Re: FEI RDA Project No / Order G Rate Design Application. Please find enclosed Catalyst Paper s Information Request No. 3.

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February 27, 2018

Mr. Patrick Wruck

Commission Secretary and Manager, Regulatory Support British Columbia Utilities Commission

Suite 410, 900 Howe Street Vancouver, BC

V6Z 2N3

Re: FEI RDA 2016. Project No. 3698899 / Order G-6-17 2016 Rate Design Application Dear Mr. Wruck:

Please find enclosed Catalyst Paper’s Information Request No. 3.

Sincerely,

Jouni Martiskainen Energy Specialist

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Topic 1: Cost Comparison of Proposed RS22 and VIGJV

Contract

In FEI’s Application Table 9-27, shown below, summarizes, “ … the revenue, change in revenue and change in rates for RS 22 and the VIGJV.” [1] It appears that the second last row in the table, “VIGJV Revenue (including System Gas)”, is calculated by taking the daily firm volume of 13,000 GJ/day and multiplying it by 365 days/year and $ 0.97/GJ for Current Rate and Option 1 for a total of $ 4,588,000. However, the revenue FEI collects from the VIGJV includes interruptible volume as well. Moreover, the row description states that “System Gas” cost is included, however the simple calculation above indicates the System Gas cost is not included.

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1.

Please confirm that the “VIGJV Revenue (including System Gas)” values

shown in the table include the value of the System Gas.

2.

Please confirm that Table 9-27 only represents the firm revenue and does not

include any interruptible revenue.

3.

Please confirm that the “VIGJV Revenue (including System Gas)” dollar value

for Option 2 does not include FEI revenue collected for balancing charges. If it

does include balancing charges, please state the balancing volume and

balancing revenue.

4.

Please update Table 9-27 to include separate rows for: Interruptible Revenue,

System Gas, and Balancing Charges.

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In FEI’s response to BCUC-FEI IR 1.35.1 [2], FEI supplied the following table showing

total revenue and costs for the VIGJV,

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5.

Please confirm that the Total Revenue shown for Joint Venture does not

include the value of any System Gas supplied by VIGJV to FEI.

6.

Please confirm that the Allocated Costs shown for Joint Venture includes an

appropriate debit for System Gas supplied by VIGJV to FEI.

7.

Please state the dollar value of System Gas used in the data for this table for

each customer. If System Gas is not represented in this table, please state the

dollar value of System Gas for each customer applicable for the time frame

represented in table.

8.

Please confirm whether a specific System Gas charge is applicable to other

large industrial firm transportation customers within FEI’s service area.

Specifically, for customers taking firm service under RS22, RS22A, and

RS22B, what is the dollar value of the System Gas charge?

In the Application FEI states [3],

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9.

Please disclose the “portion of system gas” covered by the VIGJV as a

percentage of the total system gas required for VIGJV’s service.

10.

Please detail and explain where BCH IG and VIGJV System Gas received by

FEI is accounted for in the financial schedules in the Application.

Topic 2: Treatment of VIGJV’s Contribution To RRDA/RSDA

in Rate Design

In Catalyst’s IR No. 2, FEI was asked to supply the annual contributions from the VIGJV to the RRDA, RSA, and 2009 Surplus Account, Catalyst-FEI IR 2.24 [4]. In response, FEI stated, “… it is not possible to know how much of the revenue from any of FEVI’s rate schedules, prior to amalgamation, contributed to the accumulated deficiency in the Revenue Deficiency Deferral Account (RDDA), contributed to paying off the accumulated deficiency in the RDDA or contributed to the surplus in the RSDA.” [4]. Please refer to financial schedule 34B-10 below, which Catalyst Paper has previously submitted during this RDA [5], which shows the Utility, prior to amalgamation, accounting for contributions to the RDDA by class and by customer (VIGJV). This appears inconsistent to FEI’s initial response to Catalyst-FEI IR 2.17.

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11.Please summarize the contributions that the VIGJV made to the RDDA, RSDA, and

2009 Surplus Account in the table below.

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In Catalyst-FEI IR 2.32 [6], Catalyst asked,

======================================================================= 32. Please confirm whether the VIGJV has received any benefit from its contribution to the

former Vancouver Island utility’s RDDA, 2009 Surplus Account, or RSDA.

======================================================================= and FEI’s response was [6],

“Please refer to the responses to Catalyst-FEI IRs 2.24 and 2.26. The VIGJV has received the benefit of reliable natural gas delivery service at Commission-approved contract-based rates prior to and after the amalgamation of the three natural gas utilities that now make up FEI.”

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12. The former Vancouver Island Utility’s core customers received reliable natural gas delivery service at Commission approved rates prior to and after the amalgamation of the three natural gas utilities as did the VIGJV. The core customers received an additional benefit of a 38 % rate reduction for their contribution to the $ 99 M RRDA/RSDA surplus that was distributed to FEI customers [7]. Did VIGJV receive a similar additional benefit for its contribution to the $ 99 M surplus that was distributed to FEI customers? If not, please explain.

In the Commission’s original decision to allocate the VIGJV’s IT revenue to the RDDA, the Commission stated (emphasis added) [8],

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======================================================================= 13. It appears that the Commission’s intent was that both the CDS (Centra Distribution System) customers and HPTS (High Pressure Transmission System) customers, core and VIGJV

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customers respectively, would “substantially benefit” from the RDDA balance reduction, which turned into an RSDA surplus. The CDS customers received a 38 % rate reduction for their contributions to the RDDA/RSDA [7]. Please confirm the rate impact for HPTS customers associated with their contributions to the RDDA/RSDA.

Topic 3: Treatment of VIGJV’s IT Revenue

In the Commission’s original decision to allocate the VIGJV’s IT revenue to the RDDA, the Commission stated (emphasis added) [8]

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====================================================================== In the TGVI 2010 – 2011 Revenue Requirements proceeding in response BC Hydro IR No.2.1.1, a question with respect to treatment of IT revenue, FEI stated [9] ,

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======================================================================= In this response, FEI seems to acknowledge that the original 2003 Commission decision to direct IT revenue to the RDDA “at this time” is nearing its end.

14.Since the RDDA mechanism is not currently in effect, is FEI still of the view that it is

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In response to Catalyst-FEI IR 2.29 [10], shown below, FEI stated,

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======================================================================= For further clarity;

15.Please disclose FEI’s best estimate for the cost of interruptible transmission service on

a $/GJ basis.

16.Please confirm whether FEI’s net variable cost of interruptible service for VIGJV is

positive. In other words, please confirm that the VIGJV pays for less than 100 % of the required System Gas (fuel gas, system gas, odorant, and UAC).

17. In this Application, FEI has stated that RS22 Service (almost entirely interruptible) has a R:C ratio of 1425 % [11], indicating FEI can estimate the R:C ratio of interruptible service. Please disclose the R:C ratio for VIGJV’s Interruptible Service.

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18.Please confirm the basis or approval for allocating VIGJV IT Revenue to the RSDA in

TGVI’s 2010-2011 Revenue Requirements and Rate Design application.

19.Aside from the 2003 Commission Determination [13], please reference the explicit

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Topic 4: Proposed VIGJV Cost Allocation

In response to Catalyst-FEI IR 2.1 [14], shown below, FEI states, “The above cost

allocation is also inappropriate because it is inconsistent with FEI’s customer

segmentation”.

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20.Since the VIGJV and BCH are not part of any FEI rate schedule, please clarify how

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21.Since the above cost allocation methodology, just using transmission system costs, has been used throughout the history of the VIGJV why does FEI believe the cost allocation is inappropriate?

22.Since the above cost allocation is identical to the cost allocation for 14 large, industrial

firm transportation customers in RS22A and RS22B, how can the cost allocation be inconsistent with FEI’s customer’s segmentation?

23.Does FEI not consider 13,000 GJ/day of firm demand relative to 0 GJ/Day of firm

demand (RS22) a significant “dissimilar characteristic”?

In response to Catalyst-FEI IR 2.3 [15], shown below, FEI states, “… VIGJV attracts distribution costs based on their firm demand of 13 TJ/Day and based on 5 customers (5 mills). Overall, this amounts to approximately 1.27 percent of Distribution demand-related costs and 0.58 percent of the Distribution customer-related costs totaling $ 2.2 million and $ 1.7 million.”

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======================================================================= In previous COSA led by the Utility and EES Consulting (2002, 2010), it was perfectly appropriate for the VIGJV to attract zero distribution costs [5,13]. EES Consulting also led the COSA in this current application.

24.Please explain how the Utility/EES Consulting can deem it appropriate for the VIGJV

to attract zero distribution costs in previous COSA [5,13], and then propose full distribution cost allocation for the exact same customers (VIGJV and BCH IG) in this current Application.

25. In order to justify FEI’s claim that the VIGJV attracts, “1.27 percent of Distribution demand-related costs and 0.58 percent of the Distribution customer-related costs totaling $ 2.2 million and $ 1.7 million,” [15 ] please fill in the table below, specifying the quantity of distribution pipe allocated to the VIGJV, BCH IG, RS22A, RS22B, and RS1-7,22-27. For reference, FEI’s Distribution Mains summary from the Application [16], is shown below.

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In response to Catalyst-FEI IR 2.6 [17], shown below, FEI states,

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26.Please explain why FEI thinks comparing VIGJV’s historical (pre-2012) allocated cost

of service with the proposed cost of service in this Application is inappropriate?

27.Please list the most recent COSA that included the VIGJV.

In response to Catalyst-FEI IR 2.45 [18], shown below, FEI states,

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Unfortunately, FEI’s response and Attachment 45, Schedule 3 and 4 fail to answer the question in detailing the distribution demand cost allocation for each customer. FEI’s answer appears to detail total demand cost allocation (transmission and distribution), but fails to show distribution demand cost allocation by customer as per the question.

28.Please supply the distribution demand cost allocation for each customer in the table as

requested.

In Catalyst-FEI IR 2.18 [19], shown below, FEI shows the Allocation Cost of Service from Catalyst-FEI IR Response 2.16, which represents FEI’s amalgamated utility transmission cost of service.

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In BCUC-FEI IR 1.35 [20], FEI provided the following table which included Transmission and Distribution costs and total revenue,

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======================================================================= When combining the above 2 tables, shown below, the data shows that the cost differential for using a common transmission cost allocation vs. FEI’s proposal is minimal for RS22A and RS22B, but is significant for BCH IG and VIGJV. The data in the table is not exact, but the material impact of allocating distribution costs only to VIGJV and BCH IG is clear.

29. Please format the data in the above table to enable the reader to accurately compare the allocated costs for customers using past practice methodology (exclusion of distribution costs for all customers in RS22A, RS22B, VIGJV, and BCH IG) vs. FEI’s proposal (adding distribution costs only to the VIGJV and BCH IG).

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Topic 5: Customer Segmentation and Grouping

In Catalyst-FEI IR 2, shown below, FEI states, [21]

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FEI’s theme appears to be that VIGJV, RS22A, RS22B customers that all have significant firm demand, should be grouped together with the interruptible customers within RS22. FEI also states that its treatment of RS22A and RS22B “is consistent with the Commission determination to close these rate schedules in its 1993 Phase B Rate Design Decision”[21].

The Commission in its 1993 Phase B Rate Design Decision explicitly stated, [22]

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======================================================================= Since the rationale for separating RS22A and RS22B from RS22 and closing rate schedules 22A and 22B was based on the fact that, “ … all of these interior customers moved their direct purchase gas on firm service,” and, “ … they differed from Lower Mainland large volume customers, who had historically been interruptible sales …”, FEI’s statement that it is currently appropriate to bundle the firm service of the VIGJV and BCH IG with the interruptible service of RS22 seems odd.

30. Please confirm that VIGJV, RS22A, and RS22B customers all have significant firm demand.

31.Please confirm that RS 22 customers, except for Creative Energy, have no firm

demand.

32. Please clarify FEI’s justification for the proposed grouping of RS22 Interruptible Service customers with the firm service customers of the VIGJV and BCH IG. 33. Please clarify FEI’s justification for suggesting that RS22A and RS22B firm service

should also be grouped with RS22 Interruptible Service customers if they were not grandfathered.

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34. Please explain FEI’s understanding of how this grouping would be “consistent with the Commission decisions to close these rate schedules in its 1993 Phase B Rate Design Decision.”

35. Please confirm that the Utility segregated customers in RS22A and RS22B from RS22 based on the presence or absence of firm demand, as supported by the 1993 Phase B Rate Design Decision.

36. Since RS22A and RS22B were separated from RS22 based on Lower Mainland RS22 customers having no firm demand, and nothing has changed in that respect since 1993, then why is FEI suggesting these customers should be grouped together again?

37. Please reconcile FEI’s current proposal to group firm service customers (VIGJV/BCH IG) with interruptible service customers (RS22) with the Commission’s 1993 Phase B Rate Design Decision to segregate RS22A and RS22B from RS22.

Topic 6: VIGJV and BCH IG Customer Classification

Prior to Amalgamation, VIGJV and BCH IG were considered Transmission customers by the Utility. During the FEU Common Rates, Amalgamation and Rate Design Application, the Utility referred to VIGJV/BCH IG as distinct customers, as shown below, [23]. Here the Utility clearly makes the distinction that LCS-13 Transportation Service is provided via the “distribution system”, while VIGJV/BCH IG are “two transmission customers … who are served off the transmission pipeline”. It follows that the Utility stated that VIGJV/BCH IG do not receive service via the distribution system.

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======================================================================= Also, in FEU Common Rates, Amalgamation and Rate Design Application, [24], shown below, FEI made a commitment to “continue to provide the transmission transportation service offering upon amalgamation”, emphasis added, for VIGJV and BCH IG.

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======================================================================= In response to Catalyst-FEI IR 2.9 [25], shown below, FEI states,

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======================================================================= In FEU Common Rates, Amalgamation and Rate Design Application, [26,27], shown below, FEI explicitly states that Amalgamation has no affect on VIGJV and their common rates proposal does not impact VIGJV and BCH IG,

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40)Since the Utility stated that amalgamation and common rates had no affect on and

gave no consideration to VIGJV/BCH IG, RS22A, and RS22B why is FEI now proposing to selectively apply common distribution rates to just VIGJV and BCH IG?

41)Please reconcile FEI’s proposal to apply a common distribution rate to VIGJV and

BCH IG after amalgamation with FEI’s stated intentions given to the Commission as noted above.

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References:

1. FEI RDA 2016, Exhibit B-1, Table 9-27.

2. FEI RDA 2016, Exhibit B-5, Letter dated June 9, 2017 – FEI Submitting Response to BCUC IR No. 1, page 178.

3. FEI RDA 2016, Exhibit B-1, page 9-42, lines 17-27.

4. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 17.

5. TGVI 2010 – 2011 Revenue Requirements, Exhibit B-1, TGVI Application for Approval of 2010 and 2011 Revenue Requirements, Rates, Cost of Service, Rate Design and Revenue Deficiency Deferral Account Balance as at December 31, 2008, Financial Schedule 43B-10, page 554 of 1487.

6. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 24.

7. FEU Common Rates, Amalgamation and Rate Design Application, Exhibit B-3, Table 8-11: Estimated Annual Bill Impact Comparison for Typical Residential Customers, page 172. 8. Centra Gas British Columbia Inc. 2002 Rate Design Application. Order No. G-42-03;

Decision, page 37.

9. TGVI 2010 – 2011 Revenue Requirements, Exhibit B-8, page 1.

10. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 22.

11. FEI RDA 2016, Exhibit B-1, Table 6-19: R:C & M:C Ratio Results for Rates Schedules Not Set Using COSA allocations, page 6-36.

12. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 23.

13. Centra Gas British Columbia Inc. 2002 Rate Design Application. Order No. G-42-03; Decision.

14. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 1.

15. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 3 and 4.

16. FEI RDA 2016, Exhibit B-1, Appendix 6-5, Minimum System Study Results and Peak Load Carrying Capacity Study Results, Table 1, Page 2 (page 1299 of 1782 in the Application). 17. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2

Response to Catalyst, page 5.

18. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 39.

19. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, page 13.

20. FEI RDA 2016, Exhibit B- 5, Letter dated November 7, 2017 – FEI Submitting Response to BCUC IR No.1, page 178.

21. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2 Response to Catalyst, pages 2, 4, 6, 7.

22. BCUC Phase B Rate Design Decision, October 25, 1993, pages 44-45.

23. FEU Common Rates, Amalgamation and Rate Design Application, Exhibit B-3, page 120. 24. FEU Common Rates, Amalgamation and Rate Design Application, Exhibit B-3, page 135. 25. FEI RDA 2016, Exhibit B-24, Letter dated November 7, 2017 – FEI Submitting IR No. 2

Response to Catalyst, page 7.

26. FEU Common Rates, Amalgamation and Rate Design Application, Exhibit B-3, page 136. 27. FEU Common Rates, Amalgamation and Rate Design Application, Exhibit B-3, page 178.

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