Wednesday, March 29, 2017

BCUC -- So Much For "Public Opinion"

Their "call for comments" produced such a spiralled web of crapola that it's difficult to even wade through their website listings on the issue of electricity rate tiers in British Columbia.

Good ole' Wacky Bennett must be rolling over in his grave right about now.
But he's the only one who'd have time to read it all...

My November 23, 2016 blog post on the issue is here.
We all know hydro's electricity rates have been going up and up and up for years; have a look at their 2012 document on conservation.

My November blog post had ended with the phrase:  " let's see if BCUC will come up with an analytical and thoughtful reply to their request for comments from the public."

Anyone suffering from insomnia can cure themselves by wading through the following BCUC stuff that was sent to me today in response to my "Public Comment letter".

To cut to the chase, B.C. Hydro's (through their arms-length approval function, the B.C. Utilities Commission), still hasn't seen the public outrage that since  no “baseline all electric” was determined, which would have led to higher average monthly electrical usage and a resulting higher Tier 1 level before Tier 2 rates “kicked in”, this public submission process led to exactly what the BCUC and B.C. Hydro and the current B.C. government wanted:  public input that could then be ignored, and business would go on as usual.

Anyway, here's the email I just received:

"The BCUC has issued its independent report requested by the BC Government in response to public concerns raised about BC Hydro and FortisBC’s residential inclining block (RIB) rates. As you provided a letter of comment that was considered as a part of this report, we have enclosed a pdf link to the Report.

To see all documents submitted as a part of this process, please see the following link: BCUC RIB Rate Report 
Thank you for participating in this process.
Regulatory Services
British Columbia Utilities Commission
Sixth Floor, 900 Howe Street, Vancouver, BC   V6Z 2N3
Tel:  604-660-4700 | Email:"

The 32-page Exhibit List is here.
My submission shows up on page 30, numbered E-567.

Still haven't cured your insomnia?
Well, the following will do it:  have a peek at the 2,139-page (yessiree Bob!), the 2,139 page 2015 Rate Design Application.

Doing a Ctrl-Find search of the word "baseline" leads to these statements:
  • On page 6
    -28, BC Hydro says
    : “.... AMPC stated that the inability to annually adjust baselines to reflect
    changes in use is a significant problem for a heterogeneous class, and thus a flat energy rate may be more useful in providing a conservation price signal than a tiered energy rate.”

  • The mechanism of LGS rate structure include a provision for new accounts where the last 15 percent of energy consumed in a monthly billing period will be charged at the Part 2 energy rate rather than at the Part 1 energy rate until a baseline level of consumption is established one year hence.
  • LGS Flat Energy Rate
    - A LGS flat energy rate eliminates all complexity-related issues resulting from the baseline component of the SQ LGS Energy Rate and aligns with how other similarly situated Canadian electric utilities structure larger general service energy rates (predominantly flat). However, there is a trade
    -off between the customer understanding and acceptance and the economic efficiency criteria because the flat energy rate would not be reflective of LRMC (F2017: LGS flat energy rate is 5.37cents/kWh with demand charge cost recovery at 65 per cent, and the lower end of the energy LRMC range is 9.46 cents/kWh)
  •   “Initially, freshet energy volumes will be calculated hourly by determining
    energy consumption in excess of an average MW (aMW) baseline determined in consultation with the participating customer.”
    BC Hydro sought feedback on four baseline options on slide 27 of the Workshop 10 presentation and ultimately received broad stakeholder support for pursuing Option 3,an average MW baseline discussed on page 34 of the Workshop 10 consideration memo, giving customers the ability to respond to daily HLH and LLH price signals.Options 1 and 2 were rejected because they used average freshet prices, across an entire month or season, and would have sent customers an inferior price signal relative
    to the use of an average MW baseline in Option 3.
From page 65: 
Were there any issues with setting baselines, implementation and billing?

Frankly...I quit after page 65 of 2,139.
Just couldn't pause my life for however long it would take to get through this one link!

So here's their pertinent comment: 

"B.C. Hydro's conclusion, which is also supported by COPE 378 and BCESA, is that the Customer Specific Baseline Rate is impractical due to the large number of customers, and will impose significant implementation challenges."

What does that mean?

"It means they're too lazy to canvass B.C. customers ( IS the computer age)," Kia would've said, "to accurately get a customer specific baseline", instead of guessing at it."

So, what's MY summary now?

  • Get ready for time-of-use (ToU) energy billing in British Columbia (as in Ontario, for most of their customers).

  • Get ready for continued single-digit (~5? ~6 per cent) increases...year after year after year.

...oh, and just wait until Greater Vernon Water figures out how to charge for time-of-use water consumption *grin*.

Try telling that to B.C. Hydro and the B.C. Utilities Commission!

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