July 28, 2026 · Ryan Kelly
The Electrification Question: the filings behind one missing line item
Nova Scotia's proposed 2027–2031 demand-side management plan puts $318.75M toward energy efficiency over five years. The amount for programs helping customers switch heating from oil to electricity — "strategic electrification" in the statute's words — is zero. EfficiencyOne, the province's efficiency utility, reports the measures failed the required cost-effectiveness test. Several intervenors challenge how that test applies. The oral hearing opens August 4.
How did that happen? The answer isn't in any single document. It starts with a 2022 statutory amendment and runs through the proceedings that have tried to apply it since. We traced it through the filings.
A note on how to read this post: we take no position on what the statute means, whether any test is right, or what the Board should do. Everything below is attributed — to EfficiencyOne, to an intervenor, or to the Board — and every quote links to its source in the public record, so you can read further and judge for yourself.
The sentence
Three words in the Public Utilities Act
In November 2022, the Legislature amended the Public Utilities Act's definition of demand-side management. Bill 228 (Royal Assent November 9, 2022) replaced subclause 79A(b)(iv) with this:
So a DSM plan can include strategic electrification — but only "in a manner that reduces overall greenhouse gas emissions and electricity costs." The Board reads both conditions as mandatory: its December 2025 Order states that "Strategic electrification must reduce both greenhouse gas emissions and electricity costs for customers."
Matter M12282, NSEB Board Order, Dec 10, 2025, item 2 · docketwatch.ca
The Act's word is electricity costs — not rates, not bills — and neither the amendment nor the Act defines how "reduces… electricity costs" is to be measured. The record treats that as an open question: Synapse, the Board's consultant, asks in its evidence whether impacts "should take the perspective of rates or bills (rather than a BCA perspective)."
Synapse (Alice Napoleon) evidence, Matter M12780, Exhibit E-23, pp.23–24 · docketwatch.ca
When a customer replaces an oil furnace with a heat pump, their oil spending falls and their electricity consumption rises. What that does to "electricity costs" depends on what you measure — Chapter 04 walks through the possibilities the record discusses.
The method
Following one question across 2,000+ matters
Our first two posts on this proceeding stayed inside Matter M12780 — the current plan application. This question doesn't: since Bill 228, it has run through three proceedings. We used DocketWatch, our index of Nova Scotia Energy Board filings, to follow the same statutory language, the same test, and the same parties across those matters, then verified every quote below against its source document.
The trace
Since Bill 228, in order
The 2022 amendment set the condition; the proceedings since have worked out what it requires — the parties, their experts, and the Board itself. Click a point on the timeline for the full story and its sources; the whole sequence is verified against the record.
Strategic electrification enters the statute — conditionally
Bill 228 (Royal Assent November 9, 2022) puts strategic electrification into the Public Utilities Act's demand-side management definition, with the two-part condition quoted in Chapter 01, and lengthens the DSM agreement term from three years to five. The Act does not define how "reduces… electricity costs" is to be measured — that question falls to the proceedings that follow.
S.N.S. 2022, c. 53; Royal Assent Nov 9, 2022 · discussed in the current record at E-1 and E-16
The 2026 extension: modelled, then left out
E1's one-year extension excludes electrification. Asked why, E1 answers that the extension "does not include new offerings of solar or strategic electrification… Strategic electrification cannot be assessed using the existing Total Resource Cost (TRC) test… as it excludes non-utility impacts, including other fuels." The Board's decision sets the cost benchmark the current fight uses: "the unit cost… will be $0.49/kWh in 2026, which is an increase from the 2025 forecast of $0.44/kWh. In the 2023–2025 DSM Plan, the Board approved $0.39/kWh" (¶25).
E1 response to Synapse IR-32 · docketwatch.ca · Board Decision ¶25 · docketwatch.ca
The Board refuses a broader screening test
E1 applies to replace the screening test with a benefit-cost analysis that would count other-fuel savings, emissions, and host-customer benefits, backed by a consensus with the Consumer Advocate, the Small Business Advocate, and East Coast Environmental Law. The Industrial Group and NS Power oppose it. The NSEB (as it now is) refuses the BCA for screening, on statutory grounds:
"The Board does not have the authority to evaluate the cost-effectiveness of proposed demand-side management under s. 79H or s. 79L using impacts unrelated to those directly reflected in electricity costs for customers" (¶142). The decision also states: "The PAC test, as traditionally applied, does not appropriately assess strategic electrification programs. That said, the Board must follow the legislation" (¶158). The Board orders a PAC test that credits "the increased utility revenues from these activities," and notes E1 may "propose another approach when filing its 2027-2031 DSM Plan" (¶163). The Order's full direction is quoted in Chapter 05.
NSEB Decision (2025 NSEB 18), Dec 10, 2025, ¶142, ¶158, ¶163; Order items 1–2 · docketwatch.ca
The current plan: modelled again, excluded again
E1 files the $318.75M plan with strategic electrification excluded as a resource, stating in its application: "Even under optimal assumptions where there are no peak impacts arising from the strategic electrification measures, they remained not cost-effective." The plan's first-year unit cost is $0.66/kWh, against $0.49 for 2026 — E1 states both figures on the same formula (program plus enabling-strategy investment divided by first-year savings). How to read the statute is itself now contested inside the record: E1 describes assessing each electrification resource "in isolation and without regard to other DSM resources," and separately told the Board it "assessed scenarios as a whole against the conjunctive requirements" — a difference Synapse, the Board's consultant, flags.
E1 Application, Evidence p.35 · docketwatch.ca · unit-cost formula, IR-20(a) · docketwatch.ca · "in isolation", RIR-07 · docketwatch.ca · Synapse on the tension · docketwatch.ca
Rebuttal filed; hearing opens August 4
E1's July 24 rebuttal answers every intervenor electrification ask the same way: the measures do not pass the test the Board ordered. The oral hearing before the NSEB opens August 4, 2026.
E1 Rebuttal Evidence · docketwatch.ca
The measurements
What could "electricity costs" mean?
The Act doesn't say how to measure "reduces… electricity costs." Here is what the phrase could point at, in plain terms, and what the record says about each.
Rates — the price per kilowatt-hour. Electrification adds electricity sales, and added sales can spread the system's fixed costs over more kilowatt-hours — which pushes rates down — unless the new load lands at times that force new spending. Synapse, the Board's consultant, describes both halves: "If the increase in sales occurs during non-peak times, the increased sales might result in better system utilization and spread fixed costs across the higher level of sales. In the case of space heating, electrification would likely increase the system peak…" — and in Nova Scotia, the main electrification opportunity is heating.
Synapse (Alice Napoleon) evidence, Matter M12780, Exhibit E-23, p.19 · docketwatch.ca
Bills — what a customer actually pays. This is different for everyone. A customer who switches from oil buys more electricity, so their electricity bill goes up while their oil bill goes down; whether their total energy spending falls depends on the prices of both. Customers who don't participate see only the rate effect. And the oil savings sit outside what the Board says it can count: per M12282, its focus is "impacts… directly reflected in electricity costs for customers."
Matter M12282, NSEB Decision 2025 NSEB 18, ¶142 · docketwatch.ca
What the Board has decided so far is a different question: not rates-versus-bills, but which impacts are allowed to count at all. M12282 was about EfficiencyOne's proposal to count non-utility impacts — other-fuel savings, emissions, host-customer benefits — and the Board held it cannot: it "must therefore assess the cost-effectiveness of a proposed demand-side management plan from the perspective of whether it increases or decreases electricity costs. As such, the focus is on utility costs" (¶142). The ordered test implements that boundary.
Matter M12282, NSEB Decision 2025 NSEB 18, ¶142 · docketwatch.ca
The readings lead different places. On a rates reading, some electrification could in principle qualify — if the load lands right. On a bills reading, participants' electricity bills rise, and the offsetting oil savings are non-utility impacts the Board says it cannot consider. Synapse's evidence names the unresolved question directly: whether impacts "should take the perspective of rates or bills (rather than a BCA perspective)."
Synapse evidence, Matter M12780, Exhibit E-23, pp.23–24 · docketwatch.ca
The parties
Where everyone stands as the hearing opens
In their own words, from the record:
"Modified-PAC results for all strategic electrification scenarios modelled through the 2027–2031 DSM Plan development process demonstrated that these measures did not reduce electricity costs for customers when evaluated under the Energy Board-approved modified-PAC test that includes increased utility revenues. Even under optimal assumptions where there are no peak impacts arising from the strategic electrification measures, they remained not cost-effective."
Matter M12780 (2027–2031 DSM Plan), Exhibit E-1: EfficiencyOne's Plan Application, filed Mar 31, 2026, Evidence p.35 · docketwatch.ca
"We understand that there is not much scope for change in the test given the current legislature. However, based on the discussion above, we believe there is not a robust path for comprehensive strategic electrification in Nova Scotia at this time."
Matter M12780, Exhibit E-22: Brattle Group evidence filed on behalf of NS Power, p.31 · docketwatch.ca — the same evidence goes on to recommend the Board "not interpret failed modified-PAC results as proof that SE lacks value" and that E1 be required to develop a phased electrification pathway rather than leaving it a research item
"The Board Decision, like the statutory language it is based upon, is silent about how to assess “electricity costs.” Critical details that neither the statute nor the Board specified include the level of assessment (customer, measure, program, resource, or portfolio), the time period over which to assess these impacts, and whether the impacts should take the perspective of rates or bills (rather than a BCA perspective)."
Matter M12780, Exhibit E-23: evidence of Alice Napoleon (Synapse Energy Economics, the Board's consultant), filed Jun 23, 2026, pp.23–24 · docketwatch.ca
"The PAC test, as traditionally applied, does not appropriately assess strategic electrification programs. That said, the Board must follow the legislation."
Matter M12282 (E1's application for a new benefit-cost test), NSEB Decision 2025 NSEB 18, Dec 10, 2025, ¶158 · docketwatch.ca
"While the Board leaves it open to E1 to propose another approach for addressing strategic electrification, in the absence of an acceptable approach, E1 is directed to follow the recommendation of the Industrial Group's consultant, Mr. Patrick Bowman, for assessing strategic electrification using the PAC test and including the increased utility revenues from these activities. Strategic electrification must reduce both greenhouse gas emissions and electricity costs for customers."
Matter M12282, NSEB Board Order, Dec 10, 2025, item 2 · docketwatch.ca
Three things are in that Order paragraph: E1 may propose another approach; absent one, the default is the method recommended by the Industrial Group's consultant (the record's shorthand "modified PAC" refers to this — it is the Industrial Group's label, not the Board's); and the statutory condition, restated. E1's current application does not propose another approach; it applies the ordered test and reports the results.
What's next
What the hearing may take up
The question running through this record — when the statute says strategic electrification must reduce electricity costs, what exactly gets measured? — is not resolved. The hearing that opens August 4 is the next place it will be asked: of E1's panel, of the intervenor experts, and possibly in closing argument about what s.79A(b)(iv) requires.
Every quote in this post links to its source document, and the full record is public. If your organization intervenes in NSEB proceedings, or needs to keep tabs on what's coming out of them, this is the kind of work we do. And if you'd like to try DocketWatch, the tool we used to trace this question through the record, it's in early testing: get in touch.
Sources: NSEB Matters M12249, M12282, and M12780, and the Public Utilities Act, analyzed with DocketWatch (docketwatch.ca). All quotes verbatim from the cited documents; decisions cited by paragraph.