E-1Notice of Application and Evidence
34 passages
1 1. INTRODUCTION 2 The energy landscape in Nova Scotia is in a state of significant change. The ambitious emissions reductions 3 targets under both provincial and federal legislation are fueling a transition to integrating more renewable...
AI summary Nova Scotia's energy sector is undergoing transformation due to provincial and federal emissions targets, with the Energy Reform (2024) Act creating a new Energy Board to regulate sustainable development. The Total Resource Cost (TRC) test is central to evaluating EfficiencyOne's demand-side management (DSM) plans, aligning regulatory assessments with climate policy objectives.
Table 1: Impact Categories Under TRC Test Total Resource Cost Impact Category Sub-Category Utility System Electric • Generation • Transmission • Distribution • General 12 The cost-effectiveness assessment of E1’s current 2023-2025 DSM Plan...
AI summary The document outlines the Total Resource Cost (TRC) test applied to EfficiencyOne's DSM Plan, emphasizing avoided costs in generation, transmission, and distribution. It notes NS Power's current methodology for calculating utility avoided costs and the upcoming transition to the Independent Energy System Operator. The TRC test requires a cost-effective ratio of 1.0 or greater, but the current test is criticized for not aligning with recent legislative changes.
1 6.2 CHANGES UNDER ENERGY REFORM ACT 2 The Energy Reform (2024) Act, SNS 2024, c 2, (“Energy Reform Act”) which was passed in early April 2024, 3 establishes two new statutes: 4 5 • The Energy and Regulatory Boards Act 6 • The More Access...
AI summary The Energy Reform (2024) Act introduces two new statutes, the Energy and Regulatory Boards Act and the More Access to Energy Act, and amends existing energy-related statutes such as the Electricity Act, Gas Distribution Act, and the Public Utilities Act. The Energy and Regulatory Boards Act expands the Energy Board's mandate to consider factors like competition, innovation, and sustainable development in regulatory decision-making.
1 The More Access to Energy Act establishes the following purposes: 2 3 2 The purpose of this Act is to 4 5 (a) increase competition and innovation in the Province's energy sector; 6 7 (b) ensure the provision of a safe, secure, reliable a...
AI summary The More Access to Energy Act aims to increase competition and innovation in Nova Scotia's energy sector, ensure a reliable energy supply, and support sustainable development and prosperity as defined by the Environment Act and Environmental Goals and Climate Change Reduction Act. It also outlines a transition to an independent energy system operator.
ative changes noted above have broadened the scope of what the Energy Board must now 7 consider when assessing the applications that come before it, including those pertaining to DSM activities. 8 9 6.3 LEGISLATIVE MANDATE TO CONSIDER NON-...
AI summary Recent legislative changes have expanded the Energy Board's mandate to consider non-utility impacts, including environmental and sustainability factors, when assessing DSM activities. The Environmental Goals and Climate Change Reduction Act and the More Access to Energy Act now require the integration of GHG reduction targets and sustainable development into regulatory decisions.
rimary costs and the non-utility impacts (other fuel savings and GHG 13 emissions savings) become the primary benefits. Without their inclusion the testing cannot be conducted 14 appropriately. 15 16 6.4 LEGISLATIVE MANDATE TO CONSIDER HOS...
AI summary The text discusses the legislative mandate under the Energy and Regulatory Boards Act, which requires the Energy Board to consider sustainability-focused factors, including impacts on future generations, environmental stewardship, and social responsibility, in its regulatory decision-making.
lance between 5 the materiality of impacts, and the importance of transparency in measuring all relevant impacts. 6 7 Each of these design objectives is discussed more fully in this section. 8 9 8.1 EXTENSIVE DSMAG PROCESS 10 E1 recognizes...
AI summary E1 is developing a new Best Interest of Customers (BCA) test by following a structured DSMAG consultation process and aligning with the NSPM guidelines. This process ensures the test is comprehensive, technology-neutral, and consistent with Nova Scotia legislation and policy goals.
Requirements Federal Energy Regulatory Commission (FERC) Order No. 2222 1 2 3 10.3 NON-UTILITY SYSTEM IMPACTS 4 As explained in the NSPM, best practices suggest that all impacts relating to a jurisdiction’s policy goals 5 and objectives...
AI summary The document outlines the inclusion of non-utility system impacts (N-USIs) in the Best Interest of Customers (BCA) test, emphasizing the need to consider efficiency and distributed energy resources (DERs). It references legislative changes, particularly the More Access to Energy Act, and recommendations from the EfficiencyOne Group (EFG) and the Demand Side Management Advisory Group (DSMAG).
est with 7 Legislative Framework 8 Q: What steps did EFG take to ensure the recommended Nova Scotia BCA test is aligned with and 9 reflects Nova Scotia policy and legislative priorities? 10 A: Conducting an inventory of Nova Scotia’s relev...
AI summary EFG ensured alignment of the Nova Scotia BCA test with policy and legislative priorities by reviewing relevant legislation, including the Public Utilities Act and Energy Reform Act. Amendments to the Energy and Regulatory Boards Act and More Access to Energy Act expanded the scope of impacts considered in regulatory decisions to include sustainable development and prosperity.
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AI summary The document discusses the 01234567897 73 ÿ and its implications on regulatory processes, including the role of various entities and the use of specific methodologies and standards. It references topics such as energy efficiency, demand-side management, and regulatory compliance.
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AI summary The document discusses the implementation and evaluation of energy efficiency programs, focusing on topics such as demand-side management, regulatory compliance, and the impact of various initiatives on energy usage and cost recovery. It also references regulatory processes and stakeholder engagement.
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AI summary The text discusses the importance of regulatory compliance and the need for accurate forecasting methodologies in utility proceedings. It references a variety of regulatory processes, including benefit-cost analyses and prudence reviews, and highlights the role of entities such as Nova Scotia Power and the Office of People’s Counsel in these matters.
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AI summary The document discusses regulatory proceedings related to energy efficiency and cost management in Nova Scotia, including topics such as fuel-cost-adjustment mechanisms, energy efficiency programs, and regulatory compliance. It references various legal and procedural matters and mentions entities involved in these proceedings.
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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 document discusses regulatory proceedings related to energy efficiency programs, including the implementation of demand-side management initiatives and the role of the Nova Scotia Power (NSP) in these efforts. It also covers financial and operational considerations such as cost recovery, fuel adjustment mechanisms, and compliance with regulatory standards.
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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 text discusses the regulation and management of energy systems, including the evaluation of fuel-cost-adjustment mechanisms, the role of the Board in ensuring fair practices, and the impact of various regulatory processes on energy efficiency and affordability. It also touches on the importance of stakeholder engagement and compliance with energy regulations.
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AI summary The text discusses the regulatory proceedings related to the Board of Fuel Costs (BFC) and the Board of Commissioners (BC), focusing on the implementation of the fuel-cost-adjustment mechanism and the impact of the Public Utilities Act (PQR). It references the need for regulatory oversight and the evaluation of cost-effectiveness and compliance.
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AI summary The text discusses the implementation and evaluation of fuel-cost-adjustment mechanisms and related regulatory processes, highlighting concerns about the alignment of base rates with actual costs and the effectiveness of various regulatory approaches in Nova Scotia.
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AI summary The text discusses the regulatory process and considerations related to efficiency programs, including the evaluation of benefits and costs, and references to a National Standard Practice Manual. It touches on the importance of stakeholder engagement and the need for compliance with regulatory standards.
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AI summary This document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the methodology for evaluating energy efficiency programs, including cost-benefit analysis, program evaluation, and regulatory compliance considerations.
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AI summary The document discusses regulatory proceedings related to energy management and utility practices in Nova Scotia, focusing on topics such as fuel-cost-adjustment mechanisms, energy efficiency programs, and regulatory compliance. It also addresses the involvement of entities in these proceedings and references various legal and policy frameworks.
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AI summary The document discusses the regulation of fuel-cost-adjustment mechanisms and their impact on pricing and policy in Nova Scotia. It references proceedings and stakeholder involvement related to efficiency programs and regulatory oversight.
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AI summary The document discusses various aspects of regulatory proceedings related to energy efficiency, demand-side management, and utility regulations in Nova Scotia. It includes references to programs, policies, and regulatory processes involving entities like Nova Scotia Power and EfficiencyOne, as well as topics such as benefit-cost analysis and regulatory compliance.
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AI summary The text discusses the application of a benefit-cost analysis test for EfficiencyOne, referencing regulatory practices and procedures. It touches on topics such as regulatory compliance, cost-effectiveness, and the evaluation of programs and policies.
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AI summary The text discusses regulatory proceedings involving Nova Scotia Power, focusing on fuel-cost-adjustment mechanisms, cost recovery, and the impact of regulatory decisions on utility operations. It references proceedings, stakeholder engagement, and the importance of prudence reviews in ensuring compliance and fair practices.
Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ
AI summary This document is an attachment to a Cost Analysis Test Application and references the National Standard Practice Manual. It appears to be part of a regulatory proceeding, likely related to utility cost analysis and compliance with standard practices.
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AI summary The document discusses the regulatory proceedings related to the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML), including the analysis of cost recovery mechanisms, the impact of fuel-cost-adjustment, and the evaluation of energy efficiency programs. It outlines various regulatory processes, compliance, and stakeholder engagement.
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AI summary The text discusses regulatory proceedings related to energy programs, including the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML). It mentions the Benefit-Cost Analysis (BCD) and Clean Energy (CDE) initiatives, as well as Nova Scotia Power (NSP) and Mandatory Net Output (MNO). The content involves discussions around energy efficiency and regulatory compliance.
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AI summary This text discusses the application of the National Standard Practice Manual in the context of regulatory proceedings, focusing on the implementation of standard practices for utility regulation, including the evaluation of costs, performance metrics, and the use of standardized procedures for compliance and oversight.
energyfuturesgroup.com 30 At the fifth workshop, the working group reviewed quantitative examples and host customer impacts. The working group also discussed the consultant team’s recommendation for host customer non-energy impacts (NEIs)...
AI summary The working group reviewed quantitative examples and host customer impacts, discussing the consultant team’s recommendations on non-energy impacts (NEIs) and societal NEIs. They also reviewed Nova Scotia's applicable policies, including the Energy Reform Act (ERA), which has significant implications for the structure and regulatory authority of the newly created NSEB and the categories of impacts in a new Nova Scotia test.
uncil. The ERA has major implications for the structure and regulatory authority of the newly created NSEB, as well as for the categories of impacts to be included in a new Nova Scotia test. 1. The Energy Reform Act The ERA as passed makes...
AI summary The Energy Reform Act (ERA) introduces significant changes to the Public Utilities Act, expanding the regulatory oversight Board's consideration to include sustainable development and prosperity. The ERA also impacts the structure and regulatory authority of the newly created NSEB and the categories of impacts included in a new Nova Scotia test.
GhG al Policy Section 1: Nova Scotia PRIORITY POLICIES 6 2 6 3 4 4 4 1 NSUARB Mandate NS Power Performance Standards (Public 2 1 2 1 2 Utilities Act) Demand Side Management (Public Utilities 2 1 2 Act) Electricity Act 6 1 1 1 Environmental...
AI summary The text outlines key priority policies in Nova Scotia, including the NSUARB mandate, NS Power performance standards under the Public Utilities Act, Demand Side Management, the Electricity Act, the Environmental Goals and Climate Change Reduction Act, and Nova Scotia’s Climate Change Plan for Clean Growth (2022).
Page 38 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 39 comfort, and health) to societal impacts such as economic output, energy security and reduced environmental and economic damages from G...
AI summary The document discusses the inclusion of non-utility system impacts in a new Nova Scotia Benefit-Cost Analysis (BCA) test, emphasizing the importance of considering broader policy goals such as economic output, energy security, and environmental impacts under the Energy Reform Act (ERA).
E-8See new revised evidence submitted under E-14 (Evidence of P. Bowman, on behalf of IG)
10 passages
BACKGROUND AND CONTEXT - This evidence relies on the following context for E1, and the broad understanding of the regulation of E1 - and the role of the Board. - E1 is the current franchise holder for development and delivery of DSM plans...
AI summary E1, the current franchise holder for DSM in Nova Scotia, requires Board approval for its DSM activities under the Public Utilities Act sections 79A to 79W. The Act distinguishes between DSM operations and purchase agreements with NSPI but treats both similarly in requiring Board approval. However, the legislation lacks explicit guidance on tests for 'reasonable availability' of DSM, focusing instead on cost-effectiveness.
vel: 12 - The Nova Scotia Energy Board retains discretion to allow inclusion of DSM portfolio - components that may not individually satisfy the BCA test. This discretion is grounded in - both the Board's broader mandate to consider planni...
AI summary The Nova Scotia Energy Board retains discretion to include DSM components not meeting BCA individually, considering planning objectives and public interest. E1's responses to IRs from IG and NSEB are referenced, with critiques that E1's quote does not address the Board's power to disallow components and uses wording not in legislation.
Is the E1 commentary a fair criticism of the TRC as previously applied in Nova Scotia? - Yes, from a principled perspective. In general, BCA should include all measurable and meaningful benefits - and costs at the proposed assessment scale...
AI summary The E1 commentary criticizes the TRC for excluding non-energy benefits, but the NSUARB previously limited jurisdiction to energy impacts per M08888. The new Energy and Regulatory Boards Act may permit non-energy considerations, though legal interpretation is pending. Technical challenges remain in revising TRC to meet updated requirements.
Does E1 appear to accurately portray the economic and policy framework for DSM in Nova
AI summary The document evaluates whether E1 accurately represents the economic and policy framework for Demand Side Management (DSM) in Nova Scotia, involving regulatory considerations and stakeholder inputs.
Scotia? 2020 NSUARB 56 M08888, pdf page 2 of 19. - No. - First, although the legislation indicates that cost-effectiveness shall be measured at the portfolio level, - there is no prohibition against also assessing cost-effectiveness at oth...
AI summary The NSUARB must assess DSM cost-effectiveness at multiple granularity levels, not just portfolio level, to evaluate alternatives and ensure compliance with legislative requirements. E1's proposal fails to address mandatory customer interest assessments, including cost reduction, reliability, and availability, as previously interpreted by the Board.
Is the Proposed E1 BCA the only possible response to the criticism? - No. From the outset, the assessment to be conducted was to consider two alternatives to the TRC – - either relying primarily on PAC, or developing a new Nova Scotia spec...
AI summary The Proposed E1 BCA is not the only response to criticism, as three alternatives exist: relying on PAC, developing a Nova Scotia-specific test, or adjusting TRC to include non-energy benefits. Legislative changes enabled the third approach. References include Public Utilities Act sections and a 2020 NSUARB board order.
Why is the E1 proposal on discount rates inconsistent with utility system resources? - In conducting Integrated Resource Planning ("IRP"), utilities typically compare alternative new energy - generation resources using their Weighted Avera...
AI summary The E1 proposal to use a 2% social discount rate for DSM evaluation conflicts with NSPM's requirement for consistent methods, as WACC is standard for utility IRP. Treasury Board guidance cited by E1 applies to regulatory proposals, not infrastructure investments. NSPM mandates equal footing for DSM with other resources using WACC, not lower social rates.
AREAS OF EXPERIENCE: - Utility Regulation and Rates, including Depreciation - Project Development and Planning - Utility Resource Planning
AI summary The document outlines key areas of experience related to utility regulation, project development, and resource planning. It emphasizes expertise in depreciation, utility rate design, and strategic planning for energy resources.
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.
Utility Proceeding Work Performed Before Client Year Oral Testimony NTPC 2001/03 Phase I General Rate Application Analysis and Case Preparation NWTPUB NTPC 2000 - 2002 No - Negotiated Settlement Newfoundland Hydro 2002 General Rate Applica...
AI summary The table presents a list of regulatory proceedings involving various utilities in Canada, detailing the work performed, the regulatory bodies involved, the clients, timeframes, and whether oral testimony was provided. These proceedings include general rate applications, integration hearings, and rider revisions.
E-9Evidence and Resume of Courtney Lane - Synapse
7 passages
I. INTRODUCTION AND QUALIFICATIONS - Q. Please state your name, title, and employer. - A. My name is Courtney Lane. I am a Senior Principal at Synapse Energy Economics, Inc. - ("Synapse"), located at 485 Massachusetts Avenue, Cambridge, MA...
AI summary Courtney Lane, a Senior Principal at Synapse Energy Economics, Inc., describes her firm's expertise in energy regulation, including demand-side and supply-side analysis, energy efficiency, and utility filings. She highlights over 20 years of experience in energy policy, including work on performance-based regulation and grid modernization, prior to joining Synapse at National Grid.
Evidence of Courtney Lane 1 20 programs, and the Energy Reform Act that broadens what the Board should consider 2 when it makes regulatory decisions and establishes the Energy and Regulatory Boards 3 21 Act and the More Access to Energy Ac...
AI summary Courtney Lane discusses the use of the Nova Scotia Policy Model (NSPM) in other jurisdictions, noting that 12 U.S. states and the District of Columbia have adopted it for DER cost-effectiveness tests. She also states that no Canadian provinces have used the NSPM for BCA tests, but sees no reason why they should not. The NSPM is described as objective, policy-neutral, and economically sound.
Q. How does the proposed Nova Scotia Test compare to the TRC? - A. [Table 2](#page-16-0) below provides a comparison between the proposed Nova Scotia Test and the - TRC test as most recently applied in the 2023–2025 DSM Plan. Response to N...
AI summary The proposed Nova Scotia Test is compared to the TRC test in Table 2, referencing the 2023–2025 DSM Plan. The response cites the amended Public Utilities Act (SNS 2022, c 53) and references NSEB IR-01 and IR-07(c).
Q. What is your overall assessment of the proposed Nova Scotia Test? - A. I find that the proposed Nova Scotia Test is an improvement upon the current TRC test. - Unlike the current TRC test, the Nova Scotia Test accounts for both host cus...
AI summary The proposed Nova Scotia Test is considered an improvement over the current TRC test as it accounts for host customer benefits and costs, ensuring proper valuation of DERs and avoiding biased BCA results. It aligns with Nova Scotia's energy policy goals by incorporating non-energy impacts as directed by recent legislation.
Review of Policy Developments Impacting Host Customer NEBs
AI summary The document reviews policy developments affecting Host Customer NEBs, focusing on regulatory frameworks, cost methodologies, and energy management practices in Nova Scotia. Key considerations include DSM, WACC, and GHG regulations, with references to national standards and cost tests.
Nova Scotia Utility Board, Decision in M0888, April 15, 2020, paragraph 49. 1 benefits and an array of environmental benefits with the definition of electricity 2 44 efficiency and conservation activities in the Public Utilities Act. Speci...
AI summary The Nova Scotia Utility Board discusses the reevaluation of cost-effectiveness criteria, incorporating environmental and non-energy benefits, based on recent legislative changes such as the Energy Reform Act and the Environmental Goals and Climate Change Reduction Act. This reevaluation aims to align rate-setting with broader policy goals, including sustainability and market competition.
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.
E-14Evidence of P. Bowman, on behalf of IG - Revised (Old evidence filed under E-8)
6 passages
BACKGROUND AND CONTEXT - This evidence relies on the following context for E1, and the broad understanding of the regulation of E1 - and the role of the Board. - E1 is the current franchise holder for development and delivery of DSM plans...
AI summary E1, the current DSM franchise holder in Nova Scotia, requires Board approval for DSM activities under the Public Utilities Act sections 79A to 79M. The Act links DSM operations and purchase agreements with NSPI, requiring Board review. However, legislative guidance on 'reasonable availability' tests is absent, focusing only on cost-effectiveness within availability constraints.
1 customers qua customer interests (e.g., price, reliability, availability, etc.) which appears to be 2 consistent with the Board's earlier determinations as well.4 This does not appear to prohibit the 3 Board taking into account any numbe...
AI summary The text discusses the Board's consideration of customer interests, including price, reliability, and availability, in line with earlier determinations. It emphasizes that the Board must prioritize the best interests of NSPI customers while adhering to the Energy and Regulatory Boards Act and other legislation promoting competition, innovation, and sustainable development.
Is the Proposed E1 BCA the only possible response to the criticism? - No. From the outset, the assessment to be conducted was to consider two alternatives to the TRC – - either relying primarily on PAC, or developing a new Nova Scotia spec...
AI summary The Proposed E1 BCA is not the only response to criticism. Alternatives include using PAC, developing a new test, or adjusting TRC to balance non-energy benefits. Legislative changes enabled a third approach. Cited sections of the Public Utilities Act and a 2020 NSUARB order (M08888) are referenced.
Why is E1's approach of using balanced plan design problematic? - E1 indicates that in addition to cost-effectiveness, its proposals are designed to reflect balance, such as - equitable allocation of investment and savings between resident...
AI summary E1's balanced plan design approach is criticized for prioritizing equity and access over cost-effectiveness, conflicting with NSPM Principle 1. The NSPM emphasizes cost-effectiveness as the primary DSM test unless explicitly mandated by policy. Nova Scotia's IRP principles (safety, reliability, least cost, decarbonization, robustness) are highlighted as the foundation for resource planning, with balance not typically justified in rate-funded DSM programs.
t 2017-2018): Support in regulatory proceedings before the New Brunswick Energy and Utilities Board on matters of Revenue Requirement, customer class and rate design, and smart meter implementation. For the PEI Federation of Agriculture (2...
AI summary Bowman Economic Consulting Inc. provides regulatory and technical support across various provinces, including rate design, cost of service modeling, revenue requirement analysis, and smart meter implementation. Clients include utility companies, government bodies, and law firms, with projects spanning energy, infrastructure, and environmental regulation.
Utility Proceeding Work Performed Before Client Year Oral Testimony Newfoundland Hydro Rate Stabilization Plan (RSP) Finalization of Rates for Industrial Customers Analysis, Preparation of Intervenor Evidence NLPUB Newfoundland Industrial...
AI summary The text provides a table listing various utility companies, their proceedings, and the work performed in regulatory processes, including analysis, preparation of evidence, and expert testimony. The proceedings involve rate applications, depreciation methodology, and investigations into needs and alternatives.
E-24Rebuttal Evidence of E1 including Appendix A - Energy Futures Group Rebuttal Evidence
9 passages
E1 Response - The argument that the Board can, and must, measure cost-effectiveness at the measure level requires - legislative interpretation and is a legal argument. Questions of law are within the power of the Board to - determine. Nota...
AI summary E1 argues that measure-level cost-effectiveness testing for DSM may hinder proactive market development and reduce overall benefits, advocating for portfolio-level evaluation. The Board previously allowed program-level screening but 2022 legislative amendments now mandate portfolio-level assessment. E1 asserts BCA is primarily a portfolio-level tool but will also be used at lower levels for informational purposes.
2.2.2 N S POWER CUSTOMER INTERESTS Unlike the PAC test, which accounts for only the DSM Administrator's costs and NS Power's avoided costs, the BCA test accounts for the DSM Administrator's costs and customer costs while recognizing the ex...
AI summary The BCA test is preferred over PAC and UCT as it includes customer costs and legislative requirements like those from the Energy Reform (2024) Act, ensuring alignment with sustainable development and ratepayer interests.
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.
3. SYNAPSE EVIDENCE - In response to Ms. Lane's concerns regarding justifying proxy adders, E1 relies on the Rebuttal Evidence of - EFG. E1 addresses Ms. Lane's suggestion for a 2029 updating process below.
AI summary E1 addresses Ms. Lane's concerns about proxy adders by relying on EFG's rebuttal evidence and plans to discuss a 2029 updating process. The response is part of a regulatory proceeding involving demand-side management and non-energy benefits considerations.
E1 Response - E1 supports this recommendation with the addition of a review and update for all impacts—not solely - those related to NEB proxies—commencing prior to the development of the next DSM Plan via the - proposed 'evergreen' proces...
AI summary E1 supports a recommendation to review all impacts, not just non-energy benefits (NEB) proxies, via an 'evergreen' process before developing the next DSM Plan. Engagement with DSMAG is expected to begin in 2029. E1 proposes a multi-step process to ensure the BCA test remains current, including quantifying impacts using jurisdictional data and customer surveys, with DSMAG input.
E1 Response E1 does not support the recommendation for further third-party evaluation, where it has been established these are challenging to quantify, or postponement. E1 maintains that incurring additional costs and extending the timelin...
AI summary E1 opposes further third-party evaluation of non-energy benefits (NEBs) and proxy values, arguing that existing analyses by EFG and DSMAG are sufficient. They propose an 'evergreen' process for ongoing re-evaluation and assert that delaying approval would impose unnecessary costs. The proxy value reflects aggregated NEB estimates, not individual components.
E1 Response E1 interprets this as referring to customer reliability impacts rather than system reliability impacts. - E1 agrees in principle that if a customer's reliability decreases as a result of electrification this should be considere...
AI summary E1 argues that customer reliability impacts from electrification should be considered in host customer proxy impacts, but only when natural gas customers lose backup capabilities or appliances that function without electricity. This would be reviewed via E1's 'evergreen' process, with specific conditions outlined.
Bowman - Mr. Bowman asks that the Board require E1 to show that any avoided GHG emissions are in fact the result - of DSM, and not due to an outside factor such as a cap.[6](#page-29-3)
AI summary Mr. Bowman requests the NSUARB to require E1 to demonstrate that avoided GHG emissions result from DSM programs, not external factors like a cap, emphasizing the need for clear attribution in regulatory proceedings.
Bowman - Mr. Bowman opposes the use of a 2% social discount rate, in favour of the NSPI Weighted Average Cost of - Capital ("WACC") as the discount rate for calculations. He argues: E1 indicates that the social discount rate is appropriate...
AI summary Mr. Bowman opposes the use of a 2% social discount rate, advocating for Nova Scotia Power's (NSP) Weighted Average Cost of Capital (WACC) instead. He argues that E1's reference to the Treasury Board applies to federal policy, not infrastructure, and that NSPM Principle 1 requires Demand Side Management (DSM) to use the same discount rate as utility Integrated Resource Planning (IRP), which is WACC.
100256Board Decision
20 passages
s to address the limitations of the TRC test and enhance the rigour and relevance of DSM cost-effectiveness evaluation consistent with best practices and Nova Scotia-specific legislative requirements. [16] E1 submitted that the proposed BC...
AI summary E1 proposes a Benefit-Cost Analysis (BCA) test to replace the TRC test, aligning with Nova Scotia's policy objectives by incorporating non-utility impacts and long-term benefits like GHG reduction. The BCA test follows the National Standard Practice Manual (NSPM) principles, ensuring comprehensive evaluation of DSM programs per legislative requirements.
3.5 East Coast Environmental Law [56] East Coast Environmental Law (ECEL) is a party to the Consensus Agreement and supports E1's proposed new BCA test as amended by the contents of the agreement. It states in its closing submissions: … We...
AI summary East Coast Environmental Law (ECEL) supports E1's revised BCA test, emphasizing inclusion of avoided carbon social costs in DSM evaluations. It argues that the Energy Reform (2024) Act expands the Board's environmental mandate, aligning regulatory decisions with sustainable development and prosperity goals under multiple acts. ECEL stresses that these new responsibilities complement, not override, affordability and reliability considerations.
3.6 Eastward Energy [61] In its submissions, Eastward Energy asked the Board to make a preliminary and final order that Eastward be added as a full member of DSMAG. On November 4, 2025, the Board noted that Eastward has a valuable perspect...
AI summary Eastward Energy requested DSMAG membership, which the NSUARB approved. They supported strategic electrification testing methods aligning with Posterity Group's recommendations and advocated for hybrid heating in E1's 2027-2031 DSM Plan, emphasizing economic benefits and regulatory alignment with the PUA.
4.1 Demand-side Management Legislation and Policies in Nova Scotia
AI summary The section discusses Nova Scotia's demand-side management (DSM) legislation and policies, highlighting key entities like the Nova Scotia Utility and Review Board (NSUARB) and Nova Scotia Power (NS Power). It references acronyms such as TRC, PAC, and BCA, and mentions the role of programs like DSMAG and the National Standard Practice Manual (NSPM).
4.1.1 Introduction [69] The Public Utilities Act requires NS Power to engage E1 to undertake "costeffective demand-side management". The Board must approve these agreements and "determine the cost-effective demand-side management that must...
AI summary The NSUARB must determine the cost-effectiveness test for demand-side management under the Public Utilities Act. E1 argues the Board now has jurisdiction to consider non-energy impacts, while some intervenors disagree. Legislative amendments since 2020, including the Energy Reform (2024) Act, expanded the Energy Board's consideration scope. The Board will assess statutory interpretation and the meaning of 'cost-effective' in DSM provisions.
4.1.2 Statutory Interpretation [74] Well recognized principles applied by courts and tribunals throughout the country guide the Board when interpreting legislation. A majority of the Supreme Court of Canada summarized these principles in C...
AI summary The text references the Supreme Court of Canada's Vavilov decision, emphasizing that statutory interpretation principles guide the NSUARB. It assumes legislators intended administrative bodies to apply these principles consistently when interpreting laws.
4.1.3 Board Approval of Demand-side Management [78] Before 2010, NS Power undertook its own demand-side management programs. In 2009, responding to growing concerns over the potential inherent conflict between selling electricity and takin...
AI summary Before 2010, NS Power managed its own DSM programs. In 2009, the Legislature enacted the Efficiency Nova Scotia Corporation Act, creating a not-for-profit to administer DSM programs and a fund, with NSUARB approving expenditures. The act aimed to resolve conflicts between electricity sales and demand reduction.
f customers and must be necessarily limited by the statutory definition of "electricity efficiency and conservation activities" outlined in Section 79A(b). - [38] The Board interprets the comments of the Minister of Energy cited by Efficie...
AI summary The NSUARB interprets Section 79A of the Public Utilities Act, requiring NS Power to implement cost-effective electricity efficiency programs without an environmental mandate. It rejects EfficiencyOne's environmental claims and aligns with the Industrial Group's view that regulatory jurisdiction is limited to statutory definitions. The 2014 amendments eliminated the Efficiency Nova Scotia Corporation Act's environmental focus.
4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...
AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The new definition of 'demand-side management' includes strategic electrification, and affordability requirements were removed from legislation previously considered in the 2020 NSUARB decision.
Sustainable prosperity long-term objective - 5 (1) The long-term objective of the Government is to achieve sustainable prosperity. - (2) To achieve its objective of sustainable prosperity, the Government shall - (a) establish, adopt, suppo...
AI summary The Government of Nova Scotia aims to achieve sustainable prosperity through integrated environmental and economic goals, raising awareness of climate change, promoting the clean economy, supporting well-being, enabling innovation, and improving social, environmental, and economic indicators.
4.1.6 The Meaning of "Cost-effective" under the Public Utilities Act [96] From the text used by the Legislature in s. 79I(1) of the Public Utilities Act , it follows that NS Power's statutory duty relates to demand-side management (as defi...
AI summary Section 79I of the Public Utilities Act mandates that NS Power's demand-side management (DSM) must be cost-effective and reasonably available, with the goal of reducing customer costs. The NSUARB must review DSM agreements, ensuring compliance with s. 79I and evaluating cost-effectiveness at the portfolio level. The Act does not explicitly define 'cost-effective,' leaving regulatory interpretation to the Board.
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.
osts. As noted already, strategic electrification may only be undertaken if, in addition to reducing greenhouse gas emissions, it reduces electricity costs. This is explicitly stated in s. 79A(b)(iv). [130] While the NSUARB's 2020 decision...
AI summary The NSUARB discusses jurisdiction over demand-side management (DSM), emphasizing cost reduction under the Public Utilities Act (PUA). It references s. 79A(b)(iv) and s. 79I(1), noting the Legislature's focus on electricity cost reduction. The Board aligns with the Industrial Group and NS Power, affirming that cost reduction remains central despite broader considerations like sustainable development. A prior matter (M12171) is cited regarding economical energy supply obligations.
4.2.1 Findings [151] E1 and its consultants purported to follow guidance in the NSPM in determining the proposed BCA test. However, a process that simply takes account of an inventory of energy and climate change policy goals and objective...
AI summary The NSUARB rejects E1's proposed BCA test for DSM cost-effectiveness, citing misalignment with the PUA's mandate to reduce electricity costs. The TRC test is criticized for asymmetrical application, while the PAC test is endorsed as it aligns with statutory goals. The Board directs E1 to use the PAC test for DSM plans starting in 2027.
4.3.1 Findings [162] The Board accepts the Industrial Group's suggestion that traditional cost effectiveness tests may be modified to suit specific jurisdictional requirements. The means of assessing strategic electrification in Nova Scoti...
AI summary The NSUARB accepts modifying traditional cost-effectiveness tests for strategic electrification in Nova Scotia. E1's approach to demonstrating cost reductions remains incomplete, so it must follow Mr. Bowman's PAC test recommendation temporarily. The Board allows E1 to propose an alternative method in its 2027-2031 DSM Plan if it meets statutory requirements for reducing both GHG emissions and electricity costs.
ty savings, avoided generation, etc. is to use the same discount rate as is used for utility IRP, which is the WACC." Like EFG, Mr. Bowman added that E1 may provide discount rate sensitivity analyses. [179] In its rebuttal evidence, E1 sta...
AI summary The discussion centers on the appropriate discount rate for DSM programs, with E1 advocating for a 2% social discount rate to reflect societal and intergenerational impacts, contrasting with EFG's support for WACC. E1 argues that WACC fails to account for policy goals and GHG emissions, while the Industrial Group questions WACC's applicability to PAC tests. The Board aligns with using the 2% rate for both utility and non-utility costs.
4.5.1 Findings [192] Discounting is a fundamental component of BCA. Applying a social discount rate places greater emphasis on future benefits than a standard discount rate typically would. Environment and Climate Change Canada's SC – GHGs...
AI summary The document discusses the importance of discounting in BCA, noting that Environment and Climate Change Canada's SC-GHG guidance uses a lower discount rate. It criticizes E1 for not following the Treasury Board's policy on when to apply a social discount rate, emphasizing compliance with the Treasury Board's Cost-Benefit Analysis Guide.
s. 7.1 about the discount rate to be used: The discount rate is the rate at which future costs and benefits are converted to their present equivalents. Discounting accounts for the fact that: - there is a time preference for current consum...
AI summary The NSUARB mandates using the opportunity cost of capital (WACC) as the discount rate for DSM programs, aligning with Treasury Board guidelines. This reflects the alternative investment returns of funds from NS Power ratepayers. The Board rejects social discount rates except for long-term regulatory proposals, emphasizing WACC's consistency with NS Power's IRP and PAC test requirements.
4.7 Eastward Energy on DSM Advisory Group [206] Eastward Energy requested the Board order that it be added as a full member of the DSMAG. Although E1 acknowledged Eastward's valuable information and perspectives regarding natural gas hybri...
AI summary Eastward Energy requested to join the DSMAG, arguing its expertise in hybrid peaking resources and legislative mandates under the Gas Distribution Act. E1 opposed, citing narrow focus and potential conflicts, suggesting one-on-one engagement. Eastward emphasized its pilot projects and data on GHG emissions, urging inclusion in the 2027-2031 DSM Plan.
99638Closing Submission - E1
14 passages
to apply the TRC test at the program level starting January 1, 2012. The approach was reconfirmed by the Board in its 2022 decision relating to the E1 2023-2025 DSM Plan Application: [3](#page-3-2) M03669, NSUARB Decision, Efficiency Nova...
AI summary The document discusses the application of the Total Resource Cost (TRC) test at the program level for DSM plans, reaffirmed by the NSUARB in 2022 (M10437). It argues that measure-level TRC testing is restrictive, potentially preventing proactive consideration of market developments and denying equitable access to DSM services. The 2022 legislative amendment under the Public Utilities Act shifted evaluation to the portfolio level.
3.1 OVERVIEW OF RELEVANT STATUTORY PROVISIONS E1 is the franchise holder, granted the exclusive right to supply Nova Scotia Power Incorporated (NS Power) with reasonably available, cost-effective DSM pursuant to section 79A and following o...
AI summary This section outlines the statutory provisions relevant to demand-side management (DSM) in Nova Scotia, including the 2022 amendment to the Public Utilities Act and the 2024 Energy Reform Act . These amendments expanded E1's mandate and the Nova Scotia Energy Board's responsibilities to include sustainable development, climate goals, and the transition to an independent energy system operator.
(b) the franchise holder granted a franchise pursuant to Section 79C of the Public Utilities Act; […] Thereby, these Acts together provide the Energy Board with the authority and direction to consider sustainable development and sustainabl...
AI summary The document outlines the legal framework empowering the Nova Scotia Energy Board to integrate climate and sustainability considerations into its decisions on demand-side management (DSM). This authority is rooted in statutory provisions such as the Energy and Regulatory Boards Act and the More Access to Energy Act, ensuring regulatory decisions align with provincial climate action objectives.
3.2 ALIGNMENT OF PROPOSED BCA WITH STATUTORY PROVISIONS As is discussed further below, E1 asserts that its Proposed BCA aligns with the above-noted policy and legislative objectives of the province, by incorporating utility system impacts,...
AI summary E1 argues its Proposed BCA aligns with provincial policy and legislative objectives by incorporating utility system, fuel, GHG, and health impacts into cost-effectiveness testing. EFG followed NSPM guidelines, while Ms. Lane testified that existing policies, not direct legislation, justify including societal factors like resilience and GHG reduction in the BCA framework.
- against the TRC test which is currently used by the Board for cost-effectiveness testing.[18](#page-12-0) Impact Category Sub-Category BCA Test TRC Test Utility System Electric Generation Transmission Distribution General All All Gas Onl...
AI summary The text discusses the comparison between the BCA test and the TRC test for cost-effectiveness, highlighting differences in impact categories and sub-categories, such as the inclusion of gas commodity costs, societal resilience, and public health impacts. The Proposed BCA does not reduce the utility system impact categories compared to the TRC test.
s it then was) considered the matter of a deferral of DSM funds and whether such deferral would properly be included in the NS Power rate base. In its decision, the Board commented: [33](#page-18-1) The [Department of Energy] DOE raised th...
AI summary The Nova Scotia Utility and Review Board (NSUARB) questioned the inclusion of deferred DSM funds in NS Power's rate base, citing a 7.78% financing cost versus available 3% bank rates. The Board emphasized that DSM, administered by EfficiencyOne (E1), is not a utility capital asset, undermining the use of NS Power's WACC for DSM evaluations. The DOE advocated deferring DSM costs during budget setting, while the Board directed E1 to explore cheaper financing options under the PUA.
4.4 EVERGREEN PROCESS - E1's proposed evergreen process represents a foundational commitment to maintaining the integrity, - relevance, and adaptability of its Proposed BCA framework. This process ensures that the BCA test remains - aligne...
AI summary E1's evergreen process ensures the BCA framework remains aligned with evolving legislation, policy, and market conditions in Nova Scotia. It involves periodic reviews, stakeholder engagement, and collaboration with DSMAG to quantify non-energy impacts. E1 claims no opposition to the process.
as whether DSM activities reduce costs for NSPI customers, from a utility perspective)."[38](#page-21-1) In this application, E1 is proposing that the TRC test be replaced by the Proposed BCA test. EFG, Mr. Wyatt and Ms. Lane agree that th...
AI summary E1 proposes replacing the TRC test with a BCA test, supported by EFG, Wyatt, and Lane as aligned with NSPM and policy goals. SBA concerns were addressed via PCA, with Ms. Whitten supporting zero valuation for non-energy impacts. Ms. Lane initially advocated for lower proxy values but later acknowledged justification for proposed values.
6.1 INTRODUCTION - It is E1's position that the Proposed BCA satisfies the legislative requirements for cost-effectiveness testing, - including new or amended legislative requirements. More specifically, E1 submits that the Proposed BCA -...
AI summary E1 argues that their proposed BCA meets legislative requirements for cost-effectiveness testing, including portfolio-level DSM assessment and sustainable development considerations. They also claim Mr. Bowman's approach fails to satisfy statutory requirements.
6.3.1 E1'S PROPOSED BCA In addressing this matter, it is appropriate to apply the rules of statutory interpretation and consider the relevant provisions "in their entire context and in their grammatical and ordinary sense harmoniously with...
AI summary E1's proposed BCA under the Public Utilities Act outlines statutory obligations for the NSUARB to evaluate DSM initiatives at the portfolio level. The Act requires NS Power to enter DSM purchase agreements with E1, which must be approved by the Board. The evaluation of cost-effectiveness is distinct from high-level portfolio assessments.
ate in the circumstances, whereas I see you coming at it from the other perspective where your focus is on a much narrower net that casts a narrower range of options, but also using secondary tests or M12282, E-14, Evidence of Patrick Bowm...
AI summary E1 challenges the IG's proposed approach, arguing it misaligns with statutory requirements for cost-effective DSM evaluation at the portfolio level, not measure/program levels. The IG emphasizes utility-focused policy objectives, while E1 advocates for broader policy considerations. Legal references to subsection 79H(2) of the PUA are cited.
6.5 ENERGY REFORM ACT
AI summary The section introduces the Energy Reform Act, a legislative framework under consideration in Nova Scotia's regulatory proceedings. It sets the context for discussions involving energy policy, demand-side management, and regulatory oversight, though specific arguments or details are not elaborated in the provided text.
6.5.1 E1'S PROPOSED BCA Fourth, E1 submits that its Proposed BCA allows the Board to give appropriate consideration to the extent to which a cost-effectiveness test can support the goals (including sustainability goals) set out by the Legi...
AI summary E1 argues its proposed BCA aligns with legislative goals, unlike the IG's tests. The Energy Reform Act (2024) mandates cost-effectiveness considerations in Board decisions. Section 6(2) of the Energy and Regulatory Boards Act requires the Board to evaluate cost-effectiveness when approving rates or other matters.
Public Utilities Act , RSNS 1989, c 380, s 79L(5). 1 (a) support competition and innovation in the provision of energy resources 2 in the Province; 3 (b) support the development of a competitive electricity market; 4 (c) ensure the provisi...
AI summary The text references the Public Utilities Act and the More Access to Energy Act, emphasizing the Energy Board's authority over cost-effectiveness testing and DSM Plan applications. It highlights the need to consider Section 6(2) of the Energy and Regulatory Boards Act in these applications.
99640Closing Submission - IG
7 passages
1. THE BOARD CANNOT ACCOUNT FOR BROAD SOCIETAL IMPACTS, OR NON-ENERGY IMPACTS
AI summary The regulatory board acknowledges its inability to account for broad societal impacts or non-energy impacts in its proceedings, highlighting limitations in evaluating broader consequences beyond energy-related considerations.
Background and Principles of Statutory Interpretation This application arose out of the Board's direction to undertake a "thorough assessment of the relative merits of both the PAC test and a jurisdiction-specific test,["](#page-1-0) 2 as...
AI summary The Board directed an assessment of PAC test vs. jurisdiction-specific test for DSM. E1 engaged EFG and DSMAG, but omitted comparative analysis with PAC. Province amended PUA, and E1 argues these changes expanded the Board's jurisdiction over DSM, contrary to prior rulings limiting non-energy impact considerations.
obligations set out in the PUA . As described by Mr. Bowman, E1 is effectively NSPI's "arms and legs"[10](#page-3-4) with respect to efficiency programming. What E1 does has a direct impact on NSPI. The Board has general supervision over E...
AI summary The document outlines obligations under the PUA for cost-effective DSM, emphasizing the Board's role in supervising E1, NSPI's implementation of DSM, and the requirement for programs to benefit customers. E1 is described as NSPI's operational arm for efficiency programs, with the Board ensuring compliance with PUA provisions on cost-effectiveness and customer interests.
The Board Still Cannot Account for Non-energy Benefits The Industrial Group recognizes that certain recent legislative amendments may impact the ongoing interpretation of the PUA provisions. However, the additional factors provide guidance...
AI summary The Industrial Group acknowledges recent legislative changes but argues they don't alter the PUA's focus on reducing electricity costs. E1's environmental goals must align with PUA provisions, not override them. The Board must adhere to statutory mandates, and non-energy benefits aren't within the legislative framework for cost-effectiveness evaluation.
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.
Host Customer Non-Energy Benefits The proposed BCA test suggests that the Board should weigh a number of unquantifiable proposed benefits, including customer pride, empowerment, economic well-being, comfort, amenity, and health and safety....
AI summary The proposed BCA test includes subjective non-energy benefits like customer pride and health, valued via proxy percentages of energy benefits. Critics argue these are vague and unsupported, conflicting with PUA's DSM definition. E1 clarified non-energy impacts, but the Industrial Group opposes proxy adders for intangible benefits. Synapse's consultant Courtney Lane raised concerns about proxy value arbitrariness.
age-17-4) The NSPM acknowledges that a primary test should not be run in a vacuum, and outlines that secondary tests may enhance a regulator's understanding of impacts and programming.[64](#page-17-6) The Industrial Group recognizes the va...
AI summary The NSPM emphasizes the importance of secondary tests alongside primary tests for DSM cost-effectiveness. The Industrial Group supports a primary test and complementary secondary testing in the DSM Plan. E1 must justify non-cost-effective measures using primary test results, aligning with prior Board directives. Mr. Bowman highlights the need for PCT data to assess incentive scales.
99732Reply Submission - E1
8 passages
nable prosperity results in requiring the Board to set aside sustainable development and sustainable prosperity considerations for all important DSM matters under PUA . The IG states: [10](#page-5-0) While the environmental goals articulat...
AI summary The IG argues that the Board must strictly adhere to the PUA without incorporating other policy goals like sustainable development, while E1 contends that the Board's authority under the Energy and Regulatory Boards Act allows consideration of broader policy objectives. The IG claims E1's mandate is limited to cost-effectiveness, whereas E1 asserts that excluding sustainable development contradicts legislative intent.
2.2 CRITIQUE OF HOST CUSTOMER NON-ENERGY IMPACTS AND SOCIETAL IMPACTS The IG critiques the inclusion of non-energy impacts and broad societal costs, which are characterized as vague, subjective, and unsupported by evidence. E1 disagrees. T...
AI summary The IG criticizes non-energy and societal impacts as vague and unsupported, while E1 argues they are backed by academic literature and regulatory precedent, citing multiple experts and noting Mr. Bowman's dissent. E1 emphasizes expert consensus and ongoing evidence development.
2.4 BROAD INTERPRETATION AND SOCIAL COST OF CARBON - The IG warns that adopting a broad societal test could have unintended consequences for other utilities, - potentially leading to inconsistent and unreasonable outcomes. Specifically, th...
AI summary The Industrial Group (IG) warns that using a broad societal test for evaluating E1's programming could lead to inconsistent outcomes, arguing the social cost of carbon (SCC) is not reflected in Nova Scotia energy prices. However, the text counters that SCC represents real societal costs affecting Nova Scotians, even if not directly priced.
6 3.7 SUSTAINABLE DEVELOPMENT AND PROSPERITY CONSIDERATIONS - Eastward cautions against overemphasizing sustainable development and prosperity in benefit-cost tests, - advocating for a balanced approach that considers all legislative requi...
AI summary Eastward cautions against overemphasizing sustainable development in benefit-cost tests, advocating for balance. E1 argues its Proposed BCA test appropriately considers societal impacts as one factor. Eastward Energy warns against applying social cost of carbon to other matters. E1 emphasizes the Board's specific focus on approving the BCA test as a replacement for the TRC test in DSM Plan evaluations.
4. RESPONSE TO NS POWER - NS Power's position regarding the Proposed BCA was first communicated to E1 and the DSMAG in its - Closing Submission. - The Closing Submission invites the Board to narrow Nova Scotia's DSM cost-effectiveness fram...
AI summary NS Power proposes revising the BCA framework to use its WACC and exclude certain benefits, conflicting with post-2022 legislation, the proceeding's record, and NSPM methodology. E1 argues for maintaining the current cost-effectiveness framework, including a 2% discount rate and portfolio-level screening under PUA.
4.1.2 WHY M08888 IS NO LONGER DETERMINATIVE Nova Scotia Power submits that "the Board's decision in M08888 issued April 15, 2020 holds".[38](#page-16-1) M08888, reviewed in the context of the legislative framework that existed at that time...
AI summary Nova Scotia Power argues that M08888 is no longer determinative due to legislative changes since 2020, including amendments to the PUA and new acts requiring consideration of non-energy factors like GHG reduction. The Board's previous jurisdictional limitations have been altered by these updates.
4.3 APPROPRIATE DISCOUNT RATE NS Power asserts that the WACC should be the discount rate for DSM cost-effectiveness screening. NS Power's reliance on WACC as the appropriate discount rate is both legally and conceptually flawed for several...
AI summary NS Power argues for using WACC as the discount rate for DSM cost-effectiveness screening, but opponents claim it is legally and conceptually flawed. They argue WACC misapplies NSPM principles, ignores sustainability and long-term GHG benefits, and undervalues DSM programs. A 2% social discount rate is recommended, aligning with federal guidance and legislative mandates.
5. REQUESTED BOARD ORDER Based the evidence and analysis before the Board in this matter, including as set out in these Reply Submissions, E1 respectfully requests the Board approve the Proposed BCA as supplemented by the PCA, specifically...
AI summary E1 requests the Board to approve the Proposed BCA supplemented by the PCA, including a 2% discount rate, proxy values for the 2027-2031 DSM Plan, and the evergreen process for future DSM applications. The request aligns with PUA 79H(2) and references prior submissions (M12282).
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2.0 PROPOSED BENEFIT-COST ANALYSIS TEST - [8] E1 is the holder of a franchise issued by the Minister of Energy to provide demand-side management activities to NS Power. Under the Public Utilities Act , E1 must develop a demand-side managem...
AI summary E1, a franchise holder under the Public Utilities Act, must develop demand-side management (DSM) plans for NS Power, structured in tiers (measure, program, portfolio). The NSUARB evaluates these plans using cost-effectiveness testing, ensuring measurable benefits for ratepayers and aligning with Nova Scotia's regulatory practices.
3.5 East Coast Environmental Law [56] East Coast Environmental Law (ECEL) is a party to the Consensus Agreement and supports E1's proposed new BCA test as amended by the contents of the agreement. It states in its closing submissions: … We...
AI summary East Coast Environmental Law (ECEL) supports E1's revised BCA test, emphasizing inclusion of carbon social costs in DSM evaluations. It argues that the Energy Reform (2024) Act expands the Board's environmental mandate, requiring alignment with sustainability goals under multiple acts. ECEL stresses that sustainable development and prosperity must be considered alongside affordability and reliability in energy regulation.
4.1 Demand-side Management Legislation and Policies in Nova Scotia
AI summary The section introduces demand-side management legislation and policies in Nova Scotia, referencing key entities and acronyms related to utility regulation and cost analysis frameworks.
4.1.1 Introduction [69] The Public Utilities Act requires NS Power to engage E1 to undertake "costeffective demand-side management". The Board must approve these agreements and "determine the cost-effective demand-side management that must...
AI summary The NSUARB must determine the cost-effectiveness test for demand-side management under the Public Utilities Act, with parties disagreeing on whether non-energy impacts should be considered. Post-2020 jurisdictional changes and the 2024 Energy Reform Act split NSUARB into two boards, expanding the Energy Board's consideration scope. E1 argues the Board now has jurisdiction to include non-energy impacts, while some intervenors oppose this. The Board will assess statutory interpretation and decide on BCA approval if jurisdiction is confirmed.
4.1.2 Statutory Interpretation [74] Well recognized principles applied by courts and tribunals throughout the country guide the Board when interpreting legislation. A majority of the Supreme Court of Canada summarized these principles in C...
AI summary The NSUARB applies statutory interpretation principles from the Supreme Court of Canada's Vavilov decision, assuming legislative intent aligns with these principles for administrative decisions.
4.1.3 Board Approval of Demand-side Management [78] Before 2010, NS Power undertook its own demand-side management programs. In 2009, responding to growing concerns over the potential inherent conflict between selling electricity and takin...
AI summary Before 2010, NS Power managed its own demand-side programs. In 2009, the Legislature enacted the Efficiency Nova Scotia Corporation Act, creating a not-for-profit to administer demand-side management and energy efficiency programs, funded by utility assessments. The NSUARB approved expenditures from the fund, effective January 2010.
- [85] While acknowledging that it had an over-arching public interest mandate in everything it does, the NSUARB noted its principal responsibilities in regulating utilities were to ensure safe and adequate service, just and reasonable rat...
AI summary The NSUARB emphasized its mandate to ensure safe service, just rates, and lowest long-term costs, excluding non-energy benefits. EfficiencyOne argued for broader customer interest consideration, citing 2009 ministerial comments, while the Industrial Group contended the Board's jurisdiction is limited by PUA's statutory definition of electricity efficiency activities.
4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...
AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The Act's definition of 'demand-side management' now includes strategic electrification, while affordability considerations were removed from evaluation criteria.
Sustainable prosperity long-term objective - 5 (1) The long-term objective of the Government is to achieve sustainable prosperity. - (2) To achieve its objective of sustainable prosperity, the Government shall - (a) establish, adopt, suppo...
AI summary The Government of Nova Scotia aims to achieve sustainable prosperity through integrated environmental and economic goals, public awareness campaigns, clean economy growth, well-being initiatives, supportive regulation, and continuous improvement in social, environmental, and economic indicators.
le s. 79V(1)(e) of the Public Utilities Act authorizes the Governor in Council to make regulations defining any word or expression used but not defined in the statute, there are no such regulations. [100] The NSPM is a publication of the N...
AI summary The document discusses the interpretation of 'cost-effective' under the Public Utilities Act , referencing the NSPM's guidance on benefit-cost analysis (BCA). The NSUARB emphasizes that while BCA methodology is not controversial, parties disagree on relevant benefits and costs. Statutory amendments replaced 'electricity efficiency' with 'demand-side management' but retained cost-effectiveness requirements.
(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 grants exclusive rights to Nova Scotia Power Incorporated (NSPI) for cost-effective demand-side management. NSPI must share customer data with franchise holders and cooperate with the IESO on integrated resource planning. Provisions emphasize cost-effectiveness and 'reasonably available' demand-side management, with E1 arguing for a broader benefits-costs test beyond utility impacts.
mandate to consider nonutility impacts in the assessment of cost-effectiveness and says that incorporating sustainability-focused factors into regulatory decision-making is now the law in Nova Scotia: As explained above, the Energy and Reg...
AI summary The Energy Reform Act and related legislation mandate the Energy Board to consider sustainability factors, including environmental stewardship and social responsibility, in regulatory decisions. This includes assessing the environmental impacts of demand-side management programs, promoting energy efficiency, and fostering green jobs.
[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 Eastward's reply submissions emphasize E1's focus on the Board's duty under the Energy and Regulatory Boards Act to prioritize sustainable development in DSM plans. E1 argues that the Board must explicitly address sustainable development, while East Coast Environmental Law notes this responsibility does not override other statutory considerations like affordable energy rates. NSPI aligns with E1's BCA approach, and E1 disputes the Industrial Group's interpretation of legislative changes.
osts. As noted already, strategic electrification may only be undertaken if, in addition to reducing greenhouse gas emissions, it reduces electricity costs. This is explicitly stated in s. 79A(b)(iv). [130] While the NSUARB's 2020 decision...
AI summary The NSUARB examines legislative requirements for demand-side management, emphasizing cost reduction and alignment with sections 79A(b)(iv), 79I(1), and 79H(2) of the PUA. The Board agrees with the Industrial Group and NS Power that cost reduction remains central, rejecting broader interpretations of sustainable development overriding specific cost mandates. References to Matter M12171 highlight tensions between general and specific legislative provisions.
4.2.1 Findings [151] E1 and its consultants purported to follow guidance in the NSPM in determining the proposed BCA test. However, a process that simply takes account of an inventory of energy and climate change policy goals and objective...
AI summary The Board rejects the proposed BCA test for DSM cost-effectiveness due to misalignment with the PUA's focus on reducing customer electricity costs. The TRC test is criticized for asymmetrical application. The Industrial Group supports the PAC test, which aligns with PUA's statutory requirements. The Board directs E1 to use PAC for future DSM plans.
4.4.1 Findings [166] There is no ambiguity in s. 79H(2): the Board must evaluate the proposed cost-effective demand-side management at the portfolio level. As noted previously in this decision, the Board agrees with E1 that there is a diff...
AI summary The NSUARB mandates evaluating cost-effective demand-side management (DSM) at the portfolio level, not individual measures. The Board allows alternative cost-effectiveness tests, including BCA, and requires E1 to justify measures failing primary tests. NS Power's WACC must be compared if a social discount rate is used in BCA. The Energy and Regulatory Boards Act (ERBA) permits justification based on factors under s. 6(2).
ty savings, avoided generation, etc. is to use the same discount rate as is used for utility IRP, which is the WACC." Like EFG, Mr. Bowman added that E1 may provide discount rate sensitivity analyses. [179] In its rebuttal evidence, E1 sta...
AI summary The document discusses the use of discount rates in Nova Scotia's regulatory proceedings, with E1 advocating for a social discount rate (2%) to account for societal and intergenerational impacts, while EFG and others support using WACC. E1 argues WACC fails to reflect regulatory goals, and the Industrial Group questions the application of the social rate to non-GHG costs. E1 clarifies the social rate reflects time value of money for long-term considerations.
s. 7.1 about the discount rate to be used: The discount rate is the rate at which future costs and benefits are converted to their present equivalents. Discounting accounts for the fact that: - there is a time preference for current consum...
AI summary The document establishes that the discount rate for regulatory analyses should be based on the opportunity cost of capital (WACC), as per Treasury Board guidelines. It emphasizes alignment with NS Power's IRP and the Public Utilities Act, rejecting social discount rates except for specific long-term cases. The NSUARB mandates WACC for cost-effectiveness testing of DSM programs, citing NS Power's funding source and the need for comparable evaluations.
5.0 SUMMARY OF BOARD FINDINGS [217] The Board finds it does not have the authority to approve E1's proposed BCA because the Public Utilities Act restricts the Board's ability to consider non-energy and societal benefits in assessing the co...
AI summary The Board rejects E1's proposed BCA due to the Public Utilities Act's restrictions on non-energy benefits. E1 must use PAC test and NS Power's WACC for DSM plan assessments. Strategic electrification requires GHG reduction and cost savings. Eastward is added to DSMAG. Portfolio-level cost-effectiveness evaluations are mandated.