$&2 $ÿ[0-%/'$&ÿ#(-./...

AI summary The text discusses the regulation of utility rates and the implications of cost recovery mechanisms, including the impact of delayed rate adjustments and the need for alignment between base rates and actual costs. It also touches on the evaluation of programs and the importance of ensuring equitable cost distribution among customers.

ÿ g>63=?=8><3ÿeI8>?39ÿ h5?65>95ÿ ÿ i3456ÿeI8>?39ÿ ÿ ÿ e<?65>95ÿ2 Gf153ÿeI8>?3ÿ 8>63=?=8><3ÿ=I8>?39kÿ23456A=95ÿ<2ÿ 12ÿ5::5?3ÿF<@56ÿ><7ÿ3593ÿ <53ÿ5::5?3ÿ ]_l_l_ÿQ/ R -S/ÿ&$#.!-#R!ÿ +ÿO(S\\ n#$ÿQ++#/!)ÿ X4=9ÿ95?3=2<ÿ@59?6=;59ÿA4>3ÿ98=GG2B56ÿ=...

AI summary The document discusses the impact of the fuel-cost-adjustment mechanism on rate structures and the challenges posed by the delay in base rates relative to actual costs. It emphasizes the need for alignment between rate structures and cost recovery mechanisms to avoid perverse incentives.

o merit routine inclusion Not included/or partially included in 2023-2025 test DER types not included in the 2023-2025 DSM plan Yellow shaded cells are impacts that were not included, or were only partially included, in the prior screening...

AI summary The text discusses the inclusion of distributed energy resources (DERs) in the 2023-2025 DSM plan, noting that certain DER types were not fully included. It highlights the need for a more comprehensive assessment of system impacts, such as transmission and distribution losses, and references the NSPM process and Energy Futures Group.

loads, so not likely to have large GHGs  NM  NM   GHG impacts Societal Other DR can have adverse local environmental impacts if    NM   Environmental customers deploy diesel generators Often related to and overlap w other environm...

AI summary The text discusses the environmental and societal impacts of distributed energy resources (DERs), including potential adverse local environmental effects from customer use of diesel generators. It also highlights the need to separate incremental impacts from BCA calculations to avoid double counting and mentions DER types not included in the 2023-2025 DSM plan.

idering forward looking estimates of transmission and distribution upgrade costs as opposed to relying on historic costs may be adopted. (See Tables 2 and 3, and Section IV). 4) The new jurisdictional test should include other fuel and gas...

AI summary The text discusses the adoption of forward-looking estimates for transmission and distribution upgrade costs, the inclusion of other fuel and gas impacts in a new jurisdictional test based on commodity costs minus carbon price, and the recommendation to treat gas impacts through commodity costs due to the relatively small gas system size and anticipated DSM impacts.

s on the gas system. In the future further consideration of the gas system non- commodity cost impacts may be necessary and appropriate. (See Tables 4 and 11, and Section V). 6) For host customer impacts the new jurisdictional test should...

AI summary The text discusses the need to consider non-commodity costs of the gas system, the inclusion of non-energy benefits in the jurisdictional test for host customers, the use of social cost of carbon for societal impacts, and the recommendation to assess economic and job impacts of DSM separately. It also references specific tables and sections for detailed analysis.

ed Social Costs for CO2 electric and avoided fuel Impacts $13.90 $7.30 $14.02 Host customer measure Direct Direct measure costs Host costs net of incentives ($4.80) ($4.80) ($4.80) Custmer Percent estimate for host Impacts Proxy Proxy host...

AI summary The document presents a Benefit-Cost Analysis (BCA) conducted by the Energy Futures Group (EFG) for EfficiencyOne, including social costs for CO2, direct measure costs, and host customer impacts. It outlines financial figures related to electric and avoided fuel impacts, as well as net benefits and host customer non-energy benefits.

energyfuturesgroup.com 21 Figure 1: Illustrative Example of Recommended Nova Scotia Test As illustrated, the major drivers for the differences between these cases are the value of the saved other fuel, and the valuation of the avoided carb...

AI summary The text presents an illustrative example of a benefit-cost analysis test for Nova Scotia, highlighting the differences in value between cases involving fuel oil and natural gas, as well as the benefits of replacing electric resistance heat with heat pumps. The analysis considers the value of saved fuel, avoided carbon emissions, and the resulting net benefits.

Page 23 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 24 achieve a benefit-cost ratio of 1.0 or higher to be considered cost-effective. Looking forward, it is anticipated plan level screening...

AI summary EfficiencyOne (E1) discusses the benefit-cost analysis (BCA) test application for the 2023-2025 Demand Side Management (DSM) Plan. E1 argues that the Test of Reasonableness (TRC) applied is conservative and unbalanced, violating the symmetry principle of the Nova Scotia Power (NSPM). E1 also raised concerns about understated avoided costs and the need for an optimal BCA methodology.

s, so not likely to have large GHGs  NM  NM   GHG impacts Societal Other DR can have adverse local environmental impacts if    NM   Environmental customers deploy diesel generators Often related to and overlap w other environmenta...

AI summary The text outlines the environmental and societal impacts of DERs, noting that while DR can lead to adverse local environmental effects, such as from diesel generators, these impacts are generally not material enough for routine inclusion in the NS UBCA test. It also highlights the importance of keeping incremental impacts separate from BCA calculations to prevent double counting.

acts from GHG and other air pollutants. 33 While the E1 portfolio and support for DERs will provide societal benefits and impacts beyond these two categories as indicated in Table 17, the 33 The consultant team recommends the US EPA’s bene...

AI summary The text discusses the recommendation to calculate net CO2e emissions for efficiency and fuel switching measures, referencing the Difference in Carbon Emissions (DICE) method used by E1 for the 2023-2025 Plan. It also highlights the importance of estimating benefits from air quality improvements due to reduced PM, SO2, and NOx emissions.

2023-2025 Plan (Difference in Carbon Emissions or DICE) can be applied or may be updated to reflect Nova Scotia Power’s updated emissions estimates from the latest integrated resource plan. Reductions of GHG emissions from avoided on-site...

AI summary The text discusses the application of the 2023-2025 Plan (DICE) and the consideration of lifecycle emissions in evaluating decarbonization strategies. It highlights that GHG impact estimates only account for on-site combustion and electric generation, not upstream emissions. Social costs of greenhouse gases are based on Canadian guidance, with a 2% real discount rate. Calculations of avoided GHG benefits are illustrated, noting that carbon price elements are subtracted from fuel costs to avoid double counting.

sider modifying these values to more accurately reflect specific Nova Scotia conditions and dynamics contributing to the valuation of impacts for criteria air pollutants if deemed desirable. During the discussion of quantifying criteria ai...

AI summary The document discusses the modification of criteria air pollutant values to better reflect Nova Scotia conditions. It raises concerns that absolute emissions caps may not reduce pollutants with increased DER deployment, but recommends adopting New England values for the 2027-2031 DSM plan. A benefit-cost analysis suggests using 0.55 cents per kWh for the BCA test in Nova Scotia.

mental policy objectives. We recommend a value of 0.55 cents per kWh be adopted for the Nova Scotia BCA test, based on a simple average of the US EPA benefit per kWh method for New England. We note that the BPK method does not include calc...

AI summary The document recommends a BCA test value of 0.55 cents per kWh for Nova Scotia, based on a simple average of the US EPA benefit per kWh method for New England. It notes that the BPK method does not account for offset emissions from avoided on-site combustion, particularly for heat pumps, and suggests the need for more detailed data and analysis.

- $ 341 0.74 $ 1,055,571 Total $ 13,898,925 The social cost of carbon is based on December 2022 updates from Environment Canada.42 The social cost of CO2 is used in the example, but if estimates of avoided CH4 and N20 emissions are availab...

AI summary The text discusses the social cost of carbon based on Environment Canada's 2022 updates and its application in a benefit-cost analysis (BCA) test. It also mentions the value of reducing air pollutants like PM, SO2, and NOx using EPA estimates and highlights the impact of heat pumps on electric generation and associated costs or benefits.

Page 58 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 59 The net host customer costs for each of the 1,000 heat pump replacements in this example are estimated to be $4,800 based on an average...

AI summary The document provides a benefit-cost analysis of 1,000 residential heat pump replacements, estimating net host customer costs and non-energy benefits. It also compares the scenario with pipeline gas replacement, highlighting the increased electric system impact costs and greenhouse gas impacts.

06,029) 2037 $ 92 7,878 $ 571,487 5,275 $ 162 $ 60 $ 923,452 $ (1,129,412) 2038 $ 94 7,878 $ 572,461 5,275 $ 167 $ 61 $ 929,814 $ (1,147,407) 2039 $ 96 7,878 $ 573,177 5,275 $ 170 $ 62 $ 927,575 $ (1,156,297) 2040 $ 97 7,878 $ 567,792 5,27...

AI summary Table 23 provides an estimate of greenhouse gas impacts from the deployment of 1,000 residential heat pumps displacing pipeline gas. The data includes projected costs and savings over several years. The document is part of an EfficiencyOne Benefit-Cost Analysis Test Application filed on May 16, 2025.

mphasize reducing reliance on fossil fuels and enhancing energy efficiency. On this basis, Eastward Energy's participation does not align with the group's mandate to meet these objectives effectively. Request IR-04: Reference: Evidence Pag...

AI summary Eastward Energy's participation in a DSM initiative is questioned due to misalignment with objectives of reducing fossil fuel reliance and improving energy efficiency. A response confirms a negative net benefit and low BCR for replacing 1,000 natural gas heating systems with heat pumps, and notes that E1 is considering strategic electrification in its upcoming DSM Plan.

E1 Responses to Industrial Group (IG) Information Requests NON-CONFIDENTIAL health impacts. The definitions of "sustainable development"[1](#page-29-0) and "sustainable prosperity"[2](#page-29-1) encompass environmental stewardship and soc...

AI summary E1 responds to the Industrial Group's request regarding public health impact categorization, stating it is already addressed via GHG emissions and air pollutant impacts. The response also references legislative definitions of 'sustainable development' and 'sustainable prosperity' from the Environment Act and Environmental Goals and Climate Change Reduction Act 2021. A request for clarification on addressing NSPM Appendix A (Rate Impacts) and BCA approval stages is noted.

consistent with policy, planning and regulatory requirements as discussed in part (a) of this IR response. Including non-utility benefits in the BCA test has no impact on the "reasonable availability" - of potential measures. E1's portfoli...

AI summary E1 asserts that including non-utility benefits in the BCA test does not affect the reasonable availability of measures and is consistent with policy and regulatory requirements. A separate RBIA is conducted to assess ratepayer impacts. The repeal of section 79L from the Public Utilities Act did not directly impact the BCA framework. E1 emphasizes that performance targets and indicators are part of the DSM Plan development process and will be discussed with the DSMAG.

(c) In a benefit cost test for demand side management, the social discount rate is used to convert future costs and benefits into their present-day values. This allows for a comparison of costs and benefits that occur at different points i...

AI summary This section discusses the use of a 2% real social discount rate in benefit-cost tests for demand side management, emphasizing its alignment with Nova Scotia's sustainability and prosperity goals. It notes that this rate is lower than a utility weighted average cost of capital and places greater value on future impacts. Figure G-1 from the National Standard Practice Manual illustrates how different discount rates affect DER benefits.

E1 Responses to Small Business Advocate (SBA) Information Requests NON-CONFIDENTIAL Request IR-04: - Refer to Exhibit E-1, the Report, page 20 of 68. Describe the safeguards built into the BCA Test - methodology to prevent the double count...

AI summary EfficiencyOne (E1) responds to Small Business Advocate (SBA) information requests regarding the BCA Test methodology. Key points include safeguards to prevent double-counting of benefits like avoided GHG and fuel costs, additional test runs for the BCA Test, and handling of long-term benefits such as decarbonization of the grid.

(a) Summary Table – Canadian Cost Effectiveness Testing Province Primary Test Additional Tests Used Non-Energy Benefits Nova Scotia • The Total Resource Cost Test (TRC), at the portfolio level (this changed from the program level to the po...

AI summary Nova Scotia uses the Total Resource Cost Test (TRC) as the primary cost-effectiveness screening tool at the portfolio level, with the Program Administrator Cost test (PAC) for informational purposes. Non-energy benefits are not included in the TRC, and low-income program components are not exempt from the TRC test. The NSUARB ordered E1 to update avoided costs and develop a DSM cost-effectiveness methodology.

E1 Responses to Synapse Energy Economics (Synapse) Information Requests NON-CONFIDENTIAL - above can be applied. In the illustrative example presented in the EFG Report[2](#page-3-0) 1 the carbon price - 2 is subtracted from the fossil fue...

AI summary The text discusses the application of carbon pricing in the EFG Report, where the carbon price is subtracted from fossil fuels and the avoided costs of energy, with the assumption that these costs do not include embedded avoided carbon costs.

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 approach for capturing global GHG benefits via Social Cost of Carbon, not just local impacts. It highlights PAC's inadequacy in addressing non-participant customer rate impacts and argues TRC's unbalanced application. Three alternative solutions to TRC's shortcomings are suggested.

4 For conversion of fuel oil heating to heat pumps (beneficial electrification): Proposed BCA (societal perspective) PAC (utility and its customers perspective, including revenue) Benefits = NPV of avoided fuel oil purchase, Benefits: NPV...

AI summary The document outlines a Benefit-Cost Analysis (BCA) and Public Acceptability Criteria (PAC) for converting fuel oil heating to heat pumps. It compares benefits such as avoided fuel oil purchases and reduced GHG emissions against costs like increased electric generation and installation expenses.

Should E1's proposal that BCA be conducted only at the Portfolio level be adopted? - No. - Previous sections of this submission highlighted that the Board cannot fulfill its mandate if screening - information or tests are only applied at t...

AI summary The proposal to conduct BCA only at the Portfolio level is rejected, as it would hinder the Board's mandate by failing to identify problematic measures and prevent analysis of customer class cross-subsidization. Measure-level and customer class-level BCA are necessary for effective DSM program evaluation.

Is there any relevance to measurements considering rate impacts, such as a RIM test? - A RIM test should not be applied as a screening test for energy efficiency, as it can derive excessively - narrow metrics and fail to measure proper cos...

AI summary The text argues against using RIM tests as a screening tool for energy efficiency due to their narrow metrics and inadequate cost-effectiveness measurement. However, it recommends that E1 continue reporting rate impacts at multiple granularities to enable the Board's assessment of customer impacts, including non-participants.

What recommendations do you have? - Based on the above considerations, I provide the following conclusions and recommendations for the Board: - 1) The current primary TRC test is limited in its ability to singularly inform the Board about...

AI summary The text outlines recommendations for the Board regarding the use of benefit-cost analysis (BCA) tests in evaluating demand-side management (DSM) activities. It suggests using the PAC test as the primary energy efficiency test, incorporating the E1 BCA test for broader considerations, and rejecting the E1 Proposed BCA test as the primary test. It also emphasizes the need for cost-effective measures and proper consideration of avoided utility costs and GHG emissions.

BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...

AI summary Bowman Economic Consulting Inc. provides utility regulation consulting, focusing on rate design, cost of service analysis, and demand-side management. They represent industrial energy users in regulatory proceedings before Manitoba and Newfoundland boards, including General Rate Applications and resource planning hearings.

Utility Regulation Conducted research and analysis for regulatory and rate reviews of electric, gas and water utilities in eight Canadian provinces and territories and international. Prepared evidence and expert testimony for regulatory he...

AI summary The text details experience in utility regulation, including research and analysis for regulatory and rate reviews across Canadian provinces and territories, preparation of evidence and expert testimony, and assistance with utility capital and operations planning to evaluate rate impacts and long-term stability.

Sample Projects: For the Office of the Utilities Consumer Advocate of Alberta (2016 - 2024): Analysis and strategic support of Government agency representing the interests of small utility customers. Addressed matters of utility rates and...

AI summary The text outlines a range of regulatory and utility-related projects across Alberta, Ontario, British Columbia, Manitoba, Jamaica, Yukon, and other regions. It details work involving utility rate analysis, regulatory filings, asset depreciation, rate design, and stakeholder representation before various utility commissions and boards.

Project Development, Socio-Economic Impact Assessment and Mitigation Provide support in project development, local investment opportunities or socio-economic impact mitigation programs for energy projects, including northern Manitoba, Yuko...

AI summary The text outlines support for energy project development, socio-economic impact mitigation, and community compensation resolution in regions like northern Manitoba, Yukon, and NWT. Examples include transmission line valuation for Indigenous claims, NWT rate strategy development, and feasibility studies for tribal utilities and hydro projects.

Utility Proceeding Work Performed Before Client Year Oral Testimony NTPC 2012/14 General Rate Application Analysis, Preparation of Company Evidence & Expert Testimony on all areas of Revenue Reqt, COS and Rate Design, incl Depreciation NWT...

AI summary The table outlines various utility proceedings involving analysis and expert testimony on revenue requirements, cost of service, and rate design, including depreciation, with entities such as NTPC, Manitoba Hydro, and Newfoundland Hydro, and regulatory bodies like NWTPUB, MPUB, and NLPUB.

PROFESSIONAL EXPERIENCE Synapse Energy Economics, Inc. , Cambridge, MA. Senior Principal , August 2024 – Present, Principal Associate , September 2022 – August 2024, Senior Associate, November 2019 – September 2022. Provides consulting and...

AI summary The individual's professional experience spans energy consulting, policy analysis, and regulatory work, focusing on demand-side management, energy efficiency, distributed energy resources, and performance-based regulation. Roles include senior positions at Synapse Energy Economics, National Grid, and advocacy groups, with expertise in benefit-cost assessment, program evaluation, and stakeholder engagement in energy initiatives.

PUBLICATIONS Woolf, T., M. Whited, C. Lane. 2025. Identifying and Accounting for Transfers in Benefit‐Cost Analysis of Distributed Energy Resources . Synapse Energy Economics for the National Energy Screening Project. Fortman, N., J. Micha...

AI summary The document lists publications related to benefit-cost analysis (BCA) of distributed energy resources (DERs), energy efficiency programs, and clean vehicle policies. Key contributors include Synapse Energy Economics, the National Energy Screening Project (NESP), and E4TheFuture. Topics span equity in DERs, rate impacts, and macroeconomic clean energy scenarios.

TESTIMONY Minnesota Public Utilities Commission (Docket Nos. E‐015/PA‐24‐198,M‐24‐383) : Direct and Surrebuttal Testimony of Courtney Lane regarding the Petition of Minnesota Power for Acquisition of ALLETE by Canada Pension Plan Investmen...

AI summary Courtney Lane provided testimony in multiple U.S. state regulatory proceedings on energy-related matters, including utility acquisitions, electric vehicle infrastructure, rate design, and grid modernization. She represented organizations such as the Sierra Club, Maryland Office of People's Counsel, and New Mexico Department of Justice across various cases from 2024 to 2025.

PRESENTATIONS Lane, C. 2021. "Accounting for Interactive Effects: Assessing the Cost‐Effectiveness of Integrated Distributed Energy Resources." Presentation at the 2021 American Council for an Energy‐Efficient Economy (ACEEE) National Conf...

AI summary The document lists presentations by Lane, C., covering topics like integrated distributed energy resources, ratepayer impact tests, wireless alternatives, renewable energy policy, Act 129, and electric retail competition. These were delivered at conferences, webinars, and forums from 2009 to 2021, focusing on energy efficiency, policy, and technology.

PRIOR ASSIGNMENTS (RESOURCE INSIGHT) – 1992-1996 - Technical assistance on DSM program development in the Potomac Electric Power Company collaborative, for the Maryland Office of People's Counsel. Work included characterizing new energy-ef...

AI summary The text details technical contributions to DSM program development (1992–1996), including cost-effectiveness analysis, program design, and regulatory support. Key activities involve commercial/industrial energy efficiency measures, IRP reviews, and stakeholder negotiations. Entities include utilities, regulatory bodies, and environmental organizations.

Marginal Emissions In relation to NSPI's marginal emissions, in response to Eastward's IR-11 E1's consultant, Energy Futures Group ("EFG"), notes that its use of average emissions rates for calculating impacts for the portfolio is an appro...

AI summary The document discusses NSPI's marginal emissions and the methodology used to calculate emission reduction impacts. Energy Futures Group suggests that using average emissions rates is an approximation, while a more granular approach based on hourly marginal generation and emissions rates can provide better estimates. Figure 6 from NSPI's 2024 report highlights that coal-fired baseload generation is on the margin over 75% of the time.

Natural Gas to Electric Conversions In response to Eastward's IR-04(a), EFG confirmed that " if 1,000 heat pumps were all replacing gas as a primary heating fuel, the results of the illustrative example are a negative net benefit of $17.4...

AI summary EFG reported a negative net benefit of $17.4M and a 0.45 benefit-cost ratio for replacing gas with heat pumps. Despite EFG's findings, E1 did not confirm it would exclude such measures from its 2027-2031 DSM Plan. Eastward argues that including this low-benefit measure contradicts EFG's conclusion that gas DSM savings are less than electricity savings, raising concerns about validity of strategic electrification projects.

II. SBA PERSPECTIVE ON DEMAND SIDE MANAGEMENT INVESTMENTS Q. What is the perspective of small businesses regarding DSM versus other types of investments recovered through customer rates? A. Having participated in DSMAG meetings for several...

AI summary The SBA acknowledges DSM's potential to reduce peak demand and lower capital investments, aligning with Nova Scotia's Clean Energy goals. However, factors like maintenance, load growth, and regulatory requirements may offset DSM savings, as evidenced by NS Power's capital expenditure filings. This is framed as an 'all else equal' comparison.

SELECTED EXPERIENCE - Conduct annual renegotiation of natural gas supply contract for basis and commodity pricing plus terms of service, and assist with review of renewable diesel procurement. for a major governmental authority; - Conducte...

AI summary Experience includes managing natural gas contracts, rate cases, infrastructure audits, and evaluations of utility strategies. Activities involve optimizing portfolios, negotiating supply agreements, and ensuring compliance with regulations like NERC. Work spans utilities, regulatory boards, and evaluations of LNG facilities and merger reviews.

EXPERT TESTIMONY FORUM ON BEHALF OF MATTERS Massachusetts Public Utility Commission Blackstone Gas Company ("Blackstone") DPU 14-92 and DPU 17-122, in support of Blackstone's long term gas supply contracts. DPU 18-15, Investigation by the...

AI summary The text presents expert testimony from various regulatory bodies and organizations, including the Massachusetts Public Utility Commission and the U.S. Federal Energy Regulatory Commission (FERC), related to matters such as gas supply contracts, tax rate impacts on utility rates, and rate case analyses. These proceedings involve legal and regulatory considerations for energy companies.

1 For conversion of electric resistance heating to heat pumps (energy efficiency): Proposed BCA (societal perspective) PAC (utility and its customers perspective) Benefits = NPV of avoided electric generation and capacity costs, avoided tr...

AI summary The document outlines a Benefit-Cost Analysis (BCA) and Public Acceptability Criterion (PAC) for converting electric resistance heating to heat pumps. It considers benefits such as avoided generation and transmission costs, health impacts, and GHG reductions, while also accounting for installation and program administration costs.

4 For conversion of fuel oil heating to heat pumps (beneficial electrification): Proposed BCA (societal perspective) PAC (utility and its customers perspective, including revenue) Benefits = NPV of avoided fuel oil purchase, avoided GHG gl...

AI summary The document presents a Benefit-Cost Analysis (BCA) and Public Acceptability Criterion (PAC) for converting fuel oil heating to heat pumps. Benefits include avoided fuel costs and GHG emissions, while costs involve infrastructure upgrades and program administration. From the utility's perspective, benefits include added revenue, while costs remain similar.

Should E1's proposal that BCA be conducted only at the Portfolio level be adopted? - No. - Previous sections of this submission highlighted that the Board cannot fulfill its mandate if screening - information or tests are only applied at t...

AI summary The submission argues against E1's proposal to conduct BCA only at the Portfolio level, stating it would prevent identifying outliers and hinder the Board's mandate. It emphasizes the need for customer-class-level analysis to address cross-subsidization and align with NSPM guidelines. Current DSM cost recovery methods also require class-specific cost assessments.

Is there any relevance to measurements considering rate impacts, such as a RIM test? - A RIM test should not be applied as a screening test for energy efficiency, as it can derive excessively - narrow metrics and fail to measure proper cos...

AI summary The discussion addresses the use of RIM tests for energy efficiency, arguing against their use as a screening tool due to narrow metrics. However, E1 should report rate impacts at various levels for the Board's assessment.

What recommendations do you have? Based on the above considerations, I provide the following conclusions and recommendations for the Board: - 1) The current primary TRC test is limited in its ability to singularly inform the Board about es...

AI summary The text provides recommendations for the Board regarding the use of benefit-cost analysis (BCA) tests in evaluating DSM activities. It suggests using the PAC test as the primary energy efficiency test, rejecting the E1 BCA test as a primary test, and incorporating multiple tests for balanced evaluation. It also highlights the importance of using NSPI WACC as the discount rate and ensuring accurate GHG emission calculations.

BOWMAN ECONOMIC CONSULTING INC., WINNIPEG, MANITOBA 2020 – current – Principal Consultant Conduct consulting assignments as Principal Consultant of new economic consulting firm, focused on utility regulation. Member, Society of Depreciatio...

AI summary Bowman Economic Consulting Inc. provides regulatory consulting services for utility rate design, cost of service analysis, and demand side management (DSM) initiatives. They represent industrial energy users in Manitoba and Newfoundland and Labrador before regulatory bodies, including the Manitoba Public Utilities Board and Newfoundland Board of Commissioners of Public Utilities, on matters such as rate structures, surplus energy rates, and resource planning hearings.

Utility Regulation Conducted research and analysis for regulatory and rate reviews of electric, gas and water utilities in eight Canadian provinces and territories and international. Prepared evidence and expert testimony for regulatory he...

AI summary Research and analysis conducted for regulatory and rate reviews of utilities across eight Canadian provinces and territories. Expert testimony prepared for hearings, and assistance provided in utility planning to assess rate impacts and long-term stability.

Sample Projects: For the Office of the Utilities Consumer Advocate of Alberta (2016 - 2024): Analysis and strategic support of Government agency representing the interests of small utility customers. Addressed matters of utility rates and...

AI summary The text details a range of regulatory and utility-related projects across Alberta, Ontario, British Columbia, Manitoba, and other jurisdictions. It covers rate design, asset depreciation, utility regulation, and energy policy, with involvement from multiple regulatory bodies and organizations.

Project Development, Socio-Economic Impact Assessment and Mitigation Provide support in project development, local investment opportunities or socio-economic impact mitigation programs for energy projects, including northern Manitoba, Yuko...

AI summary The text outlines support for energy project development, socio-economic impact mitigation, and local investment opportunities in regions like northern Manitoba, Yukon, and NWT. It includes examples of projects such as transmission line valuation for Indigenous claims, rate strategy development in NWT, and hydro system resiliency studies.

Utility Proceeding Work Performed Before Client Year Oral Testimony NTPC Required Firm Capacity/System Planning hearing Analysis, Preparation of Company Evidence and Expert Testimony NWTPUB NTPC 2004 Yes Nunavut Power (Qulliq Energy) 2004...

AI summary The table outlines various regulatory proceedings involving utilities and their associated work performed, including analysis, preparation of evidence, and expert testimony. These proceedings span multiple years and involve different regulatory bodies across Canada.

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 Despite these concerns, Da...

AI summary Daymark supports continuing stakeholder proceedings if EOne and EFG clarify quantification methods. It argues non-energy benefits like 'amenity' and 'pride' require independent verification, aligning with EOne/EFG's proposal to use third-party fuel price data (e.g., NYMEX, OPIS). Daymark cites Renewable Diesel (RD99) pricing as a market example where non-energy benefits do not command significant price premiums.

Response to Information Requests Request IR-1: Reference: Exhibit E-13, page 5-6. Ms. Whitten indicates that "a well-crafted DSM plan can be successful in reducing or delaying an increase in peak demand that then should translate into cust...

AI summary The text discusses Ms. Whitten's testimony regarding the benefits of a well-crafted DSM plan, emphasizing customer bill savings and the need for the BCA test to avoid increased costs for customers without corresponding benefits. It raises questions about the meaning of 'benefits' and whether Ms. Whitten supports DSM costs being incurred for broader societal benefits rather than just utility and customer bill benefits.

Response: (a) Yes. (b) In Nova Scotia, it is necessary under the Public Utilities Act s. 79L(4) for the Energy Board to consider whether the Demand Side Management (including electrification activities, programs and plans) are in the best...

AI summary The Energy Board must assess whether electrification programs benefit all Nova Scotia Power customers under the Public Utilities Act. Critics argue E1's proposals focus on global societal benefits (e.g., GHG reductions) rather than specific customer impacts, violating legislative requirements. The Board must consider non-participating customers' rate impacts, which E1's portfolio-level analysis may overlook.

Request IR-3: - Refer to the Evidence of Patrick Bowman at page 18, which states "A RIM test should not - be applied as a screening test for energy efficiency, as it can derive excessively narrow - metrics and fail to measure proper cost-e...

AI summary Patrick Bowman's evidence challenges the use of the RIM test for energy efficiency, arguing it produces narrow metrics. The proceeding questions why revenue changes in the PAC test are appropriate and how it differs from RIM. Key issues involve cost-effectiveness methodologies and regulatory testing frameworks.

Reference: Exhibit E-9 page 23. - (a) Does Synapse's support of the E1 proposed BCA test consider the source of funds for the DER programming? Specifically, given the funds for the programming are derived from utility rates, does Synapse e...

AI summary The text questions Synapse's BCA test for DER programming, querying whether benefits/costs should align with utility function (vs societal perspective) given funding from utility rates, and if non-monetary benefits (e.g., comfort, pride) meet utility principles for inclusion in electricity rates.

- Clean Heat Standards (CHS); comparing CHS approaches of Colorado, Vermont, Massachusetts and Maryland; and providing recommendations on key CHS design choices. (2023-2024) - Maryland Department of the Environment. Developed and analyzed...

AI summary Energy Futures Group, Inc. analyzed Clean Heat Standards (CHS) in multiple states, collaborated with agencies on decarbonization pathways, and provided expert testimony on gas infrastructure and rate cases. Work included Massachusetts, Maryland, Vermont, Illinois, and Ohio, focusing on policy design, emissions reduction, and utility regulation.

E1 Response - E1 submits that the non-USIs considered in the proposed BCA test address the goals of strategic - electrification, sustainable development and sustainable prosperity. All these goals are legislated matters - for consideration...

AI summary E1 argues that non-USIs in the BCA test align with legislated goals of strategic electrification and sustainable development. They oppose narrowing DSM criteria, claiming it would undermine secondary objectives and contradict stakeholder-supported Balanced Plan Approach, harming ratepayer interests and effective demand-side management.

E1 Response and rate impacts.[11](#page-10-0) The balanced plan approach has been an established design principle of DSM in Nova Scotia for several years. In 2016, the Standardized Filing Framework ("Framework") was developed in consultati...

AI summary The document discusses the 'balanced plan approach' in Nova Scotia's Demand Side Management (DSM), established via the 2016 Standardized Filing Framework. Developed with E1, NSP, and DSMAG, it ensures DSM plans balance energy avoidance, costs, and accessibility. The NSUARB endorsed the framework, and E1 has adhered to it since 2016. The Industrial Group signed the Consensus Agreement supporting this approach.

E1 Response - E1 agrees that the internalized cost of carbon for gas and other fuels should be included in these specific - impacts similar to the electric utility's avoided cost of energy, and not included in the externalized cost of - ca...

AI summary E1 agrees that internalized carbon costs for gas should be included in the PAC like electric utility avoided costs, but not in externalized carbon costs. E1 emphasizes that only electric utility avoided costs (including internalized carbon) are currently in the PAC.

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).

- benefit of being a key part of the approach needed to fulfill the Board's role under section 79L(4) of - the Act, where it must specifically assess impacts on NS Power's customers. - The PAC test is also beneficial as it permits a BCA as...

AI summary The text argues for the adoption of the PAC test over E1's proposed BCA approach, emphasizing cost-effectiveness and the inclusion of customer incentives. It also criticizes the use of a low discount rate for assessing DSM measures and highlights the importance of including revenue benefits from electrification in the PAC test.

- [1] In the course of addressing EfficiencyOne's (E1) application to the Nova Scotia Utility and Review Board (NSUARB) for approval of its supply agreement with Nova Scotia Power Incorporated (NS Power) and demand-side management (DSM) re...

AI summary The NSUARB is reviewing EfficiencyOne's application for a supply agreement with NS Power and its DSM plan. Concerns were raised about the cost-effectiveness test used, specifically the TRC test, which excludes non-energy benefits. Synapse recommended using the PAC test instead, though it does not account for participant costs and benefits.

strial Group argued the proposed proxy adders and host customer feelings are not reasonable and do not have sufficient evidentiary foundation to include them at this time. The Industrial Group states: The broad and subjective array of non-...

AI summary The Industrial Group argues that proposed proxy adders and host customer feelings lack evidentiary support and conflict with the PUA's definition of DSM. They reject subjective non-energy benefits like 'pride' or 'amenity' as incompatible with cost-effectiveness testing, emphasizing that GHG reduction or sustainability do not justify such inclusions.

3.4 Nova Scotia Power [48] NS Power does not support E1's proposed BCA test and recommends the Board approve the current TRC with two modifications which would consider, in the context of strategic electrification, GHG emissions reductions...

AI summary Nova Scotia Power opposes E1's proposed BCA test, advocating for TRC modifications to include GHG emissions reductions (net tonnage) and electricity cost reductions. It emphasizes that the Public Utilities Act mandates strategic electrification to reduce emissions and costs, arguing that the Board's core mandate is ensuring just and reasonable rates, not broader social considerations.

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

AI summary The text challenges the NSUARB's interpretation of Section 79A of the Public Utilities Act, arguing it misrepresents the Board's jurisdiction. It references the Atco case, emphasizing that the Board's authority is limited to rate-setting and system integrity, not broader regulatory powers.

(2) A franchise (a) gives the franchise holder the exclusive right to supply Nova Scotia Power Incorporated with reasonably available, cost-effective demand-side management for the purpose of this Act; … - 79K (1) Nova Scotia Power Incorpo...

AI summary The franchise agreement outlines Nova Scotia Power Incorporated's (NSP) obligations to provide information for demand-side management (DSM) activities, emphasizing cost-effectiveness and availability. The IESO's role in integrated resource planning and avoided cost calculations is highlighted, with references to the Energy Reform Act 2024. E1 argues for broader benefit-cost analysis beyond utility impacts, while the NSUARB reinforces cost-effectiveness requirements.

ts and strategies not only focus on cost-effectiveness but also contribute to broader environmental and social goals, fostering a more sustainable and equitable future. [Exhibit E-1, pp. 17-18 of 38] [116] E1 submits that the recent legisl...

AI summary E1 argues that legislative changes, including the Energy and Regulatory Boards Act and More Access to Energy Act , empower the NSUARB to prioritize environmental, social, and economic benefits of DSM programs alongside cost considerations. It emphasizes that the Board must align decisions with Nova Scotia's climate and sustainability goals, using the Proposed BCA as a tool to meet statutory obligations.

[124] Eastward expressed similar comments in its reply submissions: E1 has continued in its Closing Submissions to put considerable emphasis on the Board's requirement at section 6(2)(d) of the Energy and Regulatory Boards Act to give "app...

AI summary E1 emphasizes the Board's duty under the Energy and Regulatory Boards Act to consider sustainable development in DSM evaluations, while East Coast Environmental Law argues this does not override other considerations like affordable energy rates. NSPI notes E1's BCA is driven by sustainability, not overall legislative requirements. E1 also disputes the Industrial Group's interpretation of legislative changes.

[160] Eastward made similar comments in its submissions: In this regard the IG has noted that the approach proposed by Mr. Bowman to costeffectiveness testing for E1 for strategic electrification – running the PAC test with the additional...

AI summary Eastward supports Mr. Bowman's modified PAC test for strategic electrification, aligning with Posterity Group's recommendations to ensure cost-effective programs. E1 argues the test assesses rate impacts, not cost-effectiveness, and has focused on GHG emissions rather than electricity cost reductions in its BCA.

ORDER EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans. The Board issued its Decision on December 10, 2025....

AI summary EfficiencyOne (E1) sought approval for a new BCA test for DSM plans, but the Nova Scotia Energy Board rejected it, directing E1 to use the PAC test with NS Power's WACC. The Board mandated portfolio-level screening, strategic electrification criteria, and inclusion of Eastward in the DSM Advisory Group. E1 may use a revised BCA test for supplemental information.

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 a regulatory proceeding, representing residential ratepayers who may be affected by an application. They will address issues raised by the Energy Board and are represented by Pink Larkin, with consulting support from Green Energy Economics Group Inc.

Request IR-18: - Refer to Table 14 on page 45 of the EFG Report. - a. Please identify which Measure Categories will be applied to both the residential customer segment and the business, non-profit, and institutional (BNI) customer segment....

AI summary Request IR-18 seeks clarification on the application of Measure Categories to residential and BNI customer segments, confirmation of percentage adders for non-income qualified measures, and alignment of specified Measure Categories with E1's existing programs. It references Table 14 of the EFG Report and asks for details on proxy adders, exclusion of BNI Customer Measures, and program overlaps.

- (b) For the "direct measure costs" impact, the "Basis for Estimation" column includes the description "Host customer measure costs net of incentives". Please explain what should be considered in the calculation of "Host customer measure...

AI summary The text requests clarification on the calculation of 'Host customer measure cost' for direct measure costs, including equipment, installation, and maintenance costs. It also asks whether the $4.8M figure represents the full or incremental cost of 1000 heat pumps and seeks discussion on how reliability impacts of measures that increase peak load are reflected in avoided costs, and if this practice is consistent with E1's current approach.

Request IR-2: - Page 2 of 38 of EfficiencyOne's (E1) Evidence states: "Including non-utility impacts reflects both - best practice in benefit cost analysis test design, as well as recently enacted provincial legislation. - While the relati...

AI summary EfficiencyOne (E1) argues that including non-utility impacts in the BCA test framework aligns with best practices and provincial legislation like the Public Utilities Act and Energy Reform (2024) Act . The request seeks clarification on indirect benefits/costs, weight assignments, sensitivity analysis, policy alignment, and performance requirements for non-utility benefits in DSM evaluations.

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

AI summary Request IR-2 seeks updated versions of two tables on page 14, including a column for total resource cost test adjusted to incorporate non-energy benefits as outlined in 'Option 1' on page 12. The request emphasizes modifying existing data to reflect comprehensive cost evaluations.

13 Reference: Exhibit E-9 page 23. - 14 (a) Does Synapse's support of the E1 proposed BCA test consider the source 15 of funds for the DER programming? Specifically, given the funds for the 16 programming are derived from utility rates, do...

AI summary The text raises two questions about Synapse's BCA test for DER programming. Question (a) asks if the BCA appropriately links benefits/costs to utility functions (vs. societal perspective) given funding from utility rates. Question (b) inquires whether non-monetary benefits like comfort and empowerment meet utility principles for inclusion in electricity rates.

f the discount rate in a benefit cost analysis has a different purpose than the use of a discount rate in determining the amount of revenue requirement to be collected from Nova Scotia ratepayers for the electric utility's capital investme...

AI summary The text distinguishes between discount rates in benefit-cost analysis (BCA) and revenue requirement calculations for Nova Scotia ratepayers. It clarifies that BCA discount rates assess present value of future impacts relative to DSM investments collected via the DSM Rate Rider. Cross-examination challenges the applicability of Federal Social Cost of GHG Guidance to utility regulators, citing the Cabinet Directive on Regulation's focus on statutory instruments, not utility commissions.

6.3.2 THE IG'S PROPOSED APPROACH - The IG's proposed approach differs from the legislated direction and context. Mr. Bowman recommends - that "[t]he primary energy efficiency test should be the PAC test, applied at the measure and program...

AI summary The Industrial Group (IG) proposes using the Program Administrator Cost (PAC) test as the primary energy efficiency metric, alongside supplementary tests for electrification, societal impacts, and rate impacts. This approach contrasts with EfficiencyOne's (E1) broader 'societal test' framework. The IG emphasizes narrower criteria and specific cost-effectiveness metrics for DSM reviews.

9 7. REQUESTED BOARD ORDER - Based the evidence and analysis before the Board in this matter, including as set out in this Closing - Submission, E1 respectfully requests the Board approve the Proposed BCA as supplemented by the PCA, - spec...

AI summary E1 requests the NSUARB to approve the Proposed BCA with PCA modifications, including a 2% discount rate and evergreen process. It aligns with PUA, supports decarbonization goals, and reflects stakeholder input via DSMAG. The BCA is deemed evidence-based, consistent with legislation, and in the public interest.

Negative implications of Broad interpretation When interpreting the PUA, this Board should recall Sullivan's third question: what are the consequences of adopting a proposed interpretation? Approving a broad ranging costeffectiveness test...

AI summary The document warns that a broad interpretation of the PUA's cost-effectiveness testing could undermine existing practices, expand E1's mandate beyond legislative intent, and misapply the social cost of carbon (SC-GHG) as a ratepayer tool. It emphasizes that SC-GHG, derived from federal guidelines, is intended for legislative cost-benefit analyses, not utility rate-making.

And Mr. Bowman concluded: "So the PAC is signalling even more savings than the TRC, and I think in some cases it may signal even more savings than the BCA. But it will also help achieve more investment, for example, in the again, something...

AI summary Mr. Bowman highlights PAC's potential for greater savings and investment compared to TRC and BCA. Ms. Thompson acknowledges hybrid heating's value under E1's BCA framework. Eastward criticizes E1 for insufficient emphasis on hybrid heating's benefits, urging the Board to mandate its inclusion in future plans. Commissioner Murphy questions E1's Rebuttal on hybrid heating timelines.

AVERAGE VERSUS MARGINAL EMISSIONS RATES On cross-examination Dr. Hill confirmed that the emissions rates that EFG used for the illustrative examples in the Application "were based on information from Nova Scotia Power and represented avera...

AI summary The document discusses the use of average versus marginal emissions rates in regulatory proceedings. EFG used average rates for illustrative examples, while E1 argued for marginal rates. Eastward emphasized that future generation sources (coal, fuel oil) justify marginal rates, contrasting with hybrid heating's high efficiency. Hybrid heating's impact on peak demand and electrification's upward pressure on peaks are noted.

NATURAL GAS TO ELECTRIC CONVERSIONS In its Rebuttal Evidence E1 stated that: "In the actual event that conversion of gas heating systems to electric heat pumps results, under that application of the proposed BCA yielded a negative benefit...

AI summary EfficiencyOne (E1) argues that converting natural gas heating systems to electric heat pumps would result in a negative benefit of $17.4 million and a benefit-cost ratio of 0.45, requiring justification under existing Board directives. Eastward challenges this, arguing such a measure should not be considered valid strategic electrification and urges the Board to provide guidance on the level of justification required for such a low benefit-cost ratio.

benefits E1 proposes, fits within the list of factors. E1 did not unpack the legislative intent of section 6(2) or engage in statutory interpretation to determine how the subfactors may be considered. First, the Board's core mandate remain...

AI summary The document discusses the Nova Scotia Energy Board's (NSEB) mandate to ensure just and reasonable rates under the Energy and Regulatory Boards Act (ERBA). It emphasizes that section 6(2)'s factors supplement, not replace, this mandate. The use of 'appropriate consideration' in the legislation signals restraint in applying factors, with reference to the Rizzo case for statutory interpretation principles.

APPENDIX A Category PAC (Program Administrator Cost) Current TRC (Total Resource Cost) NS Power Recommendatio ns E1's Proposed BCA (Nova Scotia Jurisdictional Test) GHG Impacts �Excluded �Excluded Greenhouse �� gas emissions reductions to...

AI summary The table compares different cost categories and their inclusion in the Program Administrator Cost (PAC) and Total Resource Cost (TRC) under various proposals. It discusses the treatment of greenhouse gas (GHG) impacts, other fuel impacts, and host customer costs, with differences in inclusion and evaluation methods between NS Power's recommendations and E1's proposed BCA.

is comparable as it 11 contains a provision mandating consideration of the public interest, equity, and sustainable development in rate setting and in utility regulation decisions.[41](#page-12-0) 12 13 In the most recent interpretation of...

AI summary The Consumer Advocate aligns with E1, asserting that legislative changes expand the Energy Board's mandate to consider non-utility impacts like GHG emissions and environmental factors. This includes aligning with climate goals from the Environmental Goals and Climate Change Reduction Act and incorporating the Public Utilities Act's definition of demand-side management, which includes strategic electrification.

i. PAC vs TRC Where the Industrial Group diverges from NSPI is with respect to the proposed primary test to be adopted for DSM going forward. In contrast to NSPI, the Industrial Group does not view the Total Resource Cost (" TRC ") test as...

AI summary The Industrial Group opposes NSPI's proposed use of the Total Resource Cost (TRC) test for demand-side management (DSM), arguing it inaccurately measures costs and benefits for utilities and customers. They advocate for the PAC test, which accounts for customer incentives and aligns with Nova Scotia's high electricity prices, aiming to lower ratepayer costs. The Public Utilities Act (section 79L(4)) mandates consideration of customer interests.

i. PAC is Not "Too Narrow" and Suite of Tests is not "Cumbersome" and "Complex" E1 claims the PAC test "is too narrow to serve as the main assessment for portfolio-level decisionmaking["](#page-2-0) 5 . The Industrial Group emphasizes that...

AI summary E1 argues the PAC test is too narrow and the proposed tests are complex, while the Industrial Group counters that PAC is foundational and targeted. E1 focuses on environmental goals, whereas PUA mandates cost reduction for NSPI customers. The combination of tests proposed by Mr. Bowman is deemed balanced and not overly burdensome.

cisions with respect to all matters over which it has authority – even decisions that specifically relate to rates, tolls and tariffs, which are decisions that are clearly linked to economic concerns. Further, the host customer non-energy...

AI summary EfficiencyOne (E1) argues that the cost-effectiveness test in the BCA should not be conflated with the full DSM Plan review, emphasizing that the RBIA addresses electricity cost impacts. E1 asserts sustainability considerations are within its mandate under the PUA, and legislative changes do not expand its responsibilities but add considerations. The text references M12282 and discusses jurisdictional limits of regulatory decisions.

2.6 ALTERNATIVE APPROACH FOR ELECTRIFICATION PROGRAMS - Regarding electrification programs, the IG proposes a modified PAC test that includes increased revenues - from electrification as a benefit, aiming to better assess true system costs...

AI summary The IG proposes a modified PAC test for electrification programs, incorporating revenue benefits. E1 argues the PAC test has a 'fundamental flaw' as noted by Dr. Hill. The IG's approach is criticized as a rate-impact test, not cost-effectiveness, conflicting with NSPM and PUA definitions. References to M12282 and evidence from Bowman and E1 are cited.

4.2 CONFLATING DSM PLAN CONSIDERATIONS WITH COST-EFFECTIVENESS SCREENING E1 takes no issue with the "operational requirements" interpretation of NS Power with respect to the approval of DSM programs. However, this Application is not a broa...

AI summary E1 supports aligning DSM cost-effectiveness screening with PUA statutory requirements, opposing NS Power's integration of affordability into the screening test. Affordability should be addressed separately through mechanisms like the Balanced Plan Approach, not via cost-effectiveness criteria. The application focuses on statutory compliance under s. 79H(2) PUA, distinguishing screening from broader DSM plan approval processes.

oes not dictate the proper interpretation of legislation and there remains fundamental disagreement on the impact of the relevant legislative changes since the Board's decision in M08888 on E1's BCAT. First, the PUA remains the governing s...

AI summary The document argues that the PUA governs DSM in Nova Scotia, prioritizing cost-effectiveness over sustainability. It disputes E1's claim that the ERA requires balancing factors, emphasizing the ERBA's directive to 'give consideration' to sustainability without overriding cost-effectiveness. References to Board decision M08888 and ERBA section 6(2) are cited.

Asset Value New equipment, latest technologies improve asset value Water cost impacts Some efficiency measures also reduce water consumption O&M Costs Energy Efficiency (EE) and Electric Vehicles (EV) typically decrease. Demand Response (D...

AI summary The text discusses the impact of energy efficiency (EE) measures and other programs on asset value, water consumption, operational costs, productivity, economic well-being, comfort, amenity, health and safety, empowerment, and pride. It also critiques the relevance of individual benefits to sustainability goals outlined in legislative amendments, emphasizing the need for empirical support to link these benefits to broader sustainability outcomes.

Even more concerning from NS Power's perspective is that the above list of NEBs is then assigned a proxy value and factored into the assessment of broader Host Customer Impacts as listed at Table 14 of Energy Futures Group (EFG)'s evidence...

AI summary The document discusses concerns raised by NS Power regarding the use of proxy values in assessing Host Customer Impacts, particularly in the context of non-efficiency DERs. EFG recommends a generalized approach due to data limitations, while the SBA is reassured by E1's commitment to an evergreen process. NS Power argues that the Board should not approve the PCA without a fully developed and evidence-based framework.

scope to consider all environmental and societal impacts within a benefit cost test is incongruous with the mandate for franchise holders and would expand E1's role, and possibly even NSPI's testing. Similarly, the [Energy and Regulatory B...

AI summary The Industrial Group argues that expanding E1's mandate to include environmental and societal impacts in benefit-cost tests contradicts the PUA's focus on cost reduction and energy efficiency. They also oppose using a global social cost of carbon, claiming it would skew planning processes and exceed the Board's intended authority under the Energy and Regulatory Boards Act.

3.4 Nova Scotia Power [48] NS Power does not support E1's proposed BCA test and recommends the Board approve the current TRC with two modifications which would consider, in the context of strategic electrification, GHG emissions reductions...

AI summary NS Power opposes E1's proposed BCA test, advocating for TRC modifications that include GHG emissions reductions (net tonnage basis) and electricity cost reductions, alongside other fuel impacts. It emphasizes that subsection 79A(b)(iv) of the PUA mandates GHG reductions for strategic electrification but argues this does not override the core objective of reducing electricity costs. NS Power asserts the Board's mandate to ensure 'just and reasonable rates' remains central.

- (b) describe the demand-side management that the franchise holder will provide to Nova Scotia Power Incorporated; - (c) identify the amount that Nova Scotia Power Incorporated will pay to the franchise holder for the supply of demand-sid...

AI summary The Energy Board must review and approve demand-side management agreements between NS Power and E1 under the Public Utilities Act. The franchise holder must provide details on DSMP, payment terms, and justify proposals, while NS Power may develop load management technologies and undertake DSMP activities with Energy Board approval.

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

AI summary The text argues that the interpretation of Section 79A of the Public Utilities Act is incorrect, citing the Atco case to emphasize the Board's limited jurisdiction to rate setting and system integrity.

nergy supply in the Province" in s. 6(2)(c) could alter the requirement in s. 67 of the Public Utilities Act that all tolls, rates and charges shall always, under substantially similar circumstances and conditions in respect of service of...

AI summary The NSUARB interprets the Public Utilities Act (PUA) requiring NS Power to implement demand-side management (DSM) to reduce electricity costs. NS Power complies via a supply agreement with E1. The Industrial Group argues legislative objectives cannot override clear statutory language. The Board finds no ambiguity and confirms NS Power's obligation under the PUA.

[160] Eastward made similar comments in its submissions: In this regard the IG has noted that the approach proposed by Mr. Bowman to costeffectiveness testing for E1 for strategic electrification – running the PAC test with the additional...

AI summary Eastward argues that modifying the PAC test to include NSPI's revenue aligns with Posterity Group's recommendations, emphasizing cost-effective hybrid heating programs. E1 counters that this approach assesses rate impacts, not cost-effectiveness, and criticizes E1's BCA focus on GHG reductions over electricity cost savings.

ORDER EfficiencyOne (E1) applied to the Nova Scotia Energy Board on May 16, 2025, for approval of a New Benefit-Cost Analysis (BCA) Test for Evaluating Demand Side Management (DSM) Plans. The Board issued its Decision on December 10, 2025....

AI summary EfficiencyOne (E1) sought approval for a new BCA test for DSM plans, but the Nova Scotia Energy Board rejected it, directing E1 to use the PAC test instead. The Board mandated NS Power's WACC as the discount rate, required strategic electrification to reduce emissions and costs, and included Eastward in the DSM advisory group. E1 must comply with the Public Utilities Act and provide specific data for DSM plan assessments.