Our comments (attached)…

Our comments (attached) include statements of support for a long-term eDSM framework, an expansion of the program portfolio, and a role for the LDCs. We make the following suggestions: the province should establish a clear mandate to pursue all cost-effective energy efficiency as identified in regularly updated potential studies, and use this to set budgets for the proposed framework; a preliminary annual budget, to realize potential identified in the 2022 APS and match leading provinces, would be a minimum $500 million up to $900 million; and the LDCs can play an important role in identifying and executing demand flexibility initiatives to address localized grid needs. Evidence is provided from Efficiency Canada's comparative analysis of provincial energy efficiency policy and programs to support our suggestions.