
Fred James Chief Regulatory Officer Phone: 604-623-4046 Fax: 604-623-4407 [email protected] June 26, 2020 Ms. Marija Tresoglavic Acting Commission Secretary and Manager Regulatory Support British Columbia Utilities Commission Suite 410, 900 Howe Street Vancouver, BC V6Z 2N3 Dear Ms. Tresoglavic: RE: Project No. 1599047 British Columbia Utilities Commission (BCUC or Commission) British Columbia Hydro and Power Authority (BC Hydro) FortisBC Evacuation Relief Tariff Amendment Applications BC Hydro writes to provide our Reply Submission in respect of our Evacuation Relief Tariff Amendment Application. Yours sincerely, (for) Fred James Chief Regulatory Officer aj/rh Enclosure Copy to: FortisBC Attention: Doug Slater [email protected] British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3 www.bchydro.com BC Hydro Evacuation Relief Tariff Amendment Application Reply Submission British Columbia Hydro and Power Authority June 26, 2020 Reply Submission British Columbia Hydro and Power Authority June 26, 2020 Table of Contents Part I Overview ................................................................................................... 1 Part II Reply to BCOAPO’s Final Argument ......................................................... 1 Part III Reply to CEC’s Final Argument ................................................................ 4 Part IV Conclusion ................................................................................................ 7 BC Hydro Evacuation Relief Tariff Amendment Application Page i Reply Submission British Columbia Hydro and Power Authority June 26, 2020 1 Part I Overview 2 1. Two intervenors, the BC Old Age Pensioners’ Association, Active Support 3 Against Poverty, Council of Senior Citizens’ Organizations of BC, Disability 4 Alliance BC, Tenant Resource and Advisory Centre and Together Against 5 Poverty Society (BCOAPO) and the Commercial Energy Consumers 6 Association of British Columbia (CEC), participated in this proceeding 7 concerning BC Hydro’s application to approve the proposed evacuation relief 8 amendments (Evacuation Relief) to the Electric Tariff Terms and Conditions 9 (Electric Tariff).1 10 2. With some suggested adjustments, both intervenors generally support providing 11 Evacuation Relief. CEC supports the regulatory account treatment proposed by 12 BC Hydro. BCOAPO supports the regulatory account treatment, with a caveat 13 concerning whether it is appropriate that costs be borne by BC Hydro’s 14 ratepayers or its shareholder. 15 3. In this Reply Argument, BC Hydro will address issues raised in the final 16 arguments of BCOAPO and CEC. BC Hydro is not opposed to BCOAPO’s 17 proposal to include a waiver of charges for Dwellings destroyed immediately 18 before or after an Evacuation Order during a State of Emergency. BC Hydro is 19 opposed to the proposals recommended by CEC, as those suggested terms 20 are not in the interest of ratepayers.2 21 Part II Reply to BCOAPO’s Final Argument 22 4. BCOAPO supports the implementation of Evacuation Relief and has requested 23 two further refinements to Evacuation Relief. 1 BCOAPO Final Argument, filed June 16, 2020; CEC Final Argument, filed June 16, 2020. 2 Unless otherwise noted, all capitalized terms have the same definitions as set out in the Electric Tariff, including the proposed Evacuation Relief amendments. BC Hydro Evacuation Relief Tariff Amendment Application Page 1 Reply Submission British Columbia Hydro and Power Authority June 26, 2020 1 5. As a further refinement to Evacuation Relief, BCOAPO has requested that 2 section 5.8.4 of Evacuation Relief be expanded to include Medium General 3 Service (MGS) and Large General Service (LGS) Customers where there is 4 one meter and one account for service to the common area of a multiple 5 occupancy building and all residential units.3 6 6. The requested revision from BCOAPO is not necessary because: 7 a. If service to the residential units and common areas in a multiple 8 occupancy building is measured and billed from a single meter, the service 9 would be Residential Service and the appropriate rate for such service 10 would be one of the rate schedules for Residential Service. Residential 11 Customers are already included in the proposed Evacuation Relief; and 12 b. If there are one or more commercial Premises in the multiple occupancy 13 building, then service to the entire building would be MGS or LGS. As a 14 result, the situation contemplated by BCOAPO does not arise. 15 7. The second refinement proposed by BCOAPO would be to revise section 5.8.2 16 of the Evacuation Relief amendments concerning destruction of a Dwelling. 17 Specifically, BCOAPO recommends revising the waiver of charges for 18 destroyed Dwellings to include Customers whose Dwellings were destroyed 19 outside of the term of an Evacuation Period. 4 20 8. To the extent that the proposed revision applies to the destruction of a Dwelling 21 arising from the cause of a State of Emergency resulting in an Evacuation 22 Order for the area where the Dwelling was destroyed, BC Hydro is not opposed 23 to this suggested refinement. 3 BCOAPO Final Argument, page 9. 4 BCOAPO Final Argument, page 11. BC Hydro Evacuation Relief Tariff Amendment Application Page 2 Reply Submission British Columbia Hydro and Power Authority June 26, 2020 1 9. In response to BCOAPO’s proposal, and subject to approval by the 2 Commission, the proposed section 5.8.2 of the Electric Tariff can be further 3 amended by adding the underlined portion below: 4 In addition to the charges waived in paragraph 1 above, if an 5 Evacuee Customer’s Dwelling is destroyed during the 6 Evacuation Period, BC Hydro waives the following charges for 7 the Evacuee Customer: 8 (a) All outstanding charges for Service for the period immediately after the last 9 billing period, up to the date on which the Dwelling was destroyed; and 10 (b) The Service Connection charge as set out in section 3.14 (Service 11 Connection Charges), applicable to the restoration of the same Service at a 12 Dwelling that the Evacuee Customer rebuilds, provided that the Service 13 Connection charge is not recoverable as part of the Evacuee Customer’s 14 insurance. 15 In the event that a Dwelling is destroyed immediately preceding 16 or following the Evacuation Period, BC Hydro may, in its sole 17 discretion, waive the charges set out in this subsection. For 18 clarity, the charges waived in paragraph 2(b) do not include 19 costs estimated by BC Hydro to construct, including, but not 20 limited to, any Extension or Optional Facilities. 21 10. In its Final Argument, BCOAPO sets out the following question: 22 whether the current calculations of the Domestic Revenue 23 variance for the purposes of the Non-Heritage Deferral Account 24 excludes the foregone revenues BC Hydro proposes to defer to 25 the Storm Restoration Costs Regulatory Account or whether the 26 calculation of the domestic revenue variance captured in 27 Non-Heritage Deferral Account will need to specifically altered 28 [sic] to address this issue.5 29 11. BC Hydro clarifies that variances between plan and actual domestic revenues 30 (including Basic Charges, Energy Charges, and Minimum Charge for the 31 service and rate schedules identified on page 6, item 2 of the Application, with 32 the exception of the Customer Crisis Fund Rate Rider) would have been 33 captured in the Non-Heritage Deferral Account as part of the domestic revenue 5 BCOAPO Final Argument, page 16. BC Hydro Evacuation Relief Tariff Amendment Application Page 3 Reply Submission British Columbia Hydro and Power Authority June 26, 2020 1 variance, prior to the proposed regulatory treatment of revenue impacts outlined 2 in sections 2.5 and 3 of the Evacuation Relief Tariff Amendment Application. 3 12. As noted in BC Hydro’s response to BCOAPO IR 2.16.2, these variances would 4 be excluded from the domestic revenue variance captured in the Non-Heritage 5 Deferral Account to ensure that these amounts are only deferred once. This 6 means that the deferral to the Storm Restoration Costs Regulatory Account will 7 be completed prior to the calculation of amounts deferred to the Non-Heritage 8 Deferral Account, which would result in these revenue variances being removed 9 prior to the calculation of the domestic revenue variance amount deferred to the 10 Non-Heritage Deferral Account. 11 13. BCOAPO has also questioned the allocation of the revenue impacts to the 12 account of the ratepayer and posits an alternative of sharing the revenue 13 impacts between the ratepayer and shareholder.6 BC Hydro maintains its 14 position that as Evacuation Relief would be integrated into the Electric Tariff, it 15 is appropriate to allocate the revenue impacts to the ratepayer, as set out in 16 BC Hydro’s Final Argument.7 17 Part III Reply to CEC’s Final Argument 18 14. CEC agrees with and supports the majority of the proposed Evacuation Relief. 19 In particular, CEC agrees that it is reasonable to exclude MGS and LGS 20 Customers from Evacuation Relief where those customers have insurance 21 available or are not vulnerable to Evacuation Orders due to taxpayer funding.8 22 Accordingly, CEC has suggested to expand the definition of Evacuee 23 Customers to include MGS and LGS Customers who are not receiving taxpayer 24 funding, are not still operating, or do not carry business interruption insurance 6 BCOAPO Final Argument, page 15. 7 BC Hydro’s Final Argument, page 7 8 CEC Final Argument, page 6. BC Hydro Evacuation Relief Tariff Amendment Application Page 4 Reply Submission British Columbia Hydro and Power Authority June 26, 2020 1 (Additional MGS/LGS Customers).9 CEC has recommended that some 2 further feasible criteria be established to determine if an MGS or LGS Customer 3 would qualify for Evacuation Relief.10 4 15. BC Hydro does not support CEC’s recommendations because providing 5 Evacuation Relief to the Additional MGS/LGS Customers would result in a 6 significantly greater administrative and financial cost to BC Hydro and would not 7 be in the interest of ratepayers, as discussed below.
Details
-
File Typepdf
-
Upload Time-
-
Content LanguagesEnglish
-
Upload UserAnonymous/Not logged-in
-
File Pages11 Page
-
File Size-