Tuesday, November 3, 2015

Residential Inclining Block Rate Report: Rural Customers without natural gas Service: Osoyoos Times: Anarchist Mountain resident replies

BC Hydro, BC Utility Commission, spinning wheels for Minister Bill Bennett for a report without teeth to reduce the RIB.

'My colleagues and I have heard concerns from the public'??? Is that the same sort of concerns that the Public have been expressing over Triple-O-Deleting of files?  Would that be the Second Premier in a row to Taking the Knife Too Far when it comes to children?  Would that be the concerns that the Public has expressed in the manner in which Health Researchers were fired, one dying?

Concerns like the cost of IPP?



The Public has concerns and the BC Liberals Do Not Listen which is reminiscent to orders given to other investigations that might taint their reputations . eg.

Out of Scope of the the Review Process

Minister Bennett has also set certain issues as out of scope for this review process. Specifically, Minister Bennett states that any analysis of higher greenhouse gas emissions, electricity conservation, revenue neutrality resulting from the residential inclining block rates and any analysis of alternative rate structures are best left to existing regulatory processes other than this review process.

A 3 page letter request, that generated the query from the BCUC above, to this:

Energy Minister Bill Bennett: Residential Inclining Block Rate Report aka RIB

I am writing to request that the British Columbia Utilities Commission (BCUC) report to the Government of British Columbia on the impact of BC Hydro's Residential Inclining Block Rate and FortisBC's Residential Conservation Rate (referred to as the "residential inclining block rates").

My colleagues and I have heard concerns from the public that the residential inclining block rates may have unreasonable bill impacts on some customers. One of the concerns was that rural customers do not have the option of heating their homes using natural gas. Please provide me with information on customers with significant (over 10 percent) bill impacts as a result of the adoption of the residential inclining block rates including, to the extent available, low income customers. I am requesting that the BCUC provide me with information on several issues, including:

Do the residential inclining block rates cause a cross-subsidy between customers with and without access to natural gas service?;
What evidence is available about high bill impacts on low income customers?;
What evidence is available about factors that lead to high-energy use and, therefore, bill impacts for customers without access to natural gas, including low income customers?;
What is the potential for existing Demand Side Management programs to mitigate these impacts?; and
Within the current regulatory environment, what options are there for additional Demand Side Management programs, including low income programs?

FortisBC and BC Hydro have both demonstrated that their respective residential inclining block rates are resulting in residential electricity conservation, and that they are revenue neutral to the utilities. The Government is unaware of any evidence that the residential inclining block rates result in higher greenhouse gas emissions, and BC Hydro has indicated that they have no evidence of this. Any analysis of alternative rate structures and the issues listed in this paragraph would be best left to existing regulatory processes, which in BC Hydro's case is the 2015 Rate Design Application (RDA).

I would like the BCUC to work with the utilities in collecting the information it deems necessary to provide the BCUC's assessment of the five questions I have raised, and any other relevant issues with the rate that the BCUC believes have not been addressed adequately by previous reports and regulatory processes. I would also recommend the BCUC gather information from ratepayers in regions not served by natural gas regarding the impacts of conservation rates and awareness of ratepayer mitigation options.

etc.

Page 259:
5.5.1 Definition of Low Income Customers (LICO) Low Income Cut-Offs

BC Hydro proposes to use Statistics Canada’s LICO as the method for defining low income customers. LICO is an income threshold below which a family will likely devote a larger share of its income on the necessities of food, shelter and clothing than the average family. The approach is essentially to estimate an income threshold at which families are expected to spend 20 percentage points more than the average family on food, shelter and clothing. The reasons for using LICO are:
  Statistics Canada releases LICO updates annually using CPI;
  LICO includes required spending on a comprehensive set of basic necessities  and not just on one specific component such as housing or energy costs;
  LICO is sensitive to family and community size as cut-offs vary by seven family  sizes and five different populations of the area of residence.222 Thus LICO  reflects different regional costs of living between rural and urban areas and  between urban areas of different sizes; and
  LICO is the basis for all 2015 RDA residential rate modelling, as elaborated upon below.

BC Hydro proposes to use pre-tax rather than after-tax income levels. Pre-tax levels
are easier for customers and survey respondents to think about and report, and are
therefore used in the REUS (Residential End Use Survey).


BC Hydro Responds with 4092 Pages

 Residential Inclining Block Rate Report to the Government of British
Columbia

By letter dated August 17, 2015 (Commission RIB Report Methodology Letter;

Exhibit B-1 in the BCUC RIB Rate Report proceeding), the Commission requested that BC Hydro provide its submissions to the Commission by September 30, 2015 on:

methodologies for the report BC Hydro will submit to the Commission on the five questions posed by the Minister of Energy and Mines in his letter of July 6, 2015 (Minister RIB Report Letter); any other issues with the RIB rate that have not previously been adequately addressed but should be reported on in BC Hydro’s report to the Commission and the Commission’s report to the Government; and comments on the Commission’s proposed process and suggested timing. Consistent with the Minister RIB Report Letter, which provides that the Commission should use the 2015 RDA review process to collect information for the Commission’s report to Government, BC Hydro provides its submissions concerning the Commission RIB Report Methodology Letter in sections 5.5 and 5.6 of the 2015 RDA.

For further information, please contact Gordon Doyle at 604-623-3815 or by email at bchydroregulatorygroup@bchydro.com.

etc.

On Page 872   The Title

Appendix C-1D
Ministry Residential Inclining Block Report Request

Page 873

The Energy Minister's 3 page Letter is repeated

On Page 876

Erica Hamilton BCUC to BC Hydro Jessica McDonald (BC Hydro) and Michael Mulcahy (Fortis):

 Dear Ms. McDonald and Mr. Mulcahy:
August 17, 2015
BCUC RIB RATE REPORT
FortisBC

Re: Residential Inclining Block Rate Report to the Government of British Columbia

By letter dated July 6, 2015 (attached), Minister Bennett, the Minister of Energy and Mines and the Minister Responsible for Core Review, requested the British Columbia Utilities Commission (Commission) to report to the Government of British Columbia on five specific questions concerning the impact of the British Columbia Hydro and Power Authority's (BC Hydro) and FortisBC Inc.'s (FortisBC) residential inclining block rates.

Minister Bennett's letter Minister Be11nett states he has heard concerns that the residential inclining block rates may have unreasonable bill impacts on some customers including low income customers and rural customers without access to natural gas.

etc.

On Page 877  Out of Scope of the the Review Process

Minister Bennett has also set certain issues as out of scope for this review process. Specifically, Minister Bennett states that any analysis of higher greenhouse gas emissions, electricity conservation, revenue neutrality resulting from the residential inclining block rates and any analysis of alternative rate structures are best left to existing regulatory processes other than this review process.

AND

This proceeding is not a process to alter the rates. Rather it is a process to gather information and provide review and analysis on specific questions to the government. The Commission will not make recommendations in the final report but will provide analysis and conclusions as requested. We are seeking information from utilities that is as comparable as possible; thus, the first step in this process is to obtain clarity from the utilities regarding the methodology(ies) they will utilize in order to report on the five questions. We intend to make efforts to align the methodologies as much as possible in order to achieve comparable information from both utilities.

snip

BC Hydro and FortisBC are requested to provide their respective submissions to the Commission by September 30, 2015 on the following:
i. A detailed outline of the methodology(ies) for the report the utilities will submit to the to the Commission on the five questions posed by Minister Bennett including:
a. How they intend to define "low-income" customers;
b. How they intend to define "factors" that lead to high energy use;
c. For each of the five questions, the general approach they intend to take to answer the question;
d. Any other relevant method they will use to gather information or answer the questions posed within the Minister's letter of July 6, 2015.
ii. Any other relevant issues with the rates that have not previously been adequately addressed but should be reported on in the utility reports to the Commission and the Commission's report to government; and
iii. Comments on the Commission's proposed process and suggested timing.

Participant Assistance/Cost Awards will be available for participation in this full review process. Those intending to apply for assistance may include a maximum of two days for making submissions on the information identified above.

Public participation beyond the scope identified above will be established for the next phase in this review, after utility submissions and stakeholder comments are received, and common methodologies are achieved to the extent possible. This is likely to occur in spring 2016 and comments outside the scope noted above, including letters of comment, will not be accepted in advance ofthe Commission establishing a further process.

etc. etc. etc

Courtesy of Minister Bill Bennett, BC Hydro's unsuspecting Customers are paying a hidden increase in their rates for compensation in loss income to participants AND their Lawyers:


Note:
4.  Participant Assistance: Eligible Costs and Rates
The following reasonable expenses are eligible for participant assistance. The term “proceeding day” may include workshop days, negotiation days, pre-hearing conference days, hearing days, and oral argument days, and will not include town hall meeting days. The Commission Panel may award costs for preparation days, typically on a ratio of up to 2 days per proceeding day. Such ratio may be adjusted after the proceeding, by the Commission Panel, with adequate justification from Participant(s). The number of proceeding days and the ratio used for the purposes of calculating awards may vary among Participants and among members of the Participant’s team.

a. Foregone Earnings
The Commission Panel may award costs for foregone earnings up to a maximum of $175 per proceeding day. Participants claiming foregone earnings are required to provide proof of actual foregone earnings, except where to do so would be unreasonably difficult. In this case, an indication of the usual daily earnings must be provided. Where not otherwise provided for in these Guidelines, this provision may also be used to fund the appearance of witnesses who meet the Eligibility Criteria.
b. Legal Fees

The Commission Panel will consider factors such as experience before regulatory tribunals, complexity of the issue and overall conduct of the counsel in determining an appropriate contribution or partial award towards legal costs.

The Commission Panel may award legal counsel costs up to a maximum as set out in the scale below per full proceeding day or preparation day (assumed to be an eight hour day). Awards will be prorated for part days. Where the actual billing rate is less, the lesser amount will be used for the award.

Years Since Call

Maximum Daily Fee
0 – 5   $1200
5- 10  $1400
10+   $1800

AND

The Commission Panel may award costs up to a maximum set out in the scale below, per full proceeding day or preparation day (assumed to be an eight hour day). Awards will be prorated for part days. Where the actual billing rate is less, the lesser amount will be used for the award.

Years of Related Experience   Maximum Daily Fee
Consultant 0 – 5                          $640
Consultant 5- 10                         $800
Consultant 10+                         $1250
Expert Witness / Specialist      $1450
These maximums do not include provision for GST and PST, which may also be allowed, pursuant to subsection 4(g).

Way, Way Down at the bottom on Page 4889 there are Excel files:

 Page 4902    Appendix H-1B - Examples of Freshet Rate Billing - View Excel



20_04_01_RDA_APPX_E.xlsx


F2016 Forecast Revenue Requirement Generation Transmission





Cost of Energy 

IPPs and Long-term Purchases commitment 1,134.72 1,134.72 0.00

Domestic Transmission (Non-Heritage) 0.00 0.00 0.00

NIA Generation 34.30 34.30 0.00

Gas Transportation 12.10 12.10 0.00

Water Rentals 391.90 391.90 0.00

Market Purchases 56.60 56.60 0.00

Natural gas for thermal generation 26.90 26.90 0.00

Domestic Transmission (Heritage) 25.70 0.00 25.70

Non-treaty storage agreement -19.80 -19.80 0.00

Other and Surplus Sales -116.30 -116.30 0.00

Net purchases (sales) from Powerex 4.80 4.80 0.00

Heritage Deferral Account Recoveries 17.74 17.74 0.00

Non-Heritage Deferral Account Recoveries 104.82 104.82 0.00
Total 1,673.49 1,647.79 25.70








Rates going up in December of 2015 according to file: 11_02_RDA_APPX_A-1A.docx



Osoyoos Times: RICHARD McGUIRE

 Anarchist Mountain resident wins review of two-tier residential electricity rates

An Anarchist Mountain resident who believes that two-tier electricity pricing penalizes rural people who don’t have access to natural gas has won a small concession from the provincial government.

Nick Marty, a retired federal official who spent much of his career working on energy conservation, has argued that the Residential Conservation Rate (RCR) used by FortisBC and BC Hydro is discriminatory and fails to result in energy conservation.

In July, Bill Bennett, minister of energy and mines, asked the British Columbia Utilities Commission (BCUC) to answer five questions stemming from the argument made by Marty.

Originally, the process established by the BCUC to address the five questions would have limited submissions only to previous interveners, but last week Marty was told he was invited to comment “based on your interest and professional experience.”

In Marty’s argument, homeowners with access to natural gas are able to limit their electricity consumption in order to purchase all or most of their electricity at the lower-tier price. Homeowners without access to natural gas, who are usually rural, are dependent on electricity for water and space heating, so most of their electricity is purchased in the higher-tier price.

Because customers with access to gas can buy electricity at the lower rate, they have no incentive to conserve, Marty argues. On the other hand, the only viable alternative to electricity for rural residents is to burn wood, which increases pollution.

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