July 16, 2026 · Ryan Kelly
Anatomy of a $318.75M question: reading the record on Nova Scotia's next efficiency plan
On May 7 of this year, EfficiencyOne's proposed 2027–2031 demand-side management plan ($318.75M over five years, about $63.75M a year) started getting questioned.
Before the Nova Scotia Energy Board holds an oral hearing, every party gets to put written questions to every other party. In Matter M12780 they made full use of it: nearly every active party asked something, including the Board itself.
The real story sits in that record. This post shows how we read it, what the questions cluster around, and the five plain-language questions at the heart of it.
The method
How we read 600+ questions fast
Reading a regulatory record isn't hard, just slow. Too slow for most people to ever read the whole thing, and the interesting patterns don't sit in any one document. Our approach was to enumerate first, then dig: build a complete map of who asked whom from the filing index, scan what the questions are about using topic tags across the full text, and only then read the actual question text behind each theme, pulling verbatim passages with citations.
We did that reading with DocketWatch, a tool we've built that indexes NSEB filings and lets us query the record passage by passage.
The map
Who asked whom
The questions came in three waves. May 7–8: 272 IRs directed to EfficiencyOne. June 9: a small, sharp wave (~14 IRs) directed to the Board's independent savings verifier. July 6: ~93 IRs, and the frame flips: the parties start questioning each other's experts.
Here's the full asker → target matrix of numbered IRs:
| E1 | NSPI | Synapse | CA | Verifier | SNS | EE | asked | |
|---|---|---|---|---|---|---|---|---|
| Synapse | 90 | none | none | none | none | none | none | 90 |
| Industrial Group | 29 | 15 | 10 | 13 | none | 6 | 5 | 78 |
| NSEB (the Board) | 66 | none | none | none | none | none | none | 66 |
| Consumer Advocate | 19 | 10 | 9 | none | 6 | none | none | 44 |
| Small Business Advocate | 8 | none | 3 | none | 8 | 7 | none | 26 |
| NS Power | 16 | none | none | none | none | none | none | 16 |
| EfficiencyOne | none | 9 | 4 | 2 | none | none | none | 15 |
| Solar Nova Scotia | 15 | none | none | none | none | none | none | 15 |
| Affordable Energy Coalition | 11 | none | none | none | none | none | none | 11 |
| Eastward Energy | 10 | none | none | none | none | none | none | 10 |
| NRStor | 7 | none | none | none | none | none | none | 7 |
| Municipal utilities | 1 | none | none | none | none | none | none | 1 |
| received | 272 | 34 | 26 | 15 | 14 | 13 | 5 | 379 |
Synapse, the Board's own consultant, leads on volume with 90. The Industrial Group filed 78. And the Board itself asked 66, the third-highest of any party, and all directed to EfficiencyOne.
The themes
What it's all about
Scanning topic tags across the 25 IR filings gives a first cut of where the questioning leans. Directionally, the recurring axes look like this:
The fingerprints
Who leans on what
Cross the same tags against the asking party and each party's fingerprint shows up. Shading shows how much of that party's own attention leans on each topic: coarse tiers, normalized per party, so a 90-IR filer and a 10-IR filer compare on composition, not volume.
| Synapse90 | IG78 | NSEB66 | CA44 | SBA26 | NSPI16 | SNS°15 | E115 | AEC°11 | EE°10 | NRStor°7 | |
|---|---|---|---|---|---|---|---|---|---|---|---|
| program evaluation | notable | some | some | heavy | heavy | notable | notable | some | minimal | notable | notable |
| regulatory oversight | heavy | heavy | notable | some | some | heavy | notable | some | minimal | some | some |
| cost effectiveness | notable | some | some | notable | some | notable | some | heavy | some | some | heavy |
| rate design | some | heavy | heavy | notable | some | some | notable | some | minimal | some | notable |
| renewable energy | some | some | notable | minimal | some | heavy | heavy | minimal | heavy | minimal | notable |
| energy efficiency | some | some | some | notable | heavy | minimal | some | notable | some | heavy | some |
| infrastructure planning | notable | some | some | some | minimal | some | some | some | minimal | minimal | notable |
| affordability | minimal | minimal | some | notable | notable | some | minimal | notable | notable | minimal | minimal |
| DSM resource plan | minimal | some | minimal | some | notable | minimal | some | notable | minimal | some | minimal |
| incentive structures | some | some | some | minimal | some | minimal | some | minimal | minimal | some | minimal |
| cost recovery | minimal | some | some | some | some | some | some | minimal | minimal | minimal | minimal |
| DSM purchase agreement | minimal | some | minimal | some | notable | minimal | minimal | some | minimal | some | minimal |
The pattern is coherent: the parties aren't asking random questions. They're each pulling on a specific thread.
The heart of it
The five questions
Read the request text behind the maps and five questions keep coming up. Here they are in plain language. Each one below: the issue in a sentence, the verbatim requests behind it, and who's pressing.
Once the $318.75M is approved, can anyone change the plan mid-course?
EfficiencyOne proposes a "mid-term check-in" partway through the five years, but its own application says the check-in can't actually change anything. Intervenors press on what a check-in is worth if that's true.
Read the verbatim requests
"The mid-term check-in proposed below is intended to enhance transparency and stakeholder engagement during plan implementation, but does not constitute a full plan reopening or amendment process, nor does it alter E1's approved performance targets or total spending authority."
EfficiencyOne's application (Exhibit E-1, p.65), quoted at Industrial Group IR-15 · docketwatch.ca
"Please explain how the proposed mid-term check-in provides meaningful regulatory or stakeholder value beyond information-sharing if it cannot, itself, inform, recommend, or support changes to improve the effectiveness, efficiency, or cost-effectiveness of the DSM Plan."
Industrial Group IR-15(a) to EfficiencyOne · docketwatch.ca
"My concern is not with the proposed mid-term check-in, but with the absence of any trigger that would require E1 to revisit the Plan when conditions materially change. This should be better addressed through the Mid-Course Adjustment ('MCA') process."
Consumer Advocate's evidence (Exhibit E-21, p.4) · docketwatch.ca
Everyone pays for efficiency on their power bill: who actually gets the savings?
Every rate class pays for the plan through a rider on their power bill, but the bill savings land on the people who actually take part in a program. That splits the room: the Board demanded the bill impacts be broken out for participants versus non-participants, and EfficiencyOne itself named the worry directly.
Read the verbatim requests
"the main concern is for non-participants — those who may experience higher rates due to DSM spending but do not receive the associated energy savings benefits."
EfficiencyOne's response to Consumer Advocate IR-01(b) (Exhibit E-7, p.16) · docketwatch.ca
"Please provide a revised Table 6 and revised Figure 6 to show average rate and customer bill impacts of the preferred 2027-2031 DSM plan over 2027-2031 for: a) DSM participants, and b) Non-DSM participants. … please identify the percentage of NS Power customers who have participated in E1's DSM programs."
NSEB to EfficiencyOne · docketwatch.ca
"Why are the rate impacts negative for the medium industrial rate class?"
Synapse IR-77 to EfficiencyOne · docketwatch.ca
How do we know the savings are real?
Savings claims pass down a chain: EfficiencyOne reports them, an independent evaluator checks them, and the Board's own verification consultant verifies that work. The June wave of questions put the verifier himself on the receiving end, and his own response confirmed that some findings weren't independently estimated by his team.
Read the verbatim requests
"These findings are reported by the evaluator (Econoler) and were not independently estimated by the Verification Team."
the verifier Gil Peach's response to Small Business Advocate (Exhibit E-19, p.7-8) · docketwatch.ca
"What did 'checked the math' entail — full independent computation of savings, targeted spot-checks of selected calculations, or a high-level reasonableness review? Please clarify."
Consumer Advocate IR-1(b) to the verifier Gil Peach · docketwatch.ca
"a) What were the programs included in the Econoler report that showed 'negligible practical savings'? … c) What does Peach mean by 'negligible' practical savings and where is it defined in this Report?"
Small Business Advocate to the verifier Gil Peach · docketwatch.ca
Why does a saved kilowatt-hour cost 35% more than it used to?
The first-year cost of saving a unit of electricity through efficiency rose from $0.49/kWh in the 2026 plan to $0.66/kWh in this one, up about 35%. The portfolio as a whole still passes the required cost-effectiveness test, and E1 says only a handful of individual measures fail on their own. But specific pieces (residential demand response, smart-thermostat load control) don't pass by themselves, and by July the parties' experts are questioning each other over whether the costs are prudent or runaway.
Read the verbatim requests
"only nine of the 341 measures included in the Preferred Plan do not, on an individual basis pass the cost-effectiveness test."
EfficiencyOne's response to NSEB (Exhibit E-12, p.3) · docketwatch.ca · unit-cost figures ($0.49→$0.66): EfficiencyOne's response to Industrial Group (Exhibit E-9, p.19) · docketwatch.ca
"…please explain how directing E1 to acquire substantially more savings — using the same program designs and delivery models that produced the elevated unit costs — would result in lower average unit costs for ratepayers rather than higher ones."
Industrial Group IR-8(f) to T. Love (the Consumer Advocate's expert) · docketwatch.ca
Do solar panels, heat pumps, and batteries belong in an efficiency plan?
This is a dispute about which resources belong in the plan. Solar PV is inside the plan and gets attacked from both sides: the Board asks why solar and not other renewables, while NS Power's expert argues net-metered solar would be "double compensated" if it also collects efficiency incentives. Strategic electrification and behind-the-meter batteries are left out, and Solar Nova Scotia, the Affordable Energy Coalition, and NRStor each press to get their piece back in.
Read the verbatim requests
"a. Please explain why solar-PV, instead of other renewable generation has been included as a specific DSM resource. b. Please indicate whether E1 has explored other renewable energy generation resources…"
NSEB IR-23 to EfficiencyOne · docketwatch.ca
"Did E1 assess non-utility benefits from strategic electrification?"
Affordable Energy Coalition IR-8 to EfficiencyOne · docketwatch.ca
"a) Could E1 provide a rationale as to why new measures including batteries are not eligible in the Residential Demand Response Program under the Preferred Plan? … d) Has E1 factored the incremental bulk capacity benefits in addition to local capacity that new residential batteries provide in its cost effectiveness tests?"
NRStor to EfficiencyOne · docketwatch.ca
Quoting NS Power's expert: "distributed solar PV systems already receive compensation through net metering, so by including them in the DSM funding, they are double compensated for ratepayer funds." Then: "(b) If the PAC test does not account for net metering credits, please provide the effect on the Solar PV program's PAC ratio if net metering revenues are removed as a PAC benefit."
NS Power's evidence, the Brattle Group (Exhibit E-22, p.8) · docketwatch.ca · tested at Industrial Group IR-4(b) · docketwatch.ca
What's next
What we're watching
None of these five questions has a tidy answer yet. That's what the hearing is for. But they're the frame we'll be reading the responses, the evidence, and eventually the decision through: who controls a five-year plan once it's approved, who carries the cost and who collects the savings, whether the verification chain holds, what a saved kilowatt-hour should cost, and where the boundary of "demand-side management" actually sits.
If your organization intervenes in NSEB proceedings (or just needs to keep tabs on what's coming out of them), this is the kind of work we do, and we're happy to dig in with you. And if you'd like to try DocketWatch, the tool we used to read this record filing by filing, it's in early testing: get in touch.
Source: NSEB Matter M12780 public record, analyzed with DocketWatch (docketwatch.ca). All quotes verbatim from the cited filings.