BCUC Briefing Note-FortisBC Conservation Rate

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    ERICA HAMILTONCOMMISSION SECRETARY

    [email protected] site: http:// www.bcuc.com

    VIA [email protected] September 9, 2013

    Dear Mr. Fries:Re: Document Request fo r Information Regarding

    FortisBC's New Residential Conservation Rate

    SIXTH FLOOR, 900 HOWE STREET, BOX 250VANCOUVER, BC CANADA V6Z 2N3

    TELEPHONE: (604) 660-4700BC TOLL FREE: 1-800-663-1385

    FACSIMILE: (604) 660-1102Log No. 44515

    Further to your August 14, 2013 request to access documents, enclosed please find the BC UtilitiesCommission's August 20, 2013 briefing notes regarding FortisBC Inc.'s Residential Conservation Rate EvaluationReport. The briefing notes are redacted, pursuant to section 13 (1) of the Freedom of Informat ion and PrivacyAct.

    /kbbEnclosure

    IP/FOI/09-09-2013Jries_Requestfo r FBC RIB documents

    Erica Hamilton

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    BRITISH COLUMBIA UTILITIES COMMISSION

    ACTION

    MEMO TO: Erica Hamilton August 20, 2013

    Commission Secretary and Director

    FROM: Patrick Wruck

    Customer Service Specialist

    Policy, Planning and Customer Relations- on behalf of Rates

    RE: FortisBC Inc.

    FortisBCs

    Residential Conservation Rate Evaluation Report

    RECOMMENDATION

    BACKGROUND

    The FortisBC RIB rate was approved on January 13, 2012 by Order G-3-12 and the rate was implemented

    on July 1, 2012. FortisBC renamed the RIB Rate to the Residential Conservation Rate (RCR) upon

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    implementation. In Order G-3-12 FortisBC was directed to provide a RIB Rate Evaluation Report

    (Report) covering the period from the date of implementation [July 1, 2012] to December 31, 2013...

    The purpose of that Order was to implement a RIB rate [that] is intended to promote conservation by

    employing a tiered rate structure in which consumption that occurs above a certain threshold level is

    billed at a higher rate.1

    During the period (from implementation) July 1, 2012 - June 30, 2013, the Commission received 149

    complaints regarding FortisBCs RCR resulting from this Order. This is a significant increase in complaints

    regarding FortisBC. For comparison, the Commission received 3 FortisBC complaints in 2010, 15 in 2011

    and 44 in 2012. Over the three year period from 2010 to 2012 (before the new rate structure was

    implemented), 30 complaints were regarding rates.

    In addition to complaints from customers, the Commission received two complaints from the Regional

    District of Okanagan Similkameen, one complaint from the Village of Keremoeos Mayor and Council,

    and a complaint from an NDP candidate in Kaledan, BC. The Commission also received complaints from

    businesses, primarily geothermal companies who argue that the new rate structure has severely

    impacted the geothermal business in a negative way. Aside from complaints sent directly to the

    Commission, there was significant media attention including many letters to the editor in local

    newspapers, and several members of the public organized petitions and held protests.

    The concerns raised by residents can generally be summarized as follows:

    RCR is causing bills to increase up to 50%; Residents in areas that only have access to electricity are concerned that they are being

    penalized because they simply have no option but to heat their home with electricity;

    Residents that use geothermal and air source heat pumps are concerned because their cost tooperate this equipment has risen dramatically due to the RCR;

    Many complainants argue the threshold has been set too low; and Many customers state that they are now resorting to wood heating and/or natural gas instead

    of electric heating systems.

    ANALYSIS AND FINDINGS

    1Executive Summary page 1 FortisBC Inc. Residential Inclining Block Rate Decision January 13, 2012

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    UTILITY RESPONSE

    FortisBC has reviewed the draft Order and comments provided by that utility have been incorporated

    into the draft Order where appropriate. Fortis BC representatives are in general agreement with the

    new due date and the expanded terms of reference.

    REFERENCES

    Order G-3-12 and Decision

    Customer Complaints (examples provided below)

    Examples from the Complaints Received

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    I am asking and urging the BCUC to investigate the possibility of a rate structure that would be

    fair for all. The current rate schedules are not fair for those of us that only have the option of

    electricity. I am sure if the BCUC looked further into the average electricity used by those with

    natural gas and those without they would see that 1600kWh would not be a reasonable number

    for those of us without natural gas.

    A much more effective and fairer way to improve energy conservation is to change the BC

    Building Code to require more energy efficient building practices for all new structures.

    Punishing current home owners for energy consumption over which they have no control is not

    only ineffective, but also unfair and punitive.

    If British Columbia wants to continue to promote clean energy initiatives than residential

    customers who install geothermal heating and cooling should be able to purchase a larger

    quantity of electricity at tier one rates; 1600 kWh in a two month winter billing cycle is notenough to justify a geothermal system.

    5 years ago my wife and I moved into a new home. We had built the home with an eye to being

    environmentally conscious. We invested a huge amount of our funds into what we understand,

    from research we completed on our own and from information provided by the Province of BC

    (among other sources), to be the most energy efficient home heating and cooling system

    available in the market place. Fortis BC's website also confirms this opinion citing ground source

    heat pumps as saving "up to 65% on your home's heating and cooling costs".

    Since that time the BC Utilities Commission has approved the new Residential ConservationRate, which "is designed to encourage conservation and to incent customers to use less

    electricity". However, this policy is overly punitive to home owners that have been encouraged

    and supported (through the Livesmart BC program even) to invest in geothermal heating and

    cooling, the most environmentally sensitive home heating/cooling system available. It is simply

    not possible to operate a geo-thermal based home on 1,600 kWh in a billing period.

    Since homeowners such as myself have intentionally chosen to follow the environmentally

    sensitive direction encouraged by the Province of BC, I do not believe it is fair or appropriate to

    subsequently turn around and punish us with exceptionally high electrical rates.

    I appeal to you and your sense of responsibility and fairness to examine establishing a policy

    that will treat geothermal home owners more appropriately. We have spent a tremendous

    amount of our personal financial resources in an attempt to 'do the right thing' for the

    environment. Please dont punish us forevermore with exorbitantly high electrical rates.

    I would suggest geothermal homeowners could be given a rebate on the electrical use

    associated with the geo thermal unit. I am prepared to pay the higher rate on electricity

    consumed above your threshold for any other purposes, but given our dependence on the geo

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    system for heating and cooling I do not believe it is appropriate to charge us the higher rates to

    operate that system.

    I would like to express my outrage at the punitive effect this new Two-Tier billing system has on

    homeowners like myself who have chosen to heat/cool their homes with (what we were lead to

    believe is) a cleaner & more environmentally friendly Geothermal system. Granted my electricity

    usage has increased compared to conventional systems I had on previous homes but my gas

    consumption has dramatically decreased.

    I do suggest Fortis look into rectifying this situation as, besides my own increasingly irate

    position on this (just received another outrageous bill where the Block 2 charge is 1 times the

    block 1 amount), I can see the beginnings of a groundswell of discontent amongst other users in

    the same situation (ex: the upcoming meeting in Penticton & the petition signed in Oliver PLUS

    feedback from folks in my neighborhood!).

    I take pride in the attempts we have made over the years to conserve power, equipping our

    new home with an air-based heat pump, and installing windows that capture solar heat in thewinter. I even sited my house to face directly South on June 21st 1994 to maximize the

    exposure to the sun. I equipped the South side of my house with 4 foot Eaves to provide shade

    in the summer and minimize the need for air conditioning, but still allow the low winter sun to

    enter and heat my home. On sunny days my heating systems rarely runs because of the solar

    heat, even in below zero weather.

    I also bragged that I was able to keep my total utility bill under $1200. for the entire year for a

    very long time until your Utilities Commission and the Power Company (Fortis in my case) began

    to jack the rates regularly. The end result now is my bill is $1025.63 and that is just the first

    quarter of 2013. We live in a province that is power rich and this is the best our government

    and utility companies can do? I hate to think what my total bill will be for 2013. My last bill Dec

    12 to Feb 13 was 30% higher than last year for the same period. You have definitely eroded mydesire to conserve energy or anything else for that matter. There is definitely no reward in

    doing it.

    To say that this two-tier billing system is a conservation program is laughable. It is a

    punishment program for all older citizens who are on fixed incomes and who must rely on

    electricity to heat and light their homes. The BCUC must be told to return to the one lower rate

    system so people can plan their food and rent budgets more closely. As citizens of this country

    we should be entitled to power and water at the cheapest possible rates. This will not happen

    as long as you continue to `privatize` power sources and raid B.C. Hydro's profits to make up for

    your mismanaged shortfalls.

    the "Conservation Rate" that was approved to Fortis BC has not considered the novel practice

    of net metering sufficiently. This is understandable since net metering is still practiced by the

    tiniest of minorities of Fortis BC's customers and has likely not appeared on the radar of the

    BCUC sufficiently. However, with energy conservation and development of non-polluting

    renewable energy being generally considered an important objective, policies should be

    developed to encourage, rather than discourage net metering. The latter has unfortunately

    happened with the switch from Fortis BC's previous rate structure to the Conservation Rate. The

    arguments can be found in the attached exchange.

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