Topic:"Renewable Energy" in M12282

Gas Only Commodity Costs Other Fuels All Host Customer All (costs and benefits) Non-Utility System Societal Resilience GHG Emissions 3 In the National Standard Practice Manual (NSPM), Distributed Energy Resources (DERs) are defined as energ...

AI summary The text defines Distributed Energy Resources (DERs) per the National Standard Practice Manual (NSPM), including technologies like energy efficiency and demand response. It outlines impact categories such as commodity costs, resilience, and public health, noting how certain impacts are embedded within these categories.

1 as discussed below). The recent legislative amendments to the PUA now include strategic electrification 2 within the definition of demand-side management, for which the proposed BCA test allows consideration. 3 The best practice is to us...

AI summary The document discusses legislative amendments to the PUA, incorporating strategic electrification into demand-side management (DSM) and advocating for the Best Interest of Customers (BCA) test over the Total Resource Cost (TRC) framework. E1, as the franchise holder, must seek regulatory approval for its DSM Plan, with the Energy Board required to assess portfolio-level cost-effectiveness. Historical emphasis on DSM cost-effectiveness is highlighted via the 2010 NSUARB case.

Page 26 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence 1 10.2 UTILITY SYSTEM IMPACTS 2 Utility System Impacts, or “USIs”, are elements of electricity or gas systems required to deliver service to 3 utility customers. U...

AI summary The document discusses Utility System Impacts (USIs) under the new BCA test, which include generation, transmission, and distribution. These impacts are categorized and include energy generation, with examples such as the production or procurement of energy on behalf of customers. This category is included in the new BCA proposed by EfficiencyOne.

 on behalf of customers, can include calculation of line losses Capacity The generation capacity (kW) required to  meet the forecasted system peak load Environmental Actions to comply with environmental Generation Compliance regulations...

AI summary The text discusses various aspects of utility system impacts, including capacity requirements, environmental compliance, renewable portfolio standards, and ancillary services. It outlines how these factors are considered in the context of DERs and the BCA process.

h to reactive power production are matched merit routine with demand inclusion Financial Incentives Utility financial support provided to DER host customers or other market actors to  encourage DER implementation Utility Direct Direct cost...

AI summary The text outlines various aspects of utility involvement in distributed energy resources (DER), including financial incentives, direct investment, program administration, performance incentives, and risk factors such as operational, financial, and regulatory risks.

 Requirements Federal Energy Regulatory Commission (FERC) Order No. 2222 1 2 3 10.3 NON-UTILITY SYSTEM IMPACTS 4 As explained in the NSPM, best practices suggest that all impacts relating to a jurisdiction’s policy goals 5 and objectives...

AI summary The document outlines the inclusion of non-utility system impacts (N-USIs) in the Best Interest of Customers (BCA) test, emphasizing the need to consider efficiency and distributed energy resources (DERs). It references legislative changes, particularly the More Access to Energy Act, and recommendations from the EfficiencyOne Group (EFG) and the Demand Side Management Advisory Group (DSMAG).

y increased Effects fuels resulting from large enough to EV usage in NS. Cross fuel DRIPE DATE FILED: May 16, 2025 Page 30 of 38 EfficiencyOne Benefit-Cost Analysis Test Application Evidence Other Fuel Description and Examples Inclusion in...

AI summary The text discusses the inclusion of other fuel impacts in the Best Interest of Customers (BCA) analysis, particularly focusing on changes in consumption levels and the effects of gas DER on the electric system. It notes that cross-fuel impacts may be non-material for most customers but could be significant for large industrial users.

tric system (e.g., gen. to DSM in Nova utility DERs. capacity, Scotia

AI summary The text discusses the integration of distributed energy resources (DERs) within the utility system, particularly in the context of demand-side management (DSM) in Nova Scotia. It references the role of DERs in capacity planning and system reliability.

Other Utility If electric DER, impact on Not material, or Further analysis required to System Impacts gas system (e.g., T&D, large enough to determine potential decline in storage, reliability, etc.) merit routine gas consumption and deman...

AI summary The text discusses host customer impacts related to distributed energy resources (DER), emphasizing that non-energy impacts should be included in the Best Interest of Customers (BCA) test. It references the Energy Reform Act, the 2022 NSUARB Decision, and practices in other jurisdictions to support this inclusion. A proxy adder method is used to quantify these impacts.

ethod used in other jurisdictions 15 rather than quantifying a value stream for each separate impact. Table 8 presents the other fuel impact 16 categories, their description and indicates whether they are included in the new BCA proposed b...

AI summary The text discusses the inclusion of various host customer impacts in the new BCA proposed by E1, such as DER measure costs, transaction costs, interconnection fees, and risk. These impacts are relevant to different types of DER and are outlined in Table 8.

 fuel price volatility. Operational risk or failure of DER. Reliability Either captured under utility system reliability  or host customer resilience Resilience EE (weatherization) enables buildings to withstand outages better; DG. Distr...

AI summary The text discusses various non-energy impacts of efficiency and distributed energy resources (DER), including reliability, resilience, tax impacts, asset value, and water cost impacts. It mentions how DER can improve system reliability and customer resilience, the potential for tax incentives, and how efficiency measures can reduce water consumption.

$26.1 $0 $26.1 Non-Utility System Impacts: Host $0.8 $4.8 $0.8 $4.8 $0.8 $4.8 Customer Impacts Non-Utility System $0 $0 $42.4 $0 $6.2 $0 Impacts: Other Fuels DATE FILED: May 16, 2025 Page 35 of 38 EfficiencyOne Benefit-Cost Analysis Test A...

AI summary The document presents a benefit-cost analysis of heat pump replacements in Nova Scotia, evaluating impacts on air pollutants and GHG emissions. The analysis uses a 2% social discount rate and considers different fuel types being replaced, including electric resistance, fuel oil, and natural gas. The total net benefits and benefit-cost ratios are provided for each scenario.

requirements of 8 Vermont’s Global Warming Solutions Act, and leading a team conducting building sector analyses and 9 integrated scenario planning for the Massachusetts Decarbonization Roadmap. 10 Prior to joining EFG, I worked for the VE...

AI summary The individual has extensive experience in energy management and policy, with a focus on distributed energy resources, renewable energy, and energy efficiency. They have worked for organizations such as EFG and VEIC, leading large-scale programs and providing expert testimony in multiple jurisdictions.

conclude your direct testimony? 21 A: Yes. Direct Testimony of David G. Hill, Ph.D. / May 16, 2025. Page 16 On Behalf of EfficiencyOne DATE FILED: May 16, 2025 Page 18 of 18 Appendix A Attachment 1: David Hill Professional Resume Efficienc...

AI summary David G. Hill, a Managing Consultant at EFG and former Director of Distributed Resources at VEIC, provides expert testimony and regulatory support in energy efficiency and renewable energy programs. He has led studies on solar markets, decarbonization, and gas infrastructure investments, with experience in multiple states and countries.

s related to gas infrastructure investments, pilot programs and planning. He has clients in more than a dozen states and six countries; several of them are international organizations. Experience January 2020 – present: Managing Consultant...

AI summary David Hill is a managing consultant at Energy Futures Group with extensive experience in energy policy, distributed energy resources, and expert testimony on renewable energy and gas infrastructure. He has provided testimony in multiple jurisdictions, including Nova Scotia, and has worked with organizations such as the Vermont Energy Investment Corporation and the EfficiencyOne Benefit-Cost Analysis Test Application.

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

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

of the Attorney General, and filed with the Federal Energy Regulatory Commission in Docket No.CP22-2-00, on behalf of the States of Washington, California, and Oregon. 2022 In the Matter of Avoided Costs for EfficiencyOne’s 2023-2025 Deman...

AI summary The text outlines various appearances and expert testimonies provided on behalf of different organizations and states in regulatory proceedings related to energy efficiency, renewable natural gas, and integrated resource planning. These appearances were before various regulatory bodies such as the Nova Scotia Utility and Review Board, Illinois Commerce Commission, and New Hampshire Public Service Commission.

Selected Projects (from more than 100) Vermont Agency of Natural Resources. Co-leader of Vermont Pathways Analysis team providing technical support and quantitative modeling to the Vermont Climate Council, leading to adoption of Vermont Cl...

AI summary The document highlights various projects and contributions by different agencies and organizations in the fields of energy and environmental analysis. These include climate action planning, renewable gas potential assessments, and scenario modeling for greenhouse gas reduction targets.

latory, and business model implications of getting 20 percent of Vermont’s total electric supply from solar by 2025. Sun Shares. Created and launched, and responsible for management and business development of, a community solar business s...

AI summary David Hill's professional resume highlights his extensive experience in energy efficiency and renewable energy programs, including his work with Sun Shares, New Jersey Clean Energy Program, and NYSERDA. He has also provided consulting services for various energy authorities and the World Bank.

Selected Presentations 2017 Sun Shares, Easy and Affordable Solar for Employers and their Employees, American Solar Energy Society, Solar 2017, Denver. 2017 Vermont Solar Market Pathways, American Solar Energy Society, Solar 2017, Denver....

AI summary The text lists various presentations and speaking engagements related to energy efficiency, renewable energy, and solar markets, including events such as the American Solar Energy Society, Solar 2017, and the World Bank International Conference on Energy Efficiency in Cities.

2005 Market Response to Photovoltaic Incentive Offerings: An Analysis of Trends and Indicators. Presented at the International Solar Energy Society Solar World Congress, 2005. 2003 Solar Energy Value and Opportunities in Vermont, Invited S...

AI summary The text lists various presentations and publications related to renewable energy, solar energy, and energy efficiency, focusing on case studies, market responses, and software tools developed for evaluating energy efficiency and renewable energy opportunities.

Young). 1998 Eco-Efficiency Financing Resource Directory. Electronic web-site, and printed directory prepared for the Environmental Protection Agency, Region I, New England. Regulatory and Other Governmental / NGO Documents 2000 – 2012 New...

AI summary The text outlines various energy efficiency and clean energy initiatives undertaken by an individual from 1997 to 2012, including work with government agencies, NGOs, and international organizations on programs such as renewable energy plans, climate action, and energy efficiency strategies.

1996 Evaluation of the IDB's Policies and Practices in Support of Renewable Energy and Energy Efficiency: A Report to the Inter-American Development Bank. Brower and Company and Tellus Institute. 1996 Action Plan for the Massachusetts' Ind...

AI summary This section lists various reports and studies conducted between 1994 and 1996 on energy policies, renewable energy, and efficiency initiatives, including evaluations and reviews for different regions and organizations.

ropriate Technology and International Development, University of Pennsylvania, Philadelphia, PA, 1989. B.A., Geography and Political Science, Middlebury College, Middlebury, VT, 1986. Other Qualifications Nepal, Himalayan Light Foundation....

AI summary The document provides information about an individual's educational background, professional qualifications, and experience in renewable energy and international development. It also references the National Standard Practice Manual (NSPM) for Benefit-Cost Analysis of Distributed Energy Resources, as well as the National Energy Screening Project (NESP).

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AI summary The text discusses the fuel-cost-adjustment mechanism and its impact on rates, the integration of renewable energy resources, and the evaluation of various programs and policies related to energy efficiency and affordability. It also references regulatory processes and compliance with legislation.

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AI summary The document discusses the importance of aligning base rates with actual costs to avoid perverse incentives, referencing the Board's fuel-cost-adjustment mechanism in 2020. It also touches on the role of distributed energy resources and the need for accurate forecasting in regulatory proceedings.

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AI summary This document discusses the evaluation of a 2) +,-+)./ÿ7,ÿ2117ÿ7=1)+ÿ,<6ÿ611./ÿ06.c,+ÿ/533,+7ÿ61)-=?,+)6-ÿ,+ÿ/>/712ÿ611./@ÿÿ and related proceedings, including topics such as fuel-cost-adjustment, demand-side-management, and regulatory processes. It also examines the impacts of various programs and the associated costs, as well as the need for prudence reviews and compliance with regulations.

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AI summary The text discusses the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML) in the context of benefit-cost analysis (BCD) and clean energy (CDE). It references Nova Scotia Power (NSP) and mentions the need to evaluate the impact of these programs on energy assistance and clean energy initiatives.

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AI summary The text discusses the implementation of the Mandatory Net Output (MNO) and its impact on the benefit-cost analysis (BCD) and clean energy (CDE) initiatives. It references the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML) in the context of energy policy discussions.

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AI summary The text discusses the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML), focusing on benefit-cost analysis (BCD) and clean energy (CDE) initiatives. It also references Nova Scotia Power (NSP) and Mandatory Net Output (MNO) in the context of energy regulation and policy.

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AI summary The text discusses regulatory proceedings related to energy programs, including the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML). It mentions the Benefit-Cost Analysis (BCD) and Clean Energy (CDE) initiatives, as well as Nova Scotia Power (NSP) and Mandatory Net Output (MNO). The content involves discussions around energy efficiency and regulatory compliance.

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AI summary The text discusses the Yukon Energy Program (YBZ) and the Low-Income Energy Assistance Program (LML), highlighting concerns about the benefit-cost analysis (BCD) and clean energy (CDE) initiatives. It references Nova Scotia Power (NSP) and mentions the Mandatory Net Output (MNO) in the context of energy-related proceedings and regulations.

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AI summary The text contains a mix of encoded or corrupted data, URLs, and references to various regulatory proceedings, including energy efficiency programs and legal matters. It includes mentions of Nova Scotia Power, the Public Utilities Act, and other regulatory topics, though the content is not fully readable or coherent.

ry perspective, informing decisions when a program or plan is marginally cost effective, and encouraging consistency in BCA analyses across different types of distributed energy resources. 1 Discount Rate: Discount rates are used to reflec...

AI summary The text discusses the use of benefit-cost analysis (BCA) in evaluating distributed energy resources (DERs), emphasizing consistency in analyses across different DER types. It explains the role of discount rates in reflecting the time value of money and how they vary based on the perspective of the impacted party. DERs are defined as resources on the customer side of the utility meter, including energy efficiency, demand response, and distributed generation.

) as system resources.11 The working group’s review and discussion of electric utility system impacts applicability and materiality to the various DERs are summarized in Table 2 and Table 3. Table 2: Summary of Generation, Transmission and...

AI summary The text discusses the review and discussion of electric utility system impacts related to various DERs, summarizing the impacts on generation, transmission, and distribution systems in Table 2 and Table 3.

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

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

energyfuturesgroup.com 15 Non-Utility System Impacts Based on the working group’s review of Nova Scotia policies and the NSPM guidance, EFG recommends the inclusion of non-utility impacts as summarized in Table 4. Table 4: Non-Utility Impa...

AI summary The Energy Futures Group (EFG) recommends the inclusion of non-utility system impacts in Nova Scotia's policy framework, as outlined in Table 4, which categorizes impacts related to energy efficiency (EE), demand response (DR), distributed generation (DG), demand-side management (DS), electric vehicles (EV), and building efficiency (BE).

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

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

Energy Generation (time and seasonal dependent) ($8.56) ($8.56) 12.84

AI summary The text presents a financial figure related to energy generation, indicating a cost of $8.56 with a seasonal and time-dependent component, and a total of $12.84.

energyfuturesgroup.com 23 II. Introduction 1. Background EfficiencyOne (E1) is in the process of developing the next demand-side management (DSM) plan for the period of 2027-2031. As part of the five-year DSM Plan, E1 is reviewing its exis...

AI summary EfficiencyOne (E1) is developing a new demand-side management (DSM) plan for 2027-2031, including updating the Benefit-Cost Analysis (BCA) test and avoided cost methodologies. E1 is working with the DSMAG and NS Power to ensure updated electric system impacts are incorporated into the BCA framework, following best practices from the National Standard Practice Manual (NSPM) for distributed energy resources (DERs).

chnical support to and facilitate DSMAG working group discussions. Energy Futures Group (EFG) was selected through this process. Among other things, the Consultant was charged with drafting 17 Note, while this report focuses on a test for...

AI summary This document discusses the development of a uniform benefit-cost analysis (BCA) test for distributed energy resources (DERs) in Nova Scotia, informed by discussions with the Nova Scotia Power (NSPM) and the Demand Side Management Advisory Group (DSMAG). Energy Futures Group (EFG) was selected to draft the report.

26 this report on a proposed Nova Scotia uniform benefit cost analysis (BCA) test for DERs, informed by the NSPM and DSMAG working group discussions. 3. NSPM Overview The NSPM for DERs provides guidance for valuing DER opportunities to inf...

AI summary This document outlines a proposed Nova Scotia uniform benefit-cost analysis (BCA) test for distributed energy resources (DERs), informed by discussions between Nova Scotia Power (NSPM) and the Demand Side Management Advisory Group (DSMAG). The NSPM provides guidance for valuing DER opportunities to support policy goals, including reliability, low-cost energy, and greenhouse gas reduction.

27 Figure 2: Fundamental NSPM Benefit-Cost Analysis Principles 18 The NSPM also recommends a five-step process to develop a primary, jurisdiction-specific benefit-cost test for DERs. These steps are summarized in Figure 3. The focus of EFG...

AI summary The document outlines the NSPM's five-step process for developing a jurisdiction-specific benefit-cost test for DERs, with the EFG working with the DSMAG to recommend a primary BCA test based on these principles and methods.

28 Figure 3: NSPM Process to Defining a Jurisdiction's Primary Cost-Effectiveness Test The proposed Nova Scotia BCA test in this report was developed in a process that followed the first three of these five steps; steps 4 and 5 of the NSPM...

AI summary The document outlines the process used to develop a Benefit-Cost Analysis (BCA) test in Nova Scotia, including policy goals, applicable USIs, and non-USIs. The process involved workshops led by E1 and EFG, with participation from various organizations.

categories such as host customer non-energy benefits or environmental benefits, and therefore they are not recommended for separate accounting to avoid potential double counting of impacts. Working group members also identified additional...

AI summary The document discusses the inclusion of utility system impacts (USIs) in cost-effectiveness tests for DERs, emphasizing the need to compare economic merits of DERs with supply-side alternatives. It highlights potential overlaps in impact categories and notes that not all USI impacts may be relevant or material for every DER.

s that are not applicable to some DERs. In addition, even when categories of USI impacts are conceptually applicable to a DER, they may not be material enough to routinely include in a test. 1. Definitions and Examples USIs are elements of...

AI summary This text discusses the concept of utility system impacts (USIs) in the context of distributed energy resources (DERs), noting that not all USI categories are applicable to all DERs. It also references a benefit-cost analysis test application by EfficiencyOne and mentions the Energy Futures Group.

other general system impacts. 21 Table 8 provides a brief description and examples of electric system impacts. Table 8: Electric System Impact Definitions Impact Type Utility System Impact Description and Examples The production or procure...

AI summary The text discusses electric system impacts, including energy generation, capacity, environmental compliance, market price effects, and transmission capacity. Table 8 provides definitions and examples of these impacts, such as line losses, compliance with renewable standards, and wholesale market price changes.

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.

oided costs. The working group further discussed why some impacts have not been included or fully incorporated in the BCA to date for EE and DR and options for including them moving forward: • Environmental compliance- Assuming Nova Scotia...

AI summary The working group discussed why some environmental compliance and utility direct investment impacts have not been fully included in the Benefit-Cost Analysis (BCA) for energy efficiency (EE) and demand response (DR) programs. It noted that environmental compliance costs may be embedded in avoided costs and that utility investments in distributed energy resources (DERs) could increase as technologies evolve.

areas with high saturation of distributed generation or grid constraints may be more likely in the future. • Credit and collections – NS Power stated they have not experienced material impacts on costs associated with account delinquencies...

AI summary The text discusses potential future impacts of distributed energy resources (DERs) on credit and collections, program administration, risk, reliability, and resilience. NS Power notes no material impacts currently but acknowledges future risks as DER deployment increases. Energy efficiency and demand response (DR) are highlighted for their potential resilience benefits.

ing support can also support building comfort and services during recovery. It is also possible for some DR assets to have cold-start capabilities and provide resilience value. 2. Nova Scotia Electricity Utility System Impacts BCA Proposal...

AI summary The text discusses the inclusion of Utility System Impacts (USIs) in the Benefit-Cost Analysis (BCA) test for Distributed Energy Resources (DER) in Nova Scotia. It emphasizes the importance of considering system impacts on generation, transmission, and distribution to ensure accurate BCA results.

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

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

Table 12: Other Fuel Impacts Other Fuel Impacts Description and Examples EE DR DG DS EV BE Discussion Notes Primarily electrification or efficiency Fuel and related O&M costs of displacing fossil fuels. Distributed Storage Commodity   ...

AI summary The table outlines other fuel impacts, including electrification, efficiency, and compliance costs for environmental regulations. It also addresses market price effects and cross-fuel dripe in Nova Scotia. The discussion notes highlight the displacement of fossil fuels and the embedding of compliance costs in commodity prices.

Cross fuel dripe in NS for pipeline gas could Market Price Effects fuels resulting from changes in NM NM NM NM NM NM be meaningful for large industrial customers, levels of consumption but cross fuel impact is generally expected to be NM....

AI summary The text discusses potential cross-fuel impacts in Nova Scotia, particularly for large industrial customers, and the implications of gas and electric DERs on utility systems. It notes that further analysis is required to understand the effects on gas consumption and infrastructure.

demand created by BE, and implications on reliability, etc.) gas system infrastructure and operations. Key  Impacts that are both applicable and material NA Impacts that are not applicable to a given DER or in NS market NM Not material, o...

AI summary The document discusses host customer impacts related to distributed energy resources (DERs), distinguishing between energy and non-energy impacts. It notes that energy impacts are already accounted for elsewhere and focuses on non-energy benefits and costs, such as measure costs and incentives, which should be considered in a jurisdictional test. This is part of a benefit-cost analysis for a demand-side management (DSM) plan.

Page 41 of 68 EfficiencyOne Benefit-Cost Analysis Test Application Appendix B energyfuturesgroup.com 42 Table 13: Host Customer Impacts Host Customer Impact - +/- Direct Estimates EE DR DG DS BE EV Notes Not always for DR, but possible (e....

AI summary The table outlines the host customer impacts of various energy efficiency and demand response measures, including direct estimates, DER measure costs, interconnection fees, tax incentives, and water cost impacts. EfficiencyOne proposes not to include tax incentives as cost reductions due to uncertainty in their continued availability.

ent-climate-change/services/climate-change/science-research-data/social- cost-ghg.html 35 Appendix C provides the updated social costs of carbon dioxide, methane and nitrous oxide. Energy Futures Group, Inc PO Box 587, Hinesburg, VT 05461...

AI summary The text references the updated social costs of greenhouse gases and discusses the methodology used by the US Environmental Protection Agency (EPA) for calculating benefits-per-kilowatt-hour (BPK) of air quality-related public health benefits from energy efficiency and renewable energy investments, specifically using New England regional values in a Benefit-Cost Analysis (BCA) test.

36 The consultant team recommends using the New England regional values developed by the EPA in this analysis for valuation per kWh of the reduction of other air pollutants in the BCA test. The EPA calculates BPK for different regions of t...

AI summary The consultant team recommends using New England regional values from the EPA for calculating the benefit per kWh of air pollutant reductions in the BCA test. These values range from 0.34 to 0.77 cents per kWh for energy efficiency and DERs, and are considered the low end of the range due to differences in fossil fuel mix across regions.

energyfuturesgroup.com 54 VI. Example Quantification of Impacts for Nova Scotia Test 1. Introduction The consultant team recommends the new Nova Scotia test include electric utility system impacts, other fuel impacts, host customer impacts...

AI summary This section introduces the recommended approach for quantifying impacts in the new Nova Scotia test, including electric utility system impacts, other fuel impacts, host customer impacts, and GHG and air pollution emission impacts. It emphasizes that these examples are illustrative and may be updated based on stakeholder input and future analysis.

and impacts between DERs are more likely for certain costs and benefits. Interactive effects are not addressed in this report but are important areas for future analysis and consideration. 2. Residential Heat Pump Example Two cases for a c...

AI summary The text discusses the interactive effects of DERs and presents a residential heat pump example to illustrate the application of the new BCA test. It includes assumptions about system efficiency, fuel prices, and carbon pricing, with references to external data sources.

tunity to provide comments on all materials shared throughout the development process. M10473, E1 2023-2025 DSM Plan, NSUARB Order, November 8, 2022, Directive (4), page 2. Request IR-02: Reference: Evidence Page 13: Reference is made to s...

AI summary E1 responds to IR-02 by defining strategic electrification as shifting from fossil fuels to electricity to reduce costs and emissions. It outlines a test to compare GHG emissions between electricity and fossil fuels but does not confirm whether Eastward Energy was consulted on the new BCA test. The response references the Public Utilities Act and NSUARB Order M10473.

9 Impact Category Impact Type Impact Work Products Energy Generation Capacity Avoided costs of energy & capacity are currently Generation Environmental Compliance developed and provided by NS Power; in the future these are expected to come...

AI summary The text outlines the current and future responsibilities of NS Power and the NSIESO in developing avoided costs for energy generation, transmission, and distribution. It highlights the transition of responsibilities and considerations such as marginal system losses and the role of E1 in developing financial incentives.

1 1 Request IR-04: 2 3 Reference: E-1, Evidence, Section 2.2, page 4. 4 5 The National Standard Practice Manual ("NSPM"), which provides a comprehensive framework 6 for cost-effectiveness assessment of Distributed Energy Resources, identif...

AI summary The document discusses the principle of symmetry in cost-effectiveness assessments of Distributed Energy Resources, as outlined in the National Standard Practice Manual. It also addresses the use of Program Administrator Cost (PAC) test results in regulatory proceedings, explaining their informational purpose and how they relate to the Total Resource Cost (TRC) test.

(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.

- 7 See Table 5 from the EFG Report, reproduced below, as an illustrative example of the accounting. [1](#page-37-0) 8 Nova Sco tia Test ($Million), 2% Social Di scount Rate, Usine 202 3-2025 Av oided Co osts: Example based on 1,000 Heat P...

AI summary The text presents a table from the EFG Report illustrating the accounting of benefits and costs associated with replacing 1,000 heat pumps in Nova Scotia. It includes avoided costs for generation, transmission, and distribution, as well as financial incentives, program administration, and environmental impacts.

- 2 system benefit that is not measured and is considered not material. 1 Request IR-05: 4 (g) TBCS: Account for all direct and indirect costs, including opportunity costs. 5 BCA: Program and participant costs are included using consistent...

AI summary The text discusses the inclusion of costs and benefits in a benefit-cost analysis (BCA) for strategic electrification, including the consideration of host customer costs such as EV charger expenses. It also references the definition of demand-side management in the Public Utilities Act and questions how the BCA ensures alignment with strategic electrification goals.

xviii) How many states in the database are currently measuring Host Customer "Pride" impacts for their related BCA test? (Please identify the related states and whether the test is applied at the measure, program or portfolio level.) (e) P...

AI summary The response discusses the National Energy Screening Project (NESP), its mission to improve cost-effectiveness screening practices for distributed energy resources (DERs), and its products including the National Standard Practice Manual (NSPM) and Methods, Tools, and Resources (MTR) Handbook. It highlights NESP's role in convening stakeholders and providing BCA resources.

Ibid. 1 Request IR-10: 2 3 Table 4: NSPM BCA Guiding Principles 4 5 (a) Principle 5 identifies that the analysis should be forward looking and compared against a 6 scenario without the Distributed Energy Resources (DER). Please explain why...

AI summary This document discusses the application of a new Benefit-Cost Analysis (BCA) test for evaluating Demand Side Management (DSM) plans. It addresses the principle of using a scenario without Distributed Energy Resources (DER) as the basis for comparison in BCA analysis and confirms that all utility system impacts included in the TRC test are identified in Table 6 of E1's Evidence.

- (c) Public health benefits are related to a reduction in mortality and morbidity rates and associated health care and economic costs associated with each. Energy efficiency reduces the need for electric generation, and associated combust...

AI summary The text discusses public health benefits from energy efficiency and their integration into the BCA test, as well as energy security impacts and their exclusion from the new BCA test. It notes that energy efficiency reduces fossil fuel combustion and that energy security improvements from distributed energy resources are not included in the BCA test.

Date Filed: July 4, 2025 E1 (NSEB) IR-27 Page 2 of 2 1 Request IR-28: 2 3 Reference: Appendix B EFG Report 4 5 Page 8, under Not Material explains that some outcomes that don't produce a large enough 6 effect are excluded from the BCA. Ple...

AI summary The response to Request IR-28 identifies several impacts excluded from the BCA due to insufficient effect size, including renewable portfolio standard compliance, ancillary services for electric vehicles, and distribution voltage impacts for DER. These impacts are considered unlikely to significantly affect cost-effectiveness screening results.

- 2 Table 4: Non-Utility Impacts Consistent with Nova Scotia Policy Goals - 3 GHG reductions for demand response and distributed storage.

AI summary The text mentions Table 4, which outlines non-utility impacts aligned with Nova Scotia's policy goals, and highlights GHG reductions associated with demand response and distributed storage initiatives.

impact of generation changes and distributed energy resources on the T&D system; and escalating costs of T&D infrastructure. E1 has not proposed a specific methodology for M12282, E1 BCA Test Application, May 16, 2025, Appendix A, Attachme...

AI summary E1 has not proposed a specific methodology for assessing the impact of generation changes and distributed energy resources (DER) on transmission and distribution (T&D) systems, while noting escalating T&D infrastructure costs. The text references the National Standard Practice Manual (NSPM) and cites matter M12282.

M12282, E1 BCA Test Application, May 16, 2025, Appendix B: Development of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 14 of 68. 1 Request IR-39: 2 3 Reference: Appen...

AI summary The response to Request IR-39 discusses the resilience benefits of E1's demand side management (DSM) portfolio, noting that current benefits are not material but future resilience impacts from distributed generation, storage, and demand response may exist. Energy efficiency and vehicle-to-building support are also mentioned as potential contributors to system resilience.

of a Jurisdictional Benefit Cost Analysis Framework for Nova Scotia (EFG Report), Prepared by Energy Futures Group, page 12 & 33 of 68. recommended for inclusion in the proposed BCA. [1](#page-11-0) Request IR-09: Refer to Exhibit E-1, the...

AI summary The response to Request IR-09 discusses how the current Total Resource Cost (TRC) test in Nova Scotia does not adhere to the National Standard Practice Manual (NSPM) in several key principles, including the treatment of DERs, alignment with policy goals, symmetry, and inclusion of material impacts such as host customer costs.

OTHER BCA CONSIDERATIONS - E1's Application relies on the National Standard Practice Manual for Benefit-Cost Analysis of - Distributed Energy Resources ("NSPM"), produced by the National Energy Screening Project. - Does E1 appropriately in...

AI summary The NSUARB found E1's BCA methodology inconsistent with the NSPM's principles, particularly Principle 1, which requires treating DERs as utility system resources. E1's approach uses non-standard discount rates and unbalanced plan design, potentially biasing resource investment decisions against residential and business interests.

t 2017-2018): Support in regulatory proceedings before the New Brunswick Energy and Utilities Board on matters of Revenue Requirement, customer class and rate design, and smart meter implementation. For the PEI Federation of Agriculture (2...

AI summary Bowman Economic Consulting Inc. has provided technical and regulatory support across multiple jurisdictions, including rate design, cost-of-service modeling, and regulatory filings for utilities, municipalities, and Indigenous groups. Engagements span energy, infrastructure, and industrial sectors from 2013 to 2025.

Evidence of Courtney Lane 1 20 programs, and the Energy Reform Act that broadens what the Board should consider 2 when it makes regulatory decisions and establishes the Energy and Regulatory Boards 3 21 Act and the More Access to Energy Ac...

AI summary Courtney Lane discusses the use of the Nova Scotia Policy Model (NSPM) in other jurisdictions, noting that 12 U.S. states and the District of Columbia have adopted it for DER cost-effectiveness tests. She also states that no Canadian provinces have used the NSPM for BCA tests, but sees no reason why they should not. The NSPM is described as objective, policy-neutral, and economically sound.

- 1 consisting of regulators, U.S. state agencies, utilities, expert consultants, and - 2 representatives from the DER industry. - 3 The fundamental BCA principles included in the NSPM, such as comparing DERs - 4 consistently with other en...

AI summary The text discusses the relevance of Benefit-Cost Analysis (BCA) principles in the Nova Scotia Policy Model (NSPM) for evaluating Distributed Energy Resources (DERs), emphasizing consistency, symmetry, long-term analysis, and separation of rate analyses. It notes the involvement of regulators, U.S. state agencies, utilities, consultants, and DER industry representatives.

Q. If an impact is not applicable or not material, should it be excluded from the Nova Scotia Test? A. No, it should not. It is important to distinguish between the definition of the BCA test and the application of the test. All utility sy...

AI summary The Nova Scotia Energy Board (NSEB) asserts that impacts should not be excluded from the Nova Scotia Test even if not applicable or material. The distinction between the BCA test's definition and its application is critical, ensuring all relevant impacts are included for policy goals while allowing exclusion in specific DER cases. This approach supports transparency and consistency in cost-effectiveness evaluations.

1 Table 2. Comparison of Proposed Nova Scotia Test to TRC Test Impact Category Sub-Category Nova Scotia Test Total Resource Cost Test (2023–2025) Electric Utility System Generation ✓ ✓ Transmission ✓ ✓ Distribution ✓ ✓ General ✓ ✓ Gas Util...

AI summary Table 2 compares the proposed Nova Scotia Test with the TRC Test, focusing on different impact categories such as electric and gas utility systems, non-utility systems, and various subcategories. The table highlights differences in how costs and benefits are considered, particularly in the 'Host Customer' and 'Societal' categories.

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.

3 Table 4. EFG Host Customer NEB Proxy Recommendations Host Customer Impact – by Measure Category and Customer Segment Non-Income Qualified/Target Market Segment Income Qualified Target Market Segment Notes Building Shell Measures (Air Sea...

AI summary Table 4 presents NEB proxy recommendations for various energy efficiency and demand response measures, categorized by host customer impact. It shows varying percentages of benefit for non-income and income qualified market segments, with notes on factors such as health, safety, economic well-being, and resilience.

EFG Report page 46. EFG Report page 48. 1 The main justification provided by EFG are the notes summarized in Table 4 above and 2 statements that custom projects, which often highlight productivity or process 3 improvements, should have hig...

AI summary The witness expresses concerns about EFG's approach to determining NEB proxy values, particularly the lack of documentation for the 20% adder used for building shell measures and BNI Custom Measures. They recommend including host customer NEBs in the Nova Scotia Test, citing literature from other jurisdictions that quantify NEBs associated with DERs.

1 I further recommend that the Board direct E1 to launch a process for updating the NEB 2 proxies in 2029 for use in the next DSM Plan. 3 4 Q. Should the Board choose not to adopt the use of host customer NEBs, is there an alternative appr...

AI summary The text discusses the recommendation to update the Non-Energy Benefits (NEB) proxies in 2029 for the next DSM Plan. It also explores the impact of excluding host customer costs and benefits from Benefit-Cost Analysis (BCA) for DERs such as solar PV and EVs, highlighting the need for a comprehensive cost-effectiveness test that includes host customer impacts.

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

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

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

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

L Electric Utilities Corporation for an Evidentiary Hearing on the Energy Efficiency Benchmarks Established for the Period June 1, 2013 through May 31, 2016. On behalf of PennFuture. October 19, 2012. Pennsylvania Public Utility Commission...

AI summary Courtney Lane provided testimony on behalf of PennFuture in multiple Pennsylvania regulatory proceedings, including energy efficiency benchmarks, retail electricity market investigations, solar energy permitting fees, and alternative energy conservation. Testimonies span 2008 to 2012.

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

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

Professional Experience December 2005 – Present Co-Founder, Green Energy Economics Group, Inc ., Cuttingsville, VT. Consultancy specializing in energy-efficiency and renewable resource portfolios investing in electricity and gas savings, c...

AI summary The individual's professional experience spans energy efficiency, renewable resources, and civil engineering. They co-founded Green Energy Economics Group, Inc., developed cost-effectiveness models for demand-side management, and worked on energy-saving analyses. Previous roles include Senior Analyst at Optimal Energy, Inc., and civil engineering positions at Enman Engineering and Nowlan Engineering. Their work includes utility regulatory proceedings and program planning.

Massachusetts Attorney General's Office of Ratepayer Advocacy - Reviewed pilot district geothermal project (DPU 24-114). November 2024 Present. - Provided economic, technical, and policy related consulting services to the AG's office relat...

AI summary The Attorney General's Office of Ratepayer Advocacy in Massachusetts reviewed a pilot geothermal project (DPU 24-114) and provided consulting services on energy efficiency plans (Mass Save 2025-2027) and decarbonization initiatives like the Clean Heat Standard from October 2023 to the present.

California Small Business Utility Advocate (2020 to present) - Provided testimony on the Energy Efficiency Business Plans for the 2024-2027 Portfolio and comments on staff proposal for gas energy efficiency incentives and codes and standar...

AI summary The Small Business Utility Advocate (2020–present) provided testimony and comments on energy efficiency programs, gas incentives, clean energy financing, and CleanPowerSF's Food Service Program design. Key docket numbers include 22-02-005, 20-08-022, and R13-11-05.

District of Columbia Developed multi-measure cost-effectiveness screening tool for the District of Columbia Sustainable Energy Utility, as a subcontractor to Vermont Energy Investment Corporation. November 2011 – 2014.

AI summary A multi-measure cost-effectiveness screening tool was developed for the District of Columbia Sustainable Energy Utility by Vermont Energy Investment Corporation as a subcontractor between November 2011 and 2014.

PRIOR ASSIGNMENTS (ENVIRONMENTAL SOLAR DESIGN) – 1984-1985 Designed, permitted and installed solar hot water systems for commercial and residential customers. (1984-1985)

AI summary From 1984 to 1985, solar hot water systems were designed, permitted, and installed for commercial and residential customers, focusing on environmental solar design initiatives.

Introduction Eastward Energy Inc. ("Eastward") is the incumbent natural gas supplier in the Province of Nova Scotia. As this is the first Application by EfficiencyOne ("E1") to substantively raise the issue of potential strategic electrifi...

AI summary Eastward Energy Inc., Nova Scotia's incumbent natural gas supplier, opposes EfficiencyOne's (E1) first application regarding strategic electrification initiatives, arguing the proceeding could impact the provincial energy landscape. Eastward addresses concerns raised by E1's application and information request responses.

Participation in the DSMAG In response to Eastward's IR-03 E1 stated three specific reasons why in its view Eastward's participation in the Demand Side Management Advisory Group ("DSMAG") is not suitable. Eastward wishes to address each of...

AI summary Eastward challenges E1's claim that its participation in the DSMAG is unsuitable due to potential conflicts, arguing that NSPI's existing membership (a fossil fuel provider) creates a greater conflict. Eastward also highlights its interest in strategic electrification and the BCA test for cost-effectiveness analysis.

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

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

• Natural Gas to Electric Conversions o Based on the illustrative example provided by EFG, Eastward does not believe that the conversion of gas heating systems to electric heat pumps should be considered as strategic electrification, as it...

AI summary Eastward argues that converting gas heating systems to electric heat pumps should not be considered strategic electrification, citing a negative net benefit of $17.4 million and a benefit cost ratio of 0.45 based on EFG's illustrative example.

- The Quebec Government recognized the importance of hybrid heating in its 2030 Plan for a Green Economy: "Fully electrifying heating would not be ideal for Québec. It would create a significant peak demand issue at certain times during th...

AI summary The text discusses the benefits of hybrid heating systems, citing examples from Quebec, Ontario, and FortisBC. It highlights concerns about full electrification of heating, such as increased peak demand and costs, and the need for natural gas as a complementary energy source for reliability and grid stability.

1 Table 2: Illustrative Example - Hybrid System Replacing Fuel Oil Furnaces Nova Scotia Test ($Million), 2% Social Discount Rate, Using 2023-2025 Avoided Costs: Example based on 1,000 Hybrid Systems Replacing Fuel Oil Furnaces, Program Yea...

AI summary Table 2 presents a Benefit-Cost Analysis (BCA) of a hybrid system replacing fuel oil furnaces, showing net benefits with a benefit-cost ratio of 2.21 for E1 costs and 2.27 for E3 costs. The analysis includes energy generation, capacity, environmental impacts, financial incentives, and other factors such as avoided heating oil costs and health impacts from greenhouse gas emissions.

Managing Consultant Melissa Whitten joined Daymark Energy Advisors in 2009 with more than 25 years of experience in energy management and energy and financial consulting. Her work experience includes six years as Director of Gas Supply, Tr...

AI summary Melissa Whitten, with over 25 years of experience in energy management and consulting, joined Daymark Energy Advisors in 2009. She has expertise in natural gas and electric utilities, including supply, transportation, storage, LNG, RNG, and renewable diesel procurement.

PRESENTATIONS, ENERGY ORGANIZATION MEMBERSHIPS - Presented on Gas LDC Challenges in a Decarbonized World, market overview for Renewable Natural Gas and Hydrogen alternate fuels at 2022 Energy Bar Association (EBA) Annual Meeting, Washingto...

AI summary The text outlines participation in energy-related presentations and memberships, including discussions on Renewable Natural Gas (RNG), Hydrogen, and Blockchain for Energy. Key organizations involved include the Energy Bar Association (EBA), Northeast Energy & Commerce Association (NECA), and National Association of State Utility Commissioners (NASUCA). The individual has been actively involved in energy policy and decarbonization topics since 2009.

OTHER BCA CONSIDERATIONS - E1's Application relies on the National Standard Practice Manual for Benefit-Cost Analysis of - Distributed Energy Resources ("NSPM"), produced by the National Energy Screening Project. - Does E1 appropriately in...

AI summary E1's Benefit-Cost Analysis (BCA) approach is criticized for violating Principle 1 of the National Standard Practice Manual (NSPM) for DERs, which mandates treating DERs as utility system resources and comparing them with other resources using consistent methods. The NSUARB argues E1's BCA uses inconsistent inputs like discount rates and unbalanced plan design.

on, and major PUB Project Permit reviews of projects >$5 million. For Tolko Manitoba (2014-2015): Assist in negotiations with Manitoba Hydro regarding expansion of steam generation capabilities. For Kwadacha First Nation and Tsay Keh Dene...

AI summary The text outlines various projects and roles from 1998 to 2015, focusing on environmental, socioeconomic, and energy-related assessments and collaborations with organizations and First Nations in Manitoba and northern BC, including impact analyses, mitigation programs, and energy supply options.

Strategic or unstrategic electrification? A renewed cost-effectiveness test is particularly important for Nova Scotia to make sound decisions about managing electrification. The proposed test enables the inclusion of other fuel impacts alo...

AI summary Nova Scotia seeks a renewed cost-effectiveness test to evaluate electrification's strategic value by incorporating multi-fuel impacts. Efficiency Canada's report emphasizes aligning energy efficiency with net-zero goals across fuels. Efficiency Nova Scotia is positioned to balance interests as a multi-fuel administrator, mitigating electricity system costs through integrated programs like demand response and heat pumps.

EfficiencyOne's Application for approval of a New Benefit-Cost Analysis Test for Evaluating Demand Side Management (DSM) Plans (NSEB M12282) SBA Responses to NSEB Board Staff Information Requests NON-CONFIDENTIAL Despite these concerns, Da...

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

Response: - From the outset, the focus should be on the fundamental E1 transaction, which is spending on - subsidies and programs towards energy efficiency and electrification. - Anyone can undertake energy efficiency activities at any tim...

AI summary The response emphasizes that E1's role is to provide incentives and share information to boost energy efficiency and electrification, not achieve these goals directly. It argues that PAC is a more accurate measure of E1's cost-effectiveness than TRC, which overemphasizes participant spending and overlooks E1's incentive programs. The Energy Board's focus on cost-effectiveness aligns with PAC's targeted evaluation.

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.

Request IR-2:

AI summary The document outlines Request IR-2, focusing on distributed energy resources (DER), demand-side management (DSM), and benefit-cost analysis (BCA) within a Nova Scotia regulatory proceeding. Key arguments and entities are not explicitly detailed in the provided text.

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

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

Response IR-2: (a) Yes. Synapse's support for E1's proposed BCA test does consider the fact that DER programs are funded by ratepayers. Synapse does not think there should be a closer linkage between the benefits/costs included in the BCA

AI summary Synapse supports E1's proposed BCA test, acknowledging that DER programs are funded by ratepayers. However, they argue against establishing a closer linkage between the benefits and costs included in the BCA.

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.

Professional Summary Chris specializes in analysis of markets for energy efficiency, demand response, renewable energy and strategic electrification measures, as well as the design and evaluation of programs and policies – including climat...

AI summary Chris has over 25 years of experience in energy efficiency, demand response, renewable energy, and strategic electrification. He has worked globally with regulators, utilities, and governments, testified in 75+ regulatory cases, and authored reports on clean energy policies, including a national standard practice manual for distributed energy resources.

Selected Projects - Natural Resources Defense Council (Illinois, Michigan and Ohio). Critically review energy efficiency, demand response, electrification, distribution system investment and integrated resource plans filed by IL, MI and OH...

AI summary The document outlines two key projects: Natural Resources Defense Council (NRDC) engaging in energy efficiency reviews, regulatory testimony, and legislative support in Illinois, Michigan, and Ohio from 2010 to present. E4TheFuture co-authored the National Standard Practice Manual (NSPM) for distributed energy resources (DERs) and conducted training from 2016 to present, with updates expected in 2025.

Energy Futures Group, Inc - Maryland Public Service Commission. Part of team that led a year-long stakeholder Work Group in the development of a unified benefit-cost analysis (UBCA) framework for consideration of all distributed energy res...

AI summary Energy Futures Group, Inc. leads benefit-cost analysis frameworks for DERs in Maryland and Nova Scotia, advises on gas DSM and IRP committees in Ontario, and represents environmental groups in regulatory proceedings. They focus on UBCA development, demand response, electrification, and decarbonization strategies.

Selected Publications and Reports - National Standard Practice Manual for Benefit Cost Analysis of Distributed Energy Resources , Second Edition, to be published December 2025 (with Tim Woolf and others) - New Jersey's Electric Grid Has He...

AI summary The document lists publications and reports on energy efficiency, distributed energy resources (DERs), and clean heat standards (CHS). Key topics include benefit-cost analysis of DERs, building decarbonization, residential electrification, and heat pump adoption. Reports are authored by individuals and organizations such as the Natural Resources Defense Council, Environmental Defense Fund, and Vermont Energy Action Network.

Zero-Emission Freight Strategy (Part 1): New Brunswick Power (Nov. 2023 ongoing)

AI summary The document outlines the Zero-Emission Freight Strategy (Part 1) led by New Brunswick Power, part of an ongoing regulatory proceeding since November 2023. The text includes image references but no detailed analysis or arguments related to energy efficiency technologies or market research.

Transportation Energy Efficiency Technology and Market Research - Environmental and Health Impacts of Small Gasoline Powered versus Electric Powered Mobile Outdoor Equipment in Canada: Environment and Climate Change Canada (Feb. 2021-May 2...

AI summary The document lists studies on transportation energy efficiency in Canada, including environmental impacts of outdoor equipment, fuel-saving measures in heavy-duty vehicles, EnerGuide label accuracy, and vehicle technology assessments. Research was conducted by Environment and Climate Change Canada, Transport Canada, and Natural Resources Canada's Office of Energy Efficiency between 2012 and 2021.

ment that it consider NSPI customer interests in the same metric as - the E1 program screening."[7](#page-7-3) [emphasis added] - E1 Response - E1 addresses these two arguments separately, below. - 2.2.1 PEER UTILITIES - Nova Scotia legisl...

AI summary E1 argues that Nova Scotia legislation, not peer utility practices, determines the BCA test for DSM. It aligns the test with the Energy Reform (2024) Act and Public Utilities Act , emphasizing strategic electrification and sustainability. The customized test, modeled on the NSPM, incorporates environmental/social impacts, citing Efficiency Canada and a 2022 NSUARB decision.

4. GREEN ENERGY EVIDENCE

AI summary The section titled 'GREEN ENERGY EVIDENCE' introduces the context of a regulatory proceeding in Nova Scotia, focusing on green energy-related submissions. Key acronyms and entities involved in the proceeding are pre-defined for reference.

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.

Strategic Electrification Eastward Energy has reviewed the evidence in this proceeding, and this Application is the first time that E1 has substantively referred to the potential for it to start strategic electrification, and it has provid...

AI summary Eastward Energy advocates for strategic electrification, proposing a BCA test to evaluate gas-to-electric conversions. The Gas Distribution Act amendment mandates hybrid peaking resources, aligning with Nova Scotia Power's IRP findings showing $2.3B savings in hybrid peak scenarios. Eastward Energy emphasizes DSMAG's role in the 2027-2031 DSM Plan.

Electrification Tests Per Illustrative Example of 1,000 Heat Pump Replacements - as compared to Oil Heating

AI summary The document presents an illustrative analysis comparing the impacts of replacing 1,000 oil heating systems with heat pumps, focusing on electrification outcomes. It includes a figure (Figure 1) to visualize the comparison, though specific quantitative results or policy implications are not detailed in the provided text.

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.

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

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

3.6 Eastward Energy [61] In its submissions, Eastward Energy asked the Board to make a preliminary and final order that Eastward be added as a full member of DSMAG. On November 4, 2025, the Board noted that Eastward has a valuable perspect...

AI summary Eastward Energy requested DSMAG membership, which the NSUARB approved. They supported strategic electrification testing methods aligning with Posterity Group's recommendations and advocated for hybrid heating in E1's 2027-2031 DSM Plan, emphasizing economic benefits and regulatory alignment with the PUA.

4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...

AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The new definition of 'demand-side management' includes strategic electrification, and affordability requirements were removed from legislation previously considered in the 2020 NSUARB decision.

The current version is: (iv) strategic electrification of energy end uses currently powered by fossil fuels in a manner that reduces overall greenhouse gas emissions and electricity costs [108] E1 submits that strategic electrification can...

AI summary E1 argues that strategic electrification, defined under the PUA amendment, requires expanding cost-effectiveness testing beyond traditional PAC/TRC frameworks to account for non-utility benefits like fuel savings and GHG reductions. E1 claims this is essential to fulfill its mandate under the updated DSM definition.

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.

[146] In its closing submissions, the Industrial Group said: Where the PUA has clearly mandated the focus of DSM to be on the reduction of costs, the PAC is able to demonstrate that as a primary test; the Proposed BCA cannot. As confirmed...

AI summary The Industrial Group argues that the Program Administrator Cost (PAC) test aligns with the PUA's mandate to reduce electricity costs, unlike the Proposed BCA. NS Power proposes a modified Total Resource Cost (TRC) test to account for fuel switching benefits, while E1 criticizes both approaches, claiming they fail to meet legislative requirements or address strategic electrification mandates. The debate centers on cost-effectiveness criteria for demand-side management.

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

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

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

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

4.3.1 Findings [162] The Board accepts the Industrial Group's suggestion that traditional cost effectiveness tests may be modified to suit specific jurisdictional requirements. The means of assessing strategic electrification in Nova Scoti...

AI summary The NSUARB accepts modifying traditional cost-effectiveness tests for strategic electrification in Nova Scotia. E1's approach to demonstrating cost reductions remains incomplete, so it must follow Mr. Bowman's PAC test recommendation temporarily. The Board allows E1 to propose an alternative method in its 2027-2031 DSM Plan if it meets statutory requirements for reducing both GHG emissions and electricity costs.

4.5 Discount Rate [169] Benefit-cost analysis involves comparing all the costs and benefits of a program over a period of time. There will be a stream of costs and benefits that are usually spread over several years, and in some cases, dec...

AI summary The section discusses the role of discount rates in Benefit-Cost Analysis (BCA) for distributed energy resources. It explains that discount rates determine the present value of future costs and benefits, with the NSPM outlining three categories: WACC, customer-focused rates, and societal discount rates. Higher rates prioritize near-term costs, while lower rates balance long-term considerations.

4.7 Eastward Energy on DSM Advisory Group [206] Eastward Energy requested the Board order that it be added as a full member of the DSMAG. Although E1 acknowledged Eastward's valuable information and perspectives regarding natural gas hybri...

AI summary Eastward Energy requested to join the DSMAG, arguing its expertise in hybrid peaking resources and legislative mandates under the Gas Distribution Act. E1 opposed, citing narrow focus and potential conflicts, suggesting one-on-one engagement. Eastward emphasized its pilot projects and data on GHG emissions, urging inclusion in the 2027-2031 DSM Plan.

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.

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

AI summary Request IR-10 seeks clarification on non-commodity impacts in gas utility systems, including their definition, applicability to DER, required data, and EFG's methodology. The EFG Report (page 17) states non-commodity impacts are not quantified for the new jurisdictional test due to data gaps, though qualitative discussion in DSM plans and proxy adder considerations are queried.

Request IR-17: - Page 46 of the EFG report cites the use of non-energy impacts adopted in Vermont, Colorado, and Nevada. - a. To what extent did EFG use the adders adopted in these jurisdictions to inform its recommended proxy adders for t...

AI summary Request IR-17 questions EFG's use of non-energy impact adders from Vermont, Colorado, Nevada, and Massachusetts, seeking clarification on their methodology, whether other jurisdictions use adders for specific DERs, and why Massachusetts wasn't cited. It also asks about consideration of data from similar jurisdictions.

Emissions Factor Year (tonnes CO2e/MWh) 2026 0.448 2027 0.355 2028 0.431 2029 0.393 2030 0.086 2031 0.159 2032 0.320 2033 0.360 2034 0.369 2035 0.269 2036 0.355 2037 0.288 2038 0.239 2039 0.218 2040 0.221 (b) Please provide the source of t...

AI summary The document presents projected electricity emissions factors for Nova Scotia from 2026 to 2040 and requests clarification on the source of these projections and what they represent (e.g., average annual emissions intensities or marginal emissions intensities based on winter peak generation resources).

Request IR-6: - Page 17 of 38 of E1's Evidence states: "To perform cost effectiveness testing of strategic - electrification you must include the relevant benefits and costs. In the case of strategic - electrification, the electric utility...

AI summary The document raises two key questions regarding strategic electrification's cost-effectiveness testing. First, whether host customer costs (e.g., EV chargers) are included in BCA tests. Second, how the proposed BCA ensures strategic electrification reduces electricity costs as mandated by the Public Utilities Act's definition of demand-side management.

Request IR-7: - On page 18 of 38 of E1's Evidence, a hyperlink to the "National Energy Screening Project (NESP), National Standard Practice Manual (NSPM) for Benefit-Cost Analysis of Distributed Energy Resource" is provided: - a) Please de...

AI summary Request IR-7 seeks information on the National Energy Screening Project (NESP), deviations from the NSPM in the proposed BCA test, use of the MTR handbook for quantifying benefits/costs, and data from the DSPs on states' adoption of NSPM, SCT, and resilience metrics in energy efficiency evaluations.

Request IR-8: - With respect to the NSPM for Benefit-Cost Analysis of Distributed Energy Resource: - a) Please identify any Canadian jurisdictions that have adopted the NSPM as their standard approach to BCA for DSM or Distributed Energy R...

AI summary Request IR-8 seeks information on Canadian jurisdictions adopting Nova Scotia Power's (NSPM) BCA methodology for DER/DSM, differences in application compared to E1's proposal, and alternative BCA methodologies used, including California's Standard Practice Manual.

Request IR-9: - Please provide a summary of the feedback provided by the DSMAG regarding the final draft EFG - report, as referenced on page 20 of 38 of E1's Evidence. - Request IR-10: - Table 4: NSPM BCA Guiding Principles - a) Principle...

AI summary The document outlines regulatory requests related to DSM and DER BCA analyses. Key issues include clarifying the basis for comparing DER scenarios in BCA, identifying unlisted utility impacts, and evaluating the inclusion of policy goals in BCA tests. E1 is asked to confirm the Board's discretion in approving portfolios despite BCA results.

Request IR-29: - With regards to Table 2 on page 13 of 68 of the EFG Report: - a) Please describe any initiatives that E1 currently has underway or is considering related to Distributed Generation (DG). - b) Please describe any initiatives...

AI summary Request IR-29 seeks information from E1 (EfficiencyOne) regarding current or planned initiatives in Distributed Generation, Distributed Storage, Electric Vehicles, and Building and Industry Electrification. The inquiry is part of a regulatory proceeding involving Nova Scotia Power's Benefit-Cost Analysis (BCA) of Distributed Energy Resources (DER).

Request IR-39: - Page 36, Resilience, measures if a DER can help the electric system recover from a catastrophic - event. Please list the incentives and programs that E1 offers that provide resilience value to the - electric system.

AI summary Request IR-39 asks E1 to list incentives and programs that provide resilience value to the electric system through DER.

Request IR-41: - Table 13 in Appendix B lists the Host Customer Impacts. How does E1 propose to quantify the - following: - a) Transaction Costs - b) Risks - c) Resilience - d) Productivity - e) Comfort - f) Amenity - g) Empowerment - h) P...

AI summary The document requests E1 to explain how it quantifies various Host Customer Impacts, including transaction costs, risks, resilience, and others, as listed in Table 13 of Appendix B.

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.

And after the Board gives that approval and E1 is then mandated to go and carry out that plan, you're aware that E1 reports on a quarterly basis to this Board regarding its progress against that plan. A: I wasn't aware it was quarterly, bu...

AI summary The IG challenges E1's proposed BCA methodology, arguing it redundantly signals E1 to perform tasks already mandated under the Public Utilities Act. E1 claims its BCA addresses DSM goals, including strategic electrification, under its franchise rights. The discussion highlights tensions between regulatory oversight and legislative compliance.

6.4.2 IG'S PROPOSED APPROACH E1 notes that Mr. Bowman's proposed cost-effectiveness test is insufficient to address E1's legislated DSM mandate, in particular its expanded strategic electrification mandate. Mr. Bowman's proposal is to use...

AI summary E1 argues that the PAC test is insufficient for evaluating strategic electrification under its DSM mandate, as it only considers costs. E1 proposes the BCA as a more effective primary test, citing flaws in the PAC approach and complexity from using multiple tests. Experts like Dr. Hill (EFG) and Mr. Neme support this, emphasizing legislative requirements for electrification.

e: societal impact, or direct costs to the utility and ratepayers. The focus for E1, based specifically on the language of the PUA , should first and foremost be the reduction of costs for customers. The main change to the PUA since the la...

AI summary The Public Utilities Act (PUA) mandates that Efficiency One (E1) prioritize cost reduction for customers through demand-side management (DSM), including strategic electrification that reduces both greenhouse gas emissions and electricity costs. The PUA now requires the Energy Board to evaluate DSM plans at the portfolio level, while retaining discretion to approve plans not meeting program-level cost-effectiveness criteria.

e lowest long-term cost of electricity. In that decision, the Board determined there was not a separate environmental mandate for E1, however, there were some environmental benefits.[18](#page-6-4) The only relevant amendment to the effici...

AI summary The Board's jurisdiction over E1's environmental mandate is clarified, noting that while strategic electrification was added to DSM's definition under the PUA, this does not expand the Board's authority to consider non-energy benefits. Prior decisions emphasize that environmental benefits are limited to strategic electrification, not broader program impacts.

Boards Act , SNS 2024, c 2, s.6(2). It remains outside the legislative framework to evaluate cost-effectiveness that has no direct impact on the furtherance of its statutory mandate to reduce costs. The Industrial Group submits that the ad...

AI summary The Board cannot account for non-energy benefits in cost-effectiveness evaluations. The Industrial Group argues that strategic electrification and ERBA allow environmental impact consideration without displacing cost-effectiveness as the primary goal. E1's BCA fails to address electricity cost reduction, despite statutory mandates requiring cost-effectiveness testing focused on reducing electricity costs.

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.

STRATEGIC ELECTRIFICATION With respect to the recently added definition of strategic electrification in section 79A(b)(iv) of the Public Utilities Act , Ms. Thompson confirmed that strategic electrification requires both a reduction in ove...

AI summary The definition of strategic electrification under the Public Utilities Act requires reducing both greenhouse gas emissions and electricity costs. Ms. Thompson notes E1 has not advanced work on demonstrating cost reductions. Mr. Bowman argues the PAC test must include revenue benefits for electrification to pass, emphasizing that avoiding peak demand increases makes the test mathematically feasible.

And similarly. Bowman stated: "Electrification is a tricky topic when you get into traditional DSM metrics, and Mr. Neme pointed this out, but it doesn't fit easily into any of the tests, but particularly it doesn't fit in when you have le...

AI summary Bowman discusses challenges of evaluating electrification under traditional DSM metrics, noting legislative requirements that electrification must reduce customer costs to qualify as DSM. He proposes using a utility-focused PAC test with revenue considerations to assess benefits and demonstrate cost reductions. Fuel oil-to-heat-pump conversion is cited as an example with high utility costs due to capacity-driven expenses.

HYBRID PEAKING RESOURCES Subsection 2(c) of the Gas Distribution Act was added to the Act to make one of the specified purposes of the Act to facilitate the use of gas as a hybrid peaking resource to satisfy the integrated electricity syst...

AI summary Subsection 2(c) of the Gas Distribution Act enables hybrid peaking resources to meet electricity demand. Posterity Group advocates for hybrid heating in the 2027-2031 DSM Plan, supported by Nova Scotia Power, E3, and provincial examples. E1 acknowledges hybrid heating's evaluation under the BCA framework, with the IRP highlighting potential $2.3 billion savings.

espect to Nova Scotia Power's capital expenditure justification criteria when an element of capital budgeting is related to identification of least-cost alternatives for meeting needs.[62](#page-14-0) Eastward submits that the use of the s...

AI summary Eastward challenges the use of social cost of carbon in IRP analysis, warns against overemphasizing sustainability in discount rate calculations, and highlights high costs of meeting 2030 renewable energy targets. It stresses the need for balanced policy considerations and stakeholder input.

text?"; "What did the Legislature intend?"; and, "What are the consequences of adopting a proposed interpretation?". bold change to make our ratepayers have clean, reliable, and affordable energy.22 I want to thank the Clean Electricity So...

AI summary The document discusses legislation to modernize Nova Scotia's energy system, align with climate goals, and establish the Energy Board's mandate to consider climate change in decision-making. It highlights the Clean Electricity Solutions Task Force's role and the transformational impact of the legislation on energy regulation and sustainability.

Implementation Date, Nova Scotia Power Incorporated shall undertake cost-effective demand-side management that is reasonably available in an effort to reduce costs for its customers. (emphasis added) It is the reduction of costs for custom...

AI summary Nova Scotia Power Incorporated (NSP) is mandated under the Public Utilities Act (PUA) to implement cost-effective demand-side management (DSM) to reduce customer electricity costs. DSM includes activities like energy conservation, demand pattern alteration, and strategic electrification. Though section 79A(b)(iv) was amended in 2022, the core objective of reducing electricity costs remains unchanged. Legal references include M08888 and 2020 NSUARB 56.

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.

Avoided Cost Series NS Power submits that the current avoided cost series is primarily intended to inform analysis of traditional energy efficiency measures that reduce both energy and peak demand, or contribute to demand response. In the...

AI summary NS Power proposes updating the avoided cost series for DSM and Demand Response to reflect new programming, including strategic electrification. They emphasize the need for tailored cost curves and collaboration with E1 and DSMAG. The BCA test focuses on demand-side resources, not supply-side.

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.

tempts to establish the test that makes most sense for Nova Scotians based on Nova 8 Scotia policy is a consideration of whether the PAC test is the right test or not." Further, Mr. Neme 9 stated: 10 11 A. … It just became very clear from...

AI summary Mr. Neme argues that the PAC test is incompatible with Nova Scotia's policy objectives, as it excludes strategic electrification measures which are now legally required for EfficiencyOne. He highlights that the PAC test inherently rules out electrification, which adds grid costs without benefits, and emphasizes the need for a test aligned with provincial policy.

17 removals and other offsetting measures. 2021, c. 20, s. 6. 19 This legislation also articulates as a purpose the following climate change response and greenhouse 20 gas emissions reduction goals: - 22 7 The Government's goals with respe...

AI summary The text discusses legislative amendments related to climate change response and energy efficiency goals, including a target for 80% renewable electricity by 2030 and the phasing out of coal-fired electricity generation by 2030. It also outlines changes to the Public Utilities Act, specifically the definition of demand-side management.

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

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

ii. Misstatement of Approach to Evaluation of Strategic Electrification While misstating the evidence of Mr. Bowman, E1 again pleads "complexity" to argue against the use of different tests to be applied to different resources. Its submiss...

AI summary E1 argues against using different cost-effectiveness tests for DSM resources, claiming complexity and misrepresenting Mr. Bowman's evidence. The Industrial Group supports Mr. Bowman's proposal to use the PAC test for all DSM, with adjustments for strategic electrification. Critics argue E1's uniform test fails to address electrification's unique benefits and costs, while the Proposed BCA overlooks utility revenue impacts and inadequate evaluation criteria.

HYBRID HEATING With respect to the significant issue of hybrid heating, E1 simply states that, "At the hearing, Ms. Thompson confirmed hybrid heating measures are currently being considered by E1 for the 2027- 2031 DSM Plan".[6](#page-3-2)...

AI summary The document discusses E1's consideration of hybrid heating in its 2027-2031 DSM Plan, with Eastward and the Industrial Group advocating for stronger focus on hybrid heating due to cost-effectiveness and policy alignment. E1's approach is criticized for prioritizing greenhouse gas reductions over electricity cost reductions and omitting key policy guidance from the Gas Distribution Act.

2.1 LEGISLATIVE INTERPRETATION & JURISDICTIONAL LIMITS The IG contends that the Board, under the Public Utilities Act (" PUA "), is not empowered to consider broad societal impacts or non-energy benefits when evaluating the cost-effectiven...

AI summary The Industrial Group (IG) argues that the Board under the Public Utilities Act (PUA) cannot consider societal impacts or non-energy benefits when evaluating demand-side management (DSM) cost-effectiveness, emphasizing ratepayer cost reduction. They claim the new strategic electrification provision in the Energy Efficiency and Renewable Energy Act (ERBA) allows EfficiencyOne (E1) to expand programs but still requires adherence to cost-effectiveness, with sustainability limited to specific proposals.

3.1 MEMBERSHIP IN THE DSMAG - 27 In Eastward Energy's submission, the question of membership in the Demand Side Management Advisory - 28 Group (DSMAG) is raised. Eastward Energy asserts that it should be accepted as a full member, arguing...

AI summary Eastward Energy seeks DSMAG membership, arguing it would enhance collaborative energy planning. E1 opposes this, stating DSMAG members broadly represent electricity ratepayers, while Eastward Energy focuses only on strategic electrification. E1 offers one-on-one discussions instead.

3.5 RELIABILITY IMPACTS - Eastward insists that benefit-cost analyses must fully account for the reliability advantages of natural gas - systems, and that any loss of reliability from electrification should be explicitly considered. - The...

AI summary Eastward Energy argues that reliability impacts of electrification must be explicitly considered in benefit-cost analyses, while E1 agrees in principle under specific conditions, such as full electrification without backup gas. E1 proposes addressing these issues via the proposed BCA test and the evergreen process. Eastward seeks immediate action, but lacks evidence of imminent impacts. E1 trusts NS Power's avoided costs include ancillary service costs, pending further confirmation.

Consideration of greenhouse gas emissions ECEL is particularly supportive of the inclusion of the social cost of carbon among non-utility system benefits in E1's proposed BCAT.[11](#page-4-0) Additionally, the CA agrees with E1 that the le...

AI summary ECEL supports including the social cost of carbon in E1's BCAT. The CA agrees with E1 that legislative changes expand the Board's mandate to consider greenhouse gas emissions. NS Power argues for quantifying emissions reductions alongside cost savings for strategic electrification, aligning with EGCCRA's 2030 and 2050 emission targets.

Response to the Industrial Group's (IG) Closing Submissions Similarly to the above, NS Power does not intend to summarize the entirety of the IG's closing submissions but will address differences in the IG's proposed PAC and Modified PAC t...

AI summary NS Power agrees with the Industrial Group (IG) on the need for alternative cost-effectiveness tests for demand-side management (DSM) and strategic electrification under the PUA. Both parties emphasize evaluating greenhouse gas reductions and electricity cost savings, though NS Power insists on measure-level proof for strategic electrification. NS Power also supports IG's stance on primary and secondary testing for DSM analyses.

The Modified PAC test for Electrification The IG presents a secondary test called the "Modified PAC test for Electrification" for consideration to address this requirement which accounts for increased utility revenues as a benefit with res...

AI summary The IG proposes a 'Modified PAC test for Electrification' that includes increased utility revenues as a benefit of electrification. NS Power supports this but argues for incorporating 'other fuel impacts' to align with a Total Resource Cost (TRC) test. Both agree that a 2% discount rate is inappropriate, advocating for NS Power's cost of capital instead.

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.

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

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

3.6 Eastward Energy [61] In its submissions, Eastward Energy asked the Board to make a preliminary and final order that Eastward be added as a full member of DSMAG. On November 4, 2025, the Board noted that Eastward has a valuable perspect...

AI summary Eastward Energy requested DSMAG membership, which the Board approved. They supported strategic electrification testing via PAC with NS Power revenue inclusion, aligned with Posterity Group's advice. Eastward emphasized hybrid heating's economic benefits and urged E1 to prioritize it in the 2027-2031 DSM Plan, citing the Public Utilities Act's cost-reduction mandate.

4.1.5 Statutory Changes [86] In the present case, E1 notes there have been significant statutory changes since the NSUARB's decision in 2020. E1 argues that changes to the Public Utilities Act and s. 6(2) of the Energy and Regulatory Board...

AI summary E1 highlights statutory changes to the Public Utilities Act and Energy and Regulatory Boards Act since 2020, requiring the NSUARB to evaluate non-energy impacts of demand-side management. The Act's definition of 'demand-side management' now includes strategic electrification, while affordability considerations were removed from evaluation criteria.

Sustainable prosperity long-term objective - 5 (1) The long-term objective of the Government is to achieve sustainable prosperity. - (2) To achieve its objective of sustainable prosperity, the Government shall - (a) establish, adopt, suppo...

AI summary The Government of Nova Scotia aims to achieve sustainable prosperity through integrated environmental and economic goals, public awareness campaigns, clean economy growth, well-being initiatives, supportive regulation, and continuous improvement in social, environmental, and economic indicators.

The current version is: (iv) strategic electrification of energy end uses currently powered by fossil fuels in a manner that reduces overall greenhouse gas emissions and electricity costs [108] E1 submits that strategic electrification can...

AI summary E1 argues that strategic electrification cannot be evaluated using traditional PAC or TRC tests, as utility impacts are primary costs and non-utility impacts (e.g., fuel savings, GHG reductions) are primary benefits. The 2022 PUA amendment defines strategic electrification as reducing GHG emissions and electricity costs, requiring expanded cost-effectiveness analysis to include non-utility benefits.

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.

[146] In its closing submissions, the Industrial Group said: Where the PUA has clearly mandated the focus of DSM to be on the reduction of costs, the PAC is able to demonstrate that as a primary test; the Proposed BCA cannot. As confirmed...

AI summary The Industrial Group advocates for the PAC test over the Proposed BCA, emphasizing cost reduction alignment with the PUA. NS Power proposes a modified TRC test incorporating fuel impacts and GHG reductions. E1 criticizes both approaches, arguing they conflict with post-2022 statutory mandates and fail to balance utility and customer costs.

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

AI summary The text discusses the challenges of applying the traditional PAC test to strategic electrification programs under the Public Utilities Act. It highlights Mr. Bowman's proposal to modify the PAC test by including increased revenues from electrification as a benefit, ensuring cost-effective programs. The Industrial Group supports this approach, emphasizing alignment with the PUA's mandate to reduce electricity costs for NSPI customers through hybrid heating and other measures.

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

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

4.3.1 Findings [162] The Board accepts the Industrial Group's suggestion that traditional cost effectiveness tests may be modified to suit specific jurisdictional requirements. The means of assessing strategic electrification in Nova Scoti...

AI summary The Board accepts modifying traditional cost-effectiveness tests for strategic electrification in Nova Scotia. It endorses Mr. Bowman's PAC test approach for E1 but notes E1's incomplete work on demonstrating cost reductions. The Board requires E1 to meet both GHG reduction and cost-effectiveness criteria, allowing future alternative proposals in its 2027-2031 DSM Plan.

4.6 Average v Marginal Generation Emissions [199] Eastward raised a concern about E1's proposal to calculate emissions impacts for the DSM portfolio by using average emissions rates in its modelling analysis. Eastward suggested marginal em...

AI summary Eastward raised a concern about using average emissions rates in E1's DSM portfolio modelling, suggesting marginal emissions rates should be used instead. This is due to future incremental generation expected to come from coal, heavy fuel oil, and natural gas or fuel oil combustion turbines, which operate at lower efficiencies. NS Power's data shows that coal-fired generation was on the margin more than 75% of the time from 2014 to 2024.

4.7 Eastward Energy on DSM Advisory Group [206] Eastward Energy requested the Board order that it be added as a full member of the DSMAG. Although E1 acknowledged Eastward's valuable information and perspectives regarding natural gas hybri...

AI summary Eastward Energy seeks full membership in the DSMAG, arguing its expertise in hybrid peaking resources and gas distribution is critical for strategic electrification. E1 opposes, citing potential conflicts, while Eastward cites the Gas Distribution Act to support its mandate and ongoing pilot projects.

5.0 SUMMARY OF BOARD FINDINGS [217] The Board finds it does not have the authority to approve E1's proposed BCA because the Public Utilities Act restricts the Board's ability to consider non-energy and societal benefits in assessing the co...

AI summary The Board rejects E1's proposed BCA due to the Public Utilities Act's restrictions on non-energy benefits. E1 must use PAC test and NS Power's WACC for DSM plan assessments. Strategic electrification requires GHG reduction and cost savings. Eastward is added to DSMAG. Portfolio-level cost-effectiveness evaluations are mandated.

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

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