Re: Matter 541 - NB Power Rate Design Interesting news from CBC
David Amos<david.raymond.amos333@gmail.com> | Tue, Mar 28, 2023 at 4:06 PM |
To: "Holland, Mike (LEG)" <mike.holland@gnb.ca>, "blaine.higgs" <blaine.higgs@gnb.ca>, "Robert. Jones" <Robert.Jones@cbc.ca> | |
Cc: "Abigail J. Herrington" <Aherrington@lawsoncreamer.com>, "Mitchell, Kathleen" <Kathleen.Mitchell@nbeub.ca>, "Williams, Richard (OAG/CPG)" <Richard.Williams@gnb.ca>, "ceo@fermenbfarm.ca" <ceo@fermenbfarm.ca>, "louis-philippe.gauthier@cfib.ca" <louis-philippe.gauthier@cfib.ca>, "frederic.gionet@cfib.ca" <frederic.gionet@cfib.ca>, "Ron.marcolin@cme-mec.ca" <Ron.marcolin@cme-mec.ca>, "Sollows, David (DNRED/MRNDE)" <David.Sollows@gnb.ca>, "hanrahan.dion@jdirving.com" <hanrahan.dion@jdirving.com>, "nrubin@stewartmckelvey.com" <nrubin@stewartmckelvey.com>, "coneil@stewartmckelvey.com" <coneil@stewartmckelvey.com>, "lmclements@stewartmckelvey.com" <lmclements@stewartmckelvey.com>, "pbowman@bowmaneconomics.ca" <pbowman@bowmaneconomics.ca>, "brudderham@stewartmckelvey.com" <brudderham@stewartmckelvey.com>, "JohnFurey@fureylegal.com" <JohnFurey@fureylegal.com>, "jpetrie@nbpower.com" <jpetrie@nbpower.com>, "NBPRegulatory@nbpower.com" <NBPRegulatory@nbpower.com>, "lgordon@nbpower.com" <lgordon@nbpower.com>, "SWaycott@nbpower.com" <SWaycott@nbpower.com>, "George.Porter@nbpower.com" <George.Porter@nbpower.com>, "bcrawford@nbpower.com" <bcrawford@nbpower.com>, Veronique Otis <Veronique.Otis@nbeub.ca>, "Young, Dave" <Dave.Young@nbeub.ca>, NBEUB/CESPNB <General@nbeub.ca>, "Colwell, Susan" <Susan.Colwell@nbeub.ca>, "bhavumaki@synapse-energy.com" <bhavumaki@synapse-energy.com>, "mwhited@synapse-energy.com" <mwhited@synapse-energy.com>, "prhodes@synapse-energy.com" <prhodes@synapse-energy.com>, "alawton@synapse-energy.com" <alawton@synapse-energy.com>, "jwilson@resourceinsight.com" <jwilson@resourceinsight.com>, "pchernick@resourceinsight.com" <pchernick@resourceinsight.com>, Melissa Curran <Melissa.Curran@nbeub.ca>, "rdk@indecon.com" <rdk@indecon.com>, "tammy.grieve@mcinnescooper.com" <tammy.grieve@mcinnescooper.com>, "paul.black@twinriverspaper.com" <paul.black@twinriverspaper.com>, Len Hoyt <Len.Hoyt@mcinnescooper.com>, "tyler.rajeski@twinriverspaper.com" <tyler.rajeski@twinriverspaper.com>, "darcy.ouellette@twinriverspaper.com" <darcy.ouellette@twinriverspaper.com>, "dan.murphy@umnb.ca" <dan.murphy@umnb.ca>, "jeff.garrett@sjenergy.com" <jeff.garrett@sjenergy.com>, "shelley.wood@sjenergy.com" <shelley.wood@sjenergy.com>, "dan.dionne@perth-andover.com" <dan.dionne@perth-andover.com>, "pierreroy@edmundston.ca" <pierreroy@edmundston.ca>, "ryan.mitchell@sjenergy.com" <ryan.mitchell@sjenergy.com>, "sstoll@stollprofcorp.com" <sstoll@stollprofcorp.com>, "pzarnett@bdrenergy.com" <pzarnett@bdrenergy.com> | |
Saturday price hike for electricity in N.B. a projected 4.8 per cent
Changes ordered by utility board cut $50 million from proposed increase
In a letter to the EUB, responding to a series of changes required by the regulator following a two week hearing in February, N.B. Power's Stephen Waycott said making alterations will lower the rate increase from the 8.9 per cent applied for, to 5.7 per cent. An additional rebate due to customers from another issue that also takes effect on April 1 will further reduce new charges customers face.
"The combined impact … is that NB Power's in-province customers will see an average increase in electricity rates of 4.8 percent in 2023/24," wrote Waycott, who is N.B. Power's director of corporate compliance and regulatory affairs.
Every one per cent change in rates is worth just under $16 million per year to the utility.
Nancy Rubin (right) led a team of three lawyers hired by J.D. Irving Ltd. to fight N.B. Power's rate application. The group, including Brianne Rudderham (left), forced N.B. Power to provide updated budget numbers for next year that led to a reduced increase. (Ed Hunter/CBC)
For a residential customer with an annual power bill of $3,000, the new prices will add $144 plus HST in yearly charges. Separately, the utilities board also approved a $1 per month increase to customers who rent water heaters from N.B. Power, which would add to that rate increase amount.
The board still needs to grant a final approval to the changes, but that is mostly a formality. Municipal utilities in Saint John, Edmundston and Perth Andover are expected to adopt the same percentage increases for their own customers.
N.B. Power originally applied for an 8.9 per cent increase in its rates in early October, hoping to have it approved for the beginning of its next fiscal year, which begins on April 1.
It's application was challenged aggressively over eight days at hearings in February, especially by its largest private sector customer, J.D. Irving Ltd.
N.B. Power burns oil to generate electricity at its Coleson Cove generating station in Saint John. Prices for the commodity have been coming down which has led to a reduction in N.B. Power's rate increase. (Roger Cosman/CBC)
The forestry, transportation and consumer products company hired three lawyers to fight the increase. The group successfully challenged N.B. Power's use of stale data in the case it was making for higher prices.
N.B. Power had been claiming the high prices for commodities it uses to run its largest generators would attack its bottom line in the coming year.
"In a single year, the cost of fuel and purchased power necessary to supply customers in New Brunswick has increased by $102.8 million," N.B. Power president Lori Clark told the hearing on its opening day.
"This has occurred largely due to market price increases for natural gas, heavy fuel oil and electricity."
All New Brunswick electricity customers are likely to see a 4.8 per cent increase in rates beginning on Saturday. (Robert Jones/CBC)
But those claims were based on old prices from months earlier in June, 2022.
During hearings, the utility acknowledged it had fresher data internally that showed some prices had moderated, and prospects for exporting power had improved significantly.
In a preliminary ruling two weeks ago, the EUB told the utility it needed to use the more up-to-date numbers.
"The Board is not satisfied that the rates, as applied for, are just and reasonable," it wrote in demanding changes.
"NB Power is ordered to refile its 2023/2024 test year budget … and the resulting rates."
The new calculations show that despite losing one third of the requested rate increase, N.B. Power's projected profit for the coming year has more than doubled to $30 million by using the new figures.
N.B. Power did not immediately respond to a request for comment about the changes.
We do still live in a free Country, don't we ??
No way will I allow NB Power to tell me when
I can use my appliances.
Don't get me wrong, I do everything I can to
'help' NB Power , I follow the 'rule' of using Energy
in the hours they suggest and I've invested
in a Heat Pump.
Re: Matter 529 - NB Power Rate Design I noticed that J.D. Irving Limited did not send me its IRs today and that their lawyers are blocking my email WHY?
David Amos<david.raymond.amos333@gmail.com> | Thu, Mar 23, 2023 at 3:16 PM |
To: "Mitchell, Kathleen" <Kathleen.Mitchell@nbeub.ca> | |
Cc: "Abigail J. Herrington" <Aherrington@lawsoncreamer.com>, "Williams, Richard (OAG/CPG)" <Richard.Williams@gnb.ca>, "ceo@fermenbfarm.ca" <ceo@fermenbfarm.ca>, "louis-philippe.gauthier@cfib.ca" <louis-philippe.gauthier@cfib.ca>, "frederic.gionet@cfib.ca" <frederic.gionet@cfib.ca>, "Ron.marcolin@cme-mec.ca" <Ron.marcolin@cme-mec.ca>, "Sollows, David (DNRED/MRNDE)" <David.Sollows@gnb.ca>, "hanrahan.dion@jdirving.com" <hanrahan.dion@jdirving.com>, "nrubin@stewartmckelvey.com" <nrubin@stewartmckelvey.com>, "coneil@stewartmckelvey.com" <coneil@stewartmckelvey.com>, "lmclements@stewartmckelvey.com" <lmclements@stewartmckelvey.com>, "pbowman@bowmaneconomics.ca" <pbowman@bowmaneconomics.ca>, "brudderham@stewartmckelvey.com" <brudderham@stewartmckelvey.com>, "JohnFurey@fureylegal.com" <JohnFurey@fureylegal.com>, "jpetrie@nbpower.com" <jpetrie@nbpower.com>, "NBPRegulatory@nbpower.com" <NBPRegulatory@nbpower.com>, "lgordon@nbpower.com" <lgordon@nbpower.com>, "SWaycott@nbpower.com" <SWaycott@nbpower.com>, "George.Porter@nbpower.com" <George.Porter@nbpower.com>, "bcrawford@nbpower.com" <bcrawford@nbpower.com>, Veronique Otis <Veronique.Otis@nbeub.ca>, "Young, Dave" <Dave.Young@nbeub.ca>, NBEUB/CESPNB <General@nbeub.ca>, "Colwell, Susan" <Susan.Colwell@nbeub.ca>, "bhavumaki@synapse-energy.com" <bhavumaki@synapse-energy.com>, "mwhited@synapse-energy.com" <mwhited@synapse-energy.com>, "prhodes@synapse-energy.com" <prhodes@synapse-energy.com>, "alawton@synapse-energy.com" <alawton@synapse-energy.com>, "jwilson@resourceinsight.com" <jwilson@resourceinsight.com>, "pchernick@resourceinsight.com" <pchernick@resourceinsight.com>, Melissa Curran <Melissa.Curran@nbeub.ca>, "rdk@indecon.com" <rdk@indecon.com>, "tammy.grieve@mcinnescooper.com" <tammy.grieve@mcinnescooper.com>, "paul.black@twinriverspaper.com" <paul.black@twinriverspaper.com>, Len Hoyt <Len.Hoyt@mcinnescooper.com>, "tyler.rajeski@twinriverspaper.com" <tyler.rajeski@twinriverspaper.com>, "darcy.ouellette@twinriverspaper.com" <darcy.ouellette@twinriverspaper.com>, "dan.murphy@umnb.ca" <dan.murphy@umnb.ca>, "jeff.garrett@sjenergy.com" <jeff.garrett@sjenergy.com>, "shelley.wood@sjenergy.com" <shelley.wood@sjenergy.com>, "dan.dionne@perth-andover.com" <dan.dionne@perth-andover.com>, "pierreroy@edmundston.ca" <pierreroy@edmundston.ca>, "ryan.mitchell@sjenergy.com" <ryan.mitchell@sjenergy.com>, "sstoll@stollprofcorp.com" <sstoll@stollprofcorp.com>, "pzarnett@bdrenergy.com" <pzarnett@bdrenergy.com> | |
Matter No. 529 NEW BRUNSWICK ENERGY AND UTILITIES BOARD INTERROGATORY (Rule 4.2) In Relation to an Application by: New Brunswick Power Corporation (“NB Power”) In Accordance with: Section 103(1) of the Electricity Act, SNB 2013, c.E-7, to the New Brunswick Energy and Utilities Board (the “Board”) with respect to proposed changes to its rate structure, rates classes and rate design. TO: New Brunswick Power Corporation FROM: J.D. Irving Limited (“JDI”) NB Power (JDI) IR-1 March 23, 2023 Reference: In response to JDI Round 1 IR-20i, NBP provided CCAS models for monthly and seasonal cost allocation alternatives. These questions specifically reference Exhibit NBP 07.14, NBP Response to JDI IR-20gi – Attachment on the ‘CCAS Seasonal Monthly Model’ and Exhibit NBP 07.16 NDP Response to JDI IR-20i iii Attachment CCAS Seasonal ‘Alternative 1’ which provides seasonal allocation for the variable costs (specifically fuel costs). Similar scenarios were described in an Elenchus report filed in Matter 357, Exhibit NBP 2.03. Page 9 of that report in explanation of the seasonal allocation of variable costs only scenario explains: As a sensitivity, Elenchus has considered the option of applying seasonality to only the variable costs. NB Power affirms that amortization costs, plant capital costs, and most plant OM&A are indeed fixed costs which do not vary by production. The costs which differ by season are indeed the fuel, and imports (net of exports). Therefore, for this sensitivity, only the fuel and imported energy (net of exports) is considered for seasonality. This question also references NBP Exhibit 1.20 as a comparison, which is the proposed CCAS model for the same 2020-2021 Fiscal year as provided in the referenced models above. JDI is analysing cost drivers to help determine appropriate class categorization and rate design priorities given the NBEUB’s rate design goals of equity and adaptability for future changes as addressed in the Board Decision on Matter 357. Questions: (a) In regards to Exhibit NBP 07.16 please explain why purchases (less exports) of $331.127 million are not allocated seasonally (as shown in Schedule 3.2) but instead uses the ‘average demand’ allocator, given the Elenchus explanation of the scenario referenced above. Please explain your reasoning in light of the significant monthly variation for net purchases as shown in Schedule 1.6. (b) Please provide any analysis or ‘working papers’ NB Power or Elenchus undertook with regard to purchases (less exports) regarding classification and cost allocation, including especially where the work undertaken lead to the conclusion to not include in seasonal/monthly allocations. (c) Please also explain why NBP determined not to allocate purchases (less exports) of $331.127 million on a monthly basis in Exhibit NBP 7.14, instead again choosing to use the average demand allocator (as seen in Schedule 3.2). In your response, please explain your reasoning in light of the significant monthly variation for net purchases as shown in Schedule 1.6. (d) Please provide versions of NBP 07.14 and NBP 07.16 that allocate purchases (less exports) on a monthly and seasonal basis respectively. (e) Please identify what years Schedules 1.5 and 1.6 from Exhibits NBP 07.14 and 07.16 are based on. (i) If Schedules 1.5 and 1.6 are not based on the 2020-2021 fiscal year budget, please explain the rationale behind using a different year for the data. (ii) please provide Schedules 1.5 and 1.6 for the 2021-21 fiscal year budget, for both Exhibits NBP 07.14 and NBP 07.16. (iii) Please explain how these values are used for the monthly and seasonal distribution of average-demand classified costs. (iv) Please correlate net purchases from Schedule 1.6 of $355.003 million to the net purchases allocated on the basis of average demand in Schedule 3.2 and 4.2 of $331.127 million. (f) For direct-assigned fuel to the interruptible/surplus Large Industrial rate class – please explain how the $28.813 million (i.e. quantity and price) is derived and compare to the tracked monthly and seasonal allocated fuel quantity and prices (e.g. in Exhibit NBP 7.14). (g) Please provide the interruptible/surplus sales and related fuel costs of $28.813 million on a monthly and seasonal basis. (h) For Exhibit NBP 07.14, please explain how Amortization, OM&A and interest and net income (deferral account interest) is split by month. Please reference functionalized monthly allocations as provided in Schedule 1.5 (Generation by Plant) and Schedule 1.6 (Fuel Cost by Plant) if these are used to explain the basis of the monthly split for each of nuclear, thermal and hydro. If these are not used, please explain what information is. (i) Please confirm that the seasonal alternative in Exhibit NBP 07.16 is the same methodology as described above, but sums November – March for the “winter” season and April to October for the “summer” season. (ii) If not confirmed, please explain the methodology used and why it was different than the monthly scenario. (i) For Schedule 4.2, Column 12 ‘Energy Efficiency Specific’ customer allocations and total of $17.778 million as provided in Exhibit NBP 07.14 and NBP 07.16 (as well as the proposed CCAS model provided in Exhibit NBP 1.20), please reconcile the allocation and total to the currently approved CCAS model provided in Exhibit NBP 1.15. In your response, please specifically highlight if there are offsetting costs and customer allocated impacts occurring elsewhere in the CCAS model as a result of the change. (i) Please reference the CCAS model that this stepped change is highlighted in (eg. NBP Exhibit 1.18) and detail the methodological change taking place in the model. (j) Please fully explain the rationale for each of the cost of service steps that are experiencing a methodological change including - functionalization, classification, allocation and direct-assign. NB Power (JDI) IR-2 March 23, 2023 Reference: Exhibit NBP 07.25 Attachment to JDI IR-15a – Load Factor vs. Usage Questions: (a) In respect of the “large transmission” class noted in Exhibit 1.11, page iii, what is the test for “large”? (b) Please confirm (or otherwise explain) that the entire group of transmission connected customers are included in this class, regardless of their size. (c) Exhibit NBP 7.25 references 24 accounts for the ‘IB – Large Industrial’ rate category in the Transmission subcategory. Meanwhile, Table 10 from NBP Exhibit 7.18 states there are 41 customers at this level. Please explain why the full 41 accounts were not provided. (d) Please provide an updated Exhibit 07.25 for all 41 accounts. To the extent there are any ‘confidentiality’ concerns and values must be omitted, provide the rows that are public and provide stand in or proxy amounts (i.e. approximate values that won’t divulge confidentiality that give context to magnitude and usage profiles) in comparison to the other transmission accounts. (e) With respect to the accounts noted in (d), please also provide NCP, coincident peak, and annual load factor per account. NB Power (JDI) IR-3 March 23, 2023 Reference: Exhibit NBP04.76, NBP(PI) IR-15a Attachment – Working Papers – Bill_Impact_Deciles Exhibit BP04.01, In response to NBP-NBEUB IR-8 where the NBEUB asks under Alternative 4 if customers with a high bill index would be paying bills consistent with cost causation principles, NB Power states that: For Alternative 4, the basis of Table 3.6a, prices are set at unit cost. Therefore, by definition, each customer is moved to full cost coverage. Questions: a) If Alternative 4 is adopted as a result of this proceeding, is the unit cost billing approach the plan NB Power is going to propose pursuing to enact differential rate adjustments? If not, please explain. b) For the working papers listed above - specifically tabs ‘b_alt4_by_orig_rate’ and ‘b_alt_4’ – please provide the calculation inputs for each tab for the Large Industrial customers including unit costs, underlying rates used, data year, load factors, etc. underlying each calculation. Please provide by decile. c) For the unit costs used to calculate the bill impacts, please indicate the specific CCAS model used (i.e. the year used for input data, methodology, etc.) and provide the reference to the specific schedule for the unit cost values used. d) If the analysis done in the referenced working paper did not use CCAS methodology for revenue calculations, but instead used unit costs to calculate ‘alt_bill” please specify how Out-Of-Province revenue allocations have been incorporated. NB Power (JDI) IR-4 March 23, 2023 Reference: In NB Power’s Application for the AMI Capital Project (Matter 452, Exhibit NBP 1.03) it listed three fundamental shifts impacting the electricity industry to justify the expenditure: (a) Transformational changes with respect to advancing technology, including falling distributed energy resources, customer owned-generation, transportation electrification and electricity system operational advancements (including AMI); (b) Evolving customer expectations and demands to control their energy needs (including to self-generate from renewable resources); and (c) Climate change requiring a fundamental shift in the supply-side options to meet customer needs, which NB Power is investing in as part of its Energy Smart NB Plan. [summarized from Application pages 4-6]. In Exhibit NBP04.01, responding to NBP (NBEUB) IR-11a&b NB Power explains it does not have current plans for Customer Energy solutions past its water heating, area lighting and Sureconnect plans, but believes expanded product offerings could be available that meet these conditions in the next 5 years. In Exhibit NBP04.01, responding to NBP (NBEUB) IR-16, NB Power states it has not evaluated potential Canadian Electricity Regulation (CER) impacts as they remain uncertain with anticipated release of the CER by the federal government in 2023, however NB Power notes it supports the provincial governments net-zero electricity emissions by 2035 goal. Questions: (a) With regard to the “fundamental shifts” articulated by NBP including evolving customer expectations to control their energy needs/costs and pending regulations/goals that will push NB Power’s electricity supply towards decarbonization, what considerations has NB Power included in its rate design proposal that will help support these requirements? (i) Please provide a specific response with regard to the large commercial and industrial customer rate classes. (b) Please explain how NB Power’s near-term customer segmentation and differential rate adjustment plans support the three ‘fundamental shifts’ described above. On 3/23/23, David Amos <david.raymond.amos333@gmail. > Good Day, > > Please find attached my IRs in PDF and Word. > > David Raymond Amos > Message blocked Your message to nrubin@stewartmckelvey.com has been blocked. See technical details below for more information. LEARN MORE Warning This link will take you to a third-party site Error Icon Message blocked Your message to coneil@stewartmckelvey.com has been blocked. See technical details below for more information. LEARN MORE Warning This link will take you to a third-party site Message blocked Your message to lmclements@stewartmckelvey.com has been blocked. See technical details below for more information. LEARN MORE Warning This link will take you to a third-party site Message blocked Your message to brudderham@stewartmckelvey.com has been blocked. See technical details below for more information. LEARN MORE Warning This link will take you to a third-party site The response from the remote server was: 550 Administrative prohibition - envelope blocked - https://community.mimecast. [LnaF_UIsP52t4l8TIIxIUA.ca14] Final-Recipient: rfc822; brudderham@stewartmckelvey.com Action: failed Status: 5.0.0 Remote-MTA: dns; ca-smtp-inbound-2.mimecast.com for the domain stewartmckelvey.com.) 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