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:  "Good...now 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.

http://www.bcuc.com/Documents/Proceedings/2017/DOC_49001_03-28-2017_BCUC-RIB-Rate-Report.pdf

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:  commission.secretary@bcuc.com"

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 (easy-peasy...it 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!

BCUC call for Public Comments

After a bit of trouble opening/saving their requisite form, the Letter of Comment, my submission made it into the B.C. Utilities Commission pile prior to their November 24, 2016 deadline.

To cut to the chase, the Tier 1 rate for B.C. customers for electrical consumption was set at ~1,350 kWh a month.  I contend they erred (big time!) by not doing what the State of California (of all places!) did:  to set an "all electric baseline" at the outset.

Here's my submission today (which includes blog posts on the topic from ~six years ago):

"Re Tier 1 electricity rates, and the monthly ~ 1,350 kWh Tier 1 rate was set far too low.

My residential electrical bill was the reason for my writing to then-Minister Lekstrom as long ago as 2010.

Why?

Two reasons:  no natural gas is available in this area (to this date) and, most importantly, my residence uses wood heat exclusively.

Electric heaters are never activated in my residence.

Yet hydro bills in 2010 (and following years during winter) showed Step 1 had been exceeded.

We are only two adults in the residence.
Imagine the impact on a family of, say, four who have neither natural gas nor wood heat.

Rationale for my 2010 letter to the Premier of B.C., forwarded to Minister Lekstrom—and today’s Letter of Comment—I contend the BCUC, in determining the monthly kWh at which Tier 2 rates would “kick in”—used an entirely incorrect dataset.

I contend that Total kWh electrical usage in B.C. was tabulated, and the total number of utility accounts/residences determined that each residence used an average monthly amount of electricity of “x” amount.

To support my opinion, I offer that neither B.C. Hydro—nor BCUC—at the time, nor since, had canvassed the residential accounts (which are the only ones affected, as Commercial etc. has no tier process) to ascertain how many accounts use alternative heat sources:  i.e. wood, natural gas, or alternative energy sources.   So 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”.

As a result, the averaging of ALL residential account electrical usage, would have resulted in a spuriously-determined average because the process included alternative electrical sources!

To their credit, the State of California implemented a “baseline all electric” category (evidenced by supportable research, printed below).

Minister Lekstrom’s reply?  As additional historical info, I have a personal blog called Coldstream Corner on which I posted the following reply from the Minister: 

“Blair Lekstrom, minister of energy, mines and petroleum resources replied thus:
...In your email, you express concern that B.C. Hydro's Residential Inclining Block (RIB) two-step conservation rate is unfair to ratepayers who cannot lower their electricity consumption by switching to other energy sources.  The RIB rate was intended to encourage electricity conservation rather than fuel switching.  More information on the RIB rate.  

B.C. Hydro made an application to the British Columbia Utilities Commission (BCUC) for their proposed RIB rate.  In response, the BCUC initiated an extensive review with public hearings that took place during the summer of 2008.  Many public interest groups registered as interveners and represented ratepayer interests.  A higher Step 1 threshold and concerns about bill impacts for residencees with electric heating were discussed.  The BCUC considered all parties' arguments and the public interest, ordered revisions to the RIB rate, and instructed B.C. Hydro to put the BCUC revised RIB rate structure into effect.  The BCUC's "Reasons for Decision" document detail the RIB rate application.   (Coldstream Corner note:  It's 157 pages long!)

The reply continues:
B.C. Hydro's electricity rates remain the lowest in North America.  In June 2009, B.C. Hydro filed a report to the BCUC summarizing the results of a North American survey of electricity prices.  The survey, conducted by Hydro Quebec and covering over 20 utilities across Canada and the United States, found that B.C. Hydro had the lowest rates for residential customers consuming 750 kilowatt hours or less per month and the third-lowest rates for residential customers consuming 1,000 to 3,000 kilowatt hours per month.
 
One way to lower your electricity bill is through investments in energy efficiency.  (Coldstream Corner note:  now would be a good time to tell them we installed a 10 kilowatt wind turbine last year!)  British Columbia's 2010 budget includes $35 million in new funding over three years for the "LiveSmart BC: Efficiency Incentive Program".  The Ministry of Energy, Mines and Petroleum Resources is currently working with its utility partners to finalize the structure of the new Program.  Details on the Program are expected to be announced in the coming weeks, and will be posted on the LiveSmart BC website.   (Coldstream Corner note:  would now be a good time to tell them that my 10 kilowatt wind turbine was INELIGIBLE for their program last year?  seems the program only went to a maximum 3 kilowatt turbine, yet the website omitted that).
You may also find lowcost actions to reduce your energy consumption and electricity bill through B.C. Hydro's Power Smart program.   (Coldstream Corner note:  oh yes, the B.C. Hydro "program" that charged me $600.00 for a 10-minute inspection of the wind turbine components prior to start-up). 
I trust this information addresses your concerns.  Thank you for writing.  Sincerely,” etc.

While not critical for this Letter of Comment submission, the balance of my blog story was as follows:

“Coldstream Corner's contention:
The Step 2 rate is not intended to--as Minister Lekstrom says--"encourage electricity conservation".  Proof of that is B.C. Hydro's Fiscal 2011 revenue requirement application.  They need "x-dollars" from utility consumers.  More like reverse accounting!

And on page 65 of that 157 page document, "BC Hydro stated that it has conducted research into the default residential rate designs offered by 88 different utilities throughout North America, Europe and Asia"...  Europe and Asia???  Minister Lekstrom appears to think it was: "results of a North American survey of electricity prices".  

Also from the same page:  "Tariff sheets were entered in evidence from California..."  California???  That bastion of environment-first,and-to-hell-with-everything-else?  Yet, to California's credit, they have implemented a program that recognizes: 'an “All Electric” baseline allowance available upon application to those customers who have permanently installed electric space heating, or who have electric water heating and receive no energy from another source'.  California recognizes that!  Did Minister Lekstrom realize B.C. Hydro created a disparity when it did not implement a baseline "all electric" allowance?   

Rather than go on ad nauseum, picking apart the documents item by item, it seems that this creative--and reverse--accounting system has spread to Coldstream Council.  They also have a revenue requirement when considering property taxes.  And those are going up 5.59%.”

...Additional information re Hydro's "conservation" rate changes are here.”

My Letter of Comment is concluded.

Thank you for the opportunity to Comment.

Respectfully submitted, etc."

"No comment on that graphic," Kia would've chuckled.

Good...now let's see if BCUC will come up with an analytical and thoughtful reply to their request for comments from the public.

Minister Lekstrom reply concerning Hydro's Step 1 Threshold

In a December 22 posting, British Columbia's hydro authority was chastized for the virtually impossible-to-meet Step 1 "conservation" parameters (Step 2 kicks in at approx. 1350 kwh).   My residential electrical bill was the test.  Why?  Two reasons:  no natural gas is available in this area and, most importantly, my residence uses wood heat exclusively.  Electric heaters are never activated in the residence.  Yet recent hydro bills showed Step 1 had been exceeded.

We are only two adults in the residence.
Imagine the impact on a family of, say, four who have neither natural gas nor wood heat.

So I sent a letter to the Premier of B.C. to hopefully convince officials that the Step 1 threshold was too low.
Not for me...my hydro bills are relatively low because of the wood heat, but for families all over British Columbia who also have no natural gas in their area.  And no wood for heating.

Blair Lekstrom, minister of energy, mines and petroleum resources replied thus:
...In your email, you express concern that B.C. Hydro's Residential Inclining Block (RIB) two-step conservation rate is unfair to ratepayers who cannot lower their electricity consumption by switching to other energy sources.  The RIB rate was intended to encourage electricity conservation rather than fuel switching.  More information on the RIB rate.  

B.C. Hydro made an application to the British Columbia Utilities Commission (BCUC) for their proposed RIB rate.  In response, the BCUC initiated an extensive review with public hearings that took place during the summer of 2008.  Many public interest groups registered as interveners and represented ratepayer interests.  A higher Step 1 threshold and concerns about bill impacts for residencees with electric heating were discussed.  The BCUC considered all parties' arguments and the public interest, ordered revisions to the RIB rate, and instructed B.C. Hydro to put the BCUC revised RIB rate structure into effect.  The BCUC's "Reasons for Decision" document detail the RIB rate application.   (Coldstream Corner note:  It's 157 pages long!)

The reply continues:
B.C. Hydro's electricity rates remain the lowest in North America.  In June 2009, B.C. Hydro filed a report to the BCUC summarizing the results of a North American survey of electricity prices.  The survey, conducted by Hydro Quebec and covering over 20 utilities across Canada and the United States, found that B.C. Hydro had the lowest rates for residential customers consuming 750 kilowatt hours or less per month and the third-lowest rates for residential customers consuming 1,000 to 3,000 kilowatt hours per month.
 
One way to lower your electricity bill is through investments in energy efficiency.  (Coldstream Corner note:  now would be a good time to tell them we installed a 10 kilowatt wind turbine last year!)  British Columbia's 2010 budget includes $35 million in new funding over three years for the "LiveSmart BC: Efficiency Incentive Program".  The Ministry of Energy, Mines and Petroleum Resources is currently working with its utility partners to finalize the structure of the new Program.  Details on the Program are expected to be announced in the coming weeks, and will be posted on the LiveSmart BC website.   (Coldstream Corner note:  would now be a good time to tell them that my 10 kilowatt wind turbine was INELIGIBLE for their program last year?  seems the program only went to a maximum 3 kilowatt turbine, yet the website omitted that).
You may also find lowcost actions to reduce your energy consumption and electricity bill through B.C. Hydro's Power Smart program.   (Coldstream Corner note:  oh yes, the B.C. Hydro "program" that charged me $600.00 for a 10-minute inspection of the wind turbine components prior to start-up). 
I trust this information addresses your concerns.  Thank you for writing.  Sincerely, etc.


Coldstream Corner's contention:
The Step 2 rate is not intended to--as Minister Lekstrom says--"encourage electricity conservation".  Proof of that is B.C. Hydro's Fiscal 2011 revenue requirement application.  They need "x-dollars" from utility consumers.  More like reverse accounting!

And on page 65 of that 157 page document, "BC Hydro stated that it has conducted research into the default residential rate designs offered by 88 different utilities throughout North America, Europe and Asia"...  Europe and Asia???  Minister Lekstrom appears to think it was: "results of a North American survey of electricity prices".  

Also from the same page:  "Tariff sheets were entered in evidence from California..."  California???  That bastion of environment-first,and-to-hell-with-everything-else?  Yet, to California's credit, they have implemented a program that recognizes: 'an “All Electric” baseline allowance available upon application to those customers who have permanently installed electric space heating, or who have electric water heating and receive no energy from another source'.  California recognizes that!  Did Minister Lekstrom realize B.C. Hydro created a disparity when it did not implement a baseline "all electric" allowance?   

Rather than go on ad nauseum, picking apart the documents item by item, it seems that this creative--and reverse--accounting system has spread to Coldstream Council.  They also have a revenue requirement when considering property taxes.  And those are going up 5.59%.

"People should grow a warm coat like I did," suggests Kia.

Or impenetrable skin, like officials in both Coldstream and Victoria.

Additional information re Hydro's "conservation" rate changes are here.