BC Hydro's Responses to Intervener Irs No.1 and Irs on BCUC

Fred James Chief Regulatory Officer Phone: 604-623-4046 Fax: 604-623-4407 [email protected]

October 30, 2019

Mr. Patrick Wruck Commission Secretary and Manager Regulatory Support British Columbia Utilities Commission Suite 410, 900 Howe Street Vancouver, BC V6Z 2N3

Dear Mr. Wruck:

RE: Project No. 1599032 British Columbia Utilities Commission (BCUC or Commission) British Columbia Hydro and Power Authority (BC Hydro) Fleet Electrification Rate Application

BC Hydro writes in compliance with BCUC Order G-198-19 and BCUC letter dated September 23, 2019 (Exhibit A-3) requesting that BC Hydro responses to BCUC and Intervener IR No. 1 and IRs on Supplemental information be filed on October 30, 2019 as follows.

Exhibit B-4 Responses to Commission IRs (Public Version) Exhibit B-5 Responses to Interveners IRs (Public Version)

BC Hydro is also separately filing Errata No. 2 to the Application on October 30, 2019, which corrects the draft order contained in Appendix A of the Application and the definition of Billing Demand in the Overnight Rate Schedules (RS 1640, 1641, 1642, 1643) contained in Appendix B of the Application. BC Hydro has referred to the corrected Overnight Rate Schedule in Errata No. 2 in its responses to BCUC IR 1.12.3 and BCSEA IR 1.4.1.

For further information, please contact Anthea Jubb at 604-623-3545 or by email at [email protected].

Yours sincerely,

Fred James Chief Regulatory Officer ac/tl

Enclosure

British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3 www.bchydro.com Association of Major Power Customers of British Page 1 Columbia of 2 Information Request No. 1.1.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Economic Justification

Reference: Exhibit B-1, pp. 11, 36, and 45-47

BC Hydro states in its Application:

• “The Demand Transition Rate, as proposed, is justified on an economic basis. Because the incremental revenues from this new type of load exceed BC Hydro’s marginal costs of service, it will provide benefits to ratepayers over time. The Demand Transition Rate does not recover its full embedded cost of service, and for this reason the Demand Transition Rate would transition to the LGS Rate over six years” (p. 11). • “BC Hydro estimates that the incremental revenues received from new load served under the Overnight Rate will meet or exceed the marginal cost of serving new load. Therefore, ratepayers will not be harmed, and are expected to benefit from the new load, even if that new load is billed at a lower rate than existing load” (p. 36). • “[e]ven during the period where BC Hydro does not fully recover its embedded cost of service, all rate payers are still better off if the incremental revenue from this proposed new Service exceeds BC Hydro marginal costs to serve the new load” (p. 45). • “the incremental revenues received from new load served under the Demand Transition Rate will exceed the marginal cost of serving new load in the ten and fifteen year time periods. Therefore, ratepayers benefit from the new load in the medium and longer term” (p. 46).

In Table 7, BC Hydro provides the following table showing the Demand Transition Rate Ratepayer Impacts:

AMPC is seeking further clarification about the economic justification BC Hydro provides for the proposed Demand Transition Rate.

1.1.1 Are ratepayers are “better off” in the short-term period (i.e., from F2020-F2024) when BC Hydro does not fully recover its embedded cost of service? Please explain. Association of Major Power Customers of British Page 2 Columbia of 2 Information Request No. 1.1.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

RESPONSE:

If the new load that takes service under the Demand Transition Rate has low load factor, as the scenario depicted in Table 7 shows, then ratepayer benefits may not materialize until the medium term. However, as the load expected to take service under the Demand Transition Rate is associated with long term investments (e.g., public transit systems), ratepayer benefits over the medium and longer term are expected. Association of Major Power Customers of British Page 1 Columbia of 2 Information Request No. 1.1.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Economic Justification

Reference: Exhibit B-1, pp. 11, 36, and 45-47

BC Hydro states in its Application:

In Table 7, BC Hydro provides the following table showing the Demand Transition Rate Ratepayer Impacts:

AMPC is seeking further clarification about the economic justification BC Hydro provides for the proposed Demand Transition Rate.

1.1.2 Please confirm that the long-term benefits to all ratepayers over periods of ten years or longer outweigh the costs that are not recovered from Demand Transition Rate ratepayers in the short- Association of Major Power Customers of British Page 2 Columbia of 2 Information Request No. 1.1.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

term (i.e., from F2020-F2024), and form part of the “economic justification” for the Demand Transition Rate. If not confirmed, please fully explain your response.

RESPONSE:

BC Hydro confirms that the economic justification of the Demand Transition Rate is based on the expectation that incremental utility revenues from electricity sales will exceed marginal costs over time, thus benefiting all ratepayers.

The benefits included in the economic analysis of the Demand Transition Rate presented in the Application are limited to incremental revenues from electricity sales only. While there are expected to be societal benefits with fleet electrification, such as a reduction in greenhouse gas emissions and local air pollutants, these benefits are not included in BC Hydro’s economic assessment of the Demand Transition Rate. BC Hydro proposes to include an assessment of such societal benefits in the evaluation described in section 7 of the Application. Association of Major Power Customers of British Page 1 Columbia of 2 Information Request No. 1.1.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Economic Justification

Reference: Exhibit B-1, pp. 11, 36, and 45-47

BC Hydro states in its Application: • “The Demand Transition Rate, as proposed, is justified on an economic basis. Because the incremental revenues from this new type of load exceed BC Hydro’s marginal costs of service, it will provide benefits to ratepayers over time. The Demand Transition Rate does not recover its full embedded cost of service, and for this reason the Demand Transition Rate would transition to the LGS Rate over six years” (p. 11). • “BC Hydro estimates that the incremental revenues received from new load served under the Overnight Rate will meet or exceed the marginal cost of serving new load. Therefore, ratepayers will not be harmed, and are expected to benefit from the new load, even if that new load is billed at a lower rate than existing load” (p. 36). • “[e]ven during the period where BC Hydro does not fully recover its embedded cost of service, all rate payers are still better off if the incremental revenue from this proposed new Service exceeds BC Hydro marginal costs to serve the new load” (p. 45). • “the incremental revenues received from new load served under the Demand Transition Rate will exceed the marginal cost of serving new load in the ten and fifteen year time periods. Therefore, ratepayers benefit from the new load in the medium and longer term” (p. 46).

In Table 7, BC Hydro provides the following table showing the Demand Transition Rate Ratepayer Impacts:

AMPC is seeking further clarification about the economic justification BC Hydro provides for the proposed Demand Transition Rate.

1.1.3 For each of the rate structures proposed, please explain how BC Hydro quantified and balanced the impacts of its proposal in reducing barriers to fleet electrificiation against the impacts to existing ratepayers. Association of Major Power Customers of British Page 2 Columbia of 2 Information Request No. 1.1.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

RESPONSE:

BC Hydro’s fleet customers indicated that in order to support fleet electrification, new services with rate designs that provide relief from daytime demand charges for in route charging, and relief from overnight demand charges for depot charging would be required. BC Hydro assesses proposals for new rate designs on an economic and cost of service basis, as screens to ensure that all ratepayers would not be harmed and costs fairly allocated.

With respect to depot charging, BC Hydro concluded that depot customer needs could be met, and existing ratepayers not harmed, by offering an Overnight Rate with demand charges applicable from 6 a.m. to 10 p.m., and an energy charge calculated residually to recover BC Hydro’s remaining cost of service. The timing aligns with BC Hydro’s cost of service as described in Appendix F and BC Hydro’s response to BCUC IR 1.17.4. BC Hydro notes that the Overnight Rate as proposed provides benefits to all ratepayers as shown in Table 4 of the Application, on page 37.

With respect to the in route charging, BC Hydro analyzed our cost of service and concluded that applying no demand charges during the daytime may result in under-recovery of BC Hydro’s costs on an embedded or average cost basis. However, ratepayers will still be better off if the incremental revenues from the Demand Transition Rate exceed marginal costs, as the difference between incremental revenues and marginal costs will make a contribution to BC Hydro’s fixed costs, reducing pressure on rates for all customers. Please refer to Table 7 of the Application, on page 47.

Currently BC Hydro’s expected marginal cost of energy is lower than it has been recently and as a result there is economic benefit over the medium to long term to all ratepayers with offering the Demand Transition Rate. However, there is uncertainty regarding the magnitude of BC Hydro’s marginal costs in the future. Given this uncertainty, BC Hydro’s view is that in order to reduce risk to ratepayers daytime demand charge relief should be offered on a temporary basis.

BC Hydro’s engagement with fleet customers and jurisdictional review indicated that temporary relief from daytime demand charges has precedent in the utility industry and would be acceptable to fleet charging customers with in route charging. Having determined that daytime demand charge relief would need to be temporary, the next step was to decide on the duration of the relief. Please refer to BC Hydro’s response to AMPC IR 1.1.4 for a discussion of that consideration. Association of Major Power Customers of British Page 1 Columbia of 2 Information Request No. 1.1.4 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Economic Justification

Reference: Exhibit B-1, pp. 11, 36, and 45-47

In Table 7, BC Hydro provides the following table showing the Demand Transition Rate Ratepayer Impacts:

AMPC is seeking further clarification about the economic justification BC Hydro provides for the proposed Demand Transition Rate.

1.1.4 For the Demand Transition Rate proposal, which proposes no demand charge for six years followed by a demand charge that transitions to the LGS rate over the next six years, please explain how BC Hydro established this timeline for transition in relation to Association of Major Power Customers of British Page 2 Columbia of 2 Information Request No. 1.1.4 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

the overall economics of the proposed rate design and impacts on all ratepayers (both current and new customers under this proposed new rate).

RESPONSE:

BC Hydro originally examined a five-year period of no demand charges which was intended to provide customers mitigation to the financial impacts of the demand charge while they convert their fleets to electricity. The five years was informed by a jurisdictional assessment and is in line with Southern California Edison’ TOU EV-8 rate.

Stakeholders requested custom start dates to service under the Demand Transition Rate, to ensure each customer would benefit from the same demand charge free transition period. BC Hydro determined that custom dates would be administratively complex. However BC Hydro acknowledged that the procurement of vehicles could reduce the actual number of years a customer has no demand charge and thus impact the economics of their electrification projects. As such BC Hydro proposed a six-year period of no demand charge.

For comparison, the following table recalculates the Benefit Cost Ratio presented in Table 7 of the Application, assuming no demand charges for five years and seven years.

Time Period No Demand Charge for As proposed No Demand Charge (Years) five Years No Demand Charge for Ratepayer Benefit Cost for six Years seven Years Ratio Ratepayer Benefit Ratepayer Benefit Cost Ratio Cost Ratio 5 0.74 0.74 0.74 10 1.06 1.04 1.01 15 1.17 1.16 1.15

Association of Major Power Customers of British Page 1 Columbia of 2 Information Request No. 1.2.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Economic Justification

Reference: Exhibit B-1, p. 13

On p. 13, BC Hydro states:

In the case of rates that are intended to advance a public policy purpose, such as the reduction of GHGs, the Commission has determined that they must be able to stand independently on an economic or cost-of-service basis, regardless of the merits of the public policy purpose.

In footnote 6, BC Hydro states:

See, for example, section 7.1 of the Commission’s decision regarding BC Hydro’s 2015 Rate Design Application, where the Commission considered its jurisdiction to establish rates to advance the public policy purpose of mitigating poverty through preferential rates for low-income customers.

Reference: BC Hydro and Power Authority 2015 Rate Design Application, Decision and Order G-5-17, dated January 20, 2017

On p. iv, the Commission Panel states:

In summary, the Panel finds that low income rates unsupported by an economic or cost of service justification are unjust, unreasonable and unduly discriminatory and are therefore not in accordance with section 59 of the UCA. The Panel finds no evidence of legislative intent to provide the Commission with jurisdiction to set low income rates and there is no evidence the legislature intended the UCA to provide jurisdiction for low- income rates in the absence of an economic or cost of service justification.

On p. 53, the Commission Panel states:

The Panel is not persuaded that sections 23 and 38 of the UCA explicitly grant the Commission jurisdiction to set a low-income rate, in the absence of an economic or cost of service justification.

AMPC is seeking to better understand the basis for BC Hydro’s assertion that a cost-of-service or economic basis is justification for any proposed rates intended to advance a public policy purpose.

1.2.1 Please confirm that the Panel identified a requirement for BC Hydro to provide an economic or cost-of-service justification in relation to BC Hydro’s proposal for a low income rate, and not for any proposed rates intended to advance a public policy purpose. If Association of Major Power Customers of British Page 2 Columbia of 2 Information Request No. 1.2.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

not confirmed, please fully explain your response and provide references to all relevant Commission decisions in support of your response.

RESPONSE:

BC Hydro confirms that the Panel identified a requirement for there to be an economic or cost of service justification in relation to a proposed low income rate, but that requirement was not limited to a low income rate.

In the 2015 Rate Design Application Decision, the Panel explicitly agreed with BC Hydro that “the Commission is empowered to do only those things - including setting rates - that it is expressly authorized to do by the UCA, or which are necessarily implied by the UCA”.1 The Panel then found that “there are no words regarding customers' financial circumstances or incomes, and that expressions to that effect in the rate-making sections of the UCA are conspicuously absent.”2 The Panel also found that sections 23 and 38 do not provide the Commission with jurisdiction to set low-income rates.3

This was summarized by the Commission in its Decision regarding BCOAPO’s Application for Reconsideration and Variance of Order G-5-17: “…the Commission agreed with BC Hydro that [it] is empowered to do only those things - including setting rates - that it is expressly authorized to do by the UCA, or which are necessarily implied by the UCA.”4

Therefore, in order for rates that are intended to advance a public policy purpose to be lawful, they must stand independently on an economic or cost of service basis, or the Commission must have express or implied jurisdiction under the UCA to approve them.

Both proposed rates in the Application have an economic or cost of service basis.

1 https://www.bcuc.com/Documents/Proceedings/2017/DOC_48618_01-20-2017_G-5-17_BCH-2015- RDA-Decision-WEB.pdf, page 53. 2 Ibid, page 53. 3 Ibid, page 54. 4 https://www.bcuc.com/Documents/Proceedings/2017/DOC_49396_G-87-17_Reasons-for- Decision.pdf, page 12. Association of Major Power Customers of British Page 1 Columbia of 1 Information Request No. 1.3.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 Economic Justification

Reference: Exhibit B-1, p. 36

On p. 36, BC Hydro states:

The Overnight Rate design is justified on an economic basis. BC Hydro estimates that the incremental revenues received from new load served under the Overnight 9 Rate will meet or exceed the marginal cost of serving new load. Therefore, ratepayers will not be harmed, and are expected to benefit from the new load, even if that new load is billed at a lower rate than existing load.

1.3.1 Please confirm that BC Hydro’s conclusion cited above (“that the incremental revenues … will meet or exceed the marginal cost of serving new load” and “ratepayers will not be harmed, and are expected to benefit”) still holds true once BC Hydro is out of its energy surplus. If not confirmed, please fully explain your response.

RESPONSE:

BC Hydro confirms that ratepayers will benefit, i.e., a rate has an economic justification, so long as incremental revenues exceed marginal costs. This basic economic principle holds true regardless of whether BC Hydro is in a surplus or deficit. However the probability of benefits is linked to the magnitude of marginal costs. As marginal costs increase, it becomes less likely that incremental revenues will exceed costs.

BC Hydro’s marginal costs include energy, generation capacity, transmission and distribution related costs. Marginal transmission and distribution related costs are independent of whether or not BC Hydro is in an energy surplus or deficit. Marginal energy costs and marginal generation capacity costs are related to BC Hydro’s position with respect to being in a surplus or deficit, and may increase when BC Hydro’s current surplus position ends in the future. Association of Major Power Customers of British Page 1 Columbia of 1 Information Request No. 1.3.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 Economic Justification

Reference: Exhibit B-1, p. 36

On p. 36, BC Hydro states:

1.3.2 Are any cross-subsidies between rate classes built into the Overnight Rate? Please explain.

RESPONSE:

The Overnight Rate, as proposed, does not result in cross-subsidies between rate classes. There are two primary rate design elements that ensure there are no cross-subsidies. The first element is to set the energy charge to the level required to recover BC Hydro’s residual embedded cost of service. Please see section 4.2 and Appendix F for more information. The second element is to limit availability only to a new type of load that does not currently exist in BC Hydro’s service territory, i.e., fleet charging at 150 kW or more. Association of Major Power Customers of British Page 1 Columbia of 2 Information Request No. 1.4.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 Uncertainty under Demand Transition Rate

Reference: Exhibit B-1, p. 45

On p. 45, BC Hydro states “there is considerable uncertainty about the actual timing and load factor of load served under the Demand Transition Rate”.

1.4.1 What are the minimum conditions concerning the timing and load factor of load served under the Demand Transition Rate such that ratepayers are held harmless?

RESPONSE:

There are three primary characteristics of the new load to be served under the Demand Transition Rate that most impact ratepayer economics:

a) The number of years that the new load takes service from BC Hydro. This is the most important characteristic of the new load with respect to ratepayer benefits. As shown in Table 7 of the Application, ratepayer benefits arise if the load stays until fiscal 2029. Given the long lived nature of the assets and customers to be served under the Demand Transition Rate (e.g., public transit) BC Hydro expects the new load to stay for longer than this. If the new load does not stay until fiscal 2029, other things being equal, there is the risk that the Ratepayer Benefit Cost Ratio will be below 1 and which may result in increased rates for all ratepayers;

b) The load factor of the new load in the first six years that the Demand Transition Rate is offered, during which time there is no Demand Charge. The Demand Transition Rate results in the same customer bills and revenue recovery as the Large General Service Rate at a load factor of approximately 50 per cent, all else being equal. However, so long as the new load stays until at least fiscal 2029 (condition a) ratepayer benefits arise with load factors assumed to start as low as fifteen per cent for the period fiscal year 2021 to fiscal 2025 and thirty per cent for the period fiscal 2026 to fiscal 2029 as shown in Table 6, Appendix E. If the load factor of the new load is higher than what is assumed in Table 6 Appendix E, other things being equal, then the ratepayer benefits will increase since there will be greater utilization of the charging station and more energy sales relative to the Base Case. Association of Major Power Customers of British Page 2 Columbia of 2 Information Request No. 1.4.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

If the load factor of the new load is lower than what is assumed in Table 6 Appendix E, other things being equal, then the ratepayer benefits will decrease since there will be less utilization of the charging station and less energy sales relative to the Base Case; and c) The timing of the new load relative to the remaining years of when there is no demand charge under the Demand Transition Rate. The Demand Transition Rate, as proposed, offers a fixed period of time when there is no demand charge ending in fiscal 2026. Assuming the new load has a load factor below the value of 50 per cent mentioned in condition b, then all else being equal ratepayer benefits will increase if the new load commences service later rather than earlier in the demand charge relief period. This occurs because the later the new load commences service the shorter the period of demand charge relief becomes. However, even if the new load takes service in the first year that the Demand Transition rate is offered, ratepayers will benefit so long as the load stays until at least fiscal 2029, and on average, the load factor is at least fifteen per cent until fiscal 2024, increasing to 30 per cent by fiscal 2029. Association of Major Power Customers of British Page 1 Columbia of 1 Information Request No. 1.4.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 Uncertainty under Demand Transition Rate

Reference: Exhibit B-1, p. 45

On p. 45, BC Hydro states “there is considerable uncertainty about the actual timing and load factor of load served under the Demand Transition Rate”.

1.4.2 Please discuss the risk of BC Hydro not encountering the minimum timing and load factor conditions identified in the response to 4.1 above.

RESPONSE:

Please refer to BC Hydro’s response to AMPC IR 1.4.1. Association of Major Power Customers of British Page 1 Columbia of 2 Information Request No. 1.5.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Generation Capacity Marginal Cost

Reference: Exhibit B-1, Appendix E, pp. 2-4

On p. 4, BC Hydro provides the following table that summarizes BC Hydro’s Marginal Costs, including Generation Capacity for F20-F34:

Association of Major Power Customers of British Page 2 Columbia of 2 Information Request No. 1.5.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

On p. 2, BC Hydro provides the following explanation of how BC Hydro sets its Generation Capacity Marginal Costs:

When the system is in a state of capacity surplus (capacity supply is greater than peak demand), BC Hydro continues to set generation capacity marginal costs based on market values, whereas when the system is in a state of capacity deficit, the generation capacity marginal cost is set based upon the next lowest cost new generation in B.C. The marginal (lowest cost new generation) resources are assumed to be Revelstoke Unit 6, followed by a Simple Cycle Gas Turbine (SCGT). The generation capacity marginal cost also includes the marginal cost of bulk transmission, if a need of bulk transmission is necessary.

AMPC is seeking confirmation of the figures and underlying assumptions from Table 2.

1.5.1 Please confirm that the Generation Capacity Marginal Cost figures provided for F20-F22 ($38 / kW-year), F23-F31 ($60 / kW-year), and F32-34 ($123 / kW-year) are all based on generation from Revelstoke Unit 6, followed by a Simple Cycle Gas Turbine. If not confirmed, please fully explain your response.

RESPONSE:

Not confirmed. The source and basis for the Generation Capacity values used in the analysis is provided with BC Hydro’s response to AMPC IR 1.5.8 of BC Hydro’s Fiscal 2020 to Fiscal 2021 Revenue Requirements. We have attached this IR for ease of reference. AMPC IR 1.5.1 Attachment 1

Association of Major Power Customers of BC Page 1 Information Request No. 1.5.8 Dated: May 2, 2019 of 2 British Columbia Hydro & Power Authority Response issued June 6, 2019 British Columbia Hydro & Power Authority Exhibit: Fiscal 2020 to Fiscal 2021 Revenue Requirements B-6 Application

5.0 Demand Side Management

Reference: Chapter 10 - Demand Side Management

1.5.8 Appendix B of Appendix X, Fiscal 2020 to Fiscal 2022 Demand-Side Management Business Plan – Conservation and Energy Management, shows avoided costs for generation capacity for fiscal 2020 to fiscal 2022 at $38 per kW-year (2018 $), increasing to $60 per kW-year for fiscal 2023 to fiscal 2031 and increasing to $123 per kW-year for the period beyond 2031. Please explain why the generation capacity avoided costs are expected to increase more than three times over a ten-year period, and provide the basis and calculations for each of these estimates (including confirmation that these cost exclude transmission, substation and distribution capacity costs). Please discuss the extent to which these costs can be “avoided” in the short term, i.e., if peak load reduction occurs, versus locked in once new generation is commissioned.

RESPONSE:

The increase of generation capacity avoided costs by almost three times from fiscal 2020 to fiscal 2031 reflects the change in costs from system surplus to system deficit, and the change in the marginal resource through the deficit period.

The basis for the current generation capacity costs are described below. The timing for each change is determined by BC Hydro’s capacity load resource balance (LRB). The timing of each change has been updated; however, the LRB used for these updates is an earlier version than the one shown in BC Hydro’s response to BCUC IR 1.15.3. We have not updated the marginal resources for generation capacity since the Previous Application. BC Hydro’s next Integrated Resource Plan will review the marginal resources for generation capacity and will update the timing of the change from system surplus to system deficit, resulting in updated avoided cost calculations.

 From fiscal 2020 to fiscal 2022 BC Hydro expects to have a generation capacity surplus based on its LRB and used the market value for capacity. This market value was estimated at $38 per kW-year (fiscal 2018$) in BC Hydro’s John Hart Generating Station Replacement Project Application for a Certificate of Public Convenience and Necessity in 2012.

 From fiscal 2023 to fiscal 2031, BC Hydro expects to be in a deficit position for generation capacity with only existing and committed resources. During this period the capacity avoided cost is based on the next most cost-effective generation capacity resource on a unit capacity cost basis which is

BC Hydro Fleet Electrification Rate Application Page 1 of 2 AMPC IR 1.5.1 Attachment 1

Association of Major Power Customers of BC Page 2 Information Request No. 1.5.8 Dated: May 2, 2019 of 2 British Columbia Hydro & Power Authority Response issued June 6, 2019 British Columbia Hydro & Power Authority Exhibit: Fiscal 2020 to Fiscal 2021 Revenue Requirements B-6 Application

Revelstoke Unit 6. The Previous Application outlined the cost of Revelstoke Unit 6 at approximately $60 per kW-year (fiscal 2018$). This value is based on the unit capacity cost of Revelstoke Unit 6 ($51/kW-year F2016$ at point of interconnection) adjusted with delivery to the Lower Mainland and for energy benefits.

 From fiscal 2032 onwards, load is forecast to exceed the capability of planned generation resources including Revelstoke Unit 6. The capacity avoided cost from this point onwards is based on Simple Cycle Gas Turbine (SCGT). Its cost is estimated at $123 per kW-year (fiscal 2018$), based on the unit capacity cost of SCGT in Kelly Lake/Nicola area derived from engagement with industry experts in 2014-2015. The $123 per kW-year figure is composed of $80/kW-year F2016$ at point of interconnection and adjusted with delivery to the Lower Mainland, GHG costs, and adjusted for energy impacts.

The $60 per kW-year and $123 per kW-year do not include any downstream costs for regional transmission, substation, or distribution costs to deliver the capacity to customers.

One of the benefits of incremental DSM conservation activities is reduced system peak capacity requirements. This means the need for more expensive marginal resources can be reduced or deferred. The avoided cost depends on the relevant marginal resource that is applicable at the time of the DSM savings.

With regards to the extent to which these costs can be avoided in the short term (i.e., if peak load reduction occurs, versus locked in once new generation is commissioned), once a new generation resource is approved and considered committed, or commissioned, it is no longer considered a marginal resource that can be deferred by incremental DSM savings on a planning basis.

BC Hydro Fleet Electrification Rate Application Page 2 of 2 Association of Major Power Customers of British Page 1 Columbia of 1 Information Request No. 1.6.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Customer Load Forecasts

Reference: Exhibit B-1, pp. 8-9

BC Hydro states in its Application:

The proposed Overnight Rate would be available to BC Hydro customers that are businesses, government agencies or other organizations that own, or lease, and operate electric fleet vehicles or vessels, for separately metered charging with maximum demand equal to or greater than 150 kW.

The proposed Demand Transition Rate would be available to BC Hydro customers that are businesses, government agencies or other organizations that own, or lease, and operate electric fleet vehicles or vessels, for separately metered charging with maximum demand equal to or greater than 150 kW.

1.6.1 For each rate structure, please provide the customer load breakdown by type of customer forecast (i.e., business, government agency, other organization). Please comment on existing electric fleet vehicle customer load and how BC Hydro has forecast growth in its economic and cost-of-service assessments, including timing of growth and customer segment.

RESPONSE:

BC Hydro does not have such a forecast. To the best of BC Hydro’s knowledge there is no existing electric fleet load of the type that will be served under the two proposed rates. The proposed rates are intended to remove barriers to, and encourage development of such load in BC Hydro’s service territory.

The cost of service and economic analysis included in the Application are based on load scenarios informed by discussions with public transit providers who are interested in electrifying their fleets.

As described in section 7 of the Application BC Hydro proposes to monitor the number and nature of new fleet charging operations on an annual basis and file a three year evaluation report with the BCUC. The three year evaluations will provide actual economic and cost of service results. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, page 2 Exhibit B-1, Appendix C

The Application (page 2) states: “Potential fleet charging customers, such as public transit providers, have indicated that the LGS Rate demand charge is a barrier to converting their fleets to electric operation”.

1.1.1 Is BC Hydro’s evidence that these public transit providers have stated that the LGS Rate demand charge is an absolute barrier to converting their fleets to electric operations?

RESPONSE:

BC Transit in its letter of support (page 2 of Appendix C of Exhibit B-1) states “The overnight rate with demand time of use will help BC Transit minimize the impacts of demand charges that are a barrier to its electrification objectives”.

Translink states in its letter of support (page 5 of Appendix C of Exhibit B-1) that “(the Demand Transition Rate) supports Translink’s in-route charging strategy, as it mitigates the impact of the demand charge during the 5-year grace period for fleets, thereby helping the economics of fleet electrification”.

The Port of Vancouver in its letter of support (page 6 of Appendix C of Exhibit B-1) states “A competitive rate structure is essential to promoting electrification in the freight transport industry and to reducing emissions in this sector”. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.1.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, page 2 Exhibit B-1, Appendix C

1.1.2 Is it BC Hydro’s view that the LGS Rate demand charge truly is an absolute barrier to public transit providers converting their fleets to electric operations?

RESPONSE:

As described in BC Hydro’s response to BCOAPO IR 1.1.1, BC Transit, Translink and the Port of Vancouver have indicated in their letters of support that the Large General Service Rate demand charge is a barrier to meeting their electrification goals. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.1.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, page 2 Exhibit B-1, Appendix C

1.1.3 If the response to either question is yes, please reconcile with this with the customer letters of support wherein: i) BC Transit indicates that “In the January 29, 2019 Mandate Letter from the Ministry of Transportation and Infrastructure, the Minister directed BC Transit to meet or exceed the Province’s legislated targets for GHG emissions by aligning our organization’s operations with the government’s new climate plan” and ii) TransLink indicates that “we are now currently developing a Low Carbon Fleet Implementation Plan, which will identify specific investments in vehicles and charging infrastructure”.

RESPONSE:

Both BC Transit and Translink have targets for greenhouse gas emission reductions, and plans to meet those targets through fleet electrification. The Overnight Rate and Demand Transition Rate, as proposed, will help the organizations to be successful in meeting their respective targets.

Please see BC Hydro’s response to BCOAPO IR 1.1.1 for a summary of BC Transit and Translink’s submissions that the Large General Service Rate demand charge as a barrier to meet their electrification and greenhouse gas emission targets. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Reference: Exhibit B-1, page 3 and page 4 (Figure 1) Exhibit B-1, Appendix F, Attachment 1

The Application (page 3) states: “BC Hydro has modelled both the proposed Overnight Rate and Demand Transition Rate based on illustrative transit bus fleets with load projections informed by discussions with Translink and BC Transit”.

1.2.1 Is the Depot Charging Load profile shown in Figure 1 meant to represent the anticipated load for depot charging by TransLink and BC Transit?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.11.2.

The load profile shown in Figure 1 shows the prospective twenty four hour load shape for depot charging once transit bus fleet conversion for TransLink and BC Transit is substantially complete which is expected no earlier than fiscal 2029. Demand may reach 100 MW and prospective depot charging annual energy usage may reach 100,000 MWh annually by fiscal 2029. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.2.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Reference: Exhibit B-1, page 3 and page 4 (Figure 1) Exhibit B-1, Appendix F, Attachment 1

1.2.1 Is the Depot Charging Load profile shown in Figure 1 meant to represent the anticipated load for depot charging by TransLink and BC Transit?

1.2.1.1 If yes, what assumptions is it based on?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.2.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.2.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Reference: Exhibit B-1, page 3 and page 4 (Figure 1) Exhibit B-1, Appendix F, Attachment 1

1.2.2 Is Figure 1 meant to be consistent with the Depot Charging Demand used in Appendix F for the period 2029 and after?

RESPONSE:

BC Hydro notes that there are minor differences between the illustrative load shape in Figure 1 of the Application and the Depot Charging Demand used in Appendix F. However the differences are not material to the analysis presented in the Application.

Please refer to BC Hydro's response to BCUC IR 1.11.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.2.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Reference: Exhibit B-1, page 3 and page 4 (Figure 1) Exhibit B-1, Appendix F, Attachment 1

1.2.2 Is Figure 1 meant to be consistent with the Depot Charging Demand used in Appendix F for the period 2029 and after?

1.2.2.1 If not, what are the differences in assumptions?

RESPONSE:

There is a slight difference in the magnitude of the load. However, the load shape is the same.

Please refer to BC Hydro’s response to BCOAPO IR 1.2.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 Reference: Exhibit B-1, page 4 and page 5 (Figure 2)

The Application (page 4) states: “The second charging scenario is referred to as in route charging whereby vehicles will charge for approximately 10 minutes at stops on a route equipped with chargers with rated capacity of up to 450 kW”.

1.3.1 The text indicates that chargers used on route will have a rated capacity of up to 450 kW. However, in Figure 2 the maximum demand is between 200 and 250 kW in the early deployment stage and just over 250 kW in the full deployment stage. Please reconcile.

RESPONSE:

Based on discussions with customers, while a charger may have capacity rating to charge up to 450 kW, the expected peak demand at the charger is expected to be at a lower level than its capacity rating. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.4.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 Reference: Exhibit B-1, page 5

1.4.1 Please explain how the 27% and 54% load factors referenced in Figure 2 were determined.

RESPONSE:

The calculations of load factors referenced in Figure 2 are based on data that informs Figure 6 and Figure 8 and are as follows:

• 27 per cent = Monthly Total Consumption / (Monthly Peak Demand x Days x 24 Hours) = 35,000 kWh / (180 kW x 30 Days x 24 Hours) = 27 per cent

• 54 per cent = Monthly Total Consumption / (Monthly Peak Demand x Days x 24 Hours) = 105,000 kWh / (270 kW x 30 Days x 24 Hours) = 54 per cent BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.4.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 Reference: Exhibit B-1, page 5

1.4.2 In the most recent fiscal year for which BC Hydro has data, what was the average load factor for an LGS customer using the same basis for calculation?

RESPONSE:

In fiscal 2018, the average monthly load factor of Large General Service customers was 56 per cent. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.4.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 Reference: Exhibit B-1, page 5

1.4.3 In the most recent fiscal year for which BC Hydro has data, what percentage of the LGS customers had monthly load factors of: i) 54% or less and ii) 27% or less? (Note: For each customer please use its average monthly load factor as the basis for comparison)

RESPONSE:

In fiscal 2018, 42 per cent of Large General Service customers had an average monthly load factor of 54 per cent or less and 8 per cent of Large General Service customers had an average monthly load factor of 27 per cent or less. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

The Application states (page 8): “A demand charge of $12.70 /kW applies to monthly maximum demand set between 6:00 a.m. and 9:59 p.m., daily. The level of the demand charge is the same as the level of the demand charge used in BC Hydro’s LGS Rate, and is escalated each year by the general rate increase”.

The Application also states: “The basic charge is 27.52 cents per day in fiscal 2022 escalated in each following year by the general rate increase, which is the same as the Basic Charge used in the BC Hydro’s LGS Rate”.

The Application further states: “The flat energy charge of 7.41 c/kWh applies to energy usage at any time of day. As explained in section 4.2, the level of energy charge is higher than the level energy charge used in BC Hydro’s LGS Rate”.

1.5.1 Please confirm that the F2020, F2021 and F2022 rate escalations used to derive the $12.70/kW were based on BC Hydro’s F2020-F2021 RRA - Exhibit B-1 (Figure 1-2).

RESPONSE:

Confirmed. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.2 How would the estimated F2022 demand charge for the Overnight Rate change if updated to reflect the revised F2020-F2022 rate escalation per Exhibit B-11 from BC Hydro’s F2020-F2021 RRA (Figure 1)?

RESPONSE:

The fiscal 2022 demand charge for the Overnight Rate would change to $12.55/kW from $12.70/kW if updated to reflect the revised fiscal 2020 - fiscal 2022 rate escalation per Exhibit B-11 from BC Hydro’s Fiscal 2020 - Fiscal 2021 Revenue Requirements Application (Figure 1). BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.3 Please confirm that the F2020, F2021 and F2022 rate escalations used to derive the 27.52 cents/day basic charge for F2022 were based on BC Hydro’s F2020-F2021 RRA – Exhibit B-1 (Figure 1-2).

RESPONSE:

Confirmed. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.4 How would the estimated F2022 basic charge for the Overnight Rate change if updated to reflect the revised F2020-F2022 rate escalation per Exhibit B-11 from BC Hydro’s F2020-F2021 RRA (Figure 1)?

RESPONSE:

The fiscal 2022 basic charge for the Overnight Rate would change to 27.18 cents per day from 27.52 cents per day if updated to reflect the revised fiscal 2020 - fiscal 2022 rate escalation per Exhibit B-11 from BC Hydro’s Fiscal 2020 - Fiscal 2021 Revenue Requirements Application (Figure 1). BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.5 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.5 It appears that the F2022 energy rate (7.41 cents/kWh) was calculated by establishing as base F2019 energy rate of 6.738 cents/kWh (per Exhibit E, Attachment 1, Input Tab, Cell Z6) and escalating it base on BC Hydro’s F2020-F2021 RRA - Exhibit B-1 (Figure 1-2).

RESPONSE:

No question has been posed in BCOAPO IR 1.5.5.

BC Hydro notes that the fiscal year 2022 energy rate (7.41 cents/kWh) was calculated by establishing as base fiscal 2020 energy rate of 7.20 cents/kWh and escalating it based on BC Hydro’s Fiscal 2020 – Fiscal 2021 Revenue Requirements Application, Exhibit B-1. The fiscal year 2019 energy rate of 6.738 cents/kWh (per Exhibit E, Attachment 1, Base Case for Overnight Rate Tab, Cell Z6), was based on decreasing the fiscal year 2020 energy rate of 7.20 cents/kWh by the rate escalation for fiscal year 2020. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.5.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.5.1 Please confirm that the above statement is correct and, if not, indicate how the F2022 energy rate was established.

RESPONSE:

The fiscal 2022 Overnight Rate energy rate of 7.41 cents/kWh was established by applying the rate escalation based on BC Hydro’s Fiscal 2020 - Fiscal 2021 Revenue Requirements Application Exhibit B-1 (Figure 1 2) for fiscal 2021 and fiscal 2022 to the fiscal 2020 energy rate of 7.20 cents/kWh.

Please refer to BC Hydro’s response to BCOAPO IR 1.5.5. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.5.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.5.2 Please confirm that the F2019 energy rate of 6.738 cents/kWh was set such that continued escalation would yield an F2029 revenue to cost ratio of 104 percent - roughly equivalent to the revenue to cost ratio for the LGS class. If not confirmed, please explain the basis for the 6.738 cents/kWh value.

RESPONSE:

Not confirmed. The revenue to cost ratio is 101 per cent. Please refer to BC Hydro’s response BCUC Supplemental IR 1.21.4.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.5.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.5.3 How would the estimated F2022 energy rate for the Overnight Rate change if updated to reflect the revised F2020-F2022 rate escalation per Exhibit B-11 from BC Hydro’s F2020-F2021 RRA (Figure 1)?

RESPONSE:

The fiscal 2022 energy rate for the Overnight Rate would change to 7.32 cents/kWh from 7.41 cents/kWh if updated to reflect the revised fiscal 2020 - fiscal 2022 rate escalation per Exhibit B-11 from BC Hydro’s Fiscal 2020 – Fiscal 2021 Revenue Requirements Application (Figure 1).

Please refer to BC Hydro responses to BCUC IRs 1.5.2 and 1.5.2.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.5.6 Dated: October 7, 2019 of 3 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 8 and 35 (lines 15-16) Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.5.6 How would the portions of Appendix E, Attachment 1 and Appendix F, Attachments 1 & 2 related to the Overnight Rate change if updated to reflect the revised F2020-F2024 rate escalation per Exhibit B-11 from BC Hydro’s F2020-F2021 RRA (Figure 1)?

RESPONSE:

The results reported in Appendix E would not change significantly if updated to reflect the revised fiscal 2020 – fiscal 2024 rate escalation per Exhibit B-11 as shown by the updated Ratepayer Benefit Cost Ratios shown below. The tables below show that only Table 3 results change slightly.

Revised Appendix E Table 3 Results for Base Case for Overnight Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 1.11 10 1.43 15 1.42 BC Old Age Pensioner’s Organization Page 2 Information Request No. 1.5.6 Dated: October 7, 2019 of 3 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Revised Appendix E Table 4 Results for Scenario 1 for Overnight Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 0.8 10 1.0 15 1.0

Revised Appendix E Table 5 Results for Scenario 2 for Overnight Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 0.9 10 1.2 15 1.2

Below BC Hydro presents the recalculation of the cost of service analysis in Table 2 of Appendix F to reflect the revised fiscal 2020-fiscal 2024 rate escalation per Exhibit B-11 from BC Hydro’s F2020-F2021 RRA. BC Hydro notes that the revenue to cost ratio remains close to 1.

Revised Appendix F Table 2 Result of Illustrative Estimate of the Revenue to Cost Ratio of the Overnight Rate using 2029 Charges

Cost Total BCH Cost Allocator of Depot Depot Charging Cost Classified Cost Item ($M) Charging (%) ($M) Energy Related 2,350 0.25 5.9 Generation Demand Related 867 0.12 1.1 Transmission Demand Related 1,334 0.12 1.7 Distribution Demand Related 915 0.57 5.2 Customer Care 349 0.009 0.03 Total Cost 13.9

BC Old Age Pensioner’s Organization Page 3 Information Request No. 1.5.6 Dated: October 7, 2019 of 3 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Revenue Nominal Charges Charge in 2029 Billed Amount Total charge ($M) 365 Days * 26 accounts Basic Charge (Days per year * # of ($/day) 0.308 Accounts) 0.003 129,889 MWh (Total annual energy Energy use across all Charge($/kWh) 0.083 accounts) 10.9 210.24 MW (12 months * monthly Demand Charge peak Billing Demand ($/kW) 14.40 across all accounts) 3.0 Total Revenue 13.9 R/C Ratio (%) 99 Note: Besides updated charges, some numbers may be different from Table 2 in Appendix F due to rounding. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.6.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, pages 8 and 31-33

Please respond to the following question in the situation where a BC Hydro customer installs separately metered charging facilities at a location that is already a BC Hydro account.

1.6.1 Are the charging facilities considered a separate “account” and subject to a separate “basic charge”?

RESPONSE:

Customers who have existing accounts at a location will have to apply for a new separate meter for their charging facility. The separately metered charging facility will be a separate account and is subject to the Overnight or Demand Transition Rate basic charge. Customers’ existing account will remain unchanged. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.6.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, pages 8 and 31-33

Please respond to the following question in the situation where a BC Hydro customer installs separately metered charging facilities at a location that is already a BC Hydro account.

1.6.2 If there is more than one charging unit installed, will they be considered one account and have one meter?

RESPONSE:

BC Hydro will install one meter and set up one account per customer’s charging facility regardless of the number of charging units installed as long as the expected maximum demand of the charging facility is equal to or greater than 150 kW. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.6.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, pages 8 and 31-33

Please respond to the following question in the situation where a BC Hydro customer installs separately metered charging facilities at a location that is already a BC Hydro account.

1.6.3 If the installation of the charging facilities triggers the need for upgrades to the customer’s connection facilities and/or BC Hydro's upstream facilities, who is responsible for the cost of the upgrades?

RESPONSE:

When taking new electric service or upgrading existing service from BC Hydro, customers must supply, own and operate at their expense, service equipment compatible with BC Hydro’s requirements and applicable laws and regulations.

Please refer to BC Hydro’s response to BCUC IR 1.12.3 regarding the recovery of costs of BC Hydro’s upstream facilities caused by new or increased service capability. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.6.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, pages 8 and 31-33

Please respond to the following question in the situation where a BC Hydro customer installs separately metered charging facilities at a location that is already a BC Hydro account.

1.6.3.1 How does this cost responsibility differ from that applicable to any LGS customer where increased load triggers the need for upgrades?

RESPONSE:

The cost responsibility of system improvement upgrades for an existing BC Hydro customer adding charging load under the Overnight Rate or Demand Transition Rate would not differ from an existing customer adding that same charging load under a Large General Service Rate. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.7.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, page 10 Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

The Application (page 10) states: “No demand charge applies for the first six years that the rate is proposed to be offered (from fiscal 2021 to fiscal 2026)” and “The demand charge transitions from $0/kW to the LGS Rate Demand Charge over six years, starting in fiscal 2027 and ending in fiscal 2032”.

The Application also states: “A flat energy charge of 9.24 cents per kWh in fiscal 2021, escalated each year by the general rate increase, applies for the first six years that the rate is proposed to be offered. The level of this energy charge is higher than the level of the energy charge that applies to the existing LGS rate (6.10 c/kWh in fiscal 2021)”

1.7.1 Please explain the basis for: i) choosing six years as the period of time for which the demand charge will be zero and ii) six years as the period over which the demand charge will transition to the LGS demand rate.

RESPONSE:

Please see BC Hydro’s response to AMPC IR 1.1.4. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.7.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, page 10 Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.7.2 Please explain how for F2021 the energy rate of 9.24 cents/kWh was established.

RESPONSE:

As described in footnote 17 on page 44 of the Application, the 9.24 cents per kWh is based on an estimate of the fiscal 2020 Large General Service blended average price multiplied by the fiscal 2021 Revenue Requirements Application increase.

9.24 cents per kWh = 9.18 cents per kWh x (1+0.72) x 100 per cent

The fiscal 2020 Large General Service blended average price is estimated by multiplying the fiscal 2018 Large General Service class consumption and demand by the fiscal 2020 Large General Service energy and demand charge respectively and dividing this revenue by the fiscal 2018 Large General Service class consumption.

9.18 cents per kWh = (( 9,595,639,662 kWh x 6.06 cents per kWh) + (24,234,620 kW x $12.34/kW)) / 9,595,639,662 kWh

This rate calculation is undertaken so that the Demand Transition Rate is revenue neutral to the Large General Service Rate based on the Large General Service class consumption and load, and therefore the class average load factor. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.7.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, page 10 Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.7.3 Does the F2021 energy rate of 9.24 cents/kWh change as a result of BC Hydro’s update to its F2020-F2021 RRA (Exhibit B-11, Figure 1)?

RESPONSE:

Yes, the fiscal 2021 energy rate of 9.24 cents/kWh does change as a result of BC Hydro’s update to its Fiscal 2020 - Fiscal 2021 Revenue Requirements Application (Exhibit B-11, Figure 1). BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.7.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, page 10 Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.7.3 Does the F2021 energy rate of 9.24 cents/kWh change as a result of BC Hydro’s update to its F2020-F2021 RRA (Exhibit B-11, Figure 1)?

1.7.3.1 If yes, please provide the revised value and how it was derived.

RESPONSE:

The fiscal 2021 energy rate of 9.24 cents/kWh changes to 9.08 cents/kWh. The revised value is calculated by applying the revised Fiscal 2021 Revenue Requirements Application increase of -0.99 per cent rounded to -1 per cent to the base fiscal 2020 Large General Service Rate blended average price of 9.18 cents/kWh. Footnote 17, page 44 of the Application provides further explanation of the 9.24 cents/kWh derivation from the fiscal 2020 Large General Service Rate blended average price. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.7.4 Dated: October 7, 2019 of 5 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, page 10 Exhibit B-1, Appendix E, Attachment 1 Exhibit B-1, Appendix F, Attachments 1 & 2

1.7.4 How would the portions of Appendix E, Attachment 1 and Appendix F, Attachments 1 & 2 related to the Demand Transition Rate change if updated to reflect the revised F2020-F2024 rate escalation per Exhibit B-11 (Figure 1) from BC Hydro’s F2020-F2021 RRA?

RESPONSE:

Appendix E and Appendix F have been recalculated using the requested revenue requirements rate escalations as presented below. BC Hydro notes that the results are not materially different than that provided in the Application.

The Demand Transition Rate results reported in Appendix E would not change significantly if updated to reflect the revised fiscal 2020 - fiscal 2024 rate escalation per Exhibit B-11 as shown by the updated Ratepayer Benefit Cost Ratios shown below. The tables below show that only Table 6 results change slightly.

Revised Table 6 Results for Base Case for Demand Transition Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 0.73 10 1.02 15 1.14 BC Old Age Pensioner’s Organization Page 2 Information Request No. 1.7.4 Dated: October 7, 2019 of 5 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Revised Table 7 Results for Scenario 1 for Demand Transition Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 0.7 10 1.0 15 1.1

The tables below show the R/C ratio test of Demand Transition Rate results reported in Appendix F would change slightly if the Cost of Service Study is updated to reflect the revised fiscal 2020 - fiscal 2024 rate escalation per Exhibit B-11.

Revised Table 3 of Illustrative Estimate of the Revenue to Cost Ratio of the Demand Transition Rate with 15 Per Cent Load Factor and Fiscal 2024 Rates

Cost

In Route Classified Cost Total BCH Cost Allocator of In Route Charging Item ($M) Charging (%) Cost ($M) Energy Related 2,123 0.002 0.04 Generation Demand Related 785 0.005 0.04 Transmission Demand Related 1,207 0.005 0.06 Distribution Demand Related 824 0.008 0.07 Customer Care 316 0.002 0.01 Total Cost 0.21

BC Old Age Pensioner’s Organization Page 3 Information Request No. 1.7.4 Dated: October 7, 2019 of 5 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Revenue Total Nominal Charges Charges Charge in fiscal 2024 Billed Amount ($M)

Basic Charge 365 Days * 5 accounts ($/day) 0.279 (Days per year * # of Accounts) 0.001 920 MWh Energy Charge (Total annual energy use across all ($/kWh) 0.096 accounts) 0.09 8.4 MW Demand Charge (12 months * monthly peak Billing ($/kW) 0 Demand across all accounts) 0 Total Revenue 0.09 R/C Ratio(%) 43 *: Besides updated charges, some numbers may be different from Table 3 in Appendix F due to rounding.

Revised Table 4 of Illustrative Estimate of the Revenue to Cost Ratio of the Demand Transition Rate with 30% Load Factor and Fiscal 2029 Rates

Cost In Route Allocator of In Route Charging Classified Cost Total BCH Cost Charging Cost Item ($M) (%) ($M) Energy Related 2,345 0.062 1.4 Generation Demand Related 867 0.081 0.7 Transmission Demand Related 1,334 0.081 1.1 Distribution Demand Related 911 0.144 1.3 Customer Care 349 0.038 0.1 Total Cost 4.7

BC Old Age Pensioner’s Organization Page 4 Information Request No. 1.7.4 Dated: October 7, 2019 of 5 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Revenue Total Nominal Charges Charges Charge in fiscal 2029 Billed Amount ($M)

Basic Charge 365 Days * 100 accounts ($/day) 0.308 (Days per year * # of Accounts) 0.01 31,799 MWh Energy Charge (Total annual energy use across all ($/kWh) 0.087 accounts) 2.8 146 MW Demand Charge (12 months * monthly peak Billing ($/kW) 7.55 Demand across all accounts) 1.1 Total Revenue 3.9 R/C Ratio (%) 83 *: Besides updated charge, some numbers may be different from Table 3 in Appendix F due to rounding.

Revised Table 5 of Illustrative Estimate of the Revenue to Cost Ratio of the Demand Transition Rate with 52% Load Factor and Fiscal 2034 Rates

Cost Total BCH Allocator of In Route In Route Cost Charging Charging Classified Cost Item ($M) (%) Cost ($M) Energy Related 2,590 0.107 2.8 Generation Demand Related 957 0.081 0.8 Transmission Demand Related 1,472 0.081 1.2 Distribution Demand Related 1,006 0.144 1.4 Customer Care 385 0.038 0.15 Total Cost 6.3

BC Old Age Pensioner’s Organization Page 5 Information Request No. 1.7.4 Dated: October 7, 2019 of 5 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Revenue Nominal Charges Total in fiscal Charges Charge 2034 Billed Amount ($M) 365 Days * 100 accounts Basic Charge ($/day) 0.340 (Days per year * # of Accounts) 0.01 55,012 MWh Energy Charge (Total annual energy use across all ($/kWh) 0.077 accounts) 4.2 145 MW Demand Charge (12 months * monthly peak Billing ($/kW) 15.71 Demand across all accounts) 2.3 Total Revenue 6.5 R/C Ratio (%) 103 *: Besides updated charge, some numbers may be different from Table 3 in Appendix F due to rounding.

BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.8.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, pages 39-43

1.8.1 With respect to the use of in-route charging stations, is it BC Hydro’s expectation that these will be installed at locations that currently are not a BC Hydro account?

RESPONSE:

BC Hydro expects that in route charging stations will be installed at various locations. Many of the locations are currently not a BC Hydro account, while others may be at locations that are BC Hydro accounts already. All in route charging stations installed will require their own BC Hydro accounts. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.8.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, pages 39-43

1.8.2 Will each separate “location” with an in-route charging station be considered a separate account for purposes of applying the basic charge and calculating billing demand?

RESPONSE:

Each separate location with an in route charging station will be separately metered and considered a separate account. The Demand Transition Rate basic charge, energy charge and demand charge will be calculated separately and apply to each in route charging station account. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.8.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, pages 39-43

1.8.3 If the installation of the charging facilities triggers the need for upgrades to (or new) customer connection facilities and/or BC Hydro's upstream facilities, who will be responsible for the cost of the upgrades and how will that responsibility be distributed?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.6.3. and BCUC IR 1.12.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.8.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, pages 39-43

1.8.3.1 How does this cost responsibility differ from that applicable to any LGS customer requesting a new connection or where increased load triggers the need for upgrades?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.6.3.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.9.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 Reference: Exhibit B-1, page 13 (lines 9-14)

1.9.1 Please explain why “expanding the availability of the proposed services to that customer segment (i.e., third party charging service providers) would materially reduce the likelihood that ratepayers would benefit from them” relative to BC Hydro’s proposal.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.2.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.10.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, page 24

The Application states: “In respect to depot charging, both Translink and BC Transit asked if there were benefit to BC Hydro if customers could shift their depot charging load outside of BC Hydro’s peak period. They indicated that if there were an incentive to shift their charging load outside of BC Hydro’s peak periods, they could potentially adjust their operations to shift load out of BC Hydro’s peak period while still ensuring their fleet would be ready for the next day’s routes”.

1.10.1 Given that transit vehicles are likely to be required to be operating during BC Hydro’s peak period, aren’t transit operators likely to be using charging stations during the off-peak period even in the absence of an Overnight Rate?

RESPONSE:

Transit vehicles return to depots at different times of the day depending on the demand for given routes. As such, while vehicles may be running during the peak periods many of the vehicles will be returning to the depot during BC Hydro’s peak (4 p.m. to 10 p.m.) as the peak for public transportation does not carry as long into the evening as BC Hydro’s peak. In the absence of the Overnight Rate, transit operators indicated that operationally it is simplest for them to begin charging the vehicles when they return to the depot rather than waiting until 10 p.m. The Overnight Rate incents the customers to wait until after BC Hydro’s peak to begin charging. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.10.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, page 24

1.10.2 How much “cost reduction” does BC Hydro expect to see as a result of transit operators “shifting load” in response to the Overnight Rate?

RESPONSE:

BC Hydro designed the Overnight Rate to reflect depot charging customer needs and recover BC Hydro’s cost of service. To BC Hydro’s knowledge, there is no existing depot charging load in BC Hydro’s service territory.

To the extent that any depot charging load would occur during the evening peak and is shifted to the overnight period, there would be an associated marginal cost reduction in generation capacity and non-bulk transmission capacity. Please see Table 2 in Appendix E. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.11.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 28

1.11.1 Does the bill comparison in Figure 6 include the basic charge in the determination of the total bill and the $/kWh for both the LGS Rate and the Overnight Rate?

RESPONSE:

Yes, the bill comparison in Figure 6 includes the basic charge in the determination of the total bill and the $/kWh for both the Large General Service Rate and the Overnight Rate. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.11.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 28

1.11.1 Does the bill comparison in Figure 6 include the basic charge in the determination of the total bill and the $/kWh for both the LGS Rate and the Overnight Rate?

1.11.1.1 If yes, why is this appropriate if the overnight charging is being done at a location that is already an LGS customer and separate metering and an additional basic charge is only applicable in the case of the Overnight Rate?

RESPONSE:

Figure 6 is an illustrative comparison between the Overnight Rate and the Large General Service Rate for the charging demand and consumption. It does not take into consideration the location and set up of the chargers. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.11.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 28

1.11.2 In the case of the LGS Rate based bill why is the entire demand associated with the charging facility assumed to be incremental demand?

RESPONSE:

The comparison is between two separate accounts on two separate rate schedules that are separately metered. Please refer to BC Hydro’s response to BCOAPO IR 1.11.1.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.11.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 28

1.11.2 In the case of the LGS Rate based bill why is the entire demand associated with the charging facility assumed to be incremental demand?

1.11.2.1 If the charging is being done at a location that is already a BC Hydro account, wouldn’t this only be the case if charging (under the LGS rate) occurred at same time as the peak other operations at the facility?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.11.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.11.2.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 28

1.11.2 In the case of the LGS Rate based bill why is the entire demand associated with the charging facility assumed to be incremental demand?

1.11.2.2 Wouldn’t this fact, encourage transit operators being billed under the LGS Rate to shift their charging load away from the same time as the peak demand for the operations at the facility?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.11.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

It is noted (per Attachment 1, the Calculation Tab and the Table 2 in Appendix F Tab) that the F2029 Total BCH Costs (for each Classified Cost Item) are determined by escalating the F2017 values to F2029 using the CPI and then adding an amount attributable to the Overnight Rate load/accounts based on the average cost in F2029.

1.12.1 Why were the F2017 values escalated using the CPI?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.18.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.1 Why were the F2017 values escalated using the CPI?

1.12.1.1 Isn’t the overall year to year change in revenue requirement related to the level of rate escalation and the year to year change in loads/customer accounts?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.18.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.2 Between F2017 and F2029 what is the total compound increase in: i) the CPI (per Attachment 1, Calculation Tab, Column I); ii) the annual Rate Escalation (per Attachment 1, Calculation Tab, Column N); iii) Total number of customer accounts subject to the basic charge; and iv) the total energy use for all customer classes?

RESPONSE:

The total compound increase between fiscal 2017 and fiscal 2029 is estimated to be 29.7 per cent and 33.5 per cent for CPI and rate escalation, respectively. BC Hydro assumed no change to the number of accounts or total energy use for the purpose of this Application aside from illustrative estimates for electric buses.

Please also refer to BC Hydro’s response to BCUC IR 1.18.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.3 Does BC Hydro expect the relative portions of the total revenue requirement classified as Energy Related, Generation Demand-Related, Transmission Demand-Related, Distribution Demand-Related and Customer Care to remain constant (per the F2017 values) through to F2029?

RESPONSE:

For the purpose of the analysis presented in the Application, BC Hydro assumed that the relative portions of the total revenue requirement classified as Energy Related, Generation Demand-Related, Transmission Demand-Related, Distribution Demand-Related and Customer Care remain constant through to fiscal 2029. This is a reasonable assumption as the proportions have been fairly stable historically. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.3.1 If not, which components are likely to increase in relative size over the period?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.12.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.4 Please confirm that for purposes of the Cost of Service Analysis the Depot Charging load was assumed to be incremental to the load used in the 2017 FACOS.

RESPONSE:

Confirmed. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.4.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.4 Please confirm that for purposes of the Cost of Service Analysis the Depot Charging load was assumed to be incremental to the load used in the 2017 FACOS.

1.12.4.1 Why was this assumption made?

RESPONSE:

As stated in section 1.2 of the Application, the Overnight Rate is designed for the new fleet charging services load, which does not currently exist in BC Hydro’s service territory. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.5 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.5 Why was the energy allocator for Depot Charging (Attachment 1, Calculation Tab, Cells B19-B21) based on energy use at the customers’ meters as oppose to at the Generation Interface?

RESPONSE:

The energy and demand allocators in the Fully Allocated Cost of Service (FACOS) are based on the energy and demand at generation interface, which is estimated by energy and demand at meters plus distribution loss and transmission loss.

This approach follows the BCUC approved methodology for cost allocation for the purpose of BC Hydro’s Fully Allocated Cost of Service studies. This method is further discussed below.

Energy and demand cost allocation is calculated using a ratio of the energy or demand for the new service to energy or demand for all rate classes. Both the numerator and denominator include losses that cancel each other out. The calculations and methodology are further described below.

As shown in schedule 5.0 of the F2017 FACOS Study1, a distribution loss factor between 3 per cent and 6 per cent is applied to non-transmission rate classes, and a transmission loss factor of 6 per cent is applied to all rate classes.

The distribution loss factor is estimated as 3.8 per cent for the Large General Service rate class and 4.0 per cent overall for all rate classes respectively2. The difference between the distribution loss factor for the Large General Service rate class and for all rate classes overall is 0.2 per cent, which has a negligible impact on cost allocation.

1 https://www.bchydro.com/content/dam/BCHydro/customer- portal/documents/corporate/regulatory-planning-documents/regulatory-filings/reports/2019-02- 14-facos-f2017-ff.pdf 2 See Energy at Transmission Interface at column E and Energy at Customer Meter at column c of schedule 5.0 of F2017 FACOS BC Old Age Pensioner’s Organization Page 2 Information Request No. 1.12.5 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

The calculation of the energy allocator of depot charging energy is estimated according to the simplified formula below:

Energy _Cost_Depot = [ kWh_Depot x (1+D_Loss_LGS) x (1+ T_Loss_Depot)] / [kWh_sys x (1+D_Loss_sys) x (1+T_Loss_sys)] = [ kWh_Depot x (1+D_Loss_LGS) x (1+ 6%)] / [kWh_sys x (1+D_Loss_sys) x (1+6%)] = [ kWh_Depot x (1+D_Loss_LGS) ] / kWh_sys x (1+D_Loss_sys) ] = [ kWh_Depot x (1+4.0%) ] / kWh_sys x (1+3.8%) ] = kWh_Depot / kWh_sys

Where:

• Energy _Cost_Depot denotes the energy related cost allocator of depot charging load;

• kWh_Depot denotes the annual energy consumption of depot charging load at meter;

• kWh_sys denotes the sum of annual energy consumption at meter of all rate classes;

• D_Loss_LGS denotes the distribution loss factor of LGS class;

• D_Loss_sys denotes the overall distribution loss factor of all classes;

• T_Loss_Depot denotes transmission loss factor for Depot Charging load; and

• T_Loss_sys is the overall transmission loss factor for all rate classes. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.6 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.6 Is the total NCP used in the 2017 FACOS (8392510 kW per Attachment 1, Calculation Tab, Cell A34) based on demand at the customer meter similar to the point of measurement for the Depot Charging NCP?

RESPONSE:

As described in BC Hydro’s response to BCOAPO IR 1.12.5, the energy and demand allocators are based on the energy and demand at generation interface, which is estimated by energy and demand at meters plus distribution loss and transmission loss.

This approach follows the BCUC approved methodology for cost allocation for the purpose of BC Hydro’s Fully Allocated Cost of Service (FACOS) studies. This method is further discussed below.

The calculation of the demand cost allocation is calculated as per the simplified formulas below:

CP_i = [ Peak_i x (1+D_Loss_i) x (1+ 6%)] / [System_Peak x (1+D_Loss_sys) x (1+6%)] = [ Peak_i x (1+D_Loss_i) ] / System_Peak x (1+_D_Loss_sys) ]

Where:

• CP_i denotes the coincident peak allocator of ith new service class;

• Peak_i denotes the coincident peak of ith class at meter;

• D_Loss_i denotes the distribution loss factor of ith class; BC Old Age Pensioner’s Organization Page 2 Information Request No. 1.12.6 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

• 6 per cent is the transmission loss factor;

• System_Peak denotes the system peak of BC Hydro based on aggregated hourly load at meter; and

• D_Loss_sys denotes the overall distribution loss factor of all BC Hydro customers.

The same approach is used to calculate non-coincident peak demand cost allocation.

The 9,156,239 kW coincident system peak and 8,392,510 kW non-coincident system peak shown in Appendix F, Attachments 1 and 2 to BC Hydro’s Fleet Rate Application Supplemental Information, are the aggregated hourly demand of all BC Hydro customers at the customer meter plus the distribution loss.

As shown above, transmission losses of 6 per cent cancel out as they appear in both the numerator and denominator. The 4 per cent distribution loss of new service was disregarded in the calculation of 4CP and NCP allocators, because it makes a negligible impact on the estimation. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.6.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.6.1 If yes, why is this the appropriate point of measurement for use in the FACOS?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.12.6. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.7 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.7 If the Depot Charging Load is considered to be “incremental” to the loads used in the 2017 FACOS, why are the cost adjustments to account for this load calculated using the average costs (i.e., in each case the “costs” were increased by the percentage increase in the allocator due to the Depot Charging load) as opposed to incremental costs?

RESPONSE:

The cost of service analysis presented in Appendix F uses BC Hydro’s standard, the BCUC approved fully allocated cost of service study methodology as described in section 4.2 of Application. This analytical method allocates BC Hydro’s revenue requirement to the rate class or service of interest as a percentage of total revenue requirement, based on the characteristics of the load.

In contrast, the analysis presented in Appendix E analyzes only the costs that are directly required in order to serve the new load, and that would not be incurred but for the new load.

Please see BC Hydro’ response to BCUC IR 1.16.1 for additional discussion of embedded and marginal cost analysis.

BC Hydro notes that the energy related, demand related and customer related embedded costs on a per-unit of measurement basis (e.g., c/kWh, or $/kW) have been relatively stable over time. Therefore, for the purpose of the cost of service analysis presented in Appendix F, the average costs were escalated by CPI to estimate the nominal costs with inflation considered. For more information regarding cost escalation, please refer to BC Hydro’s response to BCUC IR 1.18.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.8 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.8 Is the total 4CP used in the 2017 FACOS (9156239 kW per Attachment 1, Calculation Tab, Cell A28) based on demand at the customer meter similar to the point of measurement for the Depot Charging 4CP?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.12.6. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.8.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.8.1 If yes, why is this the appropriate point of measurement for use in the FACOS?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.12.6. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.9 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.9 What is the basis for the 26 depot charging accounts assumed for F2029?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.18.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.12.10 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, pages 1-3 Exhibit B-3, Appendix F, Attachment 1

1.12.10 What would be the illustrative revenue to cost ratio for the Overnight Rate based on F2024 charges and costs? Please provide the supporting calculations.

RESPONSE:

Please refer to BC Hydro’s response to BCUC supplemental IR 1.21.5. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.13.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

13.0 Reference: Exhibit B-1, pages 34-35 Exhibit B-1, Appendix F, page 3 and Attachment 1

1.13.1 Given that the escalation rates used to calculate the F2029 Overnight Rate are not related to the rates used to escalate the F2017 FACOS result to F2029, how can the resulting revenue to cost ratio calculations be considered representative?

RESPONSE:

The escalation factors will result in reasonably representative estimates of future revenue to cost ratios assuming all customers experience the same general rate increases and cost of service escalation. This is because the calculation of revenue to cost ratios relies on allocating total revenue requirements to different customer groups, expressed in terms of a proportion of costs. If rates and costs escalate for all customers by the same amount, then the estimated proportion of costs allocated to an individual group of customers will be reasonable, even if actual cost escalation vary from estimate.

BC Hydro believes it is reasonable to assume that all customers will experience the same general rate increases given that this aligns with BC Hydro’s historic and current practice. BC Hydro acknowledges that some customer groups may experience higher or lower cost escalation than the overall average, given the difference in the nature of electrical service provided, however attempting to forecast how these differences may arise would be resource intensive and subject to uncertainty. As described in section 7 of the Application, BC Hydro proposes to monitor, evaluate and report to the BCUC on actual cost recovery following implementation of the rates.

As explained in BC Hydro’s response to BCUC IR 1.18.2, CPI was used to escalate and estimate the nominal unit energy related, demand related and customer related costs in fiscal 2029 to address the inflation impact on unit cost.

Rates were escalated by interim Revenue Requirements Application escalator for years before fiscal 2024. Revenue Requirements Application escalators were assumed to be same as the CPI after fiscal 2024.

Although the values of CPI and the Revenue Requirements Application interim escalators in some individual year may be different year over year the average values of CPI and Revenue Requirements Application escalator are reasonably close during fiscal 2018 and fiscal 2029. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.1 Is the Overnight Rate economic justification based on the premise that: i) the associated load is incremental to the system and arises due to the offering of the Overnight Rate (per page 36, lines 7-8 and Appendix E, page 5) or ii) the Overnight Rate leads to load shifting from the peak to the off period (per page 24, lines 9-11)?

RESPONSE:

BC Hydro’s economic justification of the Overnight Rate is based on the rate schedule resulting in incremental revenues that exceed marginal costs. Incremental revenues arise because this new load does not currently exist in BC Hydro’s service territory. Marginal costs are lower than incremental revenues in part because there are no generation or non-bulk transmission capacity marginal costs applied during the overnight period. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.1.1 If based on the premise that the load is incremental and arises only due to the offering of the Overnight Rate, please reconcile this view with the fact that both BC Transit and TransLink have committed to the increased use of electric vehicles (per Appendix C).

RESPONSE:

Please see BC Hydro’s response to BCOAPO IR 1.1.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.1.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.1.2 With respect to Table 4 (page 37), for each of the three time periods what percentage of the load must be viewed as incremental in order for the Ratepayer Benefit Cost Ratio to be 1.0 or greater? (Note: In preparing the response please assume that the non-incremental load would have been billed at the standard LGS Rate)

RESPONSE:

For the five year period in Table 4, 60 per cent of the load must be viewed as incremental in order for the Ratepayer Benefit Cost Ratio to be 1.0 or greater.

The Ratepayer Benefit Cost Ratios for the five and 10 year periods in Table 4 are not sensitive to the per cent of load that is viewed as incremental, as the ratios are greater than 1 even if the per cent of load that is viewed as incremental is low, such as 5 per cent. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.2 What Mid-C market price forecast was used (i.e., was it the 2017 or 2018 forecast)?

RESPONSE:

The marginal cost of energy shown in Table 2 of Appendix E of the Application is based on the ABB Fall 2017 Reference Case forecast of the Mid-C market price. It represents the B.C. Border Sell price, which is calculated as the Mid-C price adjusted (reduced) for the transmission costs associated with line losses and wheeling through the Bonneville Power Administration (BPA) system. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.2 What Mid-C market price forecast was used (i.e., was it the 2017 or 2018 forecast)?

1.14.2.1 Does the choice of Mid-C forecast impact the overall conclusions that: i) for the Base Case Scenario there is a positive ratepayer impact for all three time periods considered and ii) for Scenarios 1 and 2 there is positive rate payer impact for the 10 year and 15 year time periods.

RESPONSE:

The following tables show the revised Ratepayer Benefit Cost Ratios for the Overnight Rate using the 2018 Mid-C market price forecast as in Appendix E. The results show that the choice of Mid-C forecast does not impact the overall conclusions, since the results are comparable to the results using the 2017 Mid-C market price forecast.

Table 3 Revised Results for Base Case for Overnight Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 1.11 10 1.38 15 1.39

Table 4 Revised Results for Scenario 1 for Overnight Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 0.8 10 1.0 15 1.0

Table 5 Revised Results for Scenario 2 for Overnight Rate

Time Period (Years) Ratepayer Benefit Cost Ratio 5 0.9 10 1.1 15 1.2

BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.3 The rate payer economic assessment of the Overnight Rate includes a one-time cost of $350,000 for utilizing the transmission metering and billing solution (page 39). However, no allowance appears to have been made for the incremental cost of the additional meter, the ongoing incremental cost of reading the additional meters associated with the Overnight Rate and billing the additional accounts. Is it assumed that these costs will all be cover by revenues from the basic charge which have also been excluded from the analysis?

RESPONSE:

BC Hydro expects that the ongoing operating costs of the Overnight Rate will be similar to the operating costs of Large General Service Rate customers. Similar to other BC Hydro rates, the basic charge only recovers a portion of the customer related costs which include meter reading and billing. The remaining portion of the customer related costs will be recovered through the energy charge. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.3.1 If yes, please demonstrate that the basic charge revenues will cover these incremental costs.

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.14.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.14.3.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 Reference: Exhibit B-1, pages 24 & 36-39 and Appendix E

1.14.3.2 If not, how are these incremental costs accounted for?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.14.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.15.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

15.0 Reference: Exhibit B-1, page 36 (lines 19-22) and Appendix E

The Application (page 36) states: “The base case reported below assumes that the marginal distribution capacity cost is the contribution provided by BC Hydro under the distribution extension policy (section 8.3 of the Electric Tariff)”.

1.15.1 It is noted that Section 8.3 of the Electric Tariff applies to distribution extensions at voltages of 35 kV or less while the Overnight Rate is meant to be applicable to LGS customers. What is the distribution extension policy for LGS customers and how would using it impact the Base Case economic analysis results for the Overnight Rate (per page 37, Table 4)?

RESPONSE:

For clarification, BC Hydro’s extension policy, section 8 of BC Hydro’s Electric Tariff which is further explained in the response to BCOAPO’s IR 1.6.3 and BCUC IR 1.12.3, is applicable to all potential customers that require BC Hydro to extend its distribution system, energized at a voltage of 35 kV or less, to provide new service or upgrade existing service to a customer. The extension policy would not be applied differently for customers requesting service under the Overnight Rate or Demand Transition Rate.

Once a customer is connected to BC Hydro’s electrical system, they are billed for energy and demand on the appropriate rate schedule. Where a customer may be eligible for more than one rate schedule, the customer may opt for the rate schedule that best suits their needs. One of the eligibility criteria for taking service under Large General Service or the Overnight Rate is that the customer’s maximum demand must be greater or equal to 150 kW.

Given that the distribution extension policy in section 8.3 applies to customers requesting service under the Overnight Rate and Demand Transition Rate, it has been included as the distribution capacity cost assumed in the Base Case for both the Overnight Rate and Demand Transition Rate in Appendix E. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.16.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

16.0 Reference: Exhibit B-1, page 45 and Appendix F, pages 4-7 and Attachment 2

1.16.1 With respect to page 45 (Table 6), does the Demand Transition Rate recover embedded costs in F2024 and F2029 when the load factor reaches 50%?

RESPONSE:

The Demand Transition Rate is able recover embedded costs in fiscal 2024 and fiscal 2029 when the load factor reaches 51.9 per cent. Please refer to BC Hydro’s response to BCUC IR 1.10.7 for more information. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.16.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

16.0 Reference: Exhibit B-1, page 45 and Appendix F, pages 4-7 and Attachment 2

1.16.2 What assumptions are required (e.g., frequency of use of the in-route charging stations) for the load factor to reach 50%?

RESPONSE:

As shown in the illustrative load profile of an in route charging station in Figure 2 of the Application, the full deployment stage of nine buses per charger consuming about 10 MWh of energy per bus would reach a load factor of 50 per cent.

Please refer to BC Hydro’s response to BCUC IR 1.11.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.16.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

16.0 Reference: Exhibit B-1, page 45 and Appendix F, pages 4-7 and Attachment 2

1.16.2 What assumptions are required (e.g., frequency of use of the in-route charging stations) for the load factor to reach 50%?

1.16.2.1 Has BC Hydro consulted with BC Transit and/or TransLink regarding the likelihood that the load factor will reach 50%?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.11.2. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.16.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

16.0 Reference: Exhibit B-1, page 45 and Appendix F, pages 4-7 and Attachment 2

1.16.3 What are the load factors implicit in the 2020, 2024 and 2029 hourly load profiles set out in Appendix F, Attachment 2, Input1 Tab?

RESPONSE:

The three load factors shown in the Input 1 tab of Attachment 2 in the Supplementary Information – Exhibit B-3 (15 per cent, 30 per cent and 51.9 per cent) is part of sensitivity analysis performed for fiscal years 2024, 2029 and 2034.

In the Application, results of 15 per cent, 30 per cent and 51.9 per cent were shown for years 2024, 2029 and 2034 respectively. Please refer to BC Hydro’s response to BCUC IR 1.10.7 for the full results of load factor sensitivity analysis performed for each year. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.17.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

17.0 Reference: Exhibit B-1, page 45 and Appendix F, pages 4-7 and Attachment 2

1.17.1 Please confirm that for purposes of the Cost of Service Analysis the Demand Transition Rate load was assumed to be incremental to the load used in the 2017 FACOS.

RESPONSE:

Confirmed. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.17.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

17.0 Reference: Exhibit B-1, page 45 and Appendix F, pages 4-7 and Attachment 2

1.17.1 Please confirm that for purposes of the Cost of Service Analysis the Demand Transition Rate load was assumed to be incremental to the load used in the 2017 FACOS.

1.17.1.1 Why was this assumption made?

RESPONSE:

To the best of BC Hydro’s knowledge, the load that is expected to be served by the Demand Transition Rate does not currently exist in BC Hydro’s service territory. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.17.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

17.0 Reference: Exhibit B-1, page 45 and Appendix F, pages 4-7 and Attachment 2

1.17.2 What is the basis for the 100 Demand Transition Rate accounts assumed for F2029?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.18.3.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.18.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

18.0 Reference: Exhibit B-1, pages 46-47 and Appendix E

1.18.1 Is the Demand Transition Rate’s economic justification based on the premise that the associated load is incremental to the system and arises due to the offering of the Demand Transition Rate?

RESPONSE:

The Demand Transition Rate’s economic justification is based on the premise that the associated load results in incremental revenue.

As explained on page 46 of the Application, the incremental revenues received from the new load served under the Demand Transition Rate will exceed the marginal cost of serving the new load in the ten and fifteen year time periods. Therefore ratepayers benefit from the new load in the medium and longer term, even if that new load is served at a lower rate than existing load for a period of time. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.18.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

18.0 Reference: Exhibit B-1, pages 46-47 and Appendix E

1.18.1.1 If yes, please reconcile this view with the fact that both BC Transit and TransLink have committed to the increased use of electric vehicles (per Appendix C).

RESPONSE:

Please see BC Hydro’s response to BCOAPO IR 1.1.3. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.18.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

18.0 Reference: Exhibit B-1, pages 46-47 and Appendix E

1.18.2 What Mid-C market price forecast was used (i.e., was it the 2017 or 2018 forecast)?

RESPONSE:

The marginal cost of energy shown in Table 2 of Appendix E of the Application is based on the ABB Fall 2017 Reference Case forecast of the Mid-C market price. It represents the B.C. Border Sell price, which is calculated as the Mid-C price adjusted (reduced) for the transmission costs associated with line losses and wheeling through the Bonneville Power Administration (BPA) system. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.18.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

18.0 Reference: Exhibit B-1, pages 46-47 and Appendix E

1.18.2 What Mid-C market price forecast was used (i.e., was it the 2017 or 2018 forecast)?

1.18.2.1 Does the choice of Mid-C forecast impact the overall conclusions that there is a rate payer benefit if either a 10 year or 15 year time period is used for the analysis (per Table 7)?

RESPONSE:

The following table shows the revised Ratepayer Benefit Cost Ratios for the Demand Transition Rate using the 2018 Mid-C market price forecast, as in Table 7, page 47 of the Application. The results show that the choice of Mid-C forecast does not impact the overall conclusions, since the results are comparable to the results using the 2017 Mid-C market price forecast.

Table 7: Revised Results for Demand Transition Rate Ratepayer Impacts

Time Period for F2021-F2025 F2026-F2029 F2020- F2034 Load Factor Load Factor (%) 15 30 52 Time Period used for 5 Years 10 Years 15 Years Ratepayer Benefit F2020-F2024 F2020-F2029 F2020-F2034 Cost Analysis Ratepayer Benefit 0.73 1.02 1.15 Cost Ratio

BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.19.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 Reference: Exhibit B-1, Appendix E, pages 2 and 4-5 and Attachment 1

1.19.1 Appendix E, page 2 states that: “The generation capacity marginal cost also includes the marginal cost of bulk transmission, if a need of bulk transmission is necessary”. Do the Generation Capacity values used in the analysis (per Attachment 1, Input Tab) include any allowance for transmission costs?

RESPONSE:

Yes, the generation capacity values used in the analysis include allowance for transmission costs, which consist of cost due to transmission line losses and the cost of bulk transmission.

The table below details the value breakdown among generation, cost due to transmission line losses and the cost of bulk transmission, all in real fiscal 2018 dollars.

REV6 ($/kW-yr) SCGT ($/kW-yr) Generation 49 100 Line losses 6 5 Bulk Transmission 5 18 Total 60 123

BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.19.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 Reference: Exhibit B-1, Appendix E, pages 2 and 4-5 and Attachment 1

1.19.1.1 If yes, please breakdown the values as between generation and transmission marginal capacity cost.

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.19.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.19.1.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 Reference: Exhibit B-1, Appendix E, pages 2 and 4-5 and Attachment 1

1.19.1.2 If no, why not?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.19.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.19.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 Reference: Exhibit B-1, Appendix E, pages 2 and 4-5 and Attachment 1

1.19.2 Please provide the source and basis for the Generation Capacity values used in the analysis (per Appendix E, Table 2)?

RESPONSE:

Please refer to BC Hydro’s response to AMPC IR 1.5.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.19.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 Reference: Exhibit B-1, Appendix E, pages 2 and 4-5 and Attachment 1

1.19.3 Are Generation Capacity values consistent with BC Hydro’s most recent estimates regarding its LRB, the cost of DSM and the cost of new IPPs (as provided in BC Hydro’s Electricity Purchase Agreement Renewals (Sechelt Creek Hydro, Brown Lake Hydro, and Walden North Hydro) Application proceeding?

RESPONSE:

The underlying cost assumptions for marginal generation capacity in this Application are consistent with other recent applications; except the period of applicability for new incremental capacity resources is different due to different vintages of the capacity load resource balances (LRB).

The dollar values are consistent with BC Hydro’s most recent estimates. The period of applicability is based on the most recent capacity LRB contained in the October 3, 2019 Evidentiary Update to the Fiscal 2020 to Fiscal 2021 Revenue Requirements Application and the one used in the Application are shown in the table below.

Generation Period of Applicability Period of Applicability capacity value (based on Oct 3 capacity LRB) (used in the Application) ($) 38 per kW-yr Fiscal 2020 – 2030 Fiscal 2020 – 2022 60 per kW-yr Fiscal 2031 – 2037 Fiscal 2023 – 2031 123 per kW-yr Fiscal 2038 and beyond Fiscal 2032 and beyond

BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.19.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 Reference: Exhibit B-1, Appendix E, pages 2 and 4-5 and Attachment 1

1.19.3.1 If yes, please demonstrate that this is the case.

RESPONSE:

As stated in BC Hydro’s response to BCOAPO IR 1.19.3, the assumptions around the cost of marginal generation capacity resources is consistent with other recent proceedings, but the period of applicability for those resources is not.

As demonstration of the consistency between this Application and other recent Applications, please refer to Table 3-11 of BC Hydro’s Electricity Purchase Agreement Renewals (Sechelt Creek Hydro, Brown Lake Hydro, and Walden North Hydro) Application, reproduced below. The generation capacity values, but not the period of applicability, are consistent with the ones used in this Application after accounting for inflation.

BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.19.3.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 Reference: Exhibit B-1, Appendix E, pages 2 and 4-5 and Attachment 1

1.19.3.2 If not, how would the use of these Generation Capacity values impact the results of the economic analysis?

RESPONSE:

The results of the economic analysis for the Overnight Rate do not change when the period of applicability of new generation capacity resources is based on the most recent capacity load resource balance. In the case of the Demand Transition Rate, the Ratepayer Benefit to Cost Ratio improves when the most recent period of applicability details are used in the economic analysis as shown in the table below.

Revised Table 6, Appendix E, Base Case for Demand Transition Rate

Time Period for F2021-F2025 F2026-F2029 F2030-F2034 Load Factor Load Factor (%) 15 30 52 Time Period used for 5 Years 10 Years 15 Years Ratepayer Benefit F2020-F2024 F2020-F2029 F2020-F2034 Ratepayer Benefit 0.82 1.16 1.35 Cost Ratio

BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.20.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

20.0 Reference: Exhibit B-1, page 46 and Appendix E

The Application (page 46) states: “The base case reported below assumes that the marginal distribution capacity cost is the contribution provided by BC Hydro under the distribution extension policy (section 8.3 of the Electric Tariff)”.

1.20.1 It is noted that Section 8.3 of the Electric Tariff applies to distribution extensions at voltages of 35 kV or less while the Demand Transition Rate is meant to be applicable to LGS customers. What is the distribution extension policy for LGS customers and how would using it impact the Base Case economic analysis results for the Demand Transition Rate (per page 47, Table 7)?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.15.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.21.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

21.0 Reference: Exhibit B-1, pages 52-53

1.21.1 The Application states that BC Hydro intends to monitor the “new load” associated with each of the Overnight Rate and the Demand Transition Rate. Is there a difference between the new load associated with these two Rates and the total load associated with these two rates?

RESPONSE:

To the best of BC Hydro’s knowledge there is no existing electric fleet load of the type that will be served under the two proposed rates. Given that there is no existing load, total load under the proposed rates will be new load. BC Hydro intends to annually monitor new load that takes service under the two proposed rates. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.21.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

21.0 Reference: Exhibit B-1, pages 52-53

1.21.1.1 If yes, what is it?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.21.1. BC Old Age Pensioner’s Organization Page 1 Information Request No. 1.21.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

21.0 Reference: Exhibit B-1, pages 52-53

1.21.2 The Application states that BC Hydro intends to monitor the incremental costs associated with the Overnight Rate and the Demand Transition Rate and cites metering and billing as examples. What other types of incremental costs does BC Hydro plan on monitoring and, in particular, will it be monitoring incremental distribution and non-bulk transmission facility costs paid for by BC Hydro?

RESPONSE:

BC Hydro expects that most of the incremental costs of offering the proposed new rates will be for metering and billing. Additional incremental costs are expected to include:

• Incremental costs associated with the BCUC proceedings on these rates (i.e., Participant Cost Awards, Hearing Costs); and

• Incremental costs to retain a survey contract firm to run customer surveys, should they be needed for the evaluation.

BC Hydro monitors our distribution and transmission related costs of service as part of regular operations, therefore the resources required to monitor such costs would not be considered to be incremental. BC Hydro will report on marginal transmission and distribution related costs in the three-year evaluation. BC Sustainable Energy Association Page 1 Information Request No. 1.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 A. Policy Objectives

Topic Policy objectives

Reference Application, Exhibit B-1, section 1.2.1, page 6; section 2.1 Policy Context, pp. 16 – 17.

BC Hydro cites BC’s Climate Change Accountability Act, the CleanBC plan and the BC Government’s Mandate letter to BC Hydro as policy initiatives supporting the application.

BC Hydro states on page 2:

“In 2016, road transportation accounted for approximately 17 Mt CO2e which represents 27 per cent of the total greenhouse gas emissions in B.C.”

1.1.1 For clarity, please confirm that BC’s Energy Objectives in the Clean Energy Act are also part of the relevant policy context.

RESPONSE:

Confirmed. The Clean Energy Act is one of several documents that provides the policy context. BC Sustainable Energy Association Page 1 Information Request No. 1.1.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 A. Policy Objectives

Topic Policy objectives

Reference Application, Exhibit B-1, section 1.2.1, page 6; section 2.1 Policy Context, pp. 16 – 17.

BC Hydro cites BC’s Climate Change Accountability Act, the CleanBC plan and the BC Government’s Mandate letter to BC Hydro as policy initiatives supporting the application.

BC Hydro states on page 2:

“In 2016, road transportation accounted for approximately 17 Mt CO2e which represents 27 per cent of the total greenhouse gas emissions in B.C.”

1.1.2 Does BC Hydro interpret the policy context as providing justification for BC Hydro to seek to bring about a particular amount or proportion of GHG emissions reductions?

RESPONSE:

BC Hydro believes that the proposed Overnight Rate and Demand Transition Rate support the B.C. Government’s policies and objectives related to greenhouse gas emission reductions. However, the rates are justified on an economic basis for the reasons described in sections 4.3 and 5.3 of Exhibit B-1. BC Sustainable Energy Association Page 1 Information Request No. 1.2.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, pp.1 – 2

BC Hydro says:

“BC Hydro has received customer and stakeholder feedback suggesting that the availability of the new services be expanded to include providers of third party fast charging services to electric passenger vehicles. While BC Hydro understands the interest in rate design for a range of applications, BC Hydro proposes the availability as described in this Application, because any rate application for third party fast charging services to passenger vehicles should be informed by the B.C Government’s response to the BCUC recommendations contained in its Phase Two Report of the Inquiry into the Regulation of Electric Vehicle Charging Service (Inquiry) which deals largely with the regulatory considerations arising in the public fast charging market. The outcome of this Inquiry will directly affect the types and scope of the rates BC Hydro may put forward for approval in respect of public fast charging. As a result, it would not be effective or efficient to apply for optional services and rates for third party providers of fast charging services in advance of understanding the regulatory framework that will apply to those circumstances.” [underline added]

1.2.1 For greater certainty, please confirm or correct the following:

1.2.1.1 By “third party fast charging services” BC Hydro refers to fast charging of EVs owned by ‘third parties’ where the Customer providing the fast charging service is the ‘second party’ and BC Hydro is the ‘first party.’

RESPONSE:

BC Hydro confirms that the “third-party fast charging services” referred to are those where BC Hydro’s customer is providing fast charging services to electric vehicles owned by “third-parties” – i.e., BC Hydro’s customer is providing fast charging services to electric vehicles that BC Hydro’s customer does not own or lease, and operate. BC Sustainable Energy Association Page 1 Information Request No. 1.2.1.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, pp.1 – 2

BC Hydro says:

1.2.1 For greater certainty, please confirm or correct the following:

1.2.1.2 A provider of “third party fast charging services” is not eligible for the proposed Overnight Rate or Demand Transition Rate because EVs owned by third parties are not “owned or leased by, and operated by, the Customer.”

RESPONSE:

Confirmed. BC Sustainable Energy Association Page 1 Information Request No. 1.2.1.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, pp.1 – 2

BC Hydro says:

1.2.1 For greater certainty, please confirm or correct the following:

1.2.1.3 In the quoted paragraph, “third party fast charging services” is synonymous with “public fast charging”: neither is eligible for the proposed Overnight Rate or Demand Transition Rate.

RESPONSE:

The fleet charging rates are not intended to be available for fast charging services to consumer owned and operated electric vehicles, irrespective of whether the service is considered public or private, or offered by a third-party or by BC Hydro.

In reviewing the paragraph from the Application reproduced in the preamble above, BC Hydro concludes that its clarity could have been improved as follows:

BC Hydro has received customer and stakeholder feedback suggesting that the availability of the new services be expanded to include providers of charging services to consumer owned and operated electric vehicles. While BC Hydro understands the interest in rate design for a range of BC Sustainable Energy Association Page 2 Information Request No. 1.2.1.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

applications, BC Hydro proposes the availability as described in this Application. Any rate application for charging services to consumer owned and operated electric vehicles should be informed by the B.C. Government’s response to the BCUC recommendations contained in its Phase Two Report of the Inquiry into the Regulation of Electric Vehicle Charging Service (Inquiry) which deals largely with the regulatory considerations arising in respect of charging services to consumer owned and operated electric vehicles. The outcome of this Inquiry will directly affect the types and scope of the rates BC Hydro may put forward for approval in respect of such services. As a result, it would not be effective or efficient to apply for optional services and rates for providers of charging services to consumer owned and operated electric vehicles in advance of understanding the regulatory framework that will apply to those circumstances. BC Sustainable Energy Association Page 1 Information Request No. 1.2.1.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, pp.1 – 2

BC Hydro says:

1.2.1 For greater certainty, please confirm or correct the following:

1.2.1.4 The reference to passenger vehicles in the phrase “third party fast charging services to electric passenger vehicles” is not to be taken as a limiting factor. The proposed Overnight Rate and Demand Transition Rate are not available to third party charging services to any type of EV, including but not limited to passenger EVs. And, the proposed Overnight Rate and Demand Transition Rate are available to providers of fast charging to Electric Fleet Vehicles that they own or lease, and operate, including passenger EVs and any other type of EV that meets the proposed definition of “Vehicle.”

RESPONSE:

BC Hydro confirms that the Overnight Rate and the Demand Transition Rate are available for fast charging of electric fleet vehicles, including passenger vehicles, which are owned or leased, and operated, by BC Hydro’s customer. BC Hydro notes that all other availability criteria must also be met. BC Sustainable Energy Association Page 1 Information Request No. 1.2.1.5 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, pp.1 – 2

BC Hydro says:

1.2.1 For greater certainty, please confirm or correct the following:

1.2.1.5 The phrase “third party providers of fast charging services” is a mistake and should read “providers of third party charging services” (or “providers of charging services to third parties”).

RESPONSE:

BC Hydro confirms that it may be clearer for “third-party providers of fast charging services” to read “providers of third-party charging services” or “providers of charging services to third-parties”. BC Hydro has used these terms synonymously in the Application. BC Sustainable Energy Association Page 1 Information Request No. 1.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Exhibit B-1, pp.1 & 2, section 1.1

BC Hydro rejects the idea of providing an EV charging rate for providers of third party charging services. BC Hydro says:

“[A]ny rate application for third party fast charging services to passenger vehicles should be informed by the B.C Government’s response to the BCUC recommendations contained in its Phase Two Report of the Inquiry into the Regulation of Electric Vehicle Charging Service (Inquiry) … [I]t would not be effective or efficient to apply for optional services and rates for third party providers of fast charging services in advance of understanding the regulatory framework that will apply to those circumstances.”

1.3.1 What consultations has BC Hydro had with providers of fast charging services for third party passenger EVs or EVs more broadly? What were the results?

RESPONSE:

BC Hydro has had numerous discussions with providers of charging services to consumer owned electric vehicles. Providers of such services also participated in BC Hydro’s May 28, 2019 workshop.

The comments received from these participants were that BC Hydro should consider developing rates for providers of such services.

Please refer to BC Hydro’s response to BCUC IR 1.7.1 for additional discussion. BC Sustainable Energy Association Page 1 Information Request No. 1.3.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Exhibit B-1, pp.1 & 2, section 1.1

BC Hydro rejects the idea of providing an EV charging rate for providers of third party charging services. BC Hydro says:

1.3.2 Has BC Hydro considered what rates would be appropriate for providers of third party charging services? If so, what conclusions did BC Hydro reach?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.7.1. BC Sustainable Energy Association Page 1 Information Request No. 1.3.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Exhibit B-1, pp.1 & 2, section 1.1

BC Hydro rejects the idea of providing an EV charging rate for providers of third party charging services. BC Hydro says:

1.3.2.1 Could the Overnight Rate or the Demand Transition Rate be appropriate for providers of third party charging services?

RESPONSE:

The Overnight Rate and Demand Transition Rate are not designed for providers of third-party charging services to consumer owned and operated electric vehicles. Please refer to BC Hydro’s response to BCUC IR 1.7.1 for further discussion. BC Sustainable Energy Association Page 1 Information Request No. 1.3.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Exhibit B-1, pp.1 & 2, section 1.1

BC Hydro rejects the idea of providing an EV charging rate for providers of third party charging services. BC Hydro says:

1.3.3 Are BC Hydro and the BC Government discussing rates for providers of third party (public) charging services in Phase 2 of the Comprehensive Review of BC Hydro or in any other forum?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.7.1. BC Sustainable Energy Association Page 1 Information Request No. 1.3.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Exhibit B-1, pp.1 & 2, section 1.1

BC Hydro rejects the idea of providing an EV charging rate for providers of third party charging services. BC Hydro says:

1.3.4 Does BC Hydro plan to apply for an optional rate for providers of third party (public) charging services once the BC Government has responded to the Phase Two Report on the Inquiry into the Regulation of EV Charging Service? Would such a rate be available to BC Hydro for its provision of third party (public) fast charging service?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.7.1. BC Sustainable Energy Association Page 1 Information Request No. 1.4.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, 4.1 Overnight Rate Terms and Conditions, pp. 31 – 34; section 5.1 Demand Transition Rate Terms and Conditions, pp. 39 – 44.

1.4.1 Please confirm that the conditions of availability, definitions and rationale for the availability are the same for the Overnight Rate and the Demand Transition Rate. If they are not, please point out the differences.

RESPONSE:

The only difference between the conditions of availability, definitions and rationale for the availability between the Overnight Rate and the Demand Transition Rate is the definition of Billing Demand.

As filed in the Application, in the Demand Transition Rate, “The Billing Demand will be the highest kW Demand in the Billing Period”, and in the Overnight Rate, “The Billing Demand will be the highest kW Demand between the hours 06:00 and 21:59 daily in the Billing Period.”

BC Hydro notes that concurrent with the filing of these IR responses we have also filed an updated Overnight Rate Schedule which revises the definition of billing demand for the purposes of extension contribution and transformation discount. The revised definition for the Overnight Rate is:

The Billing Demand will be the highest kW Demand between the hours 06:00 and 21:59 daily in the Billing Period.

Notwithstanding the foregoing, the Billing Demand will be the highest kW Demand in the Billing Period for the purposes of determining: (i) any discount under this Rate Schedule for Customer supplied Transformation; and (ii) BC Hydro’s contribution towards an Extension under section 8.3 (Extension Fee for Rate Zone I) BC Sustainable Energy Association Page 1 Information Request No. 1.4.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, 4.1 Overnight Rate Terms and Conditions, pp. 31 – 34; section 5.1 Demand Transition Rate Terms and Conditions, pp. 39 – 44.

One of the proposed Terms and Conditions of the Overnight and Demand Transition Rates is:

“Availability: For Customers who qualify for General Service where the Customer is a business, government agency or other organization. For use only for separately metered charging of Electric Fleet Vehicles or Vessels owned or leased by, and operated by, the Customer, at Maximum Demand equal to or greater than 150 kW.” [underline added]

1.4.2 Why is BC Hydro proposing “the Customer is a business, government agency or other organization” as an availability criterion? What type of customer would fall outside this criterion?

RESPONSE:

The purpose of limiting the availability to “a business, government agency or other organization” is to prevent individuals from taking service under the Overnight Rate or Demand Transition Rate for personal uses.

BC Hydro decided to limit the availability to “a business, government agency or other organization” rather than explicitly exclude “individuals”, because sometimes sole proprietorships have accounts in the name of an individual, which may have caused confusion during rate implementation. BC Sustainable Energy Association Page 1 Information Request No. 1.4.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, 4.1 Overnight Rate Terms and Conditions, pp. 31 – 34; section 5.1 Demand Transition Rate Terms and Conditions, pp. 39 – 44.

One of the proposed Terms and Conditions of the Overnight and Demand Transition Rates is:

1.4.3 Did BC Hydro consider defining availability in terms of new load rather than “a business, government agency or other organization”? If so, why was this rejected? If not, would this be a more straightforward criterion for availability?

RESPONSE:

BC Hydro believes the availability criteria as proposed are required to ensure that the proposed rates are available only for the intended customers.

BC Hydro considered adding new load to the availability criteria however this is not proposed for the following two reasons.

First, the proposed rates are for use only for separately metered charging of electric fleet vehicles or vessels owned or leased by, and operated by the customer. As these loads currently do not exist they are new loads.

Second, if the new load criteria replaced the availability criteria then the proposed rates would broaden beyond the intended customers. In addition it would be administratively complex and resource intensive to implement for a General Service Rate. Developing a tariff supplement and assessing the criteria on a case by case, ongoing basis would likely be required in order to address situations such as:

• Treatment of new load added to an existing account;

• A change in site ownership or operation resulting in the closure of an existing account and opening a new account at the same location. BC Sustainable Energy Association Page 2 Information Request No. 1.4.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

BC Hydro’s view is that the proposed availability criteria meet the objectives of encouraging fleet electrification, while also being relatively simple to understand and implement. BC Sustainable Energy Association Page 1 Information Request No. 1.4.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, 4.1 Overnight Rate Terms and Conditions, pp. 31 – 34; section 5.1 Demand Transition Rate Terms and Conditions, pp. 39 – 44.

BC Hydro proposes the following definition of “vehicle” in the Terms and Conditions of the Overnight and Demand Transition Rates:

“4. Vehicle. A vehicle used for transportation, not run on rails, and includes, without limitation, buses, medium duty trucks and heavy duty trucks.”

1.4.4 For greater certainty, please confirm that this definition of “vehicle” includes passenger vehicles and light duty trucks.

RESPONSE:

Confirmed. Please also refer to BC Hydro’s response to BCSEA IR 1.2.1.4. BC Sustainable Energy Association Page 1 Information Request No. 1.4.5 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 B. Availability of the Fleet Electrification Rates

Topic Availability of Fleet Electrification Rates

Reference Application, Exhibit B-1, 4.1 Overnight Rate Terms and Conditions, pp. 31 – 34; section 5.1 Demand Transition Rate Terms and Conditions, pp. 39 – 44.

BC Hydro states:

“The Availability, Definition of Electric Fleet Vehicle or Vessel, and Metering Special Condition are intended to ensure this rate schedule applies to the new service for which it was designed, which is charging of electric fleets with Maximum Demand equal or greater than 150 kW. As noted in section 1.2, this new type of electrical load does not currently exist in BC Hydro’s service territory. Broadening the availability to include existing electrical loads would reduce the economic benefits to ratepayers.”

1.4.5 How does confining Overnight Rate and Demand Transition Rate customers to “a business, government agency or other organization” serve to ensure that the rate schedules will apply to the new service for which it is designed, or to preventing availability from being broadened to existing loads, or both?

RESPONSE:

BC Hydro proposes to limit the availability to “a business, government agency or other organization” in order to prevent individuals from taking service under the Overnight Rate or Demand Transition Rate for personal uses. Please refer to BC Hydro’s response to BCSEA IR 1.4.2. BC Sustainable Energy Association Page 1 Information Request No. 1.5.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 B. Availability of the Fleet Electrification Rates

Topic Timing of Implementation of Overnight Rate Proposal

Reference Application, Exhibit B-1, 4.5 Overnight Rate Implementation Consideration

The proposed optional Overnight Rate would be approved as of April 1, 2021, allowing approximately one year for BC Hydro to work out the metering and billing challenges.

1.5.1 Will this timing delay the implementation of EV fleets that would use the Overnight Rate?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.6.3. BC Sustainable Energy Association Page 1 Information Request No. 1.6.1 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

“BC Hydro has modelled both the proposed Overnight Rate and Demand Transition Rate based on illustrative transit bus fleets with load projections informed by discussions with Translink and BC Transit.”

BC Hydro says on pp. 7 & 8:

“The Vancouver Fraser Port Authority (VFPA) is responsible for Canada’s largest Port and has also indicated that electrification of port activities provides a significant opportunity to reduce the Port of Vancouver’s greenhouse gas emissions. The VFPA indicates that demand charges have been identified as a significant barrier to the electrification of port fleets. A copy of VFPA’s support letter for BC Hydro’s proposed rates is provided in Appendix C.”

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

“Demand charges have been identified as significant barriers to electrification of port fleets.” and “A competitive rate structure is essential to promoting electrification in the freight transport industry …”

1.6.1 Please describe in more detail the scope and depth of discussions held with BC Transit and Translink.

RESPONSE:

BC Hydro has been actively engaged with both TransLink and BC Transit regarding electrification of their fleet since 2017. At the time TransLink was entering into an agreement for the CUTRIC Pan-Canadian Electric Bus Demonstration Pilot and Trial to explore the electrification of buses and was also working on phase 1 of their Low Carbon Fleet Strategy. BC Hydro worked with TransLink to understand and provide high level feedback on their charging strategy and impacts on the BC Hydro grid.

In late 2017, BC Transit further engaged BC Hydro for support and planning with their electric bus pilot which was tested in early 2018 and in operation for brief periods by the summer 2018. Both TransLink and BC Transit recognized early on BC Sustainable Energy Association Page 2 Information Request No. 1.6.1 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

the requirement to work closely with BC Hydro as they explored their respective Low Carbon Fleet Strategies.

In December of 2018, BC Transit, TransLink and BC Hydro met to discuss the opportunities and challenges of electrifying bus transportation in the Province. The outcomes of the meeting included creating a working group comprised of all three organizations to explore how BC Hydro could remove barriers to support bus fleet electrification.

In 2019, BC Hydro met with TransLink and BC Transit regularly to identify barriers to fleet electrification such as the impact of demand charges. TransLink and BC Transit provided data to BC Hydro to explore potential rate designs that support fleet electrification. BC Sustainable Energy Association Page 1 Information Request No. 1.6.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.2 How important is the Demand Transition Rate in particular to BC Transit and Translink, in terms of their plans to electrify their bus fleets?

RESPONSE:

Please refer to BC Hydro’s response to BCOAPO IR 1.1.1. BC Sustainable Energy Association Page 1 Information Request No. 1.6.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.2.1 Please describe the circumstances of bus fleet operation in which in route charging and the Demand Transition Rate are especially important.

RESPONSE:

Charging scenarios are largely based on route distance, time in service and fleet type. If a bus is required to be in service for a number of hours without going back to the depot, they may require a charge in route to help ensure the battery has enough power to complete service. A bus fleet operator may require a combination of depot and in route charging to ensure the electric fleet can provide the same level of service as their non-electric fleet. Therefore it is important to provide a Demand Transition Rate alternative to the Overnight Rate in circumstances where fleet operators must charge in route as well as overnight. BC Sustainable Energy Association Page 1 Information Request No. 1.6.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.3 Please describe the scope and depth of discussions held with the Port of Vancouver regarding electrification.

RESPONSE:

BC Hydro has been actively engaged with the Port of Vancouver on electrification since at least 2010. The Port of Vancouver and BC Hydro collaborated on a number of electrification initiatives including the development of the Shore Power Rate. More recently there has been collaboration on a Drayage Study to examine alternative clean fuel technology in freight transport as part of the Port’s vision to reduce emissions.

The Port of Vancouver further partnered with BC Hydro in 2018/2019 in the development of an Electrification Roadmap. This roadmap is to support efforts to reduce the contributions to climate change from port activities by examining viable electric options by a 2030 timeframe. BC Sustainable Energy Association Page 2 Information Request No. 1.6.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

BC Hydro continues to work with the Port of Vancouver and its tenants to promote and engage in the electrification of fleets, cranes and vessels. The Application is supported by the Port of Vancouver, as demonstrated in their letter found in Appendix C of the Application. BC Sustainable Energy Association Page 1 Information Request No. 1.6.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.4 What, in BC Hydro’s understanding, is included in and excluded from the term “electrification of port fleets”?

RESPONSE:

Included in the “electrification of port fleets” are vessels, buses, cranes, and other fleet vehicles operated at the port, subject to meeting the availability criteria of the proposed Overnight Rate and Demand Transition Rate. BC Sustainable Energy Association Page 1 Information Request No. 1.6.5 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.5 Does BC Hydro believe that demand charges are significant barriers to electrification at the Port?

RESPONSE:

The Port of Vancouver has provided a letter of support to BC Hydro for this Application citing a competitive rate structure such as the proposed Overnight Rate and Demand Transition Rate are essential to promoting electrification and reducing emissions in this sector.

Demand charges will be a barrier to electrification at the Port in the same way that demand charges are a barrier to electrification of fleets. Please refer to the Vancouver Fraser Port Authority’s letter of support for this Application, found in Appendix C. BC Sustainable Energy Association Page 1 Information Request No. 1.6.5.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.5.1 Does BCH believe the proposed optional rates will be successful in meeting the Port’s needs for low-cost power for fleet electrification?

RESPONSE:

The Port of Vancouver has provided a letter of support (see Appendix C) to BC Hydro for this Application citing a competitive rate structure such as the proposed Overnight Rate and Demand Transition Rate are essential to promoting electrification and reducing emissions in this sector. BC Sustainable Energy Association Page 1 Information Request No. 1.6.6 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.6 Is the Port of Vancouver itself a potential customer for fleet electrification, or would the Port’s tenants and drayage providers be the main customers for fleet electrification? If the latter, has BC Hydro held discussions with Port of Vancouver tenants of or drayage service providers regarding electrification? If so, please describe the scope and depth and any outcomes of the discussions.

RESPONSE:

The Port of Vancouver is a potential customer for fleet electrification as well as the Port tenants and drayage providers, as long as they meet the availability criteria of the proposed fleet charging rates. The Port of Vancouver does have fleet vehicles that could be electrified. BC Hydro expects the majority of customers of electrification at the Port will be the tenants and drayage providers. BC Sustainable Energy Association Page 2 Information Request No. 1.6.6 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

The Port of Vancouver and BC Hydro collaborated on a Drayage Study to examine alternative clean fuel technology in freight transport as part of the Port’s vision to reduce emissions. As an outcome of the study, in 2019 the Port of Vancouver, in partnership with the Government of B.C. and TransLink, issued a Request for Expressions of Interest for a Clean Trucking Initiative Pilot Program. The Pilot is an opportunity to explore advances in alternative energy source trucks and technology with participation of the drayage community and terminals.

The Port of Vancouver further partnered with BC Hydro in 2018/2019 in the development of an Electrification Roadmap, which included consultation with Port of Vancouver tenants. This roadmap is to support efforts to reduce the contributions to climate change from port activities by examining viable electric options by a 2030 timeframe. BC Sustainable Energy Association Page 1 Information Request No. 1.6.7 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.7 Does BC Hydro expect that the Port of Vancouver or its tenants or drayage service providers will apply for service under to the Overnight Rate or the Demand Transition Rate in the next few years?

RESPONSE:

Yes BC Hydro expects that the Port of Vancouver, its tenants or drayage service providers will apply for service under the Overnight Rate or Demand Transition Rate in the next few years. BC Sustainable Energy Association Page 1 Information Request No. 1.6.7.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

BC Hydro says on p. 3:

BC Hydro says on pp. 7 & 8:

In Appendix C, the July 3, 2019 letter of the Port of Vancouver says in part:

1.6.7.1 If so, please discuss the expected volumes of power required, the expected effect on BC Hydro’s peak loads and the expected system reinforcement requirements.

RESPONSE:

The Electrification Roadmap has provided the Port and BC Hydro with a high level understanding of electrification opportunities up to 2030. This roadmap is to support efforts to reduce the contributions to climate change from port activities by examining viable electric options by a 2030 timeframe. The electric options are at varying stages of commercial availability and viability. For this reason, it is too early to forecast or model the power required or the rate schedules under which they may take service. Any new loads will be subject to BC Hydro’s extension policies. BC Sustainable Energy Association Page 1 Information Request No. 1.6.8 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

The CleanBC document (https://cleanbc.gov.bc.ca/), on page 22 says:

“For our inland ferry fleet, the future is electric. The Province is taking incremental steps in that direction as available technology increasingly supports ongoing safe, reliable and efficient service. We aim to achieve full electrification of the inland ferry fleet by 2040.”

1.6.8 Please describe the scope and depth of any discussions BC Hydro has had recently with BC Ferries regarding vessel fleet electrification.

RESPONSE:

BC Hydro has been engaged in discussions with BC Ferries regarding vessel fleet electrification since 2018. BC Hydro partnered with BC Ferries to conduct a study that explored electrification and battery technology to electrify vessels. BC Ferries has plans to electrify their Island Class of vessels as well as to explore fleet charging at terminals and the potential to electrify their entire fleet of vessels. BC Sustainable Energy Association Page 1 Information Request No. 1.6.9 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, section 1.1, p. 3; Appendix C; CleanBC plan

The CleanBC document (https://cleanbc.gov.bc.ca/), on page 22 says:

1.6.9 Does BC Hydro expect that BC Ferries will apply for service under the Overnight Rate or the Demand Transition Rate?

RESPONSE:

BC Hydro expects BC Ferries will apply for service under both the Overnight Rate and the Demand Transition Rate. BC Sustainable Energy Association Page 1 Information Request No. 1.7.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit C9-1, Seaspan intervention letter

Seaspan’s letter of intervention to this proceeding says in part:

“Our company is investing heavily in hybridization of our vessels and shore power rates are critical to our success and ability to make the largest possible reductions in GHG. … Seaspan Ferries has (2) battery hybrid vessels in operation and are currently not able to charge from shore due to the high cost of electrification. We are building (2) more vessels and would like to work with BC Hydro and the Commission in order to ensure that all (4) vessels can connect to shore power and make the largest possible reduction in GHG.”

1.7.1 Please describe the scope and depth of any recent discussions BC Hydro has had with Seaspan or other coastal fleet operators regarding electrification.

RESPONSE:

BC Hydro has been engaged in discussions with Seaspan regarding vessel fleet electrification since 2018. BC Hydro partnered with Seaspan to conduct a study that explored electrification and battery technology to electrify vessels. Seapsan is exploring the electrification of vessels to make reductions in greenhouse gas emissions.

BC Hydro has also been in discussions with several private fleet vessel operators interested in exploring electrification of vessels. BC Sustainable Energy Association Page 1 Information Request No. 1.7.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit C9-1, Seaspan intervention letter

Seaspan’s letter of intervention to this proceeding says in part:

1.7.2 What is the nature of the hybridization Seaspan mentions?

RESPONSE:

BC Hydro understands that the hybridization referenced in Seaspan’s letter of support include liquefied natural gas and electricity. BC Sustainable Energy Association Page 1 Information Request No. 1.7.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit C9-1, Seaspan intervention letter

Seaspan’s letter of intervention to this proceeding says in part:

1.7.3 Does BC Hydro believe that the Overnight Rate or the Demand Transition Rate might be appropriate to support the needs of Seaspan or other coastal fleet operators?

RESPONSE:

BC Hydro expects the Overnight Rate or the Demand Transition Rate may be appropriate for Seaspan and other coastal fleet operators. As noted on page 25 of the Application, Seaspan suggested that BC Hydro expand the definition of fleets to include marine fleets that may charge from shore side terminals. This suggestion was adopted by BC Hydro. BC Sustainable Energy Association Page 1 Information Request No. 1.7.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit C9-1, Seaspan intervention letter

Seaspan’s letter of intervention to this proceeding says in part:

1.7.4 Is it BC Hydro’s understanding that when Seaspan refers to “shore power” it is not referring to BC Hydro’s Shore Power interruptible rate?

RESPONSE:

It is BC Hydro’s understanding that when Seaspan refers to “shore power” it is not referring to BC Hydro’s existing Shore Power Service schedules (RS 1280 and RS 1891), which are interruptible.

BC Hydro’s recent discussions with Seaspan have focused on non-interruptible service at the shore, such as the proposed Overnight and Demand Transition rate in BC Hydro’s application. BC Sustainable Energy Association Page 1 Information Request No. 1.8.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, page 2

“BC Hydro has been engaging with public transportation providers to understand how BC Hydro can support the reduction of greenhouse gases in British Columbia through the conversion of their fleets from fossil fuels to clean electricity.”

1.8.1 In addition to the public transportation sector, what other potential customers does BC Hydro think there may be for the Overnight Rate and the Demand Transition Rate?

RESPONSE:

As more electric fleet options become commercially available, BC Hydro expects that a wider variety of customers may take service under the Overnight Rate or the Demand Transition Rate.

For example these may include fleet vehicles or vessels owned or leased, and operated, by municipalities, heavy duty truck operators, or courier delivery services. BC Sustainable Energy Association Page 1 Information Request No. 1.8.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 C. Potential Customers

Topic Potential Customers

Reference Exhibit B-1, page 2

1.8.2 Has BC Hydro engaged with anyone in the medium or heavy truck freight industry to identify any plans for electrification of freight trucking? Has BC Hydro examined what optional electric rates might be appropriate for providing charging services for this sector? If so, what conclusions has BC Hydro reached?

RESPONSE:

BC Hydro has engaged with manufacturers of medium and heavy duty electric vehicles to understand their market-readiness, timelines and vehicle types for freight trucking, as well as other medium and heavy duty electric vehicles including school, transit and tour buses.

BC Hydro also responded to the Port of Vancouver’s Clean Trucking Initiative Pilot Program to offer our participation for trials of Class eight electric trucks.

BC Hydro expects that the electrification of bus fleets will precede electrification of heavy duty electric vehicles. BC Sustainable Energy Association Page 1 Information Request No. 1.9.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“Translink will need to replace approximately 860 buses by 2030, of which two-thirds would require in route charging and one-third would require depot charging. By 2040, Translink will be replacing a total of approximately 1,500 buses.” [p.6]

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.1 Please confirm that replacement, in this context, means taking diesel buses out of service and replacing them with fully battery electric buses.

RESPONSE:

BC Transit will be replacing approximately 1200 existing buses due to end of life as well as expanding its fleet by about 350 buses over the next 10 years. As they procure the buses, they will be making fuel source choices based on their operational needs and climate objectives. BC Sustainable Energy Association Page 1 Information Request No. 1.9.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.2 Do Translink or BC Transit intend to deploy new trolley electric buses as well as battery electric buses in the next ten years?

RESPONSE:

BC Hydro notes that the 1,200 existing buses referenced in the preamble to this IR do not include electric trolley buses. BC Hydro understands that no decision has been made regarding any potential change to electric trolley buses. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3 What peak and energy loads does BC Hydro expect to result from serving battery electric buses of Translink and BC Transit in the next three years? Five years?

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.4.1. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3.1 Does BC Hydro’s figure of 100,000 MWh/year by F2029 for overnight charging [p. 27] represent fleet electrification by BC Transit and Translink only, or does it include other customers?

RESPONSE:

BC Hydro has modelled both the proposed Overnight Rate and Demand Transition Rate based on illustrative transit bus fleets with load projections informed by discussions with Translink and BC Transit.

The rate designs were not informed by load characteristics for other customers. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3.1.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3.1 Does BC Hydro’s figure of 100,000 MWh/year by F2029 for overnight charging [p. 27] represent fleet electrification by BC Transit and Translink only, or does it include other customers?

1.9.3.1.1 Is it an estimate or a scenario amount?

RESPONSE:

The charging demand and consumption input assumptions are informed by discussions with our customers. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3.1.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3.1 Does BC Hydro’s figure of 100,000 MWh/year by F2029 for overnight charging [p. 27] represent fleet electrification by BC Transit and Translink only, or does it include other customers?

1.9.3.1.2 Does it represent an upper bound?

RESPONSE:

The figure of 100,000 MWh/year is not an upper bound of the load that may take service under the Overnight Rate. The charging demand and consumption input assumptions were informed by discussions with the customers. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3.2 Does BC Hydro’s figure of 23,000 MWh/year by F2029 for overnight charging [p. 29] represent fleet electrification by BC Transit and Translink only, or does it include other customers?

RESPONSE:

Please refer to BC Hydro’s response to BCSEA IR 1.9.3.1. BC Hydro notes that the 23,000 MWh/year is for in route charging. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3.2.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3.2 Does BC Hydro’s figure of 23,000 MWh/year by F2029 for overnight charging [p. 29] represent fleet electrification by BC Transit and Translink only, or does it include other customers?

1.9.3.2.1 Is it an estimate or a scenario amount?

RESPONSE:

The charging demand and consumption input assumptions were informed by discussions with our customers. Please refer to BC Hydro’s response to BCUC IR 1.11.2. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3.2.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3.2 Does BC Hydro’s figure of 23,000 MWh/year by F2029 for overnight charging [p. 29] represent fleet electrification by BC Transit and Translink only, or does it include other customers?

1.9.3.2.2 Does it represent an upper bound?

RESPONSE:

The figure of 23,000 MWh/year is not an upper bound of the load that may take service under the Demand Transition Rate. The charging demand and consumption input assumptions were informed by discussions with the customers. BC Sustainable Energy Association Page 1 Information Request No. 1.9.3.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.3.3 What GHG emissions reductions does BC Hydro expect to result from electrification of TransLink and BC Transit buses supplied by power under the proposed Overnight Rate and Demand Transition Rate and the associated displacement of fossil fuel use?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.4.1. BC Sustainable Energy Association Page 1 Information Request No. 1.9.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.4 What peak and energy loads would result in the next ten to twenty years if Translink and BC Transit were to fully achieve the bus electrification plans they have outlined to BC Hydro?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.11.2.

The demand and consumption assumptions used for fiscal 2030 and beyond for the Overnight Rate and Demand Transition Rate are shown in the tables below. This data was used in the analysis for Appendix E of the Application.

Fiscal Year Depot Charging Demand (MW) Depot Charging Energy (GWh) 2030+ 108.87 129.9

Fiscal Year In Route Charging Demand (MW) In Route Charging Energy (GWh) 2030+ 12.1 55.0

BC Sustainable Energy Association Page 1 Information Request No. 1.9.4.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

BC Hydro says:

“BC Transit has a 10-year fleet replacement strategy to replace approximately 1,200 existing buses and expand the fleet by about 350 buses by 2030 with battery electric buses.” [p. 7]

1.9.4 What peak and energy loads would result in the next ten to twenty years if Translink and BC Transit were to fully achieve the bus electrification plans they have outlined to BC Hydro?

1.9.4.1 What GHG emissions reductions would result?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.4.1. BC Sustainable Energy Association Page 1 Information Request No. 1.9.5 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

On page 29, BC Hydro says that transit bus fleet conversion is expected to be substantially complete by no earlier than F2029.

1.9.5 What is the basis of BC Hydro’s statement that transit bus fleet conversion is not expected to be substantially complete before F2029? Is BC Hydro confident that there will be substantial amounts of transit bus fleet conversions within the next ten years?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.11.2. BC Sustainable Energy Association Page 1 Information Request No. 1.9.6 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

On page 29, BC Hydro says that transit bus fleet conversion is expected to be substantially complete by no earlier than F2029.

1.9.6 Has BC Hydro included battery electric bus loads in its most recent load forecast?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.11.2.1 where we explain that these load estimates are not currently captured in our load forecast. BC Sustainable Energy Association Page 1 Information Request No. 1.9.7 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

On page 29, BC Hydro says that transit bus fleet conversion is expected to be substantially complete by no earlier than F2029.

1.9.7 Does BC Hydro expect any additional loads in the next two to five years from serving non-bus electric vehicles under the proposed Overnight and Demand Transition rates?

RESPONSE:

BC Hydro anticipates additional non-bus electric fleet vehicles may take service under the Overnight and/or Demand Transition Rates over the next two to five years. Having optional rates to meet charging needs should help customers have better cost certainty with respect to charging costs and the continued development of new electric fleet vehicle types should also support conversion to electric fleet vehicles and vessels. BC Sustainable Energy Association Page 1 Information Request No. 1.9.8 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

On page 29, BC Hydro says that transit bus fleet conversion is expected to be substantially complete by no earlier than F2029.

1.9.8 What system reinforcement requirements, if any, has BC Hydro identified as being potentially necessary as a result of uptake of the Overnight and Demand Transition Rates in the next five years? Ten years?

RESPONSE:

System reinforcement requirements for customers under the Overnight and Demand Transition Rates will be dependent on the specific location of the proposed connection and the available system capacity at that location. Such reinforcements will be specific to each customer application. Examples of system reinforcements could include reconductoring, circuit reconfiguration, line extension, or bringing out a new feeder circuit. If the substation is also constrained, upgrades to the substation may be necessary.

The costs associated with system reinforcements will be allocated in accordance with BC Hydro’s Electric Tariff. BC Sustainable Energy Association Page 1 Information Request No. 1.9.9 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 D. Potential New Loads

Topic Potential New Loads

Reference Application, Exhibit B-1, section 1.2.2, pp. 6 & 7; section 3.1, page 27; section 3.2, p. 29

On page 29, BC Hydro says that transit bus fleet conversion is expected to be substantially complete by no earlier than F2029.

1.9.9 Does BC Hydro generally expect that a shift from diesel to electric buses has the potential to cause substantial additional system costs in the medium to long term?

RESPONSE:

Regarding additional system costs for the Overnight Rate, please refer to BC Hydro’s response to BCUC IRs 1.17.4 and 1.17.10.

Regarding additional system costs for the Demand Transition Rate, BC Hydro has included the system average non-bulk transmission and distribution capacity costs in the analysis in Appendix E of the Application. In the event the request triggers an extension please refer to the discussion in BCUC IR 1.12.3. BC Sustainable Energy Association Page 1 Information Request No. 1.10.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 D. Potential New Loads

Topic Potential New Loads – Demand Transition Rate

Reference Application, Exhibit B-1, section 5.2 Demand Transition Rate Cost of Service Justification, Table 6, page 45

1.10.1 Are the load factor and peak energy demand entirely an outcome of the number of vehicles in service, or does the customer have some operational control over these?

RESPONSE:

The customer may have some control over the load factor and peak energy demand. For example the sizing of the charger will dictate how quickly a vehicle can charge. This will dictate how large the peak demand is and could influence how often a vehicle needs to charge which could have some impact on load factor. BC Sustainable Energy Association Page 1 Information Request No. 1.10.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 D. Potential New Loads

Topic Potential New Loads – Demand Transition Rate

Reference Application, Exhibit B-1, section 5.2 Demand Transition Rate Cost of Service Justification, Table 6, page 45

1.10.2 If the customer does have some operational control over the load factor and peak energy demand, could the terms of the Demand Transition Rate be modified to encourage the customer to operate its fleet so as to optimize the economic and cost of service benefits for ratepayers?

RESPONSE:

Including terms within the Demand Transition Rate that would require customers to operate its fleet so as to optimize the economic and cost of service benefits for ratepayers would add significant complexity to the customers operations of their fleets. Adding such terms could act as an impediment to conversion of their fleets to electricity from fossil fuels. From a BC Hydro perspective it would require greater administration to enforce such terms. BC Sustainable Energy Association Page 1 Information Request No. 1.11.1 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 E. Economic Justification

Topic Economic Justification

Reference Application, Exhibit B-1, section 1.2 Need for the Optional Rates, p. 2; section 4.1 Overnight Rate Terms and Conditions, p. 33; section 5.1 Demand Transition Rate Terms and Conditions, p. 43; Appendix E Ratepayer Economic Analysis, p. 1 (pdf p. 83)

BC Hydro makes a point of stating that “Electric fleet charging as described in this Application does not currently exist in BC Hydro’s service territory.” BC Hydro adds, “While there are BC Hydro customers who are using electric vehicles in their fleets, their charging needs have been below 150 kW.” [p.2, underline added]

Similarly, in explaining the proposed Overnight Rate terms and conditions, and by reference the proposed Demand Transition Rate terms and conditions that are the same, BC Hydro states:

1.11.1 Is one of the reasons for the emphasis on the proposed optional rates being aimed exclusively at types of Fleet EV charging that do not yet exist in the Province that electricity consumed by these Fleet EV charging facilities would be new load, and new load that would not materialize as soon or at all in the absence of the proposed optional rates?

RESPONSE:

The pricing, terms and conditions of the proposed rates have been designed to remove barriers to fleet electrification while also providing ratepayer benefits.

Ratepayer benefits for both the Demand Transition Rate and the Overnight Rate rely on them serving new load only. If existing load, currently taking service under the Large General Service Rate, migrates to either the Overnight Rate or Demand BC Sustainable Energy Association Page 2 Information Request No. 1.11.1 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Transition Rate and pays lower electricity bills as a result, then the loss of revenue to BC Hydro will result in ratepayers being worse off.

As described in the Application, fleet customers have indicated that the existing Large General Service Rate is a barrier to electrification. The proposed Overnight and Demand Transition Rates are expected to address this barrier.

Please also refer to BC Hydro’s response to BCOAPO IRs 1.1.1. and 1.1.2. BC Sustainable Energy Association Page 1 Information Request No. 1.11.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 E. Economic Justification

Topic Economic Justification

Similarly, in explaining the proposed Overnight Rate terms and conditions, and by reference the proposed Demand Transition Rate terms and conditions that are the same, BC Hydro states:

1.11.2 Please confirm that BC Hydro being long on energy and peak capacity is a key factor in the new load induced by the proposed Overnight Rate and the Demand Transition Rate being “justified on an economic basis.”

RESPONSE:

Please refer to BC Hydro’s response to AMPC IR 1.3.1 BC Sustainable Energy Association Page 1 Information Request No. 1.11.3 Dated: October 7, 2019 of 4 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 E. Economic Justification

Topic Economic Justification

Similarly, in explaining the proposed Overnight Rate terms and conditions, and by reference the proposed Demand Transition Rate terms and conditions that are the same, BC Hydro states:

1.11.3 Please file Table D-3, Planning View of the Energy Load Resource Balance after Planned Resources, and Table D-4, Peak Capacity Load Resource Balance After Planned Resources, contained in Appendix D of October 3, 2019 BC Hydro’s Twenty-Year Load Forecast filed as Exhibit B-15 in the Commission’s proceeding regarding BC Hydro’s F2020-F2021 Revenue Requirements Application.

RESPONSE:

The tables below show Tables D-3, Planning View of the Energy Load Resource Balance after Planned Resources, and Table D-4, Peak Capacity Load Resource Balance after Planned Resources, contained in Appendix D of the October 3, 2019 Evidentiary Update to the Fiscal 2020 – Fiscal 2021 Revenue Requirements Application. BC Hydro notes that in the tables filed in Appendix D of October 3, 2019 lines 11 and 12 in the energy LRB and lines 12 and 13 in the BC Sustainable Energy Association Page 2 Information Request No. 1.11.3 Dated: October 7, 2019 of 4 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

capacity LRB were mislabeled. This has been corrected for the tables presented below.

For the energy and capacity load resource balances that include the load anticipated for the Fleet Electrification Rate Application, please refer to BC Hydro’s response to BCUC IR 1.11.1.

BC Sustainable Energy Association Page 3 Information Request No. 1.11.3 Dated: October 7, 2019 of 4 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Table D-3 Planning view of the energy load resource balance after planned resources

(GWh) F2021 F2022 F2023 F2024 F2025 F2026 F2027 F2028 F2029 F2030 F2031 F2032 F2033 F2034 F2035 F2036 F2037 F2038 F2039 1 Existing and Committed Heritage Resources (incl. Site C) (a) 46,916 46,916 46,916 47,282 50,808 52,202 52,202 52,202 52,202 52,202 52,202 52,202 52,202 52,202 52,202 52,202 52,202 52,202 52,202

2 Existing and Committed IPP Resources (b) 16,359 16,227 14,193 13,783 13,505 13,224 13,115 13,008 12,542 11,770 11,228 10,880 10,671 10,366 9,664 8,136 7,684 7,511 7,180

Future Supply-Side Resources 3 IPP Renewals 1,058 1,280 3,270 3,628 3,845 4,124 4,208 4,291 4,660 5,154 5,624 5,826 5,951 6,188 6,832 8,123 8,550 8,723 9,048 4 Expected SOP Projects and other First Nations Commitments 27 182 226 226 226 226 226 226 226 226 226 226 226 226 226 226 226 226 226 5 Rev 6 ------11 26 26 26 6 Sub-total (c) 1,085 1,462 3,496 3,854 4,071 4,350 4,434 4,517 4,886 5,380 5,850 6,052 6,177 6,414 7,058 8,360 8,802 8,975 9,300

7 Total Supply (Planning View) (d) = a + b + c 64,360 64,604 64,606 64,919 68,384 69,775 69,750 69,727 69,630 69,353 69,280 69,134 69,050 68,982 68,924 68,698 68,688 68,688 68,681

Demand - Integrated System Total Gross Requirements 8 June 2019 Mid Load Forecast Before DSM (e) (60,738) (60,688) (61,759) (63,383) (64,993) (66,144) (67,358) (68,011) (68,741) (69,291) (69,913) (70,537) (71,244) (71,932) (72,645) (73,350) (74,097) (74,827) (75,551)

Existing and Committed Demand Side Management & Others Measures 9 F19 DSM Portfolio Savings (F20-F21 RRA) 695 686 679 676 665 657 654 650 638 622 613 593 572 505 434 420 411 406 401 10 F20+ Codes & Standards (F20-F21 RRA) plus Voltage and VAR Optimization 615 964 1,235 1,482 1,713 1,920 2,108 2,271 2,427 2,584 2,726 2,856 2,982 3,110 3,239 3,367 3,494 3,622 3,750 Planned Demand Side Management Measures 11 F20+ Programs (F20-F21 RRA) 381 569 698 832 954 1,070 1,188 1,298 1,398 1,493 1,512 1,517 1,562 1,592 1,619 1,631 1,630 1,624 1,615 12 F20+ Rates (F20-F21 RRA) 128 144 149 145 142 140 139 138 137 137 137 137 136 136 136 136 135 135 135 13 Sub-total (f) 1,819 2,363 2,760 3,135 3,474 3,788 4,088 4,357 4,600 4,835 4,988 5,102 5,253 5,344 5,428 5,554 5,672 5,787 5,901

14 Surplus / (Deficit) (g) = d + e + f 5,441 6,280 5,607 4,671 6,864 7,419 6,480 6,072 5,489 4,897 4,355 3,700 3,059 2,395 1,707 902 263 (351) (969) 15 Surplus / Deficit as % of Net Load 109% 111% 110% 108% 111% 112% 110% 110% 109% 108% 107% 106% 105% 104% 103% 101% 100% 99% 99%

16 Small Gap Surplus / (Deficit) 7,272 8,448 8,224 7,746 10,128 10,864 10,345 10,156 10,240 10,070 9,760 9,275 8,737 8,188 7,640 6,871 6,248 5,671 5,029

17 Large Gap Surplus / (Deficit) 3,215 3,580 2,332 848 2,789 3,094 1,685 990 (347) (1,432) (2,226) (3,129) (3,880) (4,708) (5,538) (6,412) (7,114) (7,754) (8,412) BC Sustainable Energy Association Page 4 Information Request No. 1.11.3 Dated: October 7, 2019 of 4 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Table D-4 Peak capacity load resource balance after planned resources

(MW) F2021 F2022 F2023 F2024 F2025 F2026 F2027 F2028 F2029 F2030 F2031 F2032 F2033 F2034 F2035 F2036 F2037 F2038 F2039 Existing and Committed Heritage Resources 1 Heritage Hydroelectric (a) 11,588 11,588 11,528 11,588 12,319 12,319 12,676 12,676 12,676 12,676 12,676 12,262 12,262 12,733 12,733 12,733 12,733 12,733 12,733

2 Existing and Committed IPP Resources (b) 1,458 1,486 1,211 1,200 1,138 1,106 1,106 1,093 1,056 924 888 884 861 810 566 493 458 424 423

Future Supply-Side Resources 3 IPP Renewals 117 132 407 416 425 454 454 465 488 621 639 642 656 693 938 979 1,014 1,048 1,048 4 Expected SOP Projects and other First Nations Commitments 3 17 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 5 REV 6 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 488 488 488 488 6 Sub-total (c) 120 148 426 435 444 473 473 484 507 639 658 661 675 712 957 1,486 1,521 1,555 1,555

7 14% of Supply Requiring Reserves - excl. Rio Tinto Alcan and FortisBC (d) (1,813) (1,813) (1,805) (1,813) (1,915) (1,915) (1,965) (1,965) (1,963) (1,963) (1,960) (1,902) (1,901) (1,965) (1,965) (2,029) (2,029) (2,029) (2,029)

8 Effective Load Carrying Capability (e) = a+b+c+d 11,352 11,409 11,359 11,409 11,986 11,984 12,291 12,288 12,277 12,277 12,261 11,905 11,897 12,291 12,291 12,683 12,683 12,683 12,683

Demand - Integrated System Peak 9 June 2019 Mid Load Forecast Before DSM (f) (10,870) (10,887) (11,054) (11,264) (11,463) (11,579) (11,768) (11,906) (12,059) (12,189) (12,343) (12,508) (12,689) (12,881) (13,085) (13,296) (13,517) (13,743) (13,974)

Existing and Committed Demand Side Management & Others Measures 10 F19 DSM Portfolio Savings (F20-F21 RRA) 128 126 124 123 120 117 116 114 111 108 106 103 99 92 84 82 80 80 78 11 F20+ Codes & Standards (F20-F21 RRA) plus Voltage and VAR Optimization 129 198 246 289 327 361 391 417 441 465 486 505 523 546 569 592 615 638 662 Planned Demand Side Management Measures 12 F20+ Programs (F20-F21 RRA) 57 87 108 129 148 166 183 199 213 226 230 232 238 244 250 254 256 257 257 13 F20+ Rates (F20-F21 RRA) 15 17 17 17 16 16 15 15 15 15 15 14 14 14 14 14 14 14 14 14 Sub-total (g) 330 427 496 557 611 660 705 745 781 813 836 854 874 896 918 942 966 989 1,011

15 Surplus / (Deficit)** (h) = e + f + g 812 949 801 703 1,135 1,065 1,228 1,127 999 901 754 250 81 306 123 329 131 (71) (281) 16 Surplus / Deficit as % of Net Load ** 108% 109% 108% 107% 110% 110% 111% 110% 109% 108% 107% 102% 101% 103% 101% 103% 101% 99% 98%

17 Small Gap Surplus / (Deficit)** 1,229 1,370 1,312 1,314 1,814 1,786 2,044 2,015 2,042 2,064 2,013 1,602 1,524 1,848 1,776 2,083 1,989 1,900 1,798 18 Large Gap Surplus / (Deficit)** 499 483 233 45 436 295 341 157 (144) (378) (621) (1,223) (1,465) (1,327) (1,594) (1,459) (1,724) (1,984) (2,251) BC Sustainable Energy Association Page 1 Information Request No. 1.11.4 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 E. Economic Justification

Topic Economic Justification

In Appendix E (p. 1, .pdf p. 83), BCH states:

“BC Hydro’s energy load resource balance shows we will not need to acquire new energy resources for many years to come. When our power system is in a state of energy surplus (energy supply is greater than demand), energy marginal cost is market price.”

1.11.4 Do other rates, such as BC Hydro’s Freshet Rate (RS 1892) compete with the Overnight and Demand Transition Rates for their economic assessment to benefit from a marginal rate analysis based on market values, rather than the cost of acquiring new energy and capacity?

RESPONSE:

Each rate proposed by BC Hydro is assessed on its own merits, for customer benefits and ratepayer impacts. BC Sustainable Energy Association Page 1 Information Request No. 1.12.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 E. Economic Justification

Topic Economic Justification – Demand Transition Rate

Reference Application, Exhibit B-1, p.13

BC Hydro says:

“As noted, stakeholder feedback with regard to this Application indicated a desire to expand the availability of the proposed services, and rates, to customers that provide charging services to third-parties. In BC Hydro's view expanding the availability of the proposed services to that customer segment would materially reduce the likelihood that ratepayers would benefit from them and thus undermine their lawfulness.” [underline added]

1.12.1 Please explain why making the proposed Overnight Rate and Demand Transition Rate available to otherwise qualifying customers who provide EV charging services to third parties would reduce the economic or cost of service benefits of the proposed optional rates. Is there a concern that such customers would not be providing new load?

RESPONSE:

Yes, there is a concern that such customers would not be providing new load. Please refer to BC Hydro’s response to BCUC IR 1.2.3. BC Sustainable Energy Association Page 1 Information Request No. 1.13.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

13.0 E. Economic Justification

Topic Economic Justification – Demand Transition Rate

Reference Application, Exhibit B-1, 5.2 Demand Transition Rate Cost of Service Justification; 5.3 Demand Transition Rate Economic Justification

BC Hydro says:

“The Demand Transition Rate is justified on an economic basis. BC Hydro estimates under the base case reported below that the incremental revenues received from new load served under the Demand Transition Rate will exceed the marginal cost of serving new load in the ten and fifteen year time periods. Therefore, ratepayers benefit from the new load in the medium and longer term, even if that new load is at a lower rate than existing load for a period of time.” [underline added]

1.13.1 Please provide a definition of “justified on an economic basis” compared to “justified on a cost of service basis.”

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.16.1. BC Sustainable Energy Association Page 1 Information Request No. 1.13.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

13.0 E. Economic Justification

Topic Economic Justification – Demand Transition Rate

Reference Application, Exhibit B-1, 5.2 Demand Transition Rate Cost of Service Justification; 5.3 Demand Transition Rate Economic Justification

BC Hydro says:

1.13.2 Please clarify the paragraph quoted in the preamble. What is the relevance of the “incremental revenues received from new load served under the Demand Transition Rate … exceed[ing] the marginal cost of serving new load in the ten and fifteen year time periods”? In Year 12 the Demand Transition Rate will be the same as the default LGS rate. Why is Year 12 (or Year 13) not the time when economic benefit to other ratepayers is confirmed?

RESPONSE:

BC Hydro chose the 5, 10 and 15 years to report the Ratepayer Benefit Cost Ratio results in Appendix E to be consistent across all analysis cases and scenarios. BC Hydro agrees that there would be economic benefit to other ratepayers if 12 years was used as the period for analysis, and which is the year that the Demand Transition Rate will be the same as the default Large General Service Rate. BC Sustainable Energy Association Page 1 Information Request No. 1.14.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

14.0 E. Terms and Conditions

Topic Terms and Conditions – Demand Transition Rate

Reference Application, Exhibit B-1, 5.1 Demand Transition Rate Terms and Conditions

1.14.1 For greater certainty, please confirm that the proposed Demand Transition Rate has the same terms and conditions, year by year from Year 1 to Year 12, for each participating customer regardless of the year in which the customer adopted the Transition Rate.

RESPONSE:

BC Hydro confirms that the proposed rates and the terms and conditions of the Demand Transition Rate are not customer specific. The same rates and the terms and conditions apply to each participating customer in a given year, irrespective of when the customer commenced taking service. BC Sustainable Energy Association Page 1 Information Request No. 1.15.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

15.0 E. Terms and Conditions

Topic Terms and Conditions – Migration

Reference Application, Exhibit B-1, section 4.1, pp. 33 & 34, section 5.1, pp. 43 & 44.

1.15.1 Could participation in the Overnight Rate or Demand Transition Rate increase the likelihood of a customer meeting the conditions to be moved to the MGS rate?

RESPONSE:

Customers’ maximum demand will have to meet the 150 kW threshold to be eligible for the Overnight and Demand Transition Rates. Participating in the Overnight and Demand Transition Rates will not increase the likelihood of a customer meeting the conditions to be moved to the Medium General Service Rate. BC Sustainable Energy Association Page 1 Information Request No. 1.16.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

16.0 F. Other Issues

Topic Jurisdictional Review

Reference Exhibit B-1, section 2.2 Jurisdictional Review, pp. 17 – 23; Appendix H, Jurisdictional Review – Additional Information

1.16.1 Is there an increasing trend in the number of rates designed for charging fleet EVs in jurisdictions in the US and Canada? Is there an increasing trend in the quantity of electricity delivered under rates designed for charging fleet EVs?

RESPONSE:

Confirmed, based on BC Hydro’s jurisdictional review there appears to be an increasing trend for utilities to provide rates designed for charging EV fleets, particularly in jurisdictions in the U.S.

Given the increased number of rates designed for charging fleet EVs in U.S. jurisdictions and given the availability and declining cost of EV technology, there is an increasing trend in the quantity of electricity delivered under these rates. BC Sustainable Energy Association Page 1 Information Request No. 1.16.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

16.0 F. Other Issues

Topic Jurisdictional Review

Reference Exhibit B-1, section 2.2 Jurisdictional Review, pp. 17 – 23; Appendix H, Jurisdictional Review – Additional Information

1.16.2 For how long have the jurisdictions that BC Hydro reviewed had rates for electric fleet charging? Are any evaluation reports available from these jurisdictions? If so, please provide them.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.8.2 which shows the effective date for rates for electric fleet charging that BC Hydro reviewed.

BC Hydro is not aware of any evaluation reports available from these jurisdictions regarding these rates for electric fleet charging. BC Sustainable Energy Association Page 1 Information Request No. 1.17.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

17.0 F. Other Issues

Topic Ownership of Charging Infrastructure

Reference Application, Exhibit B-1

1.17.1 Please confirm that the customer would be responsible to procure, install and maintain all the electric vehicle charging equipment for the Overnight Rate and the Demand Transition Rate.

RESPONSE:

Confirmed. BC Sustainable Energy Association Page 1 Information Request No. 1.18.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

18.0 F. Other Issues

Topic Monitoring and Reporting

Reference Application, Exhibit B-1, section 7, pp. 52 & 53

1.18.1 Why did BC Hydro select three years as the term for an evaluation report?

RESPONSE:

Three years was selected as an appropriate trade-off between:

• Improvement in the reliability and depth of the evaluation findings that arise from a longer data collection period; and

• Timely risk and performance management. BC Sustainable Energy Association Page 1 Information Request No. 1.18.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

18.0 F. Other Issues

Topic Monitoring and Reporting

Reference Application, Exhibit B-1, section 7, pp. 52 & 53

1.18.2 Would BC Hydro agree that it would be appropriate also to evaluate the Demand Transition charge after the end of the six-year phase-in of the LGS demand charge (i.e., Year 12)?

RESPONSE:

BC Hydro will recommend whether additional evaluations should be conducted based on the outcomes of the year three evaluations. BC Sustainable Energy Association Page 1 Information Request No. 1.19.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

19.0 F. Other Issues

Topic Duration of the Overnight and Demand Transition Rates

Reference Application, Exhibit B-1

1.19.1 Has BC Hydro had any indication from potential customers that the proposed Overnight and Demand Transition Rates would need to be in effect for a minimum period in order to justify a customer making investments and applying to participate in the rate?

RESPONSE:

In discussions with BC Transit and Translink, BC Hydro understands that the life of an electric bus is approximately fifteen years. Customers will also be making significant investments in charging infrastructure.

As such, rate certainty was a key consideration when determining whether the rates should be pilots or permanent rates. Given the customer need for cost certainty and the significant capital investment, BC Hydro believes rates offered on a pilot basis would not be appropriate.

BC Hydro notes that the Demand Transition Rate ends in fiscal 2032. BC Sustainable Energy Association Page 1 Information Request No. 1.20.1 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

20.0 F. Other Issues

Topic Technological Maturity

Reference Application, Exhibit B-1

1.20.1 Please discuss the level of maturity of (a) the EV fast charging technology that would be supplied under the Overnight and Demand Transition Rates, and (b) the technology of the EVs that would be charged.

RESPONSE:

BC Hydro will not be supplying any charging or EV technology under the Demand Transition or Overnight Rates. The technology will be the choice and responsibility of the customer. BC Sustainable Energy Association Page 1 Information Request No. 1.20.2 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

20.0 F. Other Issues

Topic Technological Maturity

Reference Application, Exhibit B-1

1.20.2 Do issues of technological maturity or interoperability provide a source of significant uncertainty for customer uptake of the Overnight and Demand Transition Rates?

RESPONSE:

Technological maturity may be a source of uncertainty for customers making a decision to electrify their fleets. However, battery electric buses and other electric vehicles have been used around the world to varying degrees for a number of years. BC Hydro expects that customers may initiate trials to test electric vehicles and charging infrastructure to determine whether they meet their operational needs. BC Sustainable Energy Association Page 1 Information Request No. 1.20.3 Dated: October 7, 2019 of 1 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

20.0 F. Other Issues

Topic Technological Maturity

Reference Application, Exhibit B-1

1.20.3 How confident is BC Hydro that the capacities of chargers assumed in the Application will be adequate for the needs of customers who subscribe to the Overnight and Demand Transition Rates in the medium to long term?

RESPONSE:

The selection, purchase and operation of fleet chargers are the responsibility of customers and not BC Hydro. BC Hydro is confident that customers are undertaking the required analysis and trials where necessary to ensure that their purchase decisions reflect their needs. BC Hydro believes that the fleet charger capacity assumptions used in the Application are reflective of the customers expected charging requirements given the assumptions were informed through discussions with potential customers. Clean Energy Association of B.C. Page 1 Information Request No. 1.1.1 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, Application, Appendix E, and F20-21 RRA Exhibit B-6, response to CEABC IR 1.16.1 and 1.16.2.

In its response to CEABC IR 1.16.1 (F20-21 RRA Exhibit B-6), BC Hydro provided the following table, as an expanded version of Table A-7 from its RRA. This expanded version shows the RIM Benefit/Cost Ratios for BC Hydro’s various DSM Programs and Rate Structures. The RIM B/C Ratios are calculated using two alternative avoided costs, namely $105/MWh and $30/MWh, described as the “Market Price”.

In Appendix E (Exhibit B-1 of this Application), BC Hydro provides the following tables, showing the Ratepayer Benefit Cost Ratios (highlighted) for its two proposed new rates (“Fleet Electrification Rates”), namely the Overnight Rate, as shown in Table 4: Clean Energy Association of B.C. Page 2 Information Request No. 1.1.1 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

And the Demand Transition Rate, as shown in Table 7:

1.1.1 Please confirm that the RIM Benefit/Cost Ratio used to measure DSM Programs, as shown in Table A-7 above, is essentially the same in concept and intent as the Ratepayer Benefit Cost Ratios used to measure the proposed Fleet Electrification Rates, as shown in Tables 4 and 7. Will these two B/C Ratio measures give roughly the same calculation values, given the same assumptions? In what ways do they differ, broadly speaking?

RESPONSE:

The ratepayer impact measure test used for demand-side management initiatives is similar to the economic assessment of ratepayer benefits for the fleet electrification rates to the extent that both provide an indication of directional impacts on rates.

The nature of the initiatives is different and therefore the resulting values will differ. Demand-side management promotes conservation while the proposed rates incent additional load from the electrification of fleets, so their impact on consumption, and therefore revenues, will be different.

Please see Appendix E of the Application for additional discussion of the ratepayer economic assessment used in the Application. Clean Energy Association of B.C. Page 1 Information Request No. 1.1.2 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, Application, Appendix E, and F20-21 RRA Exhibit B-6, response to CEABC IR 1.16.1 and 1.16.2.

In Appendix E (Exhibit B-1 of this Application), BC Hydro provides the following tables, showing the Ratepayer Benefit Cost Ratios (highlighted) for its two proposed new rates (“Fleet Electrification Rates”), namely the Overnight Rate, as shown in Table 4: Clean Energy Association of B.C. Page 2 Information Request No. 1.1.2 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

And the Demand Transition Rate, as shown in Table 7:

1.1.2 Is the $30/MWh “Market Price” assumption used in Table A-7, roughly equivalent to the Energy avoided cost used to calculate the Benefits for Tables 4 and 7? What, if any, are the differences between them? What amounts for losses and wheeling charges have been added or deducted from these two avoided cost assumptions, respectively?

RESPONSE:

The market price used for demand-side management in the Fiscal 2020 - Fiscal 2021 Revenue Requirements Application (Appendix X, Appendix B) is the same as the Mid-C market price forecast used to estimate the marginal energy cost in the Fleet Electrification Rate Application.

The losses and wheeling charges assumed for demand-side management in the Fiscal 2020 - Fiscal 2021 Revenue Requirements Application (Appendix X, Appendix B) are the same as those used in the Fleet Electrification Rate Application. Please see page 5 of Appendix E for discussion of losses assumed for the Fleet Rate Application economic assessment of ratepayer benefits. Clean Energy Association of B.C. Page 1 Information Request No. 1.1.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, Application, Appendix E, and F20-21 RRA Exhibit B-6, response to CEABC IR 1.16.1 and 1.16.2.

In Appendix E (Exhibit B-1 of this Application), BC Hydro provides the following tables, showing the Ratepayer Benefit Cost Ratios (highlighted) for its two proposed new rates (“Fleet Electrification Rates”), namely the Overnight Rate, as shown in Table 4: Clean Energy Association of B.C. Page 2 Information Request No. 1.1.3 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

And the Demand Transition Rate, as shown in Table 7:

1.1.3 Appendix E of the Application gives an extensive listing of the assumptions used in the Ratepayer Benefit Cost Ratio calculations (Table 2, “Summary of BC Hydro’s Marginal Costs”, on Page 4 of 8, and “Additional Assumptions” on Page 5 of 8). Please provide a table comparing these assumptions to the assumptions that were used for the RIM B/C Ratio calculations for the DSM Programs shown in Table A-7

RESPONSE:

Please refer to Appendix X, Appendix B of the Fiscal 2020 to Fiscal 2021 Revenue Requirements Application for assumptions related to demand-side management economic tests. Please refer to Appendix E of the Application for the assumptions related to marginal cost for the fleet charging rates. Clean Energy Association of B.C. Page 1 Information Request No. 1.1.4 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, Application, Appendix E, and F20-21 RRA Exhibit B-6, response to CEABC IR 1.16.1 and 1.16.2.

In Appendix E (Exhibit B-1 of this Application), BC Hydro provides the following tables, showing the Ratepayer Benefit Cost Ratios (highlighted) for its two proposed new rates (“Fleet Electrification Rates”), namely the Overnight Rate, as shown in Table 4: Clean Energy Association of B.C. Page 2 Information Request No. 1.1.4 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

And the Demand Transition Rate, as shown in Table 7:

1.1.4 In its response to CEABC IR 1.16.2 (F20-21 RRA Exhibit B-6), BC Hydro provided its calculation models for the Financial Tables used to evaluate its DSM Programs, including the augmented Table A-7 shown above. Please provide those models again as part of the evidentiary record in this Proceeding.

RESPONSE:

BC Hydro respectfully submits that demand-side management expenditures and economic tests are outside the scope of the Fleet Electrification Rate Application, but are within the scope of BC Hydro’s Fiscal 2020 - Fiscal 2021 Revenue Requirements Application proceeding currently underway. Clean Energy Association of B.C. Page 1 Information Request No. 1.1.5 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, Application, Appendix E, and F20-21 RRA Exhibit B-6, response to CEABC IR 1.16.1 and 1.16.2.

In Appendix E (Exhibit B-1 of this Application), BC Hydro provides the following tables, showing the Ratepayer Benefit Cost Ratios (highlighted) for its two proposed new rates (“Fleet Electrification Rates”), namely the Overnight Rate, as shown in Table 4: Clean Energy Association of B.C. Page 2 Information Request No. 1.1.5 Dated: October 7, 2019 of 2 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

And the Demand Transition Rate, as shown in Table 7:

1.1.5 Why is BC Hydro requiring a B/C Ratio of 1.16 to 1.42 from its proposed Fleet Electrification Rates, when RIM Ratios of 0.4 to 0.5 appear to be acceptable for DSM Programs and Rate Structures, on a roughly equivalent avoided cost basis?

RESPONSE:

BC Hydro is not requiring a benefit cost ratio of 1.16 to 1.42 for our proposed fleet electrification rates. Rather, these are the results of the analyses in the Application.

The legal and regulatory context for the Fleet Electrification Rates is described in section 1.5 of the Application.

The legal and regulatory context for BC Hydro’s demand-side management initiatives is described in BC Hydro’s Fiscal 2020 – Fiscal 2021 Revenue Requirements Application and is the subject of that proceeding which is currently underway. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.1.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, page 2

1.1.1 Does BC Hydro have evidence as to the levels of greenhouse gas emissions that are accounted for by fleets or other sectors of road transportation?

RESPONSE:

BC Hydro does not have breakdown by sector for greenhouse gas emissions.

Please refer to BC Hydro’s response to BCUC IR 1.4.1 for discussion of greenhouse gas emission reduction targets shared with BC Hydro by BC Transit and Translink. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.1.1.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, page 2

1.1.1 Does BC Hydro have evidence as to the levels of greenhouse gas emissions that are accounted for by fleets or other sectors of road transportation?

1.1.1.1 If yes, please provide a breakdown of the greenhouse gas emissions caused by fleets versus other sectors such as individual non-commercial transportation, commercial transportation non-fleet etc.

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.1.1. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.1.1.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, page 2

1.1.1 Does BC Hydro have evidence as to the levels of greenhouse gas emissions that are accounted for by fleets or other sectors of road transportation?

1.1.1.2 Please identify and place on the record any evidence that BC Hydro has regarding the breakdown in segments for greenhouse gas emissions within road transportation.

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.1.1. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.1.1.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.0 Reference: Exhibit B-1, page 2

1.1.1 Does BC Hydro have evidence as to the levels of greenhouse gas emissions that are accounted for by fleets or other sectors of road transportation?

1.1.1.3 Please provide an estimate, by year, of the expected GHG savings from each proposed rate. Please provide all assumptions including how BC Hydro identified the ‘incremental’ GHG saving vs electrification that would have occurred regardless.

RESPONSE:

BC Hydro does not have greenhouse gas saving estimates related to each of the proposed rates given the uncertainty around future participation. However, Translink and BC Transit have provided their greenhouse gas reduction targets as discussed in BC Hydro’s response to BCUC IR 1.4.1.

BC Hydro’s response to BCOAPO IR 1.1.1 discusses the customers’ identification of existing rates as a barrier to achieving fleet electrification and associated greenhouse gas emission reductions. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.2.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Reference: Exhibit B-1, pages 2 and 3

1.2.1 Please confirm that BC Hydro is not proposing to limit the fleet electrification rate(s) to TransLink and BC Transit.

RESPONSE:

Confirmed. The fleet electrification rates will be available to customers who meet the availability criteria. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.2.1.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Reference: Exhibit B-1, pages 2 and 3

1.2.1 Please confirm that BC Hydro is not proposing to limit the fleet electrification rate(s) to TransLink and BC Transit.

1.2.1.1 If yes, please explain why.

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.2.1. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.2.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

2.0 Reference: Exhibit B-1, pages 2 and 3

1.2.2 Please provide a breakdown of BC Hydro’s other potential customers for each proposed rate.

RESPONSE:

Please refer to BC Hydro’s response to BCSEA IR 1.8.1. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.3.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 Reference: Exhibit B-1, page 5

Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.3.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.3.1 Please explain why BC Hydro utilized 9 buses for its Full Deployment illustrative load profile, and provide evidence to support the use of this figure.

RESPONSE:

The assumed number of buses is illustrative for a single in route charging account and is informed by discussions with our customers. As noted in section 7 of the Application BC Hydro will monitor the number of fleet charging operations and new load annually. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.3.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

3.0 Reference: Exhibit B-1, page 5

Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.3.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.3.2 Please provide the total range that could count as ‘Full Deployment’ for the number of buses and load factors.

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.3.1. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.4.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

4.0 Reference: Exhibit B-1, pages 6 and 7

1.4.1 Please provide a quantified summary of the capacity and energy impacts to BC Hydro from each rate over 10 years. Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.4.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

RESPONSE:

The demand and consumption assumptions for the 10 years effective Overnight Rate and Demand Transition Rate are shown in the tables below. They are informed by discussions with our customers.

Fiscal Year Depot Charging Demand (MW) Depot Charging Energy (GWh) 2022 0.75 0.7 2023 11.25 9.8 2024 22.53 22.1 2025 39.49 43.2 2026 54.93 60.7 2027 73.83 88.0 2028 99.15 117.7 2029 108.87 129.9 2030 108.87 129.9 2031 108.87 129.9

Fiscal Year In Route Charging Demand (MW) In Route Charging Energy (GWh) 2021 0.7 0.9 2022 2.9 3.8 2023 4.3 5.7 2024 8.1 10.6 2025 10.9 14.3 2026 12.1 31.8 2027 12.1 31.8 2028 12.1 31.8 2029 12.1 31.8 2030 12.1 55.0

Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.5.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 9 and 10

1.5.1 Please confirm the CEC’s understanding, or otherwise explain, that the overnight rate will only be available to existing LGS customers, or new customers who would otherwise be LGS customers.

RESPONSE:

The Overnight Rate will be available to any existing or new customer who meets the availability criteria to set up a separately metered fleet charging account that is equal to or greater than 150 kW. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.5.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 9 and 10

1.5.2 Has BC Hydro conducted research to determine if MGS customers would be interested, or if there are MGS customers that might benefit?

RESPONSE:

Please refer to BC Hydro’s response to BCUC IRs 1.2.1 and 1.2.2. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.5.2.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 9 and 10

1.5.2 Has BC Hydro conducted research to determine if MGS customers would be interested, or if there are MGS customers that might benefit?

1.5.2.1 If yes, please provide the evidence supporting BC Hydro’s assumptions regarding MGS customers.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IRs 1.2.1 and 1.2.2. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.5.2.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 9 and 10

1.5.2 Has BC Hydro conducted research to determine if MGS customers would be interested, or if there are MGS customers that might benefit?

1.5.2.2 If no, please explain why not.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IRs 1.2.1 and 1.2.2. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.5.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

5.0 Reference: Exhibit B-1, pages 9 and 10

1.5.3 Has BC Hydro identified MGS customers that may move to LGS if the overnight rate makes it possible for them to increase the quantity of electric vehicles they use?

RESPONSE:

Customers cannot increase the consumption of an existing account that includes non-charging loads to meet the availability criteria of the Overnight Rate.

The Overnight Rate is only available to separately metered fleet charging load equal to or greater than 150 kW. However, a customer who has an existing account (e.g., under the Small General Service Rate, Medium General Service Rate, or Large General Service Rate) may qualify for the fleet charging rate if they meet the availability criteria for their charging load. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.6.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, page 11 and 45 Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.6.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.6.1 Please explain which customer groups will be subsidizing the ‘Demand Transition Rate’ which does not recover its full embedded cost of service until the load factor increases.

RESPONSE:

So long as incremental revenues from the Demand Transition Rate are sufficient to recover marginal costs, no other ratepayers will be harmed, even if revenues are insufficient to recover embedded costs.

Over the short term, while revenues from the Demand Transition Rate are expected to be insufficient to cover marginal costs, costs will be recovered from all ratepayers. Likewise, over the medium to long terms, benefits will flow to all ratepayers.

Please also refer to BC Hydro’s response to BCUC IR 1.16.1. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.6.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, page 11 and 45 Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.6.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.6.2 Please provide the Revenue to Cost (R:C) ratios for each rate group.

RESPONSE:

Below is the revenue to cost ratios of all rate classes from BC Hydro’s F2017 FACOS1.

1 https://www.bchydro.com/content/dam/BCHydro/customer- portal/documents/corporate/regulatory-planning-documents/regulatory-filings/reports/2019-02- 14-facos-f2017-ff.pdf

Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.6.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, page 11 and 45 Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.6.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.6.3 How will the inclusion of the two rates likely affect the Commercial R:C ratio? Please provide quantification for each rate, and the two rates together.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.18.6. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.6.4 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

6.0 Reference: Exhibit B-1, page 11 and 45 Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.6.4 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.6.4 Over what period of time will the Demand Transition rate ‘break even’ such that it recovers all the costs that were not originally recovered in the beginning years? Please explain and provide a table demonstrating costs and total recovery.

RESPONSE:

Please see Table 7 of the Application, where it is shown that marginal costs are expected to be recovered by the tenth year of service, i.e., by fiscal 2029. The marginal cost analysis presented in Table 7 and Appendix E is the appropriate framework for considering ‘break-even’ type concepts which assess the time required to recover costs directly associated with serving the new load.

Please note that Table 6 referenced in the preamble, depicts recovery of embedded costs. Embedded costs include costs that would be incurred irrespective of serving the new load. Please refer to BC Hydro’s response to BCUC IR 1.16.1 for additional discussion of embedded cost and marginal cost analysis. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.7.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, pages 13 and 23

1.7.1 Please identify BC Hydro’s ‘stakeholder’ groups and whether all of the groups consulted were potential beneficiaries of the rates?

RESPONSE:

BC Hydro notes that the Overnight Rate and the Demand Transition Rate are expected to provide benefits to all ratepayers over time, as the difference between incremental revenues and marginal cost will contribute to reducing BC Hydro’s general rate increase. In this respect, all customers are expected to be beneficiaries from the fleet electrification rates.

Please refer to BC Hydro’s response to BCUC IR 1.9.1. Not all of the stakeholder groups would have members who may participate in the Overnight Rate or the Demand Transition Rate. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.7.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, pages 13 and 23

1.7.2 If BC Hydro included customers who were not potential beneficiaries of the rates, please provide the number of non-potential beneficiaries who were consulted.

RESPONSE:

Please see BC Hydro’s response to BCUC IR 1.9.1 for a list of stakeholders who participated in BC Hydro’s engagement for the proposed Overnight Rate and Demand Transition Rate. There is a broad range of customers and customer groups included in the engagement, not all of whom are expected to be fleet rate customers. Commercial Energy Consumers Association of British Page 1 Columbia of 4 Information Request No. 1.7.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

7.0 Reference: Exhibit B-1, pages 13 and 23

1.7.3 Please provide a detailed summary of the feedback that BC Hydro received from stakeholders who could be responsible to recovering the cost of service from the Demand Transition rate but who have no capability to make use of the rate, or are ineligible for some other reason.

RESPONSE:

It is not known whether a customer will be eligible for the Demand Transition Rate until the determination is made upon a customer’s request to be billed on the rate. Therefore, all of the input received in response to requested feedback on the Demand Transition Rate is provided in the table below.

Please also refer to section 5.6, Demand Transition Rate Response to Stakeholder and Customer Feedback, in the Application for a discussion on BC Hydro’s consideration of the feedback received.

Stakeholder/Customer Please provide your feedback on the Demand Transition Rate BC Sustainable Energy 1. The ten-year demand charge transition in Option 3 Association (BCSEA) should have a flexible start date. Both for new customers to the optional rate and for new meters added to the account of a customer on the optional rate. It can be expected that the operators of In Commercial Energy Consumers Association of British Page 2 Columbia of 4 Information Request No. 1.7.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Route charging will add new charging stations over time. 2. It would be helpful to have more explanation of the In Route fleet charging scenario. Is the public bus system the only example at this point? Not that the contractual relationship between the In Route fleet operator and the owners of the host sites is within BC Hydro’s purview, but how would that be handled? Would the individual charging unit have to connect to a feeder line, as distinct from another customer’s power? Is implementation of In Route charging going to involve substantial infrastructure investment? 3. Also, it would be useful to have more information on how the In Route charging would be handled on BC Hydro’s side. Would it involve a single account with multiple meters, with each meter having its own calculation toward the total bill? Is aggregation of this sort already done? 4. What happens when the In Route operator changes to regular LGS after the demand-charge transition is over? Would billing demand be based on the aggregate demand? 5. 5. As noted above, perhaps public fast charging stations should be eligible for Option 3 (or designs like it). BC Transit’s low carbon fleet program does not include BC Transit in-route charging and therefore do not see an application for the demand transition rate. Option #3 supports daytime charging by temporarily ChargePoint, Inc eliminating demand charges; however, it could result in significant cost impacts in later years for fleets when they are scaling up their operations. For example, the City of Vancouver and other municipalities have very ambitious EV first procurement and GHG reduction targets (e.g. Translink) for their fleets. In other jurisdictions (e.g. Southern California Edison1), rates that temporarily eliminate demand chargers have been designed primarily to address investment barriers associated with highway corridor DCFC charging, where low utilization combined with demand charges presents a significant investment barrier. The rationale for the temporary elimination of demand charges is that by the time the demand charge is eliminated, EV adoption and

1 https://www.sce.com/business/rates/electric-car-business-rates/business/rates/electric-car- business-rates Commercial Energy Consumers Association of British Page 3 Columbia of 4 Information Request No. 1.7.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

utilization will have increased and the fees collected from EV drivers for charging services will help offset demand charges when they return. The context is different for a fleet. Fleet vehicles have fairly consistent utilization over time and when EV uptake increases so too does the fleet’s overall load. The elimination of a demand charge, while providing temporary cost savings, will result in significant increases in costs in later years for fleets that have scaled up their EV and charging fleet when the demand charges are re-established. For example, a bus fleet that has five e-buses in year one, growing to 60 buses in year six will receive cost relief in years one to five, but face a drastic increase in operating costs in year six when the demand charge is re-established. In fact, even if utilization does not change from year one to year six, there still will be no economic shift to account for what will be a significant increase in operating cost once the temporary elimination of the demand charge ends. A fleet operator is not recovering cost through pricing to public EV drivers, which will ideally increase over time as EV adoption goes up. Further, temporarily eliminating demand charges may not provide the right signal for fleets to manage charging effectively and efficiently from the outset and does not necessarily encourage charging behaviour that will ultimately support the long-term stability of the grid. Implementing charging management later could be significantly more costly (for all parties) than doing so at the outset. One example of an alternative rate structure that supports daytime EV charging is Pacific Gas and 2 Electric’s proposed subscription based model . Although it does not deliver the same level of savings for daytime charging in the short-term, it does support efficient charging management in the long-term. This model is well suited for predictable loads and would provide clarity to fleets and other station owners/operators on how their costs will change as they scale up, allowing them to effectively design and manage charging from the outset. In addition, utilities like Pacific Gas and Electric are also pursuing load management and demand response program offerings for fleet operators to further encourage managed “smart” charging.

2 http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M238/K227/238227315.PDF Commercial Energy Consumers Association of British Page 4 Columbia of 4 Information Request No. 1.7.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

As an 11-year option, this type of rate option will give Tesla Motors Canada ULC charging operators and fleets certainty about pricing, which is an important consideration for their investments, and will allow them to grow into their demand. As noted in BC Hydro’s presentation, however, the rate does not encourage customers to shift their usage patterns to other time periods. Therefore, Tesla recommends looking at a combination of TOU rates with transition demand rates, similar to the rates that NV Energy (a Nevada utility). The rate, available here, starts off as almost entirely a TOU rate, and then a demand charges are phased in over a 10-year period. Some port terminals are TRS rate customers and among Vancouver Fraser Port them are terminals with the highest electrification Authority potential (read: currently highest amount of diesel powered equipment). While the RS1823 already has the daytime demand charge element which is very similar to the overnight rate so from that perspective a TSR customer has essentially an overnight rate already. However, our marine terminal fleets will need to be fast charged at various times during the day 30-60 min breaks) and that will result in demand spikes. We’d like to request that the proposed Demand Transition rate be extended to TSR customers as well.

Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.8.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, page 18

1.8.1 Did BC Hydro consider mandatory participation? Please discuss.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.1.3. Commercial Energy Consumers Association of British Page 1 Columbia of 3 Information Request No. 1.8.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, page 18

1.8.2 Do the other jurisdictions recover their cost of service? Please provide any information that BC Hydro has regarding other jurisdictions’ cost recovery.

RESPONSE:

Please refer to the following table which provides information that BC Hydro has regarding other jurisdictions’ cost recovery. Commercial Energy Consumers Association of British Page 2 Columbia of 3 Information Request No. 1.8.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Utility Rate Approved Cost Recovery Hawaiian Electric E-Bus-P Yes HECO estimates that the incremental Company (HECO) revenues from the energy sales generated by the E-Bus Program are forecasted to exceed the incremental costs to implement the pilot program. In the event that incremental costs to implement the program exceed the incremental sales, HECO does not plan to seek cost recovery for expenses. Please refer to Public Utilities Commission of the State of Hawaii, Decision and Order No. 36220, page 31 and 32. Liberty Utilities A-3 Yes Liberty Utilities states that this rate is (serves very close to full marginal cost. communities in Please refer to 2016 General Rate California Case Application of Liberty Utilities, Including Lake Phase Two (Application No. Tahoe) 15-05-008, May 1, 2015), page 35. Pacific Gas and CEV-L-S No – still under PG&E proposes to implement a Electric regulatory mechanism to track the difference review between (1) the actual cost of service, plus contribution to fixed costs, and (2) actual revenues, and proposes to collect that cost shift from customers on an equal-cents-per-kWh basis. PG&E will review the cost allocation and any cost shift in 2023 GRC Phase 2. Please refer to PG&E Commercial Electric Vehicle Rate Proposal Prepared Testimony (Proceeding A1811003, November 5, 2018), pages 2 to 16. Commercial Energy Consumers Association of British Page 3 Columbia of 3 Information Request No. 1.8.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

Utility Rate Approved Cost Recovery Southern TOU EV-8 Yes For a defined five-year California Edison implementation period, the proposed (SCE) rates would not include a demand charge, and SCE would recover costs primarily through energy charges. The demand charge would be introduced in year six, annually increasing to full cost by year 11. Under the Settlement Agreement, for distribution costs, a maximum of 60 per cent of costs that can be recovered through the demand charge and for transmission costs, allocates 30 per cent of costs to volumetric rates and 70 per cent to demand charges. Please refer to CPUC Decision on the Transportation Electrification Standard Review Projects, Docket No. A1701021 (May 31, 2018), pages 111 to 113.

Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.8.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, page 18

1.8.3 Did BC Hydro consider a seasonal time of use rate?

RESPONSE:

BC Hydro did consider a seasonal time of use rate early in the rate design process. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.8.3.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, page 18

1.8.3 Did BC Hydro consider a seasonal time of use rate?

1.8.3.1 If yes, please explain why BC Hydro did not employ a seasonal rate.

RESPONSE:

BC Hydro did not propose a seasonal rate because of its additional complexity.

We expect that consistent pricing throughout the year will be easier for fleet customers to understand and plan for. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.8.3.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

8.0 Reference: Exhibit B-1, page 18

1.8.3 Did BC Hydro consider a seasonal time of use rate?

1.8.3.2 Are there seasonal variations in the cost of market power that would impact seasonal overnight rates? Please explain.

RESPONSE:

BC Hydro has not considered how seasonal variations in the cost of market power might impact a seasonal Overnight Rate.

Please refer to BC Hydro’s response to CEC IRs 1.8.3 and 1.8.3.1. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.9.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 Reference: Exhibit B-1, page 25

1.9.1 Could passenger vehicles include taxis or other fleets with multiple passenger vehicles? Please explain.

RESPONSE:

Yes, BC Hydro confirms that taxis and passenger vehicles will be considered electric fleet vehicles, as long as they meet the requirements as set out in the proposed rate schedules for the Overnight Rate and Demand Transition Rate. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.9.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

9.0 Reference: Exhibit B-1, page 25

1.9.2 The CEC has reviewed section 1.1 and 1.5.1 and does not identify a clear reason for not including passenger vehicles in this scope of this application. Please summarize the reasons.

RESPONSE:

As described in BC Hydro’s response to CEC IR 1.9.1, passenger vehicles that meet the availability criteria would qualify to service under the proposed fleet rate.

However charging providers to consumer owned and operated electric vehicles would not qualify for service for the reasons described in BC Hydro’s response to BCUC IR 1.7.1. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.10.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, pages 24-26

1.10.1 Does BC Hydro have plans to include fleet vessels? Please discuss.

RESPONSE:

Yes, fleet vessels are included in the availability of the proposed Overnight Rate and Demand Transition Rate.

The proposed rate structures are intended to help remove the barriers to electrification of vessels that will have the option to plug in overnight as well as charge for short periods of time during the day during operations. Both BC Ferries and Seaspan have plans to explore electrification of their respective fleets. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.10.1.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, pages 24-26

1.10.1 Does BC Hydro have plans to include fleet vessels? Please discuss.

1.10.1.1 If yes, when does BC Hydro expect to include fleet vessels?

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.10.1. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.10.1.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, pages 24-26

1.10.1 Does BC Hydro have plans to include fleet vessels? Please discuss.

1.10.1.2 Under what conditions would BC Hydro include fleet vessels? Please explain.

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.10.1. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.10.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, pages 24-26

1.10.2 Please provide the expected load from fleet vessels and when this would occur.

RESPONSE:

At this time BC Hydro does not have a forecast of the magnitude of the load. BC Hydro expects some fleet vessel electric load will take service from BC Hydro as early as 2021. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.10.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, pages 24-26

1.10.3 Does BC Hydro have plans for expansion to other fleets? Please discuss and include a discussion of timing and load quantification.

RESPONSE:

The proposed rate designs in the Application are to encourage electrification of fleet transportation including fleet vessels. Timing will be based on vessel owner/lease/operators conversion or adoption of electric technology. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.10.4 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

10.0 Reference: Exhibit B-1, pages 24-26

1.10.4 Please confirm that charging for fleet vessels could occur in off- peak hours.

RESPONSE:

Confirmed. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.11.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 45

1.11.1 Please provide the evidence for the assumptions behind BC Hydro’s increases in load factor.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.10.5. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.11.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 45

1.11.2 Please provide quantification of the dollar values of the Demand Transition Rate and total costs by load factor.

RESPONSE:

Please refer to Appendix F Tables 3 to 5 of the Application. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.11.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 45

1.11.3 Please provide estimated rate impacts for other customers, by rate class, from the Demand Transition rate by year, using the load factor assumptions included in the table above.

RESPONSE:

Below are illustrative estimates of the total impact on BC Hydro’s rates for the period analyzed. Impacts would apply to general rate increases or decreases, applicable to all rate classes.

Impact on BC Hydro’s Rates Ratepayer Benefit (Revenues Less Marginal Cost), $ (%) 5-year: 15% Load Factor (707,991) +0.01 10-year: 30% Load Factor (222,003) 0.00 15-year: 52% load Factor 2,605,615 -0.05

The calculation is completed as follows. The first step is to estimate ratepayer benefits as the difference between incremental revenues and marginal costs. These calculations are presented in Table 7, Appendix E of the Application, and in the live excel model of Appendix E (Tab Scenario 1 Demand Transition) included in the Fleet Electrification Rate Application Supplemental Information. Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.11.3 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

The next step is to calculate the ratepayer benefits as a percentage BC Hydro’s revenue requirement. The fiscal 2021 plan revenue requirement of $5,288.3 million included in BC Hydro’s Fiscal 2020 - Fiscal 2021 Revenue Requirements Application was used.

Actual ratepayer benefits will vary based on the magnitude and characteristics of load that takes service under the Demand Transition Rate. As discussed in section 7, these impacts will be included in the evaluations. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.11.3.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 45

1.11.3 Please provide estimated rate impacts for other customers, by rate class, from the Demand Transition rate by year, using the load factor assumptions included in the table above.

1.11.3.1 Please provide the same information assuming the load factor growth is delayed by 5 years.

RESPONSE:

Please see below for results. With the exception of change to the load factor, all calculations and inputs are as described in BC Hydro’s response to CEC IR 1.11.3.

Impact on BC Hydro’s Rates Ratepayer Benefit (Revenues Less Marginal Cost), $ (%) 5-year: 15% Load Factor (707,991) +0.01 10-year: 15% Load Factor (2,242,416) +0.04 15-year: 30% load Factor (1,191,634) +0.02

BC Hydro notes that this load factor scenario does not align with the information and data provided to us by potential Demand Transition Rate customers for fleet charging. Further, as described in section 7 of the Application, BC Hydro intends to monitor and evaluate the economic impact on ratepayers and may apply to the BCUC to amend pricing, terms and conditions based on the evaluation outcomes. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.11.3.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 45

1.11.3 Please provide estimated rate impacts for other customers, by rate class, from the Demand Transition rate by year, using the load factor assumptions included in the table above.

1.11.3.2 Please provide the same information assuming the load factor growth is delayed by 10 years.

RESPONSE:

Please see below for results. With the exception of change to the load factor, all calculations and inputs are as described in BC Hydro’s response to CEC IR 1.11.3.

Impact on BC Hydro’s Rates Ratepayer Benefit (Revenues Less Marginal Cost), $ (%) 5-year: 15% Load Factor (707,991) +0.01 10-year: 15% Load Factor (2,242,416) +0.04 15-year: 15% load Factor (2,392,159) +0.05

BC Hydro notes that this load factor scenario does not align with the information and data provided to us by potential Demand Transition Rate customers for fleet charging. Further, as described in section 7 of the Application, BC Hydro intends to monitor and evaluate the economic impact on ratepayers and may apply to the BCUC to amend pricing, terms and conditions based on the evaluation outcomes. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.11.4 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 45

1.11.4 How will BC Hydro report on the recovery of cost of service to the BCUC? Please explain.

RESPONSE:

Please refer to section 7 of the Application for the proposed monitoring and evaluation plan. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.11.5 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

11.0 Reference: Exhibit B-1, page 45

1.11.5 Please discuss BC Hydro’s options if the load factors do not increase, and the rate does not recover its cost of service.

RESPONSE:

As described in section 7 of the Application, BC Hydro intends to monitor and evaluate the economic impact on ratepayers and may apply to the BCUC to amend pricing, terms and conditions based on the evaluation outcomes. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.12.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, Appendix E page 1 of 8

1.12.1 Please provide BC Hydro’s most recent Load Resource Balance.

RESPONSE:

BC Hydro’s response to BCSEA IR 1.11.3 shows the latest energy and capacity load resource balances after planned resources. BC Hydro’s response to BCUC IR 1.11.1 shows the same tables, but includes the additional energy and capacity requirements for depot and in route charging as used in the analysis for Appendix E of the Application. Commercial Energy Consumers Association of British Page 1 Columbia of 1 Information Request No. 1.12.1.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

12.0 Reference: Exhibit B-1, Appendix E page 1 of 8

1.12.1.1 Has BC Hydro accounted for the proposed fleet charging in its most recent LRB? Please explain and provide quantification for how the impact affects the load resource balance, or how it would affect the Load Resource balance if it is not included.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.11.1. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.13.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

13.0 Reference: Exhibit B-1, page 9, 50-51

Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.13.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.13.1 Please explain why the proposed overnight rate design shown in figure 3 does not correspond to the super off peak period shown in figure 9.

RESPONSE:

BC Hydro derived the pricing for the super off peak period in Figure 9 and the overnight period in Figure 3 during separate rate design processes and acknowledges that the two periods could be aligned to be the same.

BC Hydro developed the super off peak period for a voluntary residential TOU rate for discussion in a stakeholder engagement workshop held on March 3, 2017.

BC Hydro’s proposed Overnight Rate design shown in Figure 3 provides demand charge relief between 10 p.m. and 6 a.m. when BC Hydro’s system has spare capacity while still recovering BC Hydro’s cost of service. The overnight period was chosen to meet the customer’s depot charging requirements while still meeting BC Hydro’s capacity needs. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.13.2.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

13.0 Reference: Exhibit B-1, page 9, 50-51

Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.13.2.1 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.13.2 The paragraph in the preamble refers to BC Hydro’s system peaks which occur in the winter months.

1.13.2.1 Please explain what effect seasonality has on the rate design.

RESPONSE:

Although BC Hydro’s proposed Overnight Rate does not have prices that vary by season, the rate provides a price signal for depot charging to occur during the overnight period and away from BC Hydro’s system peaks which occur in the evening hours of the winter months. Commercial Energy Consumers Association of British Page 1 Columbia of 2 Information Request No. 1.13.2.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

13.0 Reference: Exhibit B-1, page 9, 50-51

Commercial Energy Consumers Association of British Page 2 Columbia of 2 Information Request No. 1.13.2.2 Dated: October 7, 2019 British Columbia Hydro & Power Authority Response issued October 30, 2019 British Columbia Hydro & Power Authority Exhibit: Fleet Electrification Rate Application B-5

1.13.2 The paragraph in the preamble refers to BC Hydro’s system peaks which occur in the winter months.

1.13.2.2 Please explain when system peaks occur in the summer season.

RESPONSE:

Please refer to BC Hydro’s response to CEC IR 1.13.1.

The system peak in the summer months, including June, July and August, occurred at approximately 6 p.m.