Topic:"Regulatory Oversight" in M12282

...............................................9 5.1 Portfolio Level Evaluation............................................................................................................ 9 5.2 Jurisdiction to Consider Non-Energy Impacts ....

AI summary The document outlines sections addressing portfolio-level evaluation, jurisdiction to consider non-energy impacts, legislative changes to the Public Utilities Act and Energy Reform Act, and E1's efforts to develop a new Best Interest of Customers (BCA) test. It includes directives for cost-effectiveness testing and updates to Nova Scotia's policy objectives.

ii EfficiencyOne Benefit-Cost Analysis Test Application Evidence Table 5: Comparison of Input Categories for TRC Test and Proposed New BCA Test............................... 26 Table 6: Electric System Impact Categories .....................

AI summary EfficiencyOne's application introduces a new BCA test for evaluating energy efficiency programs, contrasting with the existing TRC test. Tables and figures outline impact categories (system, fuel, societal) and DSM planning terminology. Appendices include evidence from David Hill and a jurisdictional BCA framework by Energy Futures Group.

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.

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.

6, 2025 Page 19 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 • Session 6 - July 15, 2024: the DSMAG reviewed and discussed societal impacts beyond 2 greenhouse gases, host customer impacts, and societal non-energy...

AI summary The document outlines the steps taken by EfficiencyOne and EFG in developing the new BCA test, following the NSPM procedure. It highlights the DSMAG's involvement in reviewing societal impacts and providing feedback on the EFG report.

rgy Management and Policy Planning at the University of Pennsylvania. 26 Further details on my work experience and education are provided in my professional resume, included 27 as Attachment 1. Direct Testimony of David G. Hill, Ph.D. / Ma...

AI summary The testimony discusses the expert's experience in regulatory hearings and their recommendations for a benefit-cost analysis framework for Nova Scotia, developed in collaboration with EFG, E1, and the Demand Side Management Advisory Group (DSMAG).

e the primary objectives for developing a new Nova Scotia benefit cost test? 13 A: Aligned with guidance from the NSPM the objectives of this work were to develop a Nova Scotia 14 test that: 15 • Includes jurisdictionally specific impact c...

AI summary The primary objective of developing a new Nova Scotia benefit-cost test is to align with local policy priorities, ensure balanced consideration of costs and benefits, and provide a transparent and flexible framework for evaluating energy system investments. EFG worked with EfficiencyOne and the DSMAG to develop the test through structured meetings and feedback sessions.

and analysis of energy efficiency and demand response in Dominion’s 2020 IRP. Docket No. 2019-226-E. 2019 Efficiency One 2020-2022 DSM Plan: Portfolio Diversification and Lighting Transition. Expert Witness Testimony submitted on behalf of...

AI summary This text lists various expert witness testimonies and presentations related to energy efficiency, demand response, and utility regulation, including matters involving Nova Scotia Power, Efficiency Nova Scotia, and the Office of People’s Counsel in Maryland and Pennsylvania.

Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual 0123ÿ516789ÿ 1ÿ1ÿÿÿ 0179ÿ1ÿ778ÿ189ÿ72982ÿ 78ÿ 127ÿ 0778ÿ 88ÿÿ 7827ÿ ÿ 07ÿ7...

AI summary This document is an attachment from an EfficiencyOne Benefit-Cost Analysis Test Application, referencing the National Standard Practice Manual. It contains various sections and references related to energy efficiency programs and regulatory processes.

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AI summary The text appears to be a list of sections or headings from a regulatory proceeding document, likely related to energy regulation in Nova Scotia. It includes sections on various topics such as benefit-cost analysis, test for regulatory compliance, and other regulatory processes.

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AI summary This text discusses the regulatory considerations for energy efficiency programs, including the evaluation of program effectiveness, stakeholder engagement, and the implementation of energy efficiency initiatives. It touches on the importance of program evaluation, performance monitoring, and the role of regulatory oversight in ensuring program success.

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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 implementation and evaluation of a fuel-cost-adjustment mechanism, highlighting its impact on base rates and the need for alignment with actual costs. It also touches on the role of efficiency programs and regulatory oversight in managing energy resources and ensuring equitable outcomes.

ost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ

AI summary The text references an 'ost Analysis Test Application' and 'Attachment 2: National Standard Practice Manual,' suggesting the document pertains to a regulatory process involving compliance and standard practices.

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AI summary The text lists various topics and sections related to regulatory proceedings in Nova Scotia, including energy efficiency programs, rate structures, and regulatory processes. It includes references to entities such as Nova Scotia Power and the Building Code Division, as well as various regulatory and legislative topics.

ost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ

AI summary The text references an 'Ost Analysis Test Application' and 'Attachment 2: National Standard Practice Manual,' suggesting a regulatory process involving standardized practices and testing procedures.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 43 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"#ÿ%&'(ÿ) #+ ,#-ÿ./ÿ01#ÿ2...

AI summary This document is an appendix from a regulatory proceeding related to the EfficiencyOne Benefit-Cost Analysis Test Application. It references the National Standard Practice Manual and outlines procedures and standards for conducting benefit-cost analyses in regulatory contexts.

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AI summary The text discusses the National Standard Practice Manual and its application in a cost analysis test, focusing on practices related to regulatory compliance, standard procedures, and the evaluation of cost-related matters within a regulatory framework.

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AI summary The document discusses the UVWX mechanism and its implications, including concerns about its design, implementation, and impact on stakeholders. It addresses the need for clarity, fairness, and alignment with regulatory goals, and outlines various considerations and recommendations for improvement.

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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 the regulation of energy and utility matters, focusing on the 2027-2031 Demand-Side Management Preferred Resource Plan, energy efficiency, and the role of the Board in oversight and compliance. It mentions the evaluation of programs and their impact on customers, as well as regulatory processes.

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AI summary The text discusses regulatory proceedings involving energy efficiency programs, fuel cost adjustments, and legal frameworks. It references legislative acts and regulatory processes, including compliance and stakeholder engagement. Key topics include energy efficiency, affordability, and regulatory oversight.

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AI summary The text discusses the regulation of energy and utility matters in Nova Scotia, focusing on topics such as energy efficiency, cost recovery, and regulatory processes. It references regulatory proceedings, cost mechanisms, and energy policies, emphasizing the role of the Board and the importance of stakeholder engagement in decision-making.

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AI summary The text discusses the implementation and evaluation of a fuel-cost-adjustment mechanism in Nova Scotia, highlighting concerns about its effectiveness and potential for creating perverse incentives due to delays in base rate adjustments. It also explores the broader implications for energy pricing and regulatory oversight.

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AI summary The text discusses the Nova Scotia Power (NOP) and its role in regulatory proceedings, including the application of fuel-cost-adjustment mechanisms, the impact of cost-of-capital proceedings, and the evaluation of the efficiency of programs and services. It also touches on the regulatory oversight of energy and utility matters in Nova Scotia.

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AI summary The text discusses the regulatory process in Nova Scotia, focusing on the mechanisms and policies related to energy management and cost adjustments. It references specific regulatory proceedings and mentions the importance of aligning base rates with actual costs.

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AI summary This text discusses the analysis of a regulatory proceeding involving Nova Scotia Power (NOP) and the Hydro-Informatics and Jurisdiction (HIJ). It references the Benefit-Cost Analysis Framework (678) and discusses topics such as energy efficiency, cost recovery, and program evaluation in the context of regulatory oversight and stakeholder engagement.

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AI summary The text discusses the regulation of energy costs and the implementation of mechanisms such as the fuel-cost-adjustment and the impact of these mechanisms on pricing and customer affordability. It emphasizes the need for accurate cost recovery and the importance of regulatory oversight in managing energy-related financial obligations.

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AI summary The text references a regulatory proceeding involving Nova Scotia Power and the Affordable Bill Cap, discussing topics related to rates, energy efficiency, and regulatory processes.

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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 text discusses the impact of the fuel-cost-adjustment mechanism on pricing and the need for alignment between base rates and actual costs. It also references the role of the Board in addressing these issues and the importance of regulatory oversight in ensuring fair and effective energy policies.

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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 is part of a regulatory proceeding and includes an appendix referencing the EfficiencyOne Benefit-Cost Analysis Test Application and an attachment citing the National Standard Practice Manual. It appears to be related to energy efficiency programs and regulatory processes.

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AI summary The document discusses the Fuel Adjustment Mechanism (FGH) and its impact on Nova Scotia Power (NSP). It highlights issues with the mechanism, such as delays in base rate adjustments and potential perverse incentives. The text also references the 234 program and the :;< mechanism, emphasizing concerns related to cost recovery and regulatory oversight.

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AI summary The text discusses the regulatory process and proceedings related to energy and utility matters in Nova Scotia, including topics such as the Board's proceedings, fuel-cost-adjustment mechanisms, and other regulatory considerations. It mentions entities involved in these proceedings and outlines the context of the discussions.

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AI summary This text discusses the regulation of energy costs in Nova Scotia, focusing on the fuel-cost-adjustment mechanism, its impact on base rates, and the need for alignment between rates and actual costs. It also touches on the role of regulatory oversight and the importance of prudence reviews in ensuring fair and effective energy policies.

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AI summary The text discusses the regulation of energy costs and the impact of fuel-cost-adjustment mechanisms on rate structures. It highlights the need for alignment between base rates and actual costs and mentions the role of regulatory oversight in managing these adjustments.

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AI summary The text discusses the role of the Nova Scotia Utility and Review Board in reviewing and approving various aspects of utility regulation, including the handling of costs, rates, and financial mechanisms. It references the importance of ensuring fair and reasonable utility practices and the impact of regulatory decisions on consumers and providers.

Tÿ Tÿ Tÿ Tÿ UVÿWXIWÿFYGYÿZIYÿ[Mÿ[WXGMÿ\FGHYÿ W[ÿZGJGMIWGÿGHG]WMN]NW^ÿ]IJÿ fGHNIONHNW^ÿ Tÿ Tÿ ]MGIWGÿ][YWYÿ[MÿWXGYGÿN_ I]WYÿ fGYNHNGJ]Gÿ Tÿ Tÿ T8ÿr7ÿ8s ÿsÿvÿÿs 6ÿ678ÿÿts7ÿ8ÿt7ÿ8s sÿ su7ÿTÿÿ7r6ÿÿtsÿ 87ÿ8ÿ 7uÿwÿ6...

AI summary The text discusses regulatory proceedings related to energy management and utility operations in Nova Scotia, mentioning topics such as demand-side management, energy efficiency, and regulatory oversight. It includes references to various programs, policies, and entities involved in energy regulation.

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AI summary The text discusses the Board of Commissioners (BC) and the Board of Fuel Costs (BFC), indicating their involvement in proceedings related to fuel costs and other regulatory matters. Specific details are not provided due to the text being incomplete or corrupted.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 153 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 document discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It mentions the application of benefit-cost analysis in regulatory proceedings and refers to a specific test framework used in the process.

ULÿKNGGHÿQMENHRÿLKÿZEFZ\ÿZFMERQZUMEKHGHÿTME\HNÿELMÿXF RIRLFXÿFErMGNEXFELKVÿ\GN]MVFÿ Rÿ uvwx[Dwÿ[NX\VMKEQFÿ Oÿ LNÿQUKGHFÿLUKEÿYUKLÿLUFIÿZMRQUKGHFÿFEFGKVVIÿGFWTMGFÿXNGFÿFEFGHIÿ P ÿQ N R LÿS FQK T RFÿR LN G K H F ÿ L F Q U E N VN H MF Rÿ H yK...

AI summary The text appears to be a portion of a regulatory proceeding document from Nova Scotia, discussing topics related to energy management, fuel costs, and regulatory processes. It references various programs, entities, and regulations that are relevant to the energy sector and utility governance.

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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 regulation of energy utilities in Nova Scotia, focusing on the management of costs, the implementation of programs, and the evaluation of regulatory processes. It outlines the role of the Board in overseeing energy efficiency initiatives and the importance of aligning billing procedures with regulatory standards.

CFAB_ÿBCTÿGCFMA_TB[ÿ VBAGBFGHCQÿ\BzGCOÿGFÿMDRMEGBPP[ÿG\RHAFBCFÿFHÿBEEHWCFÿSHAÿFNMÿTMFBGPMTÿFG\MÿRMAGHTDÿFNBFÿFNM[ÿBAMÿM{RMEFMTÿ FHÿHRMABFMtÿ @NMÿ8ÿ2 8ÿRAGCEGRPMÿAM}WGAMDÿBEEHWCFGCOÿSHAÿYHFNÿAMTWEMTÿBCTÿGCEAMBDMTÿBGAÿM\GDDGHCDÿSAH\ÿ aa...

AI summary The text discusses the regulation and management of energy and utility services, including the evaluation of cost mechanisms, regulatory processes, and the impact of policy decisions on utility operations. It references proceedings and evaluations related to fuel-cost-adjustment and the role of regulatory oversight in managing utility services.

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.

!# #&"ÿ!&'(>ÿÿ KLMLNÿ PQRSTUVQÿXYZQUR[]ÿ^Z_ÿ̀SZaUSbÿ E-'ÿ'$&#&"ÿ&-&ÿ/1$(ÿ$+ÿ /$&!/0(ÿ+#(&!#3)&'+ÿ(&/!%'ÿ, "ÿAA' &ÿ&-'ÿ;:685;4:<6ÿ /(&I'AA' &# '$'((>ÿJ$ÿ (/,'ÿ ('(ÿ&-'ÿ'$&#&"ÿ/1$#$%ÿ&-'ÿ(&/!%'ÿ,#%-&ÿ3'ÿ+#AA'!'$&ÿA!/,ÿ&-'ÿ'$&#&"ÿ /$&!/00#$%ÿ...

AI summary The text discusses the regulation of fuel-cost-adjustment mechanisms and their impact on rate-setting processes, emphasizing the need for alignment between base rates and actual costs. It highlights concerns about perverse incentives and the importance of regulatory oversight in ensuring fair and effective pricing structures.

!ÿ#$#%&'()(% &(+,ÿ ./01ÿ2/34567ÿ861270961ÿ5/6ÿ96:6;051ÿ3:8ÿ2<151ÿ=<15ÿ76>6?3:5ÿ5<ÿ6>62570;02350<:ÿ761<@7261AÿB5ÿ086:50;061ÿC6Dÿ ;325<71ÿ5/35ÿ3;;625ÿ6>62570;02350<:ÿ96:6;051ÿ3:8ÿ2<151ÿ3:8ÿ47<?0861ÿE@083:26ÿ<:ÿ38876110:Eÿ2<==<:ÿ 2/3>>6:E61ÿF...

AI summary The text discusses the importance of the fuel-cost-adjustment mechanism and its impact on rate-setting, emphasizing the need for accurate cost recovery and alignment of base rates with actual costs. It highlights the role of regulatory oversight in ensuring fair and effective energy pricing and service delivery.

=C; A>:6=ÿ~s€spt‚ÿB6O>7EBÿ6BB@;>6<9FÿZ> 7?=6B<=C; B<=>DC<>@7ÿ@?ÿ J9<=@:9CAÿJ=@FC; <>@7Vÿ9:9;<=>?>;6<>@7ÿ@?ÿDC>:F>7EBÿ;67ÿ@DO>6<9ÿ 7Eÿ :F>7EBÿ<@ÿ B<=>DC<>@7ÿB8B<9AÿI>7;:CF>7Eÿ>7B<6::6<>@7ÿ@?ÿ6ÿE6BÿA9<9=KVÿB6O>7Eÿ @7BPÿSG>Bÿ ;67ÿ@;;C=ÿ>7ÿ...

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.

"'ÿ.ÿ)"'"%")!8:ÿ60)$-'10 1+4ÿ$912"2ÿ/0)ÿ&!.1'"0ÿ$+2ÿ%"$0,!1+4ÿ&!4!$%ÿ1%&$/)0ÿ31''ÿ2"&"+2ÿ+ÿ) "ÿ '"9"'ÿ.ÿ4!$+,'$!1)8ÿ.ÿ$9$1'$-'"ÿ2$)$ÿ=)"%&!$'ÿ$+2ÿ'/$)1+$'D:ÿ6#10)1+4ÿ+j01)"ÿ)"/ +'48ÿ%$8ÿ-"ÿ '1%1)"2ÿ1+ÿ&!9121+4ÿ) "ÿ'"9"'ÿ.ÿ2$)$ÿ4!$+,'$!1)8ÿ...

AI summary The document discusses the 5670 program, a demand-side management initiative, and its implementation challenges. It references the need for adjustments in fuel costs, regulatory oversight, and the evaluation of energy efficiency programs. The text also touches on the importance of stakeholder engagement and the role of the Nova Scotia Power (NSP) in these proceedings.

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AI summary The text discusses regulatory proceedings related to energy and utility matters, including topics such as fuel-cost-adjustment mechanisms, rate proceedings, and cost-of-capital proceedings. It references specific matters and board orders, indicating a focus on regulatory oversight and compliance.

ÿ!"+#$ %"#ÿ!$ÿ ÿ&$! 4-$ÿ$-(%!" 2ÿ2! 4ÿ 6 %#3ÿ($!^#,ÿ)!$- +#8ÿÿ Xÿ27ÿÿj \ÿT,-ÿ+- +!"ÿ "4ÿ#%5-ÿ!)ÿ#,-ÿTUVÿ6- dÿ&-%"(ÿ 44$-++-4ÿ^%22ÿ 2+!ÿ%56 #ÿ!+#S -))-#%7-"-++.ÿ&- '+-ÿVkl+ÿ!6-$ #-ÿ #ÿ4%))-$-"#ÿ#%5-+ÿ4-6-"4%"(ÿ!"ÿ#,-ÿ+- +!"ÿ "4m!$ÿ#%5-ÿ...

AI summary The document discusses the implementation of the TUV mechanism, referencing the /01 framework and the Vkl program. It highlights the integration of the TUV mechanism with the /01 and the Vkl program, including discussions on cost recovery, program evaluations, and regulatory oversight.

1#ÿ#""# &,ÿ)%ÿ'1)!#ÿ ),&,ÿ2,##ÿ 3# &!)%ÿ4565785ÿ9%ÿ&+#ÿ ',#ÿ)"ÿ:;3ÿ!%!&!'&!1#,<ÿ&+#ÿ!%&#$' &!1#ÿ#""# &,ÿ)%ÿ'1)!#ÿ ),&,ÿ'$#ÿ=!>#=?ÿ&)ÿ -#ÿ,0'==<ÿ.%=#,,ÿ'%ÿ.%&!=ÿ&+#ÿ!%!&!'&!1#,ÿ$#' +ÿ+!@+ÿ$'&#,ÿ)"ÿ#(=)?0#%&5ÿ AÿCDEÿÿCDÿ66 5ÿ;+#%ÿ0.=&!(=...

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.

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.

National Standard Practice Manual ÿ !"#$%ÿ'() +ÿ,-,ÿ.%/#01!23ÿ4%1ÿ5261ÿ5#$7%ÿ ÿ 278 8ÿ9:ÿ8ÿ:;7: ÿ<=;>ÿÿÿÿ:8ÿ8ÿ ÿ68:8ÿÿ;; <ÿ>ÿ ?@AÿBCDAÿBEFG@DÿDEBHÿIDÿAHJDÿCK@ÿBIKÿL@ÿED@MÿNCFÿD@G@FIOÿPEFPCD@DQÿRCFÿ@SITPO@Uÿ VÿX...

AI summary The text discusses the National Standard Practice Manual, with sections on procedures, regulations, and standards, particularly related to energy efficiency, cost analysis, and regulatory compliance. It includes references to benefit-cost analysis tests and regulatory processes.

_hmÿ dhkKJLMÿ NOPÿnÿXkoÿWkghÿ fpÿ STiÿ PVWXYZM[ÿVMMZMZÿjkKÿZ_lMKg_hmÿ dhkKJLMÿ NOPÿnÿ^_L^ÿWkghÿ Spÿ STQÿ qrWXYZM[ÿ\N]ÿXkosÿVkhÿVMMZMZÿjkKÿZ_lMKg_hmÿ dhkKJLMÿ ]Mg_ZMVh_JXÿnÿXkoÿWkghÿ tÿ STfÿ PVWXYZM[ÿVMMZMZÿjkKÿZ_lMKg_hmÿ dhkKJLMÿ ]Mg_ZMVh_...

AI summary The text appears to be a fragmented and encoded regulatory document related to energy management and proceedings. It includes references to energy efficiency, demand-side management, and regulatory processes, though the content is not clearly legible or structured.

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AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on base rates, noting a lag of 18 months between actual costs and base rates, which created perverse incentives. It also references the need for regulatory oversight and evaluation of cost-effectiveness in energy programs.

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AI summary The text discusses the regulation and management of energy systems, including topics such as fuel cost adjustments, energy efficiency programs, and the role of regulatory bodies in ensuring proper oversight and compliance. It also touches on the implementation of various programs and the evaluation of their effectiveness.

!ÿ#$%&'()ÿ+$+,-'ÿ./&%%(%0ÿ 1234567ÿ8943363:ÿ8;47<67=>ÿ499?@ÿA<696<6=>ÿ<?ÿ5?;=ÿB2345674992ÿ?8<656C=ÿ1DE>ÿ43Bÿ54F656C=ÿ 2><=5IÿJG=>=ÿ<28=>ÿ?KÿB234567ÿ8943363:ÿ8;?7=>>=>L;=K=;;=Bÿ<?ÿ4>ÿ63<=:;4<=BÿB6><;6MA<6?3ÿ 8943363:ÿNO1PQÿK?;ÿB6><;6MA<6?3R...

AI summary The document discusses the regulation of energy and utility services in Nova Scotia, focusing on cost recovery, rate design, and the impact of various programs on customers. It highlights the importance of aligning rate structures with actual costs and ensuring fair treatment of consumers.

K?;ÿ7?584;63:ÿ43Bÿ?8<656C63:ÿ B6KK=;=3<ÿ;=>?A;7=>Iÿ !kÿ( aY[lVma_[ ÿ iG48<=;>ÿnÿ 7A>>ÿG?@ÿB6KK=;=3<ÿ1DE>ÿ743ÿM=ÿ4>>=>>=Bÿ63ÿ6>?94<6?3ÿA>63:ÿ ÿIÿ iG48<=;>ÿooÿ 7A>>ÿG?@ÿrsÿÿ743ÿM=ÿA>=Bÿ<?ÿ4>>=>>ÿ1DE>ÿ;=94<6H=ÿ<?ÿ4ÿ>...

AI summary The document discusses the implementation of a fuel-cost-adjustment mechanism and its impact on base rates, highlighting challenges such as lagging rates and the need for adjustments. It also addresses the evaluation of programs and the importance of regulatory oversight in managing energy-related matters.

bÿDNJAPEJNÿTG NDÿC_DGFQ_ÿC_NÿRABCDAEFCAGHÿQDARÿPCÿPÿJG ÿOGBCaÿUCÿCKTAOPJJKÿ_PBÿHGCÿPOOGFHCNRÿ ^GDÿ@c[BÿPBÿPJCNDHPCAMNBÿCGÿCDPRACAGHPJÿRABCDAEFCAGHÿBKBCNZÿCNO_HGJGQANBaÿÿ U@Wÿ_PBÿDNONHCJKÿNMGJMNRÿPBÿPÿZGDNÿOGZTDN_NHBAMNÿ̀PKÿ^GDÿRABCDAEFCAGH...

AI summary The text discusses regulatory proceedings related to energy and utility matters in Nova Scotia, including topics such as rate adjustments, fuel costs, and energy efficiency programs. It also touches on legal and procedural aspects of these proceedings.

ÿ 278 ?ÿ@AÿBC DEÿ FGÿHIJKLMLÿNJLÿOPQQÿMHQPLÿRGNLSNKHQÿGOÿTUVWXÿPNKQKNKLWÿSLLYÿNGÿZGNJÿHYMHSILÿNJLK[ÿRQHSSKS\ÿR[GILWWLWÿ]K^L^ÿ _T ÿHSYÿOPQQaWbWNLcÿRQHSSKS\dÿHSYÿLSJHSILÿGRL[HNKGSHQÿIHRHZKQKNKLW^ÿeKNJGPNÿNJLÿ[LfPKWKNLÿGRL[HNKGSHQÿ IHRHZKQK...

AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism in Nova Scotia, highlighting concerns about its impact on base rates and the need for adjustments to align with actual costs. It also mentions the importance of regulatory oversight and the evaluation of various programs and initiatives.

Attachment 2: National Standard Practice Manual ÿ

AI summary This document is an attachment referencing the National Standard Practice Manual, likely used as a regulatory guideline or procedural framework within the Nova Scotia regulatory proceeding.

@1:6ÿ?:2@2KÿWU55ÿ/3I95ÿ̀EaKXÿ [ÿ 7ÿÿÿDA:Bÿ<=>ÿA52:HA?52ÿ;199ÿ4H@ÿH4;3A7ÿ4A522HA5ÿ:6ÿA3@52Kÿ>57H?57ÿ23952ÿ9537ÿ@:ÿ 9:2@ÿA5F56H52ÿ;01?0ÿB1J0@ÿA5VH1A5ÿ16?A53257ÿA3@52ÿ16ÿ:A75Aÿ@:ÿA5?:F5AÿD1857ÿ?:2@2ÿ:F5AÿD5;5Aÿ 23952Kefÿ [ÿ] 8ÿÿ...

AI summary The text discusses the regulation of energy rates and the challenges faced by the utility sector in Nova Scotia, including the impact of fuel-cost adjustments and the need for regulatory oversight. It highlights the importance of aligning base rates with actual costs and the role of the Board in ensuring fair and reasonable practices.

?:C9:D?>ÿC9:ÿHIJ@ÿA7ÿA=ÿA<<:? ÿF?a?FOÿEA:7FMÿC9:ÿ78?ÿ =??>ÿ79ÿY??Eÿ78?ÿA=AFM@?@ÿ@BDEF?ÿA=>ÿAGG?@@BPF?OÿA=>ÿEA:7FMÿP?GA;@?ÿG;@79D?:@ÿWBFFÿ?VE?:B?=G?ÿ78?ÿ:A7?ÿ BDEAG7@ÿC:9DÿHIJ@ÿB=ÿA=ÿA<<:? ÿCA@8B9=Qÿb;:78?:Oÿ:?<;FA79:@ÿA=>ÿ978?:ÿ@7AY?89F>?:...

AI summary The text discusses the regulation and management of energy efficiency programs, including the implementation of fuel-cost-adjustment mechanisms, the evaluation of cost-recovery strategies, and the role of regulatory oversight in ensuring equitable and effective program delivery. It emphasizes the importance of aligning policy with program performance and stakeholder engagement.

3171L578ÿ8b<17Dÿ6;?68A?9BÿW?;7:8Aÿ;471;?ÿ19ÿ7;ÿA8E1917ÿ9;38ÿ;@ÿ7:8ÿHIJÿ=891L?9ÿ7;ÿ@1?=ÿ F5D9ÿ7;ÿ=821E8Aÿ7:83ÿ57ÿ2;F8Aÿ6;97ÿm8BLBGÿ@1?=1?Lÿ7:1A=V45A7Dÿ@1?5?61?Lÿ;AÿA8b<1A1?Lÿ:;97ÿ6<97;38A9ÿ7;ÿ45Dÿ 1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ...

AI summary The text appears to be part of a regulatory proceeding document, including a benefit-cost analysis test application related to EfficiencyOne and a reference to the National Standard Practice Manual. It discusses topics such as cost-benefit analysis and regulatory procedures.

ÿ !"#ÿ%&'(ÿ) +,-.#ÿ/"#0#12+2 31ÿ34ÿ531&6#",ÿ%7#"+#ÿ83,9 1#:ÿ; ..ÿ<,-+=20ÿ on ]n pHM@E CBOÿq?PPÿXOGLVTKÿhnk ^n E]n Y[ lTHBL@C ZZ ZPCVTB?Q?VLT?HM Eon Ygÿhijk ZjK EFn DPPÿYZ[K Emn ÿ >?@ABCÿDEFÿGBHI?JCKÿLMÿCNLOGPCÿHQÿLÿAKCQAPÿRLSÿTHÿGBCKCMTÿTU...

AI summary The text discusses the implementation and evaluation of the fuel-cost-adjustment mechanism in Nova Scotia, highlighting its impact on base rates and the need for alignment with actual costs. It references the importance of regulatory oversight and the role of the Board in managing energy costs and ensuring fair practices.

:9:ÿ9;79ÿ@88=>ÿ@Aÿ7Aÿ7AA=70ÿG7:4:ÿ7A?ÿ7>Bÿ8@00B89B?ÿGFÿ=940494B:ÿB78;ÿ FB7>ÿ:;@=0?ÿGBÿ788@=A9B?ÿD@>ÿ4Aÿ9;BÿFB7>ÿ9;BFÿ7>Bÿ8@00B89B?ÿD>@5ÿ=94049Fÿ8=:9@5B>:Hÿh764970ÿ8@:9:ÿ :;@=0?ÿGBÿ75@>94iB?ÿ@EB>ÿ9;Bÿ>B_=079@>FÿG@@Oÿ04DBÿ@Dÿ9;Bÿ4AEB:95BA9Hÿ...

AI summary The text discusses the regulation of energy costs, including the fuel-cost-adjustment mechanism, the impact of delayed base rates on incentives, and the need for adjustments in energy pricing. It also highlights the importance of regulatory oversight and stakeholder engagement in managing energy resources and ensuring equitable access to services.

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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.

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AI summary The document discusses the application of the fuel-cost-adjustment mechanism and its impact on rate structures, including the role of the $8<+ in managing costs and the implications of the mechanism on pricing and regulatory oversight.

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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.

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AI summary The text discusses the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML), referencing benefit-cost analysis (BCD) and clean energy (CDE). It also mentions Nova Scotia Power (NSP) and Mandatory Net Output (MNO), and outlines procedures related to energy programs and regulatory processes.

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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.

1234ÿ678ÿ9 67ÿ ÿ76ÿ8 ÿ 8ÿ78 ÿÿ  ÿ DATE FILED: May 16, 2025 Page 282 of 302 Appendix A - EfficiencyOne Benefit-Cost Analysis Test Application Attachment 2: National Standard Practice Manual ÿ !"!#$ÿ#%$ÿ&!&'(!)#'$ $(#+,...

AI summary The text discusses the EfficiencyOne Benefit-Cost Analysis Test Application and references the National Standard Practice Manual. It outlines the process for evaluating benefit-cost analyses, emphasizing the importance of accurate cost and benefit calculations in regulatory proceedings.

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AI summary The document discusses the regulation of fuel-cost-adjustment mechanisms and the impact of delayed base rates on incentives. It highlights the need for alignment between base rates and actual costs and the importance of regulatory oversight to ensure fair practices and effective cost recovery.

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AI summary The text discusses the implementation and evaluation of a fuel-cost-adjustment mechanism, emphasizing its impact on rate structures and the need for alignment between base rates and actual costs. It also highlights the importance of regulatory oversight and the role of fuel-cost-adjustment in ensuring fairness and transparency in utility pricing.

! !.$+/ÿ!\0!!(ÿ+!ÿ)&#$&15!ÿ0-/+/ÿ-.ÿ +!ÿ"#-,#&%/4ÿt ! ÿ5&#,!5'ÿ.$\!(ÿ"-#+.-5$-ÿ0-/+/ÿu!V2&5ÿ+-ÿ&1-2+ÿmvÿ"!#0! +ÿ-.ÿ+!ÿ/2%ÿ-.ÿ+!ÿ.$)!ÿ "#-,#&%ÿ0-/+/wÿ&#!ÿ&((!(ÿ+-ÿ+!ÿ/2%ÿ-.ÿ+!ÿ)&#$&15!ÿ$%"&0+/ÿ-.ÿ+!ÿ.$)!ÿ"#-,#&%/7ÿ+!ÿ"-#+.-5$-ÿ$+/!5.ÿ$/ÿ /-...

AI summary The text discusses the regulation and management of energy costs, including the use of fuel-cost-adjustment mechanisms and the impact of rate-setting on affordability and cost recovery. It references the need for alignment between base rates and actual costs and the role of regulatory oversight in ensuring fairness and efficiency in energy pricing.

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AI summary The text discusses the implementation of a fuel-cost-adjustment mechanism and its impact on base rates, highlighting potential misalignments between actual costs and rate structures. It also touches on the role of regulatory oversight in addressing these issues.

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AI summary The text discusses the regulation of utility rates and the importance of aligning base rates with actual costs to avoid perverse incentives. It emphasizes the need for accurate cost recovery mechanisms and the role of regulatory oversight in ensuring fair and reasonable pricing for customers.

alysis Test Application Attachment 2: National Standard Practice Manual ÿ ÿ"87ÿ#878$ÿ$# ÿ&'(ÿ) +&,-.ÿ/(01'(ÿ1'ÿ2)-314-ÿ&56ÿ&784.- (5-.ÿ01'ÿ0'((9')7('.3)+ÿ&57ÿ .+)::1;('<ÿÿ ÿ1 ÿ#878$ÿ$# ÿ)5,:47(ÿ&784.- (5-.ÿ01'ÿ0'((9')7('.3)+ÿ&57ÿ...

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.

! "ÿ $%&'() +ÿ,-.+)(/ÿ0-'ÿ$+ÿ1+&'234100()(&+5ÿ1)-+-%3ÿ6$,11178ÿ9:9:8ÿ; 8 ÿ 8ÿ66 <ÿ278ÿ ÿ9 8ÿ278ÿÿ= ÿ3878>8ÿ?'&@ '&AÿB3ÿC'(D E5 D FÿG E5( +Fÿ$% ++FÿH-/AFÿ +Aÿ H'-EEB&'28ÿI55@EJKKLLL8 )&&&8-'2KE(5&EKA&0 ./5K0(/&EK@A0EKB9...

AI summary The text appears to be a portion of a regulatory proceeding document from Nova Scotia, involving discussions on energy efficiency, rate structures, and stakeholder engagement. It references various proceedings, regulations, and entities involved in the energy sector, but lacks detailed arguments or claims.

Utility Gas Emissions  emissions System Other Estimated health impacts from Societal Environmental  PM, SO2 and NOx air pollutants Embedded in other Public Health E Environmental and GHG Economic Should be addressed outside of Developmen...

AI summary The text discusses the categorization of impacts related to gas emissions, public health, and environmental considerations, emphasizing the need for separate studies outside the BCA framework. It references the structure of these categories and their sub-elements described in the report.

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).

Utility outreach to trade allies, technical training, marketing, Program Administration administration/management, & evaluation of effort to promote DERs Incentives offered to utilities to encourage successful, effective Utility Performanc...

AI summary The text discusses various aspects of utility operations, including outreach, program administration, risk management, system reliability, resilience, and compliance with regulatory requirements. It highlights efforts to promote distributed energy resources (DERs), incentives for utilities, and the importance of adhering to regulatory standards such as FERC Order 2222.

(b) Confirmed. Please refer to EFG's Report[1](#page-23-0) 1 , Summary Table 1, page 12. 2 3 (c) Yes, with the above noted exception that the proposed Nova Scotia Jurisdictional Test 4 (NSJT) test will not address green jobs creation and s...

AI summary The Energy Board is not explicitly required to assess job market or economic growth impacts, but EfficiencyOne argues that these considerations align with broader sustainability and innovation objectives under the Energy and Regulatory Boards Act. These impacts are indirectly reflected in benefit-cost analysis through host customer and societal benefit categories.

res Group (EFG). (a) Appendix E of the National Standard Practice Manual (NSPM) provides an overview of the five "traditional" screening tests and a discussion of the perspectives associated with each test. It notes that a jurisdiction ado...

AI summary The document discusses the proposed new primary test for Nova Scotia, which includes all material electric utility system impacts, program administration, and incentive costs for E1, as well as host customer costs and benefits and societal impacts. It also mentions that the participant cost test and non-participant cost tests are best used in a supplemental fashion for program design and assessing rate impacts.

(a) Please refer to EfficiencyOne's (E1) response to NSEB IR-03 part (a). (b) Please refer to E1's response to NSEB IR-03 part (a). (c) The process and workshops conducted by EFG focused on the development of a jurisdictional test, based o...

AI summary The document references EfficiencyOne's response to NSEB IR-03 part (a) and discusses the development of a jurisdictional test for distributed energy resources (DERs) by EFG, based on the NSPM. The test is recommended to be applied at the portfolio level for all DERs, with information on screening at the measure and program level provided for informational purposes.

dix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 42 of 68. Ibid., page 45 of 68. - i) The EFG report contains citations for comparative information...

AI summary The EFG report discusses the use of proxy values for non-energy impacts in a jurisdictional benefit-cost analysis (BCA) framework for Nova Scotia. It acknowledges that while detailed survey research could provide more accurate estimates, it would be too resource-intensive. Instead, the proxy method is recommended as a practical and cost-efficient approach, with the evergreen process allowing for future refinement of these values.

1 Request IR-10: 2 3 Refer to the EFG Report on page 17, which states "The gas utility system non-commodity 4 impacts are not recommended for quantification for the new jurisdictional test. Additional 5 data on gas system costs would be re...

AI summary The document discusses the definition and applicability of non-commodity impacts on gas utility systems, particularly in relation to distributed energy resources (DERs) in Nova Scotia. It also asks about the data required to quantify these impacts and whether they will be addressed in future filings.

- (c) Please refer to EfficiencyOne's (E1) response to NSEB IR-22. - (d) It is not determined at this time whether E1 will qualitatively or quantitatively address the non-commodity gas system impacts. EFG's recommendation is that for this...

AI summary The text discusses EfficiencyOne's (E1) response to a regulatory inquiry and Energy Futures Group's (EFG) recommendation regarding the appropriate method for addressing non-commodity gas system impacts in the Nova Scotia benefit cost analysis (BCA) test. EFG suggests using the commodity cost of gas as a proxy for system impacts, citing discussions with the Demand Side Management Advisory Group (DSMAG).

- Refer generally to the EFG Report and the DSMAG stakeholder process for developing the - proposed Nova Scotia Test. Please provide a summary of all non-consensus issues. For each - non-consensus issue, please identify which organizations...

AI summary The text requests a summary of non-consensus issues in the proposed Nova Scotia Test, identifying organizations that did not support the consensus and alternative positions. It refers to EfficiencyOne's response to NSEB IR-09 for details.

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.

- directed to conduct a "thorough assessment of the relative merits of both the PAC test and a jurisdiction- - specific test" in order to "determine the optimal cost-effectiveness testing methodology for Nova Scotia." 5

AI summary The document directs a thorough assessment of the PAC test and a jurisdiction-specific test to determine the optimal cost-effectiveness testing methodology for Nova Scotia.

- decision making tool to approve or reject the DSM Plan as is the case with the approved screening test." 8 - This includes the following: - "E1 currently provides and intends to continue to provide the results from the Program Administra...

AI summary E1 proposes using the Benefit-Cost Analysis (BCA) as the primary decision-making tool for approving DSM Plans, while providing Program Administrator Cost (PAC) results for informational purposes. E1 argues that non-binding metrics like PAC and BCA at the measure/program level will inform portfolio development, which also considers criteria such as balanced investment and equitable access. The NSUARB retains discretion to evaluate DSM components beyond the BCA.

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.

benefits). Public Utilities Act, s.79H(1). Public Utilities Act, s.79L(4). Public Utilities Act, s.79I(1). 2020 NSUARB 56 M08888, paragraph 33, pdf page 15 of 19. Public Utilities Act, s.79L(4).

AI summary The text references multiple sections of the Public Utilities Act (s.79H(1), s.79I(1), s.79L(4)) and cites a 2020 NSUARB decision (M08888, paragraph 33, pdf page 15 of 19), indicating legal and regulatory considerations in the proceeding.

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.

ro system resiliency study in response to Snare River drought. For New World Dairy (2015-2017): Assist in negotiations regarding Non-Utility Generation and interconnection with Newfoundland Hydro For Yukon Energy Corporation (2005 - 2015):...

AI summary The text outlines past involvement in energy-related projects across Canada, including resource planning, environmental assessments, and regulatory interactions. Key activities include project management for hydroelectric developments, expert testimony before regulatory bodies, and negotiations with utility providers in Newfoundland, Yukon, Northwest Territories, and Manitoba.

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.

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 - types. The recommended way to address this is to include such impacts but indicate those - that are "not applicable" or "not material."

AI summary Courtney Lane's evidence discusses addressing impacts in regulatory proceedings by including them but noting those that are 'not applicable' or 'not material.' The approach emphasizes clarity in distinguishing material from non-material considerations.

Q. How will the Nova Scotia Test be used to determine cost-effectiveness? - A. As was done in the prior DSM Plans, E1 will conduct the BCA at the measure, program - component, program, resource, and portfolio (i.e., Plan) levels and will m...

AI summary The Nova Scotia Test will evaluate DSM Plans' cost-effectiveness at the portfolio (Plan) level, per the November 9, 2022, Public Utilities Act amendment. E1 will conduct BCA analyses at multiple levels, but the Board's evaluation focus has shifted from program to portfolio level.

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. Should the Nova Scotia Test include other fuels? A. Yes. There are several policies and energy goals that support the inclusion of other fuels, such as natural gas, fuel oil, propane, and gasoline and diesel for electric vehicles, in th...

AI summary The Nova Scotia Test should include other fuels like natural gas and propane to align with climate policies and electrification goals. The Climate Change Plan for Clean Growth and amended Public Utilities Act support this, emphasizing reduced heating oil use and strategic electrification. The Energy Reform Act and related legislation also expand regulatory considerations to include sustainable development and host customer impacts.

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.

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.

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.

Pennsylvania Program design, implementation planning, regulatory support, technical reference manual development and portfolio cost-effectiveness tool for Columbia Gas of Pennsylvania. Assisted - with testimony before the Pennsylvania Publ...

AI summary Activities include program design, regulatory support, and testimony preparation for energy companies in Pennsylvania before the PUC. Involves Columbia Gas, Philadelphia Gas Works, UGI Gas, and Peoples Natural Gas, with multiple docket numbers spanning 2006–2022. Focuses on energy efficiency, cost-effectiveness analysis, and portfolio design.

Wisconsin Portfolio and project cost-effectiveness calculator development. Cost-effectiveness analysis, assistance with contractor selection and regulatory support for 3-year energy-efficiency portfolio for Focus on Energy in Wisconsin. Ju...

AI summary A 3-year energy-efficiency portfolio project for Focus on Energy in Wisconsin (2011–2013) involved developing a cost-effectiveness calculator, conducting analyses, supporting contractor selection, and providing regulatory assistance.

Texas - Cost and savings analysis on proposed Public Utility Commission rules for utilities pursuing statutory DSM savings goals, on behalf of the Sierra Club. May-June 2012. - Analysis of and report on achievable savings and costs for Aus...

AI summary Analysis of Texas Public Utility Commission rules on DSM savings goals for utilities, conducted for the Sierra Club (May-June 2012), and a report on energy efficiency resource acquisition options for Austin Energy, commissioned by the Austin City Council (April 2012). Both efforts focus on cost and achievable savings assessments.

Illinois Portfolio and project cost-effectiveness calculator development. Cost-effectiveness analysis, assistance with contractor selection and regulatory support for 3-year energy-efficiency portfolio for Peoples Gas in Illinois. Septembe...

AI summary Development of a cost-effectiveness calculator for Peoples Gas Illinois' 3-year energy-efficiency portfolio (2008-2012), including analysis, contractor selection support, and regulatory assistance.

of C&I market transformation and retrofit programs. The project included performance of measure and program level quantitative cost-effectiveness analysis and budgeting, relying on both primary and secondary data sources. Involved with fol...

AI summary The text outlines work on energy-efficiency programs, cost-effectiveness analyses, and consulting for organizations like the National Academy of Sciences and Pennsylvania Public Utility Commission. Projects include developing DSM tools, evaluating energy-saving potential, and creating technical manuals for utility merger applications. Focus areas include C&I market transformation, rebate calculations, and savings algorithms (1998–2006).

- E1's second rationale for why in its view Eastward should not be part of the DSMAG, is that the - DSMAG members have expertise in DSM and strategic electrification, and Eastward's primary - focus on the promotion of fossil fuels use does...

AI summary E1 argues Eastward's fossil fuel focus conflicts with DSMAG's mandate, while Eastward highlights its expertise in gas technologies and alignment with GDA's framework. Eastward emphasizes its role in hybrid peaking resources and data on gas emissions, countering E1's claim that its participation contradicts regulatory goals.

1 The SBA represents a constituency of small businesses who receive service under three of 2 NS Power's rate classes, specifically the Small General, General and Small Industrial 3 classes. These small businesses pursue investments they ho...

AI summary The Small Business Advocate (SBA) represents small businesses affected by NS Power's rate classes and emphasizes the need for a Benefit-Cost Analysis (BCA) that minimizes DSM Plan costs while achieving energy policy goals. The SBA stresses that the BCA should not lead to increased costs for customers without corresponding benefits and highlights the importance of reliability and consistency for small businesses during Nova Scotia's energy transition.

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.

INTRODUCTION - This Pre-filed Testimony has been prepared by Mr. Patrick Bowman of Bowman Economic Consulting Inc., - retained by the Industrial Group ("IG") of Nova Scotia. This testimony reviews and assesses the 2025 - EfficiencyOne ("E1...

AI summary Mr. Patrick Bowman of Bowman Economic Consulting Inc., retained by Nova Scotia's Industrial Group, provides pre-filed testimony assessing Efficiency One's 2025 Application to implement a new Benefit-Cost Analysis Test for Demand Side Management Plans. The Application was filed with the Nova Scotia Energy Board on May 16, 2025. Bowman emphasizes his role as an independent, objective witness with extensive experience in utility regulation and energy efficiency.

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.

- decision making tool to approve or reject the DSM Plan as is the case with the approved screening test."[8](#page 1-9) - This includes the following: - "E1 currently provides and intends to continue to provide the results from the Progra...

AI summary E1 proposes using the BCA test for DSM Plan approval, committing to provide PAC test results and other data for informational purposes. It suggests non-binding metrics like PAC and BCA at measure/program levels will inform portfolio development, while the NSUARB retains discretion to consider non-BCA compliant components. E1 emphasizes balanced portfolio design and equitable sector allocation.

Does E1 appear to accurately portray the economic and policy framework for DSM in Nova Scotia? 2020 NSUARB 56 M08888, pdf page 2 of 19. - No. - First, although the legislation indicates that cost-effectiveness shall be measured at the port...

AI summary The document states E1 does not accurately portray the DSM framework in Nova Scotia. The NSUARB must assess cost-effectiveness at granular levels beyond the portfolio level to meet legislative requirements, including evaluating alternative DSM plans. E1's proposal fails to address customer interests, which the Board mandates as central to DSM assessments.

benefits). Public Utilities Act, s.79H(1). Public Utilities Act, s.79L(4). Public Utilities Act, s.79I(1). 2020 NSUARB 56 M08888, paragraph 33, pdf page 15 of 19. Public Utilities Act, s.79L(4).

AI summary The text references sections of the Public Utilities Act (s.79H(1), s.79I(1), s.79L(4)) and cites a 2020 NSUARB board order (M08888, paragraph 33) in a regulatory proceeding context.

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 principles requiring consistent methods with utility IRP (using WACC). Treasury Board guidance cited by E1 applies to regulatory proposals, not infrastructure investments, and emphasizes uniform discount rates for cost-benefit analysis.

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 in utility regulation, including depreciation, project development, planning, and resource planning. These areas reflect expertise relevant to regulatory proceedings in Nova Scotia's energy sector.

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.

ro system resiliency study in response to Snare River drought. For New World Dairy (2015-2017): Assist in negotiations regarding Non-Utility Generation and interconnection with Newfoundland Hydro For Yukon Energy Corporation (2005 - 2015):...

AI summary The text outlines involvement in energy-related projects across multiple jurisdictions, including resource planning, environmental assessments, and regulatory reviews for organizations like Yukon Energy Corporation, Northwest Territories Power Corporation, and Tolko Manitoba. Activities include project management, expert testimony, and interconnection negotiations.

Utility Proceeding Work Performed Before Client Year Oral Testimony Yukon Energy Corporation Final 1997 and Interim 1998 Rate Application Analysis and Case Preparation Yukon Utilities Board (YUB) Yukon Energy 1998 No Manitoba Hydro Curtail...

AI summary This table lists various utility proceedings with details on the utility, proceeding type, work performed, regulatory body, client, year, and whether oral testimony was provided. Each entry outlines legal and regulatory work conducted by utilities and clients in different jurisdictions.

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-1: - Reference: Exhibit E-9, page 6-7. - Synapse cites Step 1 as being to articulate Nova Scotia's applicable policy goals related - to distributed energy resources (DER). - (a) Please confirm or otherwise explain whether Synaps...

AI summary Request IR-1 asks Synapse to clarify whether it considered the Public Utilities Act's requirement that DER activities must serve customers' best interests, whether a broader BCA test aligns with policy goals, and if adopting a PAC test would conflict with Nova Scotia's policy objectives. The inquiry centers on regulatory interpretations of DER policy and evaluation methodologies.

Response IR-1: - (a) Synapse considered the factors that the Energy Board must take into account when evaluating whether a DSM application is in the best interest of customers. See response to IR-1(b). - (b) Synapse's understanding is that...

AI summary Synapse evaluated factors for the Energy Board's DSM application, citing the Energy Reform Act and Energy and Regulatory Boards Act as expanding regulatory considerations to include sustainable development, prosperity, and GHG emission reductions.

Synapse Energy Economics Responses to the Industrial Group Information Requests NON-CONFIDENTIAL test to the utility function. A BCA test that only links benefits/costs to the utility function is essentially the PAC (also known as the util...

AI summary Synapse Energy Economics argues that the BCA test (PAC/UCT) does not align with Nova Scotia's policy goals, as noted in Courtney Lane's evidence. The Energy Board evaluates DSM plans at the portfolio level, not individual DER measures. Synapse contends that DER measures with cost-effective BCA results, including non-energy benefits, are 'useful' and 'used' once operational.

aft proposals from the Massachusetts Department of Environment on different elements of the state's forthcoming Clean Heat Standard regulations. Co-authored white paper on

AI summary The text references proposals from the Massachusetts Department of Environment related to the Clean Heat Standard regulations, alongside a co-authored white paper on the topic. The Energy Futures Group, Inc. is contextually linked to the proceeding.

Energy Efficiency in Buildings, Volume 5 (with Marty Kushler) - Energy Efficiency as a Resource in the ISO New England Forward Capacity Market , in Energy Efficiency, published on line 06 June 2010 (with Cheryl Jenkins and Shawn Enterline)...

AI summary The document lists publications focused on energy efficiency in buildings, including studies on energy efficiency as a resource in electricity markets, comparative analyses of energy programs, and community-based strategies. Key authors include Marty Kushler, Cheryl Jenkins, and Blair Hamilton, with contributions from organizations like the British Department of Energy and Climate Change and the Energy Trust of Oregon.

- Newfoundland Energy Solutions Potential Study: Newfoundland Power Inc. (Nov. 2023 ongoing) - Technical Reference Manual (TRM) Jurisdictional Review: Enbridge Gas Inc. (Nov.2023 Apr. 2024) - Data Development: Building Decarbonization Alli...

AI summary The document lists energy efficiency and market research studies conducted by organizations like FortisBC, NRCan, Enbridge Gas Inc., and others from 2019 to 2024. Projects span feasibility studies, decarbonization, retrofits, and energy benchmarking, highlighting collaborative efforts in energy policy and technology development.

2.1 PORTFOLIO-LEVEL SCREENING

AI summary The section outlines portfolio-level screening processes, likely involving evaluation of energy programs and initiatives. Key entities include Nova Scotia Power and related organizations, with acronyms such as BCA and DSM referenced. The context suggests a regulatory analysis framework.

Bowman Scotia.[1](#page-4-2) He states: The evidence of Patrick Bowman of Bowman Economic Consulting Inc., for the Industrial Group, represents the only intervenor party to take issue with E1's position that cost-effectiveness screening of...

AI summary Patrick Bowman of Bowman Economic Consulting Inc. challenges E1's position that DSM cost-effectiveness should be assessed at the portfolio level, arguing that the legislation allows for granular assessments at program or measure levels. He asserts the Board must evaluate alternative DSM plans at various scales to ensure cost-effectiveness and compliance with statutory mandates, including customer interests and reasonable program availability.

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.

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

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

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

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

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

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

Eastward Eastward Energy argues for inclusion in the DSMAG. In particular, it notes: [...T]his Application is the first time that E1 has substantively referred to the potential for it to start strategic electrification, and has in its Appl...

AI summary Eastward Energy seeks inclusion in the DSMAG to contribute expertise on gas-to-electric conversions and strategic electrification, emphasizing their role as a natural gas supplier and hybrid peaking resource facilitator.

- Ontario, PEI, Saskatchewan, Newfoundland and Labrador, and Yukon. This PAC test also has the 1 M12282 - EfficiencyOne 2 Application for a Benefit-Cost Test 3 Opening Statement of Patrick Bowman 4 5 6 EfficiencyOne ("E1") is proposing to...

AI summary EfficiencyOne is proposing a new primary test for conducting Benefit-Cost Analysis (BCA), addressing concerns with the previous Total Resource Cost (TRC) Test, which was unbalanced by not fully accounting for customer cost savings. EfficiencyOne's chosen approach is considered inferior.

irement that DSM must reduce electricity costs for customers, but includes many suggested benefits that, if taken into account, could increase electricity costs for customers (although from a societal perspective, customers could still be...

AI summary The NSUARB finds the Public Utilities Act limits consideration of non-energy benefits in DSM cost-effectiveness assessments, requiring use of the PAC test. While the Act restricts broader considerations, the Board retains discretion to evaluate specific DSM measures for sustainable development alignment when plans meet cost-effectiveness criteria.

ns broadened the Board's mandate to include sustainable development, sustainable prosperity, and climate goals aligned with the Environmental Goals and Climate Change Reduction Act ., SNS 2021, c 20. - [14] In accordance with the NSUARB's...

AI summary Nova Scotia expanded the NSUARB's mandate to include sustainability and climate goals under the Environmental Goals and Climate Change Reduction Act. E1, working with DSMAG and Energy Futures Group, proposed replacing the TRC test with a new BCA test to address its narrow scope and exclude environmental benefits, aligning with modern legislation and best practices.

3.2 Industrial Group [34] The Industrial Group is not a party to the Consensus Agreement. It objects to the use of the proposed BCA test as the new primary cost-effectiveness test. It recommends the Board approve the PAC test as the primar...

AI summary The Industrial Group opposes using the BCA test for DSM Plan applications, advocating instead for the PAC test at portfolio, program, and measure levels. They argue the Board should exclude non-energy impacts like carbon social effects. The group also highlights changes to the Public Utilities Act that expanded DSM to include strategic electrification, emphasizing cost reduction as the Act's focus.

tes" and that the "listed factors in section 6(2)(a-e) [of the Energy and Regulatory Boards Act ] supplement, but do not replace, the Board's primary mandate." In its closing submissions, it states: The operative phrase of section 6(2) is...

AI summary Nova Scotia Power (NS Power) argues that section 6(2) of the Energy and Regulatory Boards Act requires 'appropriate consideration' of factors without imposing prescriptive requirements. It contends that 'sustainable development' in the More Access to Energy Act does not mandate non-utility impacts in benefit-cost analysis (BCA) and asserts that E1 has failed to link host customer benefits to 'sustainable development'.

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.

rect test to track the DSM policy objective of a reduction of costs for customers set out in section 79I of the Public Utilities Act . [Footnotes omitted] [Eastward Energy Closing Submissions, p. 8] [64] In relation to NS Power's marginal...

AI summary Eastward Energy argues that NS Power's use of average emissions rates is inappropriate due to future reliance on low-efficiency fossil fuels, advocating for marginal emissions rates. They challenge E1's BCA test results for heat pump replacements (BCR 0.50), deeming them insufficient for strategic electrification and requesting regulatory guidance on justification thresholds.

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.

- [117] A court interpreting a statutory provision does so by applying the "modern principle" of statutory interpretation, that is, that the words of a statute must be read "in their entire context and in their grammatical and ordinary sen...

AI summary The text discusses the 'modern principle' of statutory interpretation, emphasizing that statutes must be read in context, grammar, and alignment with legislative intent. It references court cases ( Rizzo & Rizzo , Bell ExpressVu ) and the Interpretation Act , highlighting consistency with text, context, and purpose in both judicial and administrative interpretations.

- (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 NSUARB must review and approve demand-side management purchase agreements between NS Power and E1 under the Public Utilities Act. The Energy Board establishes a process for reviewing applications, requiring franchise holders to provide information to justify proposed DSM. NS Power may rely on the franchise holder's expertise.

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

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

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 Public Utilities Act (PUA) authorizes defining terms like 'cost-effective' through regulations, though none exist. The NSPM, a U.S.-based stakeholder publication, discusses benefit-cost analysis (BCA) for distributed energy resources. E1 submitted the NSPM as evidence. The NSUARB acknowledges BCA's use but notes disputes over relevant benefits and costs. Statutory amendments replaced 'electricity efficiency' with 'demand-side management' but retained cost-effectiveness requirements.

impacts (other fuel savings and GHG emissions savings) become the primary benefits. Without their inclusion the testing cannot be conducted appropriately. [Emphasis added] [Exhibit E-1, p. 17 of 38] [109] The Board assumes the argument E1...

AI summary The document discusses the inclusion of non-utility benefits (fuel savings, GHG emissions) in cost-effectiveness tests for strategic electrification under the Public Utilities Act. The NSUARB argues that legislative intent focuses on electricity cost reduction, not non-energy benefits, citing jurisdictional limitations and the absence of explicit statutory language requiring such inclusion.

nges in Nova Scotia results in the Board doing nothing more than it has always done by taking relevant policy goals into consideration when making discreet demand-side management decisions. It states: …This approach effectively suggests th...

AI summary Eastward argues that recent legislative amendments, including the replacement of the Utility and Review Board Act with the Energy and Regulatory Boards Act, do not meaningfully impact demand-side management (DSM) regulation in Nova Scotia. This contradicts the principle that legislation has substantive effect. The Consumer Advocate criticizes the Industrial Group's stance that legislative objectives like sustainability cannot override specific statutory language in the Public Utilities Act (PUA).

4.1.6.1 Findings [128] Considering the text, context and purpose of the legislation, the Board finds that the purpose of the demand-side management provisions in the Public Utilities Act is to reduce electricity costs for customers. Demand...

AI summary The NSUARB finds that demand-side management under the PUA aims to reduce electricity costs for customers, primarily through NS Power's initiatives. Strategic electrification, now included in DSM definitions, must also reduce electricity costs. The removal of 'affordability' from legislative provisions suggests cost reduction (specifically electricity costs) remains the focus.

Impact Category Sub-Category BCA Test TRC Test Utility System Electric Generation Transmission Distribution General All All Gas Only Commodity Costs Not Included Non-Utility System Other Fuels All Not Included Host Customer All (costs and...

AI summary The document outlines the BCA Test and TRC Test categories for assessing impacts, with specific considerations for utility and non-utility systems. Mr. Bowman recommends using the PAC test as the primary cost-effectiveness test, suggesting modifications to account for strategic electrification and align with the Public Utilities Act's objective of reducing electricity costs.

4.7.1 Findings [209] Noting that E1 is currently preparing its 2027-2031 DSM Plan, Eastward asked the Board to make an early finding about its membership in the DSMAG before its input may be too late to be incorporated into the new plan. [...

AI summary The NSUARB ruled in favor of Eastward's inclusion in the DSMAG, countering E1's objection that Eastward's narrow focus conflicts with DSMAG's purpose. The Board emphasized the value of Eastward's contributions, directing E1 to include Eastward in the DSMAG ahead of the 2027-2031 DSM Plan.

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 cannot approve E1's proposed BCA due to Public Utilities Act restrictions on non-energy benefits. E1 must use PAC test and NS Power's WACC for DSM plan assessments. Strategic electrification must meet GHG and cost reduction criteria. Eastward is added to DSMAG. Portfolio-level evaluation allows overall cost-effective DSM plans despite individual measure failures.

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.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act - and- IN THE MATTER OF: an application by EfficiencyOne for approval of a New Benefit-Cost Analysis Test for Evaluating SBA Consultant Melissa Whitten Daymark Energy Advi...

AI summary The Nova Scotia Energy Board is considering EfficiencyOne's application for approval of a new benefit-cost analysis test for evaluating Demand Side Management Plans under the Public Utilities Act. Melissa Whitten from Daymark Energy is involved as an SBA Consultant.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: The Public Utilities Act -and- IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans

AI summary The Nova Scotia Energy Board is considering matters under the Public Utilities Act and an application by EfficiencyOne for approval of a new benefit-cost analysis test to evaluate demand side management plans.

NOVA SCOTIA ENERGY BOARD IN THE MATTER OF: THE PUBLIC UTILITIES ACT - and - IN THE MATTER OF: AN APPLICATION by EFFICIENCYONE for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management Plans

AI summary The Nova Scotia Energy Board is considering an application by EfficiencyOne under the Public Utilities Act for approval of a new benefit-cost analysis test to evaluate demand side management plans. The proceeding focuses on methodological standards for assessing energy efficiency initiatives.

Request IR-7: - Refer to lines 22-23 on page 15 of the evidence of David Hill and pages 30-33 of Appendix B. - a. What specific instructions did EFG give to the DSMAG for completing the assignment for reviewing Nova Scotia energy policies?...

AI summary Request IR-7 seeks clarification on instructions given by EFG to DSMAG for reviewing Nova Scotia energy policies and the number of DSMAG participants who submitted responses. It references specific pages in David Hill's evidence and Appendix B.

Request IR-5: - Please describe how the BCA as proposed by E1 aligns with the Treasury Board of Canada - Secretariat Canada's Cost-Benefit Analysis Guide for Regulatory Proposals, 2019 and Canada's - Policy on Cost-Benefit Analysis (2018)...

AI summary Request IR-5 asks EfficiencyOne (E1) to explain how its proposed Benefit-Cost Analysis (BCA) aligns with Canada's 2019 Cost-Benefit Analysis Guide and 2018 Policy on Cost-Benefit Analysis. Specific elements under review include scope, time horizon, market distortions, health impacts, and social costs of greenhouse gases.

Request IR-2: - Refer to Exhibit E-1, the Application, Notice of Application, page 5, paragraph 24. - a) Explain why E1 proposes a 2 percent real discount rate for societal impact. - b) Provide any internal or external studies, regulatory...

AI summary Request IR-2 asks for an explanation of E1's proposed 2% real discount rate for societal impact, including supporting studies, precedents, or stakeholder comments. The request references Exhibit E-1, the Application, and page 5, paragraph 24.

Request IR-10: - Refer to Exhibit E-1, the Application, page 23 of 38, lines 25-26. - a) Please provide the criteria used to categorize each impact category as reliable.

AI summary Request IR-10 asks for the criteria used to categorize each impact category as reliable, referencing Exhibit E-1, page 23 of 38, lines 25-26 of the application.

21 And References: E-1, Evidence, Section 4.2 – 2026 DSM Plan Extension, page 8; and 22 Section 11, pages 35 – 36 - 23 (a) To compare the new BCA test with the existing approved TRC test, for the 24 entirety of the 2026 DSM Plan, at the po...

AI summary The text requests a comparison between the new BCA test and the existing TRC test for the 2026 DSM Plan, asking whether non-energy impacts outweigh energy-related impacts. This relates to the evaluation of the DSM Plan Extension and involves considerations of cost-effectiveness and regulatory processes.

- 28 (b) Please compare the new BCA test against the current TRC test for the 29 three examples provided in section 11 of E1's Evidence. 1 2 (i) In the calculation provided, do the "non-energy impacts" outweigh the "energy-related" impacts...

AI summary The text requests a comparison of the new BCA test with the current TRC test using three examples from E1's Evidence. It also asks whether non-energy impacts outweigh energy-related impacts, if E1 includes considerations of green jobs and economic growth in the BCA, and if the Energy Board has jurisdiction to review job market and economic growth impacts when regulating E1's activities.

1 (b) Please further explain how "medical outcomes and costs" overlap, or are 2 embedded within GHG Emissions and Other Environmental 3 considerations? 4 Request IR-11: 5 Reference: E-1, Appendix A, Attachment 2, National Standards Practic...

AI summary The text contains regulatory requests asking for explanations on how medical outcomes and costs overlap with GHG emissions and environmental considerations, as well as how E1 proposes to address Rate Impacts in the NSPM, including BCA tests and perspectives. It also asks why only American jurisdictions were reviewed in the preparation of E1's filing.

1 2025 M12282 2 NOVA SCOTIA ENERGY BOARD 3 IN THE MATTER OF: The Public Utilities Act 4 IN THE MATTER OF: An Application by EfficiencyOne for approval of a New Benefit- 5 Cost Analysis Test for Evaluating Demand Side Management 6 Plans 7 8...

AI summary EfficiencyOne seeks approval for a new Benefit-Cost Analysis (BCA) test to evaluate demand-side management plans. The Industrial Group requests clarification from Synapse Energy Economics on whether Synapse considered the Public Utilities Act's requirement that DER activities serve customers' best interests and whether a broad societal-type BCA test aligns with Nova Scotia policy goals.

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.

Energy Reform (2024) Act , SNS 2024, April 2024, Part I: Energy and Regulatory Boards Act (Schedule A), Part II: More Access to Energy Act (Schedule B). 1 3 In this Act, […] 2 3 9 "sustainable development" has the same meaning as in the En...

AI summary The Energy Reform (2024) Act introduces new obligations for the Energy Board, requiring it to consider factors such as competition, innovation, sustainability, and reliability when approving rates and other matters. It aligns with the Environment Act and the Environmental Goals and Climate Change Reduction Act.

ile it is acknowledged that federal departments rely on the Federal Social Cost of GHG Guidance to assess the costs and benefits associated with greenhouse gas emissions in Regulatory Impact Analyses, this does not preclude the use of the...

AI summary The text discusses the use of Federal Social Cost of GHG Guidance beyond Regulatory Impact Analyses, referencing hearing transcript M12282 and past NSUARB decision M06733. It emphasizes that DSM cost-effectiveness tests should use discount rates aligned with public interest, not utility shareholder preferences, and highlights the relevance of GHG emission considerations in regulatory decisions.

nts do you wish to make regarding the terms of that proposed Partial Consensus Agreement? A. Only that it reflects some of the recommendations in my evidence related to reducing the proxy adders. Mr. Bowman's evidence advocates for the Pro...

AI summary EfficiencyOne (E1) opposes using Program Administrator Cost (PAC) as the primary cost-effectiveness test at the legislatively mandated portfolio level, advocating instead for measure and program-level testing. E1 commits to providing PAC and Benefit-Cost Analysis (BCA) results at lower levels for the Nova Scotia Utility and Review Board's consideration, while Mr. Bowman's evidence supports PAC as a primary test.

rocess for the review and approval of the application" respecting a demand-side management purchase agreement (s. 79L(1)). These are two separate statutory requirements, which are not to be conflated. M10437, NSUARB Decision, E1 2023-2025...

AI summary The text outlines statutory requirements for E1's DSM Plan application under the Public Utilities Act (PUA), distinguishing between section 79H(2)'s portfolio-level cost-effectiveness assessment and section 79L(1)'s broader evaluation. It emphasizes that cost-effectiveness is part of a comprehensive review, not the sole criterion, and that E1 must provide required information to the NSUARB.

pproach to statutory interpretation. It ignores the entirety of subsection 79H(2), giving it no meaning, even though in Nova Scotia, "[t]he law shall be considered as always speaking".[63](#page-30-0) Mr. Bowman's report is based on the pr...

AI summary The Industrial Group (IG) challenges Mr. Bowman's interpretation of Nova Scotia's Public Utilities Act, arguing that cost-effectiveness must be assessed at the portfolio level per s. 79H(2), not measure/program levels. The IG cites the Supreme Court of Canada's Bell ExpressVu decision, emphasizing statutory interpretation principles. Mr. Bowman acknowledges his report's premise may be incorrect but asserts the Board isn't prohibited from alternative assessments.

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.

Building on the provisions outlined above, E1's position is that the legislative framework not only empowers the Board to consider issues of sustainable prosperity and sustainable development, but in fact obliges it to do so as part of its...

AI summary E1 argues that the legislative framework empowers and obliges the Board to prioritize sustainable development and prosperity, as defined in statutes like the Environment Act and the Energy and Regulatory Boards Act . These laws require the Board to consider long-term societal outcomes, including energy efficiency and emissions reduction, when evaluating DSM plan applications and cost-effectiveness.

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.

Applicable Legislative Provisions for Cost Effectiveness Testing The issue before the Board now, is what costs and what benefits should be weighed when evaluating DSM. Energy efficiency and conservation activities are contained within thei...

AI summary The Board considers legislative provisions under the PUA governing DSM cost-effectiveness testing. NSPI and E1 have statutory obligations under ss 79A-79W of the PUA , with E1 serving as NSPI's franchisee for energy efficiency. The PUA mandates NSPI to contract with E1 for DSM activities, emphasizing alignment with regulatory objectives.

Prior Interpretation of the Board's Jurisdiction Up until this application, the predecessor Board made clear that it did "not have the jurisdiction to take into account non-energy impacts in cost-effectiveness testing" in relation to DSM.[...

AI summary The Board clarified its jurisdiction excludes non-energy impacts in DSM cost-effectiveness testing, focusing solely on energy-based costs and benefits. EfficiencyOne argued for broader environmental considerations under the PUA, but the Board rejected this, citing statutory definitions. The Board emphasized 'cost-effective' means evaluating electricity efficiency activities for affordability and long-term cost reduction, acknowledging limited environmental benefits.

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 ERBA requires the Board...

AI summary The Board is criticized for not adequately considering non-energy benefits in regulatory decisions. The text argues that expanding benefit-cost analysis to include all environmental and societal impacts would conflict with franchise mandates and possibly expand E1's role. The ERBA requires the Board to consider factors like competition and innovation, but these do not expand E1's mandate under the PUA. The PUA's focus remains on cost reduction and energy efficiency, with sustainability as a supporting factor.

use of the social cost of carbon within that context is with respect to cost-benefit analyses in the introduction of a piece of legislation; it is not a tool that impacts costs charged to ratepayers. Of particular concern is how far this e...

AI summary The document discusses concerns over the broad interpretation of section 6(2) of the ERBA, which mandates consideration of sustainability in regulatory decisions. It highlights E1's reliance on sustainability factors and EFG's argument for a broad societal test in energy regulation. The use of social cost of carbon in legislation is noted as not directly impacting ratepayer costs, but consistency in regulatory oversight remains a concern.

Inconsistency across DERs The Industrial Group takes no issue with the use of the National Standard Practice Manual (" NSPM ") for Distributed Energy Resources (" DERs" ) as a guiding framework in formulating an appropriate cost-effectiven...

AI summary The Industrial Group supports using the NSPM for DERs but highlights inconsistent application of its principles. Concerns include E1's proposed 2% discount rate, which is deemed too low and not aligned with standard practices. The need for non-green energy investments to meet net-zero goals is acknowledged, but the BCA's consistency across NSPI and IESO remains unexplored. The Industrial Group disputes the discount rate's justification and cites legislative gaps.

Modified PAC test for Electrification The PAC need not be rigid or "ruthlessly applied".[73](#page-19-0) It can be applied or modified as needed, like a jurisdictional test. As suggested by Mr. Bowman, this can be done with respect to stra...

AI summary The document discusses modifying the PAC test for electrification, proposing inclusion of increased revenues from electrification to better assess system costs. Mr. Bowman's approach aligns with Posterity Group's hybrid heating recommendations, reducing utility costs and passing PAC tests. This aligns with the PUA and E1's mandate to lower electricity costs for NSPI customers.

advocate and advance a differing position. There is simply no legitimate reason to keep Eastward out of the DSMAG and there is significant value having it as a fully participating member of the DSMAG. From the pre-filed evidence and oral t...

AI summary Eastward Energy argues for full DSMAG membership, asserting its exclusion caused oversights in E1's evidence and policy reviews. It highlights E1's reliance on DSMAG for input and the omission of the Gas Distribution Act and hybrid heating savings in E1's application. The request cites section 79(G)(1) of the Public Utilities Act.

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.

The Board's Jurisdiction to Take Non-energy Impacts into Account in Cost-effectiveness Testing for Demand-side Management Plans The second issue concerns the Board's jurisdiction to take non-energy impacts into account in cost-effectivenes...

AI summary The document addresses whether the Nova Scotia Utility and Review Board (UARB) can consider non-energy impacts in cost-effectiveness testing for Demand-side Management (DSM) plans. It references the Energy Reform (2024) Act and the EfficiencyOne (Re) case, where the UARB previously ruled against considering non-energy impacts. ECEL supports EfficiencyOne's argument that the new Act expanded the Board's jurisdiction to include non-energy benefits in DSM cost-effectiveness analyses.

Decision, 297808, para 71. September 9, 2022. 2 M10473 – Board Decision, 297808, paras 72-73. 3 E1 Evidence, paras 14-15. factors. The above list is pulled from the purpose section of the More Access to Energy Act (MAEA) and is not entirel...

AI summary EfficiencyOne's proposal advocates for expanding the Benefit Cost Analysis (BCA) test to include non-utility system impacts, such as greenhouse gas and air pollutant effects, under the Energy Reform (2024) Act (ERA). This aligns with factors outlined in the More Access to Energy Act (MAEA) and Energy and Regulatory Boards Act (ERBA), emphasizing broader considerations for regulatory decisions.

LEGISLATIVE AND REGULATORY FRAMEWORK AND ANALYSIS Though there have been legislative changes in Nova Scotia, the Board's decision in M08888 issued April 15, 2020 holds. There, the Board found that it did not have the jurisdiction to consid...

AI summary The Nova Scotia Energy Board's 2020 decision (M08888) reaffirms its jurisdictional limits, emphasizing cost-effectiveness, safe service, and reasonable rates over non-energy benefits. Sections 79H and 79I of the PUA mandate NSP to implement cost-effective DSM programs, with cost-effectiveness defined to include E1's efficiency activities. Current legislation does not empower the Board to consider non-energy impacts except for greenhouse gas reduction through electrification.

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.

The More Access to Energy Act Bill 404 created the More Access to Energy Act (MAEA) which carriesthe following purpose: The purpose of this Act is to - (a) increase competition and innovation in the Province's energy sector; - (b) ensure t...

AI summary The MAEA aims to boost energy sector competition, ensure reliable energy supply, and integrate sustainability goals from the EGCCRA and EA. E1 emphasizes these goals, but the text notes ambiguity in applying sustainable development principles to the JST and distinguishes policy language from prescriptive BCA requirements.

NS POWER'S POSITION This initiative overall has made great progress throughout the DSMAG; however, more work is required to eliminate the potential for unintended consequences and to ensure alignment with the current and existing legislati...

AI summary NS Power emphasizes the need for careful evaluation of DSM programs to avoid increasing customer costs and align with legislative frameworks. It recommends modifying the TRC test to include greenhouse gas emissions reductions, electricity cost savings, and displaced fuel impacts. The NSEB's regulatory regime and strategic electrification under the PUA are highlighted as key considerations.

CONCLUSION DSM remains a vital tool for managing system costs, advancing electrification, and supporting the energy transition. However, its primary purpose must remain clear: to deliver measurable, economically sound benefits to customers...

AI summary DSM is essential for managing costs and energy transition but must prioritize customer benefits without unnecessary burdens. NS Power's recommendations are seen as balanced and transparent, allowing the Board to incorporate evolving policy considerations while maintaining cost-effectiveness and affordability.

Ibid at para 201; see also Nova Scotia Power Incorporated (Re) , 2018 NSUARB 154 at paras 87-91, affirmed in Nova Scotia (Attorney General) v. Nova Scotia (Utility and Review Board) , 2019 NSCA 66. - 2 (iv) strategic electrification of ene...

AI summary The text discusses the expansion of the Energy Board's consideration of environmental and societal impacts in assessing DSM cost-effectiveness, referencing past decisions and legislative amendments. It highlights the Board's interpretation of its statutory mandate to include factors like competition, innovation, and sustainable development.

as set out in the Vavilov decision to 23 examine the PUA amendment regarding strategic electrification in isolation from the other relevant 24 amendments to the Board's governing legislation. 25 26 In reference to the PUA , the Industrial...

AI summary The Consumer Advocate challenges the Industrial Group's interpretation of the PUA amendment, arguing that the Board's mandate under the Energy and Regulatory Boards Act requires balancing policy objectives like sustainability. The Industrial Group claims legislative goals cannot override specific statutory language, but the Consumer Advocate counters that the Board must consider broader objectives. The Industrial Group also criticizes the proposed demand-side management test as unique compared to other Canadian jurisdictions.

Response to E1 Unsurprisingly, E1 takes a vastly different approach to statutory interpretation which has largely been addressed in the Industrial Group's initial submissions. Without repeating those, the Industrial Group will address some...

AI summary The Industrial Group addresses E1's differing statutory interpretation approach, focusing on critiques of Mr. Bowman's endorsement of PAC and DSM application review methods. References include prior submissions, diagrams, and cross-examination testimony confirming GHG inclusion in social cost of carbon calculations.

SUSTAINABLE DEVELOPMENT AND SUSTAINABLE PROSPERITY 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 "appropriate consider...

AI summary E1 emphasizes the Board's duty under the Energy and Regulatory Boards Act to consider sustainable development and prosperity in DSM plans. E1's BCA proposal is framed as aligning with these goals, though NSPI and East Coast Environmental Law caution against overriding other legislative priorities like affordable energy rates. The Board's decision may set a precedent for future cases, with Mr. Bowman's approach avoiding global carbon cost methodologies.

CONCLUSION In conclusion, Eastward submits that nothing in the closing submissions of E1 or the other parties to this proceeding has changed its view on the issues of concern that it has raised, and it provides this Rebuttal Argument in fu...

AI summary Eastward maintains its position that other parties' closing submissions did not alter its concerns, reaffirming its requests to the Board with a rebuttal argument. The submission references prior documents and page numbers for context.

Closing Submissions, page 2, page 5, page 7, and page 9. Ibid , page 10. Sustainability should only be considered in the context of E1's mandate of energy-based efficiency and cost-effectiveness. E1 disagrees with the IG's conclusions. E1...

AI summary E1 argues that the Proposed BCA should include host customer non-energy impacts for a symmetrical cost-benefit analysis, citing alignment with legislative amendments and expert support. E1 disputes the IG's claim that the BCA prioritizes sustainability over other policy goals, emphasizing it aligns with the Total Resource Cost test and includes all prior considerations. Dr. Hill's testimony is referenced to support the minor impact of host customer benefits.

2.7 SUPPORT FOR PRIMARY AND SECONDARY TESTING - 2 The IG supports both primary (PAC) and secondary tests for DSM cost-effectiveness specifically the - 3 Proposed BCA and relevant information on the host customer or Participant Cost test ("...

AI summary The Industrial Group (IG) supports both primary and secondary tests for demand-side management (DSM) cost-effectiveness, including the Proposed BCA and Participant Cost Test (PCT). EfficiencyOne (E1) maintains that cost-effectiveness screening must occur at the portfolio level under the Public Utilities Act (PUA), as outlined in section 79H(2), and clarifies it has not retreated from its original position.

3.4 NATURAL GAS TO ELECTRIC CONVERSIONS With respect to natural gas to electric conversions, Eastward Energy raises concerns with regard to an illustrative example regarding conversion of gas heating systems to electric heat pumps, noting...

AI summary Eastward Energy expresses concern over E1's illustrative example of natural gas-to-electric conversions, citing a negative benefit and benefit-cost ratio below 1.0. E1 clarifies the example is hypothetical and reaffirms that justification would be required under existing Board directives if the example were accurate. The Board has already provided guidance on this issue.

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.

October 21, 2025 Crystal Henwood Clerk of the Board Nova Scotia Energy Board 1601 Lower Water Street, 3rd Floor Halifax, NS B3J 3S3 Re: M12282 Demand Side Management (DSM) Benefit Cost Analysis Test (BCAT) Rebuttal Submission Dear Ms. Henw...

AI summary Nova Scotia Power Incorporated (NS Power) submits a rebuttal to EfficiencyOne's (E1) proposed Benefit Cost Analysis Test (BCAT) for Demand Side Management (DSM) Plans, emphasizing the need for consensus aligned with legislative intent and cost-effectiveness frameworks. NS Power argues the Nova Scotia Energy Board (NSEB) cannot consider host customer non-energy impacts or societal impacts post- Energy Reform Act (ERA) enactment, citing the Public Utilities Act (PUA) as the governing legislation.

CONCLUSION E1's proposed test leaves the Board with no transparent evidentiary pathway to assess whether the proposed non-energy benefits or their associated values are reasonable, reproducible, or consistent with statutory intentions. As...

AI summary E1's proposed test lacks transparency in assessing non-energy benefits, per NS Power's submission. NS Power emphasizes the need for revisions to align with legislative frameworks like the PUA and advocates for collaborative efforts to refine cost-effectiveness testing. The conclusion underscores the necessity of further alignment between statutory intentions and practical implementation.

ates the following avoided utility system costs, which are intended to include the full set of utility system impacts permissible under the Public Utilities Act and consistent with NSPM definitions:

AI summary The analysis outlines avoided utility system costs calculated under the Public Utilities Act (PUA) and aligned with National Standard Practice Manual (NSPM) definitions, encompassing all permissible utility system impacts.

3.2 Industrial Group [34] The Industrial Group is not a party to the Consensus Agreement. It objects to the use of the proposed BCA test as the new primary cost-effectiveness test. It recommends the Board approve the PAC test as the primar...

AI summary The Industrial Group opposes using the BCA test as the primary cost-effectiveness standard, advocating instead for the PAC test for DSM Plan applications and a modified PAC test for strategic electrification. It argues that programs failing the PAC test require justification and that non-energy impacts, like carbon social effects, should not be considered. The group emphasizes complementary use of the PAC test with secondary evaluations and notes the Public Utilities Act amendment adding strategic electrification to DSM's definition.

tes" and that the "listed factors in section 6(2)(a-e) [of the Energy and Regulatory Boards Act ] supplement, but do not replace, the Board's primary mandate." In its closing submissions, it states: The operative phrase of section 6(2) is...

AI summary NS Power argues that section 6(2) of the Energy and Regulatory Boards Act requires 'appropriate consideration' of factors without prescribing their weight, and that 'sustainable development' in the BCA test lacks clear linkage to non-utility impacts. It contends E1's approach misinterprets legislative intent by transforming policy language into prescriptive 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 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.

rect test to track the DSM policy objective of a reduction of costs for customers set out in section 79I of the Public Utilities Act . [Footnotes omitted] [Eastward Energy Closing Submissions, p. 8] [64] In relation to NS Power's marginal...

AI summary Eastward Energy argues that NS Power's use of average emissions rates is inappropriate, as future incremental generation will rely on inefficient coal and fuel oil sources. They critique E1's BCA test, noting a 0.50 benefit-cost ratio for natural gas-to-electric conversion, deeming it invalid for strategic electrification. Eastward requests the Board to establish justification thresholds for low-benefit measures.

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.

pretive exercises undertaken by courts. They emphasized that regardless of the form of analysis, the interpretation must be consistent with the text, context and purpose of the contested provision: - [119] Administrative decision makers ar...

AI summary The text discusses statutory interpretation principles, emphasizing that administrative decision-makers need not use formalistic methods but must align interpretations with the text, context, and purpose of provisions. Courts require consistency with these elements, as illustrated by the SCC case Canada Trustco Mortgage Co. v. Canada , where precise language's ordinary meaning was pivotal.

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

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

om the text in s. 79L(9) (much of which is now included in s. 79L(5)). E1 submitted this affordability requirement featured in the NSUARB's reasons in reaching its conclusions in its decision in 2020: Section 79L(9) has been repealed, ther...

AI summary Section 79L(9) of the PUA was repealed, removing affordability as a statutory requirement for electricity efficiency activities. E1 acknowledges the NSUARB's continued focus on affordability but notes its removal from statutory obligations. The Energy Reform (2024) Act now mandates the Board to consider factors like competition, innovation, and sustainable development in regulatory decisions, aligning with broader energy legislation.

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 The Public Utilities Act (PUA) mandates NS Power to implement cost-effective demand-side management, with the NSUARB ensuring compliance. The Act does not explicitly define 'cost-effective,' leaving interpretation to the Board. The Board must evaluate proposals at the portfolio level and ensure they align with s. 79I's requirements.

impacts (other fuel savings and GHG emissions savings) become the primary benefits. Without their inclusion the testing cannot be conducted appropriately. [Emphasis added] [Exhibit E-1, p. 17 of 38] [109] The Board assumes the argument E1...

AI summary The Board examines the interpretation of 'cost-effective' in the Public Utilities Act, considering whether strategic electrification should include non-utility benefits. It notes the NSUARB's previous jurisdiction limitations and suggests the Legislature should have been more direct in prescribing cost-effectiveness assessments. The current subclause emphasizes reducing electricity costs alongside GHG emissions.

4.1.6.1 Findings [128] Considering the text, context and purpose of the legislation, the Board finds that the purpose of the demand-side management provisions in the Public Utilities Act is to reduce electricity costs for customers. Demand...

AI summary The Board finds that demand-side management under the Public Utilities Act aims to reduce electricity costs, with NS Power responsible for implementation. Strategic electrification must also reduce electricity costs, as per s. 79A(b)(iv). The removal of 'affordability' from the Act suggests a focus on electricity cost reduction rather than broader affordability considerations.

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.

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.