Geoffrey Higgins Acting Chief Regulatory Officer ......HBL Historic Baseline load – a measure of historical ... Further to your April 10, 2015 application on the above noted matter,

British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3 www.bchydro.com

Geoffrey Higgins

Acting Chief Regulatory Officer Phone: 604-623-4046 Fax: 604-623-4407 [email protected]

May 15, 2015 Ms. Erica Hamilton Commission Secretary British Columbia Utilities Commission Sixth Floor – 900 Howe Street Vancouver, BC V6Z 2N3 Dear Ms. Hamilton: RE: Project No. 3698832

British Columbia Utilities Commission (BCUC or Commission) British Columbia Hydro and Power Authority (BC Hydro) Application for Approval of Shore Power Rate (Application)

BC Hydro writes in compliance with Commission Order No. G-58-15 to provide its responses to Round 1 information requests as follows:

Exhibit B-2 Responses to Commission IRs

Exhibit B-3 Responses to Intervener IRs

Submission Concerning Remainder of Application Regulatory Review

The Commission’s Regulatory Timetable for the Application (Exhibit A-2 in the Commission’s Shore Power Rate proceeding) provides that on Tuesday, May 19, 2015 BC Hydro is to make written submissions as to whether further Application regulatory review is needed, and if so whether the further review should proceed by way of Streamlined Review Process. BC Hydro seeks an extension to Thursday, May 21, 2015 to make these submissions as it is hosting a meeting on May 20, 2015 of the five interveners in the Application regulatory review process to determine if there is common ground with respect to the need for further Application regulatory review.

BC Hydro also proposes that the date for intervener submissions, with respect to whether further Application regulatory review is needed, should also be extended by two days, to Thursday, May 28, 2015.

B-2

mailto:[email protected]

markhuds

BC HYDRO SHORE POWER RATE

May 15, 2015 Ms. Erica Hamilton Commission Secretary British Columbia Utilities Commission Application for Approval of Shore Power Rate (Application) Page 2 of 2

For further information, please contact Gordon Doyle at 604-623-3815 or by email at [email protected].

Yours sincerely, Original signed

Geoffrey Higgins Acting Chief Regulatory Officer ac/af Enclosures (2) Copy to: Commission Project No. 3698832 (Shore Power Rate Application) Registered

Intervener Distribution List.

mailto:[email protected]

Application for Approval of Shore Power Rate

Page i

Glossary of Commonly Used Terms and Abbreviations in Information Responses

B

B.C.

BCOAPO

BCUC, Commission

British Columbia

British Columbia Old Age Pensioners’ Organization et al

British Columbia Utilities Commission

BCSEA B.C. Sustainable Energy Association and Sierra Club of British Columbia

C

CEC Commercial Energy Consumers Association of British Columbia

CPCN Certificate of Public Convenience and Necessity

D

DSM Demand Side Management

E

EPA Electricity Purchase Agreement

ESA Electricity Supply Agreement

Exhibit B-1 BC Hydro’s Application to the Commission for approval of Shore Power Rate

F

F Fiscal year

FACOS Fully Allocated Cost of Service

G

GHG Greenhouse gas – any of the atmospheric gases that contribute to climate change such as Water Vapour, Methane or Carbon Dioxide



Page ii

GWh Gigawatt-hour – one billion watt-hours or one million kilowatt hours of Electric Energy being an amount of Electric Energy that will serve about 100 residential customers for one year

H

HBL Historic Baseline load – a measure of historical consumption based on a three year average of annual consumption used for Rate Schedules 1600, 1601, 1610 and 1611, expressed in kilowatt-hours (kWh)

I

IRP Integrated Resource Plan

IR Information Request

K

kW Kilowatt

kWh Kilowatt-hour

L

LGS Large General Service

LOO Local Operating Order

LRMC Long Run Marginal Cost

M

Mid-C Mid-Columbia electricity trading hub

MWh Megawatt hour

MW Megawatts

O

O&M Operating and Maintenance



Page iii

P

PMV Port Metro Vancouver

PRPA Prince Rupert Port Authority

R

RDA

RRA

Rate Design Application

Revenue Requirement Application

RS Rate Schedule

T

T&D

TS

Transmission and Distribution

Tariff Supplement

TSR Transmission Service Rate

U

UCA Utilities Commission Act

ERICA HAMILTON COMMISSION SECRETARY

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

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

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

FACSIMILE: (604) 660-1102

Log No. 50015

PF/BCH/Shore Pwr Rate/A-3_Commission IR No. 1

VIA EMAIL [email protected] April 24, 2015 BC HYDRO SHORE POWER RATE

EXHIBIT A-3 Mr. Geoffrey Higgins Acting Chief Regulatory Officer British Columbia Hydro and Power Authority 16th Floor – 333 Dunsmuir Street Vancouver, BC V6B 5R3 Dear Mr. Higgins:

Re: British Columbia Hydro and Power Authority Project No. 3698832 / Order G-58-15

Application for Approval of Shore Power Rate Further to your April 10, 2015 application on the above noted matter, enclosed please find Commission Information Request No 1. In accordance with the Regulatory Timetable, please file your responses no later than Friday, May 15, 2015. Yours truly, Erica Hamilton kbb

BRITISH COLUMBIA UTILITIES COMMISSION INFORMATION REQUEST NO. 1 TO BC HYDRO AND POWER AUTHORITY

British Columbia Hydro and Power Authority Application for Approval of Shore Power Rate

Reference: Exhibit B-1 Application, p. 1-2 1.0Definition of Port Customers

The Application states on page 1-2 that:

Under the Shore Power Rate, the customers are port authorities, terminal operators, wharf operators and dock operators in BC Hydro’s service area (Port Customers). Shore power refers to the electrical services BC Hydro provides to Port Customers who in turn re-sell electricity pursuant to TS 86 to eligible vessels while in port and connected to BC Hydro’s electrical system. Each vessel owner/operator will be considered like a short-term tenant of the Port Customer for electricity supply purposes.

1.1 For greater clarity, would BC Hydro please describe whether a Port Customer is a unique account or a customer with multiple accounts? Please explain if, instead of an existing customer who will set up a separate meter for shore power, a Port Customer can be a new customer setting up specifically to resell shore power.

1.1.1 Table 1-4 on page 1-14 presents the potential shore power uptake at bulk or break-bulk terminals at Port Metro Vancouver or Prince Rupert Port Authority. These facilities are located in multiple locations: North Vancouver, Vancouver, Delta, Prince Rupert and Surrey. Is a Port Customer a location-specific facility such as the terminal operator?

1.2 Please confirm, otherwise explain, that the Port Customer and the eligible vessels be supplied electrical service to one point of interconnection, but will be metered in parallel. Please provide a sample one line diagram identifying the expected point of interconnection, the BC Hydro supply to the Port Customer and the Port Customer meter, the eligible vessel supply and meter, the eligible vessel self-generation, and the asset ownership.

1.3 Please confirm, otherwise explain, that if the Port Customer and the eligible vessels are metered in parallel, the Port Customer will be paying for its own demand through its own demand charges, but will not be paying a demand charge for the demand associated with the eligible vessels.

1.4 Please provide a sample calculation showing the anticipated Port Customer charges for a typical month and compare this to the situation where the Port Customer and vessels were in series (with the vessel meter downstream of the Port Customer meter) (i.e., in series the Port Customer incurs demand charges associated with the demand from the vessels and the vessels only pay the energy charges as per the requested rate schedule).

1.5 The Application describes the vessel owner/operator as a short-term tenant of the Port Customer for electricity supply purposes. Please confirm, otherwise explain, that BC Hydro designed the capacity of each Port Customer’s supply based on the facilities’ own projected use and did not include consideration of reselling shore power to eligible vessels.

1.5.1 If confirmed, please further confirm, otherwise explain, that the rates currently charged to these existing customers (e.g., a port authority under RS 1823) were designed to

BC Hydro – Shore Power Rate Application 2 BCUC IR-1

recover the costs of the Port Customer supply systems, considering the demands, loads, revenues and costs known at the time.

1.5.2 In BC Hydro’s view, will a customer such as a port operator or terminal operator require more maintenance and/or more/earlier system improvement on the BC Hydro network on account of the anticipated additional load associated with the vessels? Why or why not?

1.6 Does BC Hydro agree that with new short-term tenants consuming at the port facilities, the level of demand on BC Hydro system will change? If so, how will it change?

1.7 Does BC Hydro agree that with existing customers who may be reselling shore power at their facilities, the demand and energy profiles of the existing customers will change?

Reference: Exhibit B-1, Application, Section 1.2 p. 1-3 2.0Tariff Supplement (TS) 76

TS 76 is the existing non-firm Shore Power Rate for Port Metro Vancouver’s Canada Place cruise ship terminal. On page 1-3 of the Application, BC Hydro states that shore power facilities at Canada Place were installed in 2008 and the Commission approved TS 76 in December 2008, the approval of which was granted in accordance with the Ministerial Order BC Regulation 291/2008, also known as the Shore Power Regulation. On page 2-9 of the Application, BC Hydro describes the new Shore Power Rate as similar to TS 76 and discusses the design features of TS 76.

2.1 Please provide a copy of the Electric Tariff Supplement No. 76 “Agreement for Provision of Shore Service to Canada Place” either in your response to this IR question or as a supplement to the Exhibit B-1 Application.

2.2 Please provide a copy of Order G-197-08 and Ministerial Order M 252 in your response to this question.

Reference: Exhibit B-1. Application, Section 1.2.1, Page 1-3; 3.0Appendix B-9 Workshop Summary p. 3 of 6 TS 76

Page 1-3 of the Application says that TS 76 applies to “a specific customer (PMV), one location (Canada Place), one vessel type (cruise ships) and is available only during May to October cruise ship season.” The term of agreement of TS 76 is for a period of ten years from the effective date of December 19, 2008 and either one of the signatory parties, BC Hydro or the Vancouver Fraser Port Authority are entitled to terminate the agreement at any time with 30 days’ advance notice. The following is an excerpt from TS 76 Section 1.0:

1.1 Definitions

The following definitions and any terms defined internally in this Agreement will apply to this Agreement and all notices and communications made pursuant to this Agreement:

Cruise Season. The months of April, May, June, July, August, September and October during any year of this Agreement.


3.1 Can BC Hydro confirm that the Definitions section of TS 76 defines the cruise season as “The months of April, May, June, July, August, September and October” during any year of this Agreement? If confirmed, can BC Hydro reconcile the difference between the cruise season definition used in TS 76 and the description of the cruise season in the Application?

3.1.1 Does this discrepancy have any effects on the input assumptions used in Tables 2-1 and 2-2? If so, please update the tables.

3.2 Have cruise ships taken shore power outside the Cruise Season? Have other vessels taken shore power at Canada Place? If so, under which rate schedule(s) did they take electricity service?

3.3 Has BC Hydro considered terminating TS 76 and moving the provision of shore power service to cruise ships at Canada Place wharf to be served under an all-encompassing TS 86? If not, why not?

3.4 Total energy sales under TS 76 were 3.6 GWh in 2014 (page 1-4). Please discuss the energy sales in terms of BC Hydro’s gross and net revenues.

3.4.1 Based on the PMV forecast on annual load (MWh) and PRPA forecast on container ship visits (Appendix B-3), what is the likelihood that BC Hydro would be required to make market electricity purchases in order to provide shore services under TS 86 in the short term and in the long term (e.g., 8- to 10-year horizon)?

3.4.2 Under TS 76, the Vancouver Fraser Port Authority pays an Administrative Charge of $150.00 per month per account in the cruise season. Does this charge recover all the incremental billing and administrative costs which was the intent of the Administrative Charge? Please provide, by year since the implementation of TS 76, any under- or over-collection?

3.4.3 Does the monthly Administrative Charge recover other costs not related to billing and administrative costs? If so, please itemize those costs.

3.4.4 Please describe the incremental OM & A costs of the transmission and distribution systems as a result of providing shore power services.

3.4.5 Please comment on how the gross and net revenues from sales and the monthly Administration Charge under TS 86 would be included in BC Hydro’s revenue requirements application for F16 and beyond?

Reference: Exhibit B-1, Application, Section 1.2.2, p. 1-5; Appendix B-3; Appendix C1 4.0Customer requests for Shore Power Rate

The Application cites the Port Metro Vancouver’s facilities at GCT Deltaport and DPWW Centerm as well as Prince Rupert Port Authority’s facilities at Fairview Container Terminal as in need of the proposed Shore Power Rate because shore power is a key component of their respective strategies relating to environmental stewardship.

4.1 Has the Greater Victoria Harbour Authority also expressed interests or make any plans known to BC Hydro to have shore power available at its facilities? Will a potential request from Greater Victoria Harbour Authority be served under TS 86 or TS 76? Please explain your answer.


4.2 In its letter of support, Prince Rupert Port Authority (PRPA) indicates that it has 200 container ships calling annually and this is projected to increase to 350 visits with the planned expansion of Fairview Container Terminal that will also utilize additional shore power connections. In BC Hydro’s view, does the PRPA currently have the spare capacity to serve the demand of these 350 eligible vessel visits? Where will BC Hydro get this energy?

4.3 Special Condition 3 in the proposed RS 1280 and RS 1891 states that a Port Customer that provides port electricity under RS 16xx and RS 1823 is not eligible to take port electricity under the RS 1280 and RS 1891. Have any of these customers made a Shore Power Rate request to BC Hydro?

Reference: Exhibit B-1, Application, pp. 1-8 and 1-9, Table 1-3 5.0Comparison with ports and utilities in other jurisdictions

The Application states that the major ports in North America have shore power rates in effect and that the majority of the ports/electric utilities provide shore power on a non-firm basis with no demand charge. The Application also says that RS 1823 and RS 16xx are the relevant BC Hydro firm rate comparators given the Port Metro Vancouver and Prince Rupert Port Authority requests. Table 1-3 describes current shore power rates in effect from BC Hydro’s survey of ports/electric utilities. Rates are obtained from each utility’s current tariff as of April 1, 2015. For PMV/BC Hydro (2009), the energy charge for distribution customer is described as 8.796 cents/kWh (F2016) based on RS 1823 Tier 2 energy rate grossed up by distribution loss.

5.1 According to TS 76, the applicable rate is RS 1880. Please explain why the TS 76 applicable energy rate is not used to indicate the current Shore Power Rate in effect.

5.2 According to page 1-4 in the Application, the missed connection due to BC Hydro available capacity issue was 5 percent. In BC Hydro’s view, does the fact that the existing Shore Power Rate is limited to a defined Cruise Season help in lowering the missed connection statistic?

5.2.1 Among the ports and utilities surveyed and presented in Table 1-3, how many of them apart from BC Hydro has a shore power rate that is seasonal in its availability?

5.3 For those ports and utilities that have no demand charges, do they serve the shore power rate only during the off-peak months? Please provide examples in your response.

5.4 For those ports and utilities that have no demand charges, how many of them vary their energy charge?

5.4.1 Are their respective energy charges based on a blended demand/energy rate to maintain revenue neutrality and to recover full cost?

5.4.2 Are their respective energy charges based on a standby rate, such as an RS 1880 equivalent?

5.4.3 Are their respective energy charges based on the energy only component of a rate that comprises demand and energy charges similar to BC Hydro’s transmission stepped service rate or LGS conservation rate?


Reference: Exhibit B-1, Application, p. 1-14 Table 1-4 6.0Load per visit

The cruise ships have peak load of 10 to 12 MW per visit and other vessels have peak load of 2 to 5 MW per visit.

6.1 Has power factor been addressed in serving the cruise ships at Canada Place wharf under TS 76? If so, please describe how it is being addressed and how BC Hydro expects it to be addressed in the expanded version.

Reference: Exhibit B-1, Application, Sections 2.2 pp. 2-1 to 2-3 7.0Factors considered in developing Shore Power Rate

The Application lists three factors being considered in the development of the proposed Shore Power Rate: (a) characteristics of the prospective shore power load; (b) shore power rates offered in other jurisdictions; and (c) TS 76 and port customer preference. Page 2-3 states that:

Nothing in the Shore Power Regulation referenced in section 1.2.1 of this Application required the Commission to set TS 76 as a non-firm rate with no demand charge. In BC Hydro’s view, there is no basis for finding that the structure of TS 76 is appropriate for cruise ships docking at Canada Place but not for container ships, bulk carrier ships and other ocean-going vessels docking at DPWV Centerm, GCT Deltaport and Fairview Container Terminal or future cruise ship Port Customer.

7.1 According to the Application, one of the characteristic of shore power is that it is naturally interruptible. Would the year-round offer of the Shore Power Rate subject eligible vessels to more frequent misconnection since ships seeking the Shore Power Rate under TS 86 will also be requesting shore power during the winter peaking months from November to March at BC Hydro?

7.2 Please comment if there is a hierarchy of interruption for non-firm customers. In the event of capacity or energy constraint, which interruptible customers (or a group of customers) are disconnected before others?

Reference: Exhibit B-1, Application, Section 2.3, pp. 2-3 to 2-7 8.0Rate options and comparison of rates

BC Hydro determined that port customers do not require firm service and shore power load can be interrupted given that ships are equipped with on-board generators. Based on a scenario where three vessel visits per month is assumed for a cruise ship, a container ship and a bulk carrier, Table 2-2 presents the comparison of charges under TS 76 with charges under RS 1823.

8.1 According to footnote 23 on page 2-7, the demand charge component for RS 16xx recovers 53 percent of demand-related cost and the demand component of RS 1823 recovers 65 percent of the fixed costs. Since the demand charges currently do not recover in full the fixed cost, please provide: (a) by how much the energy charges are increased in the existing rate schedule to recover the demand-related cost, and (b) an estimate of the increase in energy charges (RS 1823 and RS 16xx) in order to recover the proposed removal of demand charge.


8.1.1 In BC Hydro’s view, if there is no demand charge (or if the demand charge is discounted) in the proposed RS 1891 and RS 1280, by how much the energy charges be raised to reflect a recovery of the change in demand profile or increase in capacity utilization in order to recover investment costs?

8.2 Please confirm that the rates used in the assumptions in Table 2.2 are F2016 rates pursuant to Appendix B of Direction No. 6 to the BCUC (BC Regulation 29/2014).

8.3 On page 2-5, the Application refers to the blended rates under TS 1823 as ranging from $100/MWH to $349/MWh compared to $85/MWh under TS 76. For LGS service, blended rates range from $132/MWh to $490/MWh based on the load characteristics identified in Table 2-2. Would BC Hydro please confirm that ‘blended’ rate refers to blending the different tiers of energy rates? For example, the RS 1823 blended energy rate per MWH of 43.03 is based on 90 percent consumption at $38.36/MWh and 10 percent consumption at $85.03?

8.3.1 In Table 1-3 on page 1-11, the Application describes the Port of San Diego & San Diego Gas and Electric as having a blended 18-21 cents/kWh (by season for cruise ship). Please explain whether, in this instance, the ‘blended’ rate refers to the blending of different tiers of energy charges or whether it refers to blending energy and demand charge components such that there will be no separate demand charge.

According to Table 2-2, a container vessel operator would:

• If taking service at transmission voltage, receive savings of $14.74/MWh per month ($85.03–$99.77) under the proposed TS 86 instead of taking service under RS 1823; the tier 2 energy price of RS 1823 being the same as RS 1880; and

• If taking service under distribution voltage, receive savings of $47.31/MWh per month ($85.03–$132.34) under the proposed TS 86.

8.4 Based on the same assumptions used for Table 2-2, please calculate: (a) the gross revenue per monthly/billing period and, if possible, annually) for BC Hydro, (b) the costs (e.g., cost of energy, OM & A expenses, depreciation and amortization, taxes, finance charges, allowed net income), and (c) the net revenue per monthly/billing period and, if possible, annually for BC Hydro.

Reference: Exhibit B-1, Application, pp. 2-7 to 2-9 9.0Rate options

According to Table 2-3 of the Application, RS 1823 and RS 16xx perform poorly on three out of the eight Bonbright criteria:

• Firm rates would force port customers to pay a premium for firm service they have not requested and do not need.

• A CBL or HBL-based design will likely require more effort by customers to manage their bills.

• There is no basis for requiring eligible vessels to take service under the firm rates given the Commission-approved TS 76.

In addition, BC Hydro also states that RS 1880, although it is a non-firm rate, is not suitable because RS 1880 is intended as standby supply to replace energy, it aims to enable self-generation. Furthermore, its availability is restricted to transmission service customers with on-site generation.


9.1 Is the argument of non-suitability of RS 1880, i.e., the intent of standby rate is to enable self-generation, also valid for cruise ships’ shore power at Canada Place wharf? If not, why not?

9.2 Please confirm, otherwise explain, that a customer who has access to RS1880, incurs demand charges.

9.3 Please provide a sample one line diagram of an RS 1880 customer. Please identify the point of interconnection, the BC Hydro supply to the customer, the customer’s meters, the customer self-generation and meters, and the asset ownership. Please compare this sample one-line to the one line for vessels/Port Customers previously requested.

9.4 Please confirm, otherwise explain, that RS 1880 customers use spare capacity of existing supply and receive non-firm service, and vessels are anticipated to use spare capacity of existing supply and receive non-firm service.

9.5 Please provide a sample calculation showing the Port Customer charges for supplying eligible vessels if incurred under RS 1880 and compare these charges to the scenario where the Port Customer and vessels meters were in series and to where they were in parallel.

9.6 If the requested TS 86 is approved, would BC Hydro also seek to amend RS 1880 as the applicable energy rate in TS 76?

Reference: Exhibit B-1, Application, Section 2.4, pp. 2-9 to 2-10 10.0Shore Power Rate Bonbright assessment

Table 2-10 of the Application summarizes the assessment of the Shore Power Rate with the conclusion that the rate performs well against all eight Bonbright criteria. Specifically, it recovers the cost of energy, all incremental costs of serving Port Customers, and that it aligns with TS 76 and rate design approaches in other jurisdictions that offer shore power services. The Application states that the shore power load is not included in BC Hydro’s load forecast and does not advance any future delivery infrastructure projects.

10.1 Does BC Hydro use, as inputs in its long term load forecast, the projected demand and energy from Port Customers?

10.1.1 Page 1-6 of the Application refers to the BC Hydro 2013 Integrated Resource Plan which includes an ‘action’ to work with the BC government, ports and industry to expand availability of shore power to shipping at BC ports. Please confirm the Port of Vancouver was evaluating port-side electrification for vessels using shore-side electrical power while berthed rather than diesel power as far back as 2007.1 How much has BC Hydro invested since 2007 in system improvements or contributions to system extensions in anticipation of the port’s requirement?

1 BC Hydro’s 2007 Long Term Acquisition Plan, Appendix B1, page 24 of 84


10.2 The assessment in Table 2-4 concludes that the Shore Power Rate incorporates non-firm rate design and pricing principles for TS 76 (and for RS 1880); these principles are Commission approved. Does the year round nature of TS 86 make this tariff supplement distinct from the energy availability for “non-peaking months only” of TS 76? If, hypothetically, the cruise ships of Greater Victoria Harbour are served under TS 86, would this be considered undue discrimination since the cruise ships of Canada Place wharf are served under TS 76 and under different features?

Reference: Exhibit B-1, Application, Section 2.5, p. 2-12: Appendix C1 RS 1280 and RS 1891 11.0Availability

Page 2-12 of the Application states that upon request for non-firm shore power service, BC Hydro will determine if it has the capacity available to provide service to the Port Customer. If BC Hydro determines that it can provide the non-firm service, BC Hydro and the Port Customer will enter into a Shore Power Service Agreement (BC Hydro ‘s proposed TS 86), as required by Special Condition 2 of RS 1280 and RS 1891. The executed TS 86 will be in effect for the period during which the Port Customer receives non-firm shore power service (up to an initial ten year term).

11.1 Is BC Hydro referring to the first request which initiates the Power Service Agreement or is BC Hydro also referring to discrete requests from time to time?

11.2 Assuming that the preamble refers to a Port Customer’s request for shore power service to enter into the Power Service Agreement, what are the consideration factors in BC Hydro’s determination as to whether it can, or cannot, provide the non-firm service?

11.2.1 Is the existing wire capacity leading to the port interconnection a consideration?

11.2.2 Is further upstream reinforcement to the BC Hydro system a consideration?

Reference: Exhibit B-1, Application, Section 2.5.1.2, p. 2-12; Appendix C1 RS 1280 and RS 1890 12.0Shore Power Rate migration

BC Hydro states that Port Customers that opt for firm service for shore power under the applicable default rate are not eligible to migrate to the non-firm Shore Power Rate. The reason for Special Condition 3 is that the Port customer’s load will have been factored into the load forecast, infrastructure improvements will have been made to provide firm service and BC Hydro will likely have provided a contribution toward the infrastructure.

12.1 To the best of BC Hydro’s knowledge, how many customers will be affected by this Special Condition 3?

12.2 Please describe the circumstances where a Port Customer will “opt for” firm service. Is this option being presented to Port Customers who have shore power capabilities? Are Port Customers given a period of time to exercise an option?

12.2.1 In the most recent BC Hydro annual load forecast report, how much demand (MW) and energy (GWh) out of the total are projected annual sales to Port Customers, say, for 2016 and 2021?


Reference: Exhibit B-1, Application, Section 2.5.1.4, p. 2-13 13.0Energy Rate

BC Hydro proposes to charge the same energy rate for non-firm shore power service as the RS 1823 Tier 2 energy rate. For distribution Port Customers, the Shore Power Rate energy charge would be adjusted by the primary distribution loss factor. RS 1823 consists of a demand charge and energy charge and the demand charge recovers 65 percent of the demand-related cost according to footnote 23 in the Application.

13.1 Has BC Hydro explored other rate schedule options to apply the Shore Power Rate under TS 86 where: (a) there would be a demand charge to reflect the utilization of capacity and the change in demand profile; (b) there would be a discounted demand charge to reflect the utilization of capacity and the non-firm energy; and (c) the would be no demand charge for ease of customer understanding but the demand-related cost will be recovered by increases to the energy component of RS 1823? If the analyses of the options were carried out, please provide them in the response; if not, why not?

Reference: Exhibit B-1, Application, Section 2.5.2.2 pp. 2-16 to 2-18 14.0Infrastructure costs

Page 2-16 of the Application states that there will be no System Improvements Costs as a result of providing shore power to a distribution voltage Port Customer site such as DPWW Centerm. If a Port Customer request triggers System Improvement costs, the Port Customer will not be permitted to take service under the Shore Power Rate and must instead take service under the default General Service rate. Page 2-18 of the Application states that under Special Condition 1 of RS 1891, BC Hydro will not be required to construct System Reinforcement under TS 6 to provide Shore Power Services.

14.1 Under the scenario where a customer of BC Hydro who is not a Port Customer triggers System Improvement costs, and if later the Port Customer seeks shore power service, then the Port Customer is permitted take service under the Shore Power Rate. Does BC Hydro agree with this interpretation?

14.2 Would BC Hydro please comment if the proposed infrastructure cost treatment in section 2.5.2.2 generally complies with the existing transmission and distribution extension policies? Please discuss the similarities and differences.

14.2.1 Can BC Hydro confirm that the existing transmission and distribution extension policies are subject to review in the 2015 rate design application scheduled for filing in September 2015?

Reference: Exhibit B-1, Application, Appendix A1 15.0

The Application and draft order seek approval of RS 1280 and RS 1891 and TS 86 for the provision of non-firm shore power service. TS 86 is based on the previously approved 76 and expands port customer and vessel eligibility.

15.1 Is BC Hydro amenable to the Commission narrowing the scope of the review of this Application to issues related to expansion on port customer and vessel eligibility and place the design of the shore power rate structures, and their accompanying distribution and transmission extension policies to the 2015 RDA?

British Columbia Utilities Commission Information Request No. 1.1.1 Dated: April 24, 2015 British Columbia Hydro & Power Authority Response issued May 15, 2015

Page 1 of 1

British Columbia Hydro & Power Authority Application for Approval of Shore Power Rate

Exhibit: B-2

1.0 Reference: Exhibit B-1 Application, p. 1-2

Definition of Port Customers



1.1.1 For greater clarity, would BC Hydro please describe whether a Port Customer is a unique account or a customer with multiple accounts? Please explain if, instead of an existing customer who will set up a separate meter for shore power, a Port Customer can be a new customer setting up specifically to resell shore power.

RESPONSE:

A Port Customer could have one or more accounts. With respect to the second part of this question, BC Hydro is of the view separate metering is required regardless. As set out section 2.5.2.4 of Exhibit B-1, non-firm shore power will be metered separately so that they can be billed and monitored separately.

British Columbia Utilities Commission Information Request No. 1.1.1.1 Dated: April 24, 2015 British Columbia Hydro & Power Authority Response issued May 15, 2015

Page 1 of 1


Exhibit: B-2





1.1.1.1 Table 1-4 on page 1-14 presents the potential shore power uptake at bulk or break-bulk terminals at Port Metro Vancouver or Prince Rupert Port Authority. These facilities are located in multiple locations: North Vancouver, Vancouver, Delta, Prince Rupert and Surrey. Is a Port Customer a location-specific facility such as the terminal operator?

RESPONSE:

A Port Customer could be a port authority with multiple facilities at a particular location or it could be a specific facility managed by a terminal operator. An example of the former is PMV which has requested non-firm shore power service for Centerm facility in Vancouver and GCT Deltaport in Delta. Please refer to the definition of “Port Customer” set out in section 2.5.1.1 of Exhibit B-1.


Page 1 of 3


Exhibit: B-2





1.1.2 Please confirm, otherwise explain, that the Port Customer and the eligible vessels be supplied electrical service to one point of interconnection, but will be metered in parallel. Please provide a sample one line diagram identifying the expected point of interconnection, the BC Hydro supply to the Port Customer and the Port Customer meter, the eligible vessel supply and meter, the eligible vessel self-generation, and the asset ownership.

RESPONSE:

Not confirmed. For Port Customers connected at transmission voltages, metering will be in series; refer to Figure 1 below. For Port Customers connected at distribution voltages, metering will either be in series or in parallel, depending on the characteristics of the existing service connection. Figures 2 and 3 below identify potential metering configurations for Port Customers served at distribution voltages. BC Hydro notes that as set out section 2.5.2.4 of Exhibit B-1, non-firm shore power will be metered separately so that they can be billed and monitored separately.

With respect to asset ownership, BC Hydro notes the following:

The PRPA (Fairview Container Terminal) transmission line is owned by the Port Customer and the PMV (GCT Deltaport) transmission line is owned by BC Hydro. With the exception of metering equipment, all infrastructure downstream of the Point of Interconnection is owned by the Port Customer; and

For Port Customers such as the PMV Centerm facility connected at distribution voltages, with the exception of metering equipment, all infrastructure downstream of the Point of Interconnection will be owned by the Port Customer. Any off-site distribution infrastructure required will be funded by the Port Customer and owned by BC Hydro pursuant to section 2.1 of TS 86.


Page 2 of 3


Exhibit: B-2

BC Hydro notes the following. Section 7 of the proposed TS 86 states “The Port Customer owns and is responsible for the maintenance of all electrical equipment required for the supply of Port Electricity to docked Eligible Vessels at the Port Facility (the “Port Electricity Electrical Equipment”), other than the meters, metering transformers and any associated apparatus supplied by BC Hydro”. Section 6 of TS 86 states that “BC Hydro owns and is responsible for the maintenance of meters and metering transformers installed on the Port Customer’s premises for the purposes of billing”.

Figure 1 Transmission Voltage Connected Customer


Page 3 of 3


Exhibit: B-2

Figure 2 Distribution Voltage Connected Customer Example A

Figure 3 Distribution Voltage Connected Customer Example B


Page 1 of 1


Exhibit: B-2





1.1.3 Please confirm, otherwise explain, that if the Port Customer and the eligible vessels are metered in parallel, the Port Customer will be paying for its own demand through its own demand charges, but will not be paying a demand charge for the demand associated with the eligible vessels.

RESPONSE:

A Port Customer will pay all applicable charges including demand charges in accordance with the applicable firm service rate schedule for the consumption not associated with non-firm shore power service. Consumption related to non-firm shore power service will be paid in accordance with the proposed Shore Power Rate and does not include any demand charges because it is an interruptible (non-firm) service.


Page 1 of 1


Exhibit: B-2





1.1.4 Please provide a sample calculation showing the anticipated Port Customer charges for a typical month and compare this to the situation where the Port Customer and vessels were in series (with the vessel meter downstream of the Port Customer meter) (i.e., in series the Port Customer incurs demand charges associated with the demand from the vessels and the vessels only pay the energy charges as per the requested rate schedule).

RESPONSE:

The charges set out in RS 1280 and RS 1891 are the same regardless whether the metering is done in series or parallel.

For Port Customers with shore power service metered in series, demand for each 30-minute interval measured with the shore power meter will be deducted from the demand measured with the upstream meter for the same 30-minute intervals. Similarly, energy usage during the billing period measured on the shore power meter will be deducted from the measured energy on the upstream meter for the same period. Shore power energy will be billed according to that measured on the shore power meter.


Page 1 of 1


Exhibit: B-2





1.1.5 The Application describes the vessel owner/operator as a short-term tenant of the Port Customer for electricity supply purposes. Please confirm, otherwise explain, that BC Hydro designed the capacity of each Port Customer’s supply based on the facilities’ own projected use and did not include consideration of reselling shore power to eligible vessels.

RESPONSE:

Port Customer non-firm shore power loads have not been and will not be included in BC Hydro’s energy or peak demand load forecasts, and therefore such non-firm loads are not a factor in planning for and designing the capability of BC Hydro’s transmission and distribution systems.


Page 1 of 1


Exhibit: B-2





1.1.5.1 If confirmed, please further confirm, otherwise explain, that the rates currently charged to these existing customers (e.g., a port authority under RS 1823) were designed to recover the costs of the Port Customer supply systems, considering the demands, loads, revenues and costs known at the time.

RESPONSE:

Firm service rates such as RS 1823 are designed to generally recover the costs of the relevant rate class.


Page 1 of 2


Exhibit: B-2





1.1.5.2 In BC Hydro’s view, will a customer such as a port operator or terminal operator require more maintenance and/or more/earlier system improvement on the BC Hydro network on account of the anticipated additional load associated with the vessels? Why or why not?

RESPONSE:

With respect to the “system improvement” portion of this IR, as set out in section 2.5.2.2 of Exhibit B-1, page 2-16, lines 5 to 9, there will be no System Improvement Costs as a result of providing shore power to a distribution service Port Customer site such as PMV’s Centerm facility. Port Customers requesting non-firm shore power service are not included in BC Hydro’s energy or peak demand load forecasts, and accordingly requests for non-firm shore power service pursuant to the proposed Shore Power Rate will not result in any System Improvement Costs. In addition, per Special Condition 1 of RS 1280 there will be no costs associated with an extension for the purposes of extending increasing the capacity of BC Hydro’s distribution system to provide non-firm service as Port Customers will not be allowed to take such service if such costs are triggered.

Physical Maintenance

BC Hydro does not expect to have any incremental physical maintenance of the system due to the addition of non-firm shore power loads as a result of Commission approval of the proposed Shore Power Rate. Physical system plant will continue to be operated within equipment ratings.

Maintenance Cost

This IR, as does other IRs such as BCUC IR 1.3.4.4, inquires into shore power-related infrastructure maintenance costs, which relate to the composition of demand costs:

To facilitate a shore power distribution service connection under the proposed Shore Power Rate, new facilities may be added including all labour/material for the extension of the existing system to the Port Customer’s site as well as any necessary switching equipment and protection and control upgrades at the


Page 2 of 2


Exhibit: B-2

substation. While the upfront cost for these facilities are paid for by the Port Customer pursuant to section 2.1 of TS 86, there will be some ongoing maintenance of these items (pole top inspections, manhole inspections, cable splice inspection/maintenance, trouble calls on these facilities, protection and control maintenance at the substation);

For transmission service-related shore power requests, there are no significant incremental O&M costs because no System Reinforcements will be implemented to provide shore power;

O&M cost is a small proportion of the overall shore power-related infrastructure cost and only occurs if BC Hydro owns and maintains the infrastructure. BC Hydro estimates that the annual cost of incremental O&M on a shore power-related extension is approximately 1 per cent of the extension’s construction cost. The incremental O&M on upstream distribution and transmission costs (primary system, substation, transmission system) is zero as no such asset additions are required because shore power is non-firm;

BC Hydro estimates the average cost of shore power extensions at $1 million and estimates that incremental O&M would be about $10,000 per site using the 1 per cent figure described above;

Per the F2014 FACOS, incremental O&M associated with an extension is largely demand-related. As part of the 2015 RDA stakeholder engagement process, BC Hydro has noted that its energy charges recover a portion of demand-related costs. For example, the firm rate LGS demand charge recovers about 50 per cent of LGS rate class demand costs;

Since shore power is non-firm and there is no demand charge in the proposed Shore Power Rate, BC Hydro recovers incremental O&M associated with an extension through the energy charge set out in RS 1280 (Distribution Service); and

BC Hydro’s proposal to base the RS 1280 and RS 1891 energy charges on the RS 1823 Tier 2 energy charge, rather than lower spot market price forecast or the lower LGS average energy rate of 5.76 cents/kWh (F2016), helps ensure that additional costs such as O&M are recovered from Port Customers using this new service. The RS 1891 energy charge is the RS 1823 Tier 2 energy price which for F2016 is 8.503 cents/kWh, while the RS 1280 energy charge is the RS 1823 Tier 2 energy price adjusted for losses which is 8.796 cents/kWh for F2016. Section 5.6 of the 2013 IRP contains BC Hydro’s electricity market forecast. The mid-electricity market forecast price is about $33/MWh in 2020 (Real 2016 $CDN) which is well below the RS 1823 Tier 2 energy price. A link to the 2013 IRP is: https://www.bchydro.com/energy-in-bc/meeting_demand_growth/irp/document_centre/reports/november-2013-irp.html.


Page 1 of 1


Exhibit: B-2





1.1.6 Does BC Hydro agree that with new short-term tenants consuming at the port facilities, the level of demand on BC Hydro system will change? If so, how will it change?

RESPONSE:

While the level of energy may change on a short-term basis, BC Hydro does not agree that the level of required capacity on the BC Hydro system will increase as a result of short-term tenants consuming energy under proposed Shore Power Rate. As described in section 2.4 of Exhibit B-1, service under the proposed Shore Power Rate is provided on a non-firm as-available basis (refer in particular to Special Condition 1 of RS 1280 and RS 1891 and to section 4.1 of TS 86; copies are found in Appendix C-1 of Exhibit B-1). Accordingly, BC Hydro does not include non-firm shore power load in its load forecasts.


Page 1 of 1


Exhibit: B-2





1.1.7 Does BC Hydro agree that with existing customers who may be reselling shore power at their facilities, the demand and energy profiles of the existing customers will change?

RESPONSE:

Currently there is only one Port Customer reselling non-firm shore power in BC Hydro’s service area – namely PMV at Canada Place wharf pursuant to TS 76. There has been no change in BC Hydro’s energy or capacity requirements as a result of TS 76. PMV is separately metered for shore power service purposes under TS 76.

Prospectively, the existing demand and energy profile of Port Customers will not change as a result of the proposed Shore Power Rate because as noted in BC Hydro’s response to BCUC IR 1.1.1, Port Customers will be separately metered for shore power service purposes.


Page 1 of 1


Exhibit: B-2

2.0 Reference: Exhibit B-1, Application, Section 1.2 p. 1-3

Tariff Supplement (TS) 76

TS 76 is the existing non-firm Shore Power Rate for Port Metro Vancouver’s Canada Place cruise ship terminal.

On page 1-3 of the Application, BC Hydro states that shore power facilities at Canada Place were installed in 2008 and the Commission approved TS 76 in December 2008, the approval of which was granted in accordance with the Ministerial Order BC Regulation 291/2008, also known as the Shore Power Regulation. On page 2-9 of the Application, BC Hydro describes the new Shore Power Rate as similar to TS 76 and discusses the design features of TS 76.

1.2.1 Please provide a copy of the Electric Tariff Supplement No. 76 “Agreement for Provision of Shore Service to Canada Place” either in your response to this IR question or as a supplement to the Exhibit B-1 Application.

RESPONSE:

A copy of TS 76 is provided as Attachment 1 to this response.

111 Accepted: December 18, 2008 Order No. G-197-08

Commission Secretary

BC Hydro

Electric Tariff

Supplement No. 76

Effective: December 19, 2008

AGREEMENT FOR PROVISION OF SHORE SERVICE

TO

CANADA PLACE

This Agreement (hereinafter referred to as "Shore Power Agreement" or "Agreement") is made to be effective on the __ day of , 200_,

BETWEEN:

AND:

BRITISH COLUMBIA HYDRO AND POWER AUTHORITY,

having its head office at 333 Dunsmuir Street,

Vancouver, British Columbia V6B 5R3

("B.C. Hydro")

VANCOUVER FRASER PORT AUTHORITY

100 The Pointe

999 Canada Place

Vancouver, British Columbia, V6C 3T 4

("the VFPA")

(Each of B.C. Hydro and the VFPA are referred to individually as the "Party" and collectively, as the "Parties")

B-1

BCUC IR 1.2.1 Attachment 1

BC Hydro Application for Approval of Shore Power Rate Page 1 of 28

Accepted: December 18, 2008 Order No. G-197-08


BC Hydro

Electric Tariff

Supplement No. 76


WHEREAS the VFPA owns and is charged with operating the wharf at Canada Place, Vancouver Harbour, and wishes to install facilities to enable cruise ships docked at the Canada Place wharf to connect to and receive electricity supply from the wharf while they are at berth. This electricity supply will relieve the docked cruise ships of the need to operate their onboard diesel generating units while at berth, thereby reducing air emissions in the Vancouver Harbour area; and

WHEREAS the VFPA is currently receiving service from B.C. Hydro pursuant to Rate Schedule 1211 approved by the British Columbia Utilities Commission, and in addition, wishes to receive a non-firm electricity supply ("Shore Power") from B.C. Hydro for the east and west berths at Canada Place in order to provide the Shore Power to the docked cruise shipss, and

WHEREAS the B.C. Hydro and the VFPA wish to enter into this Shore Power Agreement to provide for the supply of Shore Power to the Canada Place wharf.

NOW THEREFORE, THIS AGREEMENT WITNESSES that the Parties agree as follows:

1 INTERPRETATION

1.1 Definitions


Delivery Points. The physical locations at the Canada Place Wharf at which Shore Power is delivered by B.C. Hydro to the VFPA and received by the VFPA from B.C. Hydro, as set forth in the Local Operating Order.

Canada Place Wharf. The VFPA wharf at Canada Place, Vancouver Harbour, for the berthing of cruise ships and other ocean going vessels.


Electricity. Electrical power and electrical energy. Power is measured and expressed in kilowatts (kW) or kilovolt-amperes (kV.A) and energy is measured and expressed in kilowatt-hours (kW.h).

Local Operating Order. The operating order entered into by B.C. Hydro and the VFPA which outlines the procedures to be followed when working on electrical facilities at or in the vicinity of the Delivery Points, and for connecting and disconnecting docked cruise ships to and from the Shore Power delivery facilities, and procedures for related matters, as the same may be revised from time to time.

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BC Hydro

Electric Tariff

Supplement No. 76


Port Electricity. Electricity delivered by the VFPA to cruise ships docked at Canada Place Wharf in Vancouver.

Shore Power. Electricity supplied by B.C. Hydro on a non-firm basis to the VFPA for delivery as Port Electricity to cruise ships docked at Canada Place Wharf.

1.2 Interpretation

Unless otherwise specified herein, all references to Sections are to those set forth in this Agreement. Reference to any Party includes any permitted successor or assignee thereof. The term "including" followed by descriptive words is used in this Agreement by way of example only and is not intended to limit the scope of the provision. The headings used in this Agreement are for convenience and reference purposes only.

2 AVAILABILITY

2.1 Delivery Facilities

B.C. Hydro and the VFPA will each use commercially reasonable efforts to complete the installation of all necessary equipment and upgrades within B.C. Hydro's distribution system and the Canada Place Wharf ready for delivery of Shore Power and Port Electricity as of April 1, 2009. The "Distribution Extensions" provisions in Part 8 of B.C. Hydro's Electric Tariff Terms and Conditions will apply in respect of any "Extension" (as defined in the said Terms and Conditions) to B.C. Hydro's distribution system to enable the supply of Shore Power to the Canada Place Wharf, except that having regard to the nature of the service to be provided by B.C. Hydro under this Agreement no contribution will be payable by B.C. Hydro towards the cost of the Extension.

2.2 Use of Electricity

Shore Power supplied by B.C. Hydro pursuant to this Shore Power Agreement shall be used only for the supply of Port Electricity to cruise ships docked at the Canada Place Wharf from time to time during the Cruise Season. Shore Power taken under this Shore Power Agreement shall not displace Electricity that would otherwise be taken by the VFPA under Rate Schedule 1211 for uses other than supply of Port Electricity to docked cruise ships.

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"" Ill.I BC Hydro


Electric Tariff

Supplement No. 76 <..

SLkuvJY-~ Effective: December 19, 2008 Commission Secretary

3 TERM

3.1 Term of Agreement

Notwithstanding the actual date of execution, the term of this Agreement will commence on the effective date specified on page 1 (the "Effective Date") and will continue for a ten year period (the "Term") unless terminated prior to the expiration thereof in accordance with Section 3.2 or 3.3.

3.2 Early Termination by the VFPA

The VFPA shall be entitled to terminate this Agreement at any time by giving B.C. Hydro 30 days advance written notice of termination, effective on the date specified in such notice; provided that the VFPA shall remain obligated to pay any amounts accrued and owing hereunder as of the date of termination.

3.3 Early Termination by B.C. Hydro

B.C. Hydro shall be entitled to terminate this Agreement by giving theVFPA 30 days advance written notice of termination if, at any time during the Term, the costs of this Agreement are determined by the British Columbia Utilities Commission ("BCUC"), or any other regulatory body having jurisdiction from time to time in respect of B.C. Hydro's rates, to be imprudent or not in the interests of B.C. Hydro's ratepayers, or if B.C. Hydro is unable for any reason to recover the costs of this Agreement in its rates. Upon termination under this section, neither party shall have any further or other liability or obligation to the other.

4 ELECTRIC SERVICE TO BE PROVIDED

4.1 Non-firm Electricity

B.C. Hydro will sell and deliver to the VFPA, and the VFPA will purchase and receive from B.C. Hydro, at the Delivery Points, Shore Power during Cruise Season, but only if and to the extent that such Electricity and the ability to deliver the Electricity are available to B.C. Hydro at times appropriate for receipt by the VFPA.

The supply of Electricity shall be alternating current 3 phase 4 wire, having a frequency of approximately 60 hertz metered at a nominal potential of 12,470 volts phase-to-phase and

B-4





BC Hydro

Electric Tariff

Supplement No. 76


delivered at a nominal potential of 12,470 volts phase-to-phase at the Point of Delivery, subject to normal variations from the said frequency and voltages.

The load shall be limited to 14 MVA maximum at the Canada Place wharf east berth and 14 MVA maximum at the Canada Place wharf west berth, and shall not be increased without the prior written approval of B.C. Hydro.

The physical delivery of Shore Power may be interrupted, curtailed, or suspended at any time and for any reason by B.C. Hydro provided that B.C. Hydro shall give the VFPA as much advance notice of such interruption, curtailment, or suspension as is reasonably practical under the circumstances and as outlined in the Local Operating Order referred to in Section 7.1.

5 RATES, CHARGES, METERING AND BILLING

5.1 Applicable Energy Rate

The basic monthly rate or charge for Shore Power delivered in any billing month shall equal the product of (i) the number of kilowatt hours of Shore Power delivered to the VFPA in that month, multiplied by (ii) the energy charge set out in B.C. Hydro's Rate Schedule 1880 and multiplied by (iii) 1.0344 to account for distribution losses.

In addition to this basic monthly rate or charge, B.C. Hydro will also include in its bills or invoices to the VFPA, and the VFPA will also pay or reimburse B.C. Hydro for, the following: (i) any taxes, levies, surcharges and similar imposts required to be charged and collected pursuant to any applicable law, regulation or order binding on B.C. Hydro (ii) power factor penalties under Section 5.8, and (iii) any late payment charges, if applicable.

5.2 No Demand Charge

Because of the non-firm nature of the energy provided under this Agreement, and because the VFPA will bear the costs of all necessary delivery facilities and the costs of applicable operating, maintenance and related services, there is no demand charge for service under this Agreement.

B-5



... Ill.I BC Hydro


Electric Tariff

Supplement No. 76

Effective: December 19, 2008 Commission Secretary

5.3 Administrative Charge

In addition to the energy charge provided for in Section 5.1, the VFPA will pay an Administrative Charge of $150.00 per month per account in the cruise season. B.C. Hydro will establish a separate account for each of the east and west berths at Canada Place Wharf.

5.4 Charge to Operate Switchgear

On each occasion that B.C. Hydro is required to dispatch power line technicians or other workers to operate the switchgear for each connect and disconnect of cruise ships docked at the Canada Place Wharf, B.C. Hydro will charge, and the VFPA will pay, the reasonable time and labour costs for this service. The charge will be based on prevailing BC Hydro's contracted labour rates and will be separately itemized on the VFPA's monthly bill.

5.5 Rate Rider

The Deferral Account Rate Rider as set out in Rate Schedule 1901 applies to all charges payable under this Agreement, before taxes and levies.

5.6 Rate Revisions

The rates and charges set out in this Section 5, including the Administrative Charge provided for in Section 5.3, are subject to adjustment from time to time in accordance with any restructuring or other changes made to the rates in B.C. Hydro's Rate Schedule 1880 and Rate Schedule 1901 as approved by the BCUC; and further are subject to any restructuring or other changes made to the rates and charges provided for in this Agreement, as approved by the BCUC.

5. 7 Power Factor

The average lagging Power Factor shall not be less than 90%. B.C. Hydro, in its discretion, may make continuous tests of Power Factor or may test the VFPA's Power Factor from time to time. If the VFPA's Power Factor is lower than 90%, B.C. Hydro may require the VFPA, at the VFPA's expense, to install Power Factor corrective equipment to ensure that a lagging Power Factor of not less than 90% is maintained.

B-6



n1I UJI BC Hydro


Electric Tariff

Supplement No. 76


5.8 Failure to Comply with Power Factor Requirements

If the VFPA neglects or refuses to install such Power Factor corrective equipment or auxiliaries as required by Section 5.6 above forthwith upon a request so to do, B.C. Hydro may at its sole option:

(a) disconnect service, or

(b) require a payment (in addition to the regular payment) of fifty cents (50¢) per month per 100 watts or fraction thereof of the connected load, or

(c) increase the VFPA's bill for Electricity by a surcharge in accordance with the following table; the amount of the surcharge so determined shall be added to the minimum bill or the calculation of the bill under the rate clause, whichever is the greater.

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... UJI BC Hydro


Electric Tariff

Supplement No. 76


Lagging Power Factor as Determined Lagging Power Factor Surcharge

by B.C. Hydro

Less than 100% but 90% or more Nil

Less than 90% but 88% or more 2%









Less than 50% 80%

No credit will be allowed for leading Power Factor.

5.9 Metering and Billing

Shore Power is primary metered.

B.C. Hydro owns and is responsible for the maintenance of meters and metering transformers installed on the VFPA's premises for the purposes of billing.

B.C. Hydro may render accounts as often as it deems necessary. Current bills are due and payable upon presentation. A late payment charge at a rate and under terms and conditions contained in B.C. Hydro's Electric Tariff will be applied to amounts which remain unpaid one month from the billing date. If it becomes necessary to disconnect service, payment of the full amount due plus a reconnection charge will be required before service is restored.

B-8



nw llUI BC Hydro


Electric Tariff

Supplement No. 76


6 MAINTENANCE

The VFPA owns and is responsible for the maintenance of all electrical equipment required for the supply of Port Electricity to docked cruise ships at the Canada Place wharf (the "Port Electricity Electrical Equipment"), other than the meters and metering transformers supplied by B.C. Hydro. The VFPA will at all times maintain, repair and replace the Port Electricity Electrical Equipment in accordance with the requirements of B.C. Hydro's Electric Tariff and the Local Operating Order.

7 OPERATIONS

7.1 Connection/disconnection procedures.

The procedures for connecting and disconnecting docked cruise ships to and from Port Electricity Electrical Equipment, and procedures for related matters (including synchronization, transfer of loads, communications, safety, among others) will be set forth in the Local Operating Order to be agreed upon and signed between B.C. Hydro and the VFPA. The Parties may from time to time agree in writing to change the provisions of the Local Operating Order without such changes or the Operating Order itself being considered modifications or amendments to this Agreement. B.C. Hydro shall not be obligated to deliver Shore Power under this Agreement until the Local Operating Order is signed.

8 PROTECTING EQUIPMENT AND POWER QUALITY

8.1 The VFPA's protection of B.C. Hydro's quality of power.

The VFPA shall at all times design, install, operate and manage its facilities and equipment (including generation and loads) to avoid adverse impacts on the quality and reliability of power available to B.C. Hydro and B.C. Hydro's other customers. B.C. Hydro shall be entitled to prescribe reasonable protective measures to implement this requirement. B.C. Hydro may from time to time reasonably change such requirements without such changes being considered modifications or amendments to this Agreement.

B-9





BC Hydro

Electric Tariff

Supplement No. 76


8.2 Protection by the VFPA of its own equipment and machinery.

During operation of its facilities, equipments, and loads, the VFPA will at all times take all necessary steps (including complying with requirements reasonably imposed by B.C. Hydro for this purpose) to prevent adverse impacts on the VFPA's equipment and machinery. The VFPA shall, for example, cause cruise ships docked at the Canada Place Wharf that are receiving, or will receive, Port Electricity under this Agreement to install and maintain in good operating condition suitable protective devices (including suitable motors) reasonably satisfactory to B.C. Hydro for equipment aboard the cruise ships including but not limited to:

(i) Line starting and overload protective devices;

(ii) Devices to protect against under- and over-voltage, and under- or over frequency;

(iii) Devices to protect three-phase equipment from single-phase operation and phase reversal.

(iv) Devices to protect against reverse power flowing from the cruise shipss into the B.C. Hydro system.

The VFPA will further cause the cruise ship owners to permit B.C. Hydro to inspect the protective devices aboard the cruise ships from time to time to determine that the protective devices comply with the requirements of this section.

9 RESALE OF ELECTRICITY

In respect of any resale of Shore Power by the VFPA as Port Electricity to cruise ship operators, the VFPA agrees that the price it will charge for the supply of Port Electricity to cruise ships docked at Canada Place Wharf during any Cruise Season will not exceed the price payable to B.C. Hydro for the Shore Power supplied during that Cruise Season. The rates and charges for Port Electricity may be set by the VFPA on a different basis from the rates and charges payable to B.C. Hydro for Shore Power, for instance to permit the VFPA to recover the charges payable to B.C. Hydro under sections 5.3 and 5.4 of this Agreement pro rata from cruise ship operators, so long as the rates and charges set by the VFPA are designed to recover only the overall price payable to BC Hydro for Shore Power supplied during that Cruise Season.

8-10





10 GENERAL CONDITIONS

10.1 Terms and Conditions of Agreement:

BC Hydro

Electric Tariff

Supplement No. 76


Except to the extent inconsistent with the terms and conditions of this Agreement, in which case the terms and conditions of this Agreement shall prevail, the supply and taking of electricity is subject to the terms and conditions of the B.C. Hydro's Electric Tariff (including amendments thereto or replacements thereof) as filed with and approved by the BCUC. The VFPA may inspect B.C. Hydro's Electric Tariff during normal business hours at B.C. Hydro's Head Office or its other general offices and such right to inspect is sufficient notice of the terms and conditions contained therein.

·. 10.2 Assignment:

Neither Party will assign this Agreement or its rights hereunder without the prior written consent of the other Party, not to be unreasonably withheld.

10.3 Law:

This Agreement is governed by the laws of British Columbia and the laws of Canada applicable therein, without regard to conflict of laws rules that would lead the Proposal of any other law.

11 NOTICES

11.1 Notices:

All notices specified in this Agreement, to be given for record purposes must be provided as outlined below.

11.2 Address for Notice

All written notices, statements or payments will be made to the addresses and or facsimile numbers specified below.

B-11




Commission Secrefary

If to the VFPA:

Vancouver Fraser Port Authority

100 The Pointe

999 Canada Place

Vancouver, B.C., V6C 3T4

Facsimile:

If to B.C. Hydro:

B.C. Hydro Customer Care and Power Smart

900 - 4555 Kingsway

Burnaby, British Columbia V5H 4T8

Facsimile: (604) 453-6285

BC Hydro

Electric Tariff

Supplement No. 76


A Party may change its address by providing notice of same in accordance with this Section.

11.3 Delivery of Notices

Notices required to be in writing will be delivered by letter, facsimile or other documentary form. Notice by mail will be deemed received on the date of actual delivery. Notice by facsimile or courier delivery will be deemed received on the Business Day on which it was transmitted (sender having received evidence of successful transmission) or delivered (unless delivered after the close of the Business Day in which case it will be deemed received on the next Business Day).

10.4 VFPA Authorized Agent

The VFPA may appoint a third party as its authorized agent to act on the VFPA's behalf in connection with any of the matters or things to be done or performed by the VFPA under this Agreement, and may delegate such powers to its authorized agent as it deems advisable, provided that the VFPA shall at all times remain responsible for performance of its obligations hereunder, and for all breaches or defaults in its obligations and for any liabilities arising therefrom. The VFPA may change its authorized agent from time to time as it sees fit. The VFPA shall give prompt notice in writing to B.C. Hydro of the appointment of an authorized

B-12




Comm0ission Secretary

BC Hydro

Electric Tariff

Supplement No. 76


agent, and of any changes thereto, and shall also notify B.C. Hydro in writing of the powers delegated to its authorized agent from time to time.

12 MISCELLANEOUS

12.1 General

This Agreement constitutes the entire agreement between the Parties relating to the subject matter contemplated by this Agreement. No amendment or modification to this Agreement will be enforceable unless reduced to writing and executed by both Parties.

12.2 No Third Party Beneficiaries

This Agreement will not impart any rights enforceable by any third-party (other than a permitted successor or assignee bound to this Agreement).

12.3 Waiver

No waiver by a Party of any default by the other Party will be construed as a waiver of any other default. No waiver shall be valid and effective unless it is in writing signed by the Party giving the waiver.

12.4 Relationship

Nothing in this Agreement will be construed to create an association, trust, partnership or joint venture between the Parties or impose a trust or partnership covenant, obligation or liability on or with regard to any one or more of the Parties.

12.5 Severability

Any provision declared or rendered unlawful by any applicable court of law or regulatory agency or deemed unlawful because of a statutory change will not otherwise affect the remaining lawful obligations that arise under this Agreement.

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... I.I.I



12.6 Signing in Counterpart

BC Hydro

Electric Tariff

Supplement No. 76


The Parties may execute this Agreement in one or more counterparts to be construed as one, effective as of the Effective Date.

The Parties have executed this Agreement.

BRITISH COLUMBIA HYDRO AND POWER

AUTHORITY

Title: ---------------


Name: ---------------

Title: ---------------

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~ Commission Secretary

BC Hydro

Electric Tariff

· Supplement No. 76


AGREEMENT FOR PROVISION OF SHORE SERVICE;

TO

CANADA PLACE

This Agreement (hereinafter rsferred to as "Shore Power Agreement" or "Agreement") is made to be effective on the~ day of ::JA ilJV Ml.~ 200j, . ·

BETWEEN:

AND:

BRITISH COLUMBIA HYDRO AND POWER AUTHORITY,

. having its head office at 333 Dunsmuir Street,

Vancouver, British Columbia V68 5R3

("B.C. Hydro")


100 The Pointe ·

999 Canada Place

Vancouver, British Columbia, V6C 3T4 . .

("the VFPA")

(Each of B.C. Hydro and the VFPA are referred to Individually as the · "Party" and collectively, as the "Parties")

B-1



1:1 BC Hydro


Electric Tariff

Supplement No. 7.6

~ Effective: December 19, 2008 ~omrrytsslo~ Secretary

WHEREAS the VFPA owns ~nd is charged with operating the wharf at Canada Place, Vancouver Hiarbour, and wishes to Install facilities to enable cruise ships docked at the. Canada Place wharf to connect to and receive electricity supply from the wharf while they are at berth. This electricity supply will r,lleve the docked cruise ships of the need to operate their onboard diesel generating units while at berth, thereby reducing air emissions in thf!! Vancouver Harbour area; and

WHEREAS the VFPA is currently receiving service from B.C. Hydro pursµant to Rate Schedule 1211 approved by the British Columpia Utllitles Commission, and In addition, wishes to. receive a non·firm electricity supply {"Shore Power") from B.C. Hydro for the east and west berths at .. Canada Plac_e In order to provide the Shore Power to the docked cruise shlpss, ~nd

WHEREAS the B.C. Hydro and the VFPA wish to enter Into this Shore Power Agreement to provide for the supply of Shore Power to the Canada Place wharf.

NOW THEREFORE, THIS AGREEMENT WITNESSES that the Parties agree as follows:

1 INTERPRETATION

1.1 Definitions

The following definitions and any terms defined internal.ly In this Agreement will apply to this Agreement and all notices and communications made pursuan~ to this Agreement:

Delivery Points. The physical locations at the Canada Place Wharf at which Shore Power is delivered by B.C. Hydro to the VFPA and received by the VFPA from· B.C. Hydro, as set forth In the Local Operating Order. '

Canada Place Wharf. The VFPA wharf at Canada Place, Vancouver Harbour, for the berthing of cruise ships and other ocean going vessels, ·

cruh~e Season. The months of April, May, June, July, August, September and October during any yea( of thi~ Agreement.

Electricity. ·aectrical power and electrical energy. Power Is measured and expressed In kilowatts (kW) or kilovolt-amperes (kV.A) and energy Is measured and expressed In kilowatt-hours (kW.h). ·

Local Operating Order. The operating order entered lnto by a.c. Hydro and the VFPA which outlines the procedures. to be followed when working on electrical facllities at or In the vicinity of the Delivery Points, and for connecting and dlsc6nnecting· docked cruise ships to and from the Shore Power dellveiy facilities, and procedures for related· matters, as the same ll)aY be revised from time to time.

B·2



Accepted: December 18, 2008 · Order No. G-197-08


BC Hydro

Electric Tariff

Supplement No. 76

Effective: oe·cember 19, 2008

Port Electricity. Electricity delivered by the VFPA to cruise ships docked at Canada Place Wharf in Vancouver.

Shore Power. Electricity supplied by s.c. Hydro on a non-firm basis tO .the VFPA for delivery as Port Electricity to cruise ships docked at Canada Place Wharf.

1.2 Interpretation

Unless otherwise specified herein, all references to Sections are to those set forth In .this Agreement. . Reference to any Party includes any permitted successor or assigne(' thereof. The term "including" followed by descriptive words ls used In this Agreement by way of example only and is not intended to limit the scope of the provision. The headings used In this Agreement are for convenience and reference purposes only.

2 AVAILABILITY

2.1 Delivery Facilities

· B.C. Hydro and the VFPA will each use commercially reasonable efforts to complete the installation of all necessary equipment and upgrades within B.C. Hydro's distribution system and the Canada Place Wharf ready for delivery of Shore Power and Port Electricity as of April 1, 2009. The "Distribution Extensions" provisions in Part 8 of B.O. Hydro's Electric Tariff Terms and Conditions wlll apply in respect of any "Extension" (as definei;I in the said Terms and Conditions) to B.C. Hydro's distribution system to enable the supply of Shore Power to the Canada .Place Wharf, except that having regard to the nature of the service to be provided by B.C. Hydro under this Agreement no contribution will be payable by B.O. Hydro towards the cost of the Extension. ···

2.2 Use oH:lectricity

Shore Power supplied by B.C. Hydro pursuant to this Shore Power Agreement shall be used only for the supply of Port Electricity fo cruise ships docked at the Canada Place Whart from time to time during the Cruise Season. Shore Power taken under this Shore Power Agreement shall not displace Electricity that would otherwise be taken by the VFPA under Rate Schedule 1211 for u~es other than supply of Port Electricity to docked cruise ships.

B-3



.na IU BC Hydro

Accepted: December 18, 2.008 Order No. G·.197-08

Electric Tariff

Supplement No. 76


3 TERM

3.1 Term of Agreement

Notwithstanding the actual date of execution, the term of this Agreement will commence on the effe.ctlve date spec;ified on page 1 (the "Effective Date") and will continue for a ten year period (the "Term") unless terminated prior io 1he expiration thereof In aooordanoe with

.section 3.2 or 3.3. · ·

3.2 . Early' Termination bv the VFPA

. . The VFPA shall be entitled to terminate this Agreement at any time by giving B.C. Hydro 30 . days advance written notice of termination, effective on the date specified in such notice; provided that the VFPA shall remain obligated to pay any amounts ·accrued and owing hereunder as of the qate of termination.

3.3 Early Termination bv 8.C. Hydro

B.C. Hydro shall be entitled to terminate this Agreement by giving the VFPA 30 days advano~ written notice of termination If, at any time during the Term, the costs of this Agreemenf are de'termlne.d by. the British Columbia Utilities Commission ("BCUC"), or any other regulatory body having jurisdiction from time to tim~ in respect of B.C. Hydro's rates, to be ·Imprudent or not in the Interests of B.C. Hydro's ratepayers, or If B.C. Hydro is unable for any. reason to reeover the co$ts of this Agreement In Its rates. Upon termination µnder this section1 neither party shall have any further QT other llablllty or obligation to the other.

4 ELECTRIC SERVICE TO BE PROVIDJ;D

4.1 Non·fi~m EJectrlclty

B.C. Hydro will .sell and deliver to the VFPA, and the VFPA will purchase and receive from B.C. Hydro, at the Delivery Points, Shore Power during Cruise Season, but only If and to the· extent that such Electricity and the abillty to deliver the Electricity are available to B.C. Hydro at times appropriate for receipt by the VFPA. ·

The supply of Electricity shall be alternating current 3 phase 4 wire, having a frequency of approximately 60 hertz metered at a nominal potential of 12,470 volts phase-to-phase and

B-4



m BC Hydro

Accepted: December 18, 2008 order No. G-197-08

Electric Tariff

Supplement No. 76

Effective: . December 19, 2008 Commission Secretary

delivered at a nominal potential of 12,470 volts phase-to-phase at the Point of Delivery, subject to normal variations from the said frequency and voltages.

The load shall be limited to 14 MVA maximum at the Canada Place wharf east berth and 14 MVA maximum at the Canada Place wharf west berth, and shall not be increased without the prior written approval of B.C. f-jydro.

The physical delivery of Shore Power· may be Interrupted, curtailed, or suspended at any time and for any reason by B.C. Hydro provided that B.C. Hydro shall give. the VFPA as much advance notice of such interruption, curtailment, or suspension as is reasonably practical under the circumstances and as outlined In the Local Operating Order referred to In Section 7.1. .

5 RATES, CHARGES, METERING AND BILLING

5.1 Applicable Energy Rate

. The basic monthly rate or charge for Shore Power delivered in. any billing month shall equal the product of (i) the number of kllowa1t hours of Shore Power delivered to the VFPA In that month, multiplied i?Y (ii) the energy charge set out in 8.C. Hydro's Rate Schedule 1880 and multipUed by (lif) 1.0344 to account for distribution losses. ·

In addition to this basic monthly rate or charge, B.C. Hydro wlll also .include In its· bills or Invoices to the VFPA, and the VFPA will also pay or reimburse B.C. Hydro for, the following: (i) any taxes, levies, surcharges and similar imposts required.to be charged and collected pursuant to any applicable law, regulation or order binding on B.C. Hydro (II) power factor penalties under Section 5.8, and ,(iii) any late payment charges, If applicable.

5.2 No Demand Charge

Be9ause of the non-firm nature of the energy provided under this Agreement, and because the VFPA will bear the costs of all necessary delivery facilities and the costs of applicable operating, maintenance and related services, there is no demand charge for service under thls A!;Jreement. ·

B-5





.5.3 Administrative Charge

BC Hydro

Electric Tariff

supplement No. 76

Effective~ December 19, 2008

In addition to the energy charge provided for in Section 5.1, the VFPA will pay an· Administrative Charge of $160.00 per month per account In the cruise season. B.C. Hydro wlJI establish a separate account for each of the east and west berths at Canada Place Wharf.

. . 5.4 Charge to Operate Switchgear

On each occasion that B.C. Hydro Is required to dispatch power line technicians or other workers to operate the switchg~ar for each connect and disconnect of cruise ships docked at the Canada Place Wharf, B.C. Hydro wlll charge, and the VF.PA wUI pay, the reasonable time and labour costs for this service.· The charge will be based on prevailing BC Hydro's contracted labour rates and wm be separately itemized on the VFPA's monthly bill.

5.5 Rate Rider

The Deferral Account Rate Rider as set out In Rate Schedule. 1901 applies to all charges payable under this Agreement, before taxes ar.id Ievi.es.

5.6 ft.ate Revisions

The rates and charges set out In this Section 6, Including the Administrative Charge provided for h:i Section 5.3, are subject to adjustment from. time to time ~n accordance with any restructuring or other changes made to the rates lri B.C. Hydro's Rate Schedule 1880 and Rate Schedu)e 1901 as approved by ttie BCUC; and further .are subject to any restructuring or other changes made to the rates and charges provided for in this Agreement, as approved. by the BCUC. . .

5.7 · Power Factor

The average lagging Power.Factor shall not be less than 90%. B.C. Hydro, In Its discretion, may make continuous tests of Power Factor or may test the VFPA's Power Factor from time to time. If the VFPA's Power Factor is lower than 90%, B.C. Hydro may require the VFPA, at . the VFPA's expense, to install Power Factor corrective equipment to ensure that a lagging Power"Factor of hot less than 90% is maintained.

8·6.





5.8 Failure to Comply with Power Factor Requirements

BC Hydro.

Electric Tariff

Supplement No. 76

Effective: December 19, 2008 '

If the VFPA neglects or refuses to. install such. Power Factor corrective equipment or aux!llarles as required by Section 5.6 above forthwith upon a request so to do, B.C. Hydro may at its sole option:

(a) disconnect service, or .

(b) require a payment (in addition to the regular payment) of fifty cents (50¢) per month per 100 watts or fraction thereof of the connected load, or

(c) Increase the VFPA's bill for Electricity by a surcharge in accordance with the following. · table; the amount of the surcharge so determined shall be added to the minimum bill or the calculation of the bill under the rate clause, whichever is the greater .

. 8·7



III Accepted: December 18, 2008 Order No. G-197-08

BC Hydro ·

Electric Tariff

Supplement No. 76


Lagging Power Factor as Determined Lagging Power Factor Surcharge

by .B.C. Hydro

Less than 100% but 90% or more Nil



Less than ?5% but 80% or more 9%

Less than 80%· but 75% or more 16%


Less than 70% but 65% or niore 34%

Less than 65~ but 60% or more 44%

Les·s than 60% but 55% or more 57%


Less than 50% 80%

No credit will be allowed for leading Power Factor.

5.9 Metering and Billing

Shore Power Is primary metered.

B.C. Hydro owns and is responsible for the maintenance of meters and metering transformers installed on the VFPA's premises for the purposes of billing.

B.C. Hydro may render accounts as often as it deems necessary. 9urrent bills are due and payable upon presentation. A late payment charge at a rate and under terms and conditions contained in B.C. Hydro's Electric Tariff will be applled to amounts which remain unpaid one month from the billing date. If It becomes necessary to disconnect se1Vlce, payment of the full amount due plus a reconnection charge will be required before service is restored.

8-8



Accepted: December 18, 2008 order No. G-197·08


6 MAINTENANCE

E;IC Hydro

Electric Tariff

Supplement No. 76

Effective: December 19, 2008 .

The V.FPA owns and is responsible for the maintenance of all electrical equipment required for the supply of Port Electricity to docked cruise ships at the Canada Place wharf (the "Port Electricity Electrlcal Equipmert"), other than the meters and metering transformers supplied by B.C. Hydro. The VFPA will at all times maintain, repair and replace the Port Electricity Electrical Equipment in accordance with the requirements of B.C, Hydro's Electric Tariff and the LocalOperatinQ Order.

7 OPERATIONS

. 7 .1 Connection/disconnection procedures.

The procedures for connecting and disconnecting docked cruise ships to and from Port Electricity Electrical. Equipment, and. procedures for related .matters Oncluding synchronization, transfer of loads, communications, safety, among others) will be set forth in the Local Operating Order to be agreed upon and signed between B.C. Hydro and the VFPA. The Parties rhay from time to time agr.ee In writing to change the provisions of the Local Operating Order without such change·s or the. Operating Order itself being considered modifications or amendments to this Agreement. B.C. Hydro shall not be obligated to deliver Shore Power.underihis Agreement until the Local Operailng Order is signed.

8 PROTECTING EQUIPMENT AND POWER QUALITY .

8.1 The VFPA's protection of B.C. Hydro's quality of power.

The VFPA shall at all times design, install, operate and manage its facilities and equipment (including generation and loads) to avoid adverse impacts on the· quality and reliability of power available to B.C. Hydro and B.C. Hydro's other customers. B.C. Hydro shall be entitled to prescribe reasonable protective measures' to Implement this requirement. B.C. Hydro may from time to time reasonably change such requirements without such changes being considered modifications or amendments to this Agreement.

8·9



Ill Accepted: December 18, 2008 order No. G-197·08

BC Hydro

·electric Tariff

Supplement No. 76

Commission Secretary Effective: Decem~er 191 2008

8.2 Protection by the VFPA .of its own equipment and ·machinery.

During operation of Its facilitles, equipments, and loads, the VFPA wlll at all times 'take all necessary steps (Including complying with req4lrements reasonably imposed by B.C. Hydro for this purpose) to prevent adverse Impacts on the VFPA's equipment and. m~chfnery, The VFPA shall, for example, cause cruise ships docked at the Canada Place Wharf that are receiving, or will receive, Port Electricity under this Agreement to Install and maintain iri good operating condition suitable protective. devices (Including suitable motors) reasonably satisfactory to B.C. Hydro for equipment aboard the cruise ships including but not llmfted .to:

(i) Line starting and overload. protective devices;

(ii) Devices to protect against under .. and over-voltage, and under- or over frequency;

(Ill) Devices to protect three-phase equipment from single-phase operation and phase reversal.

(Iv) Devices to protect against reverse power flowing from the cruise shlpss Into the B,C, Hydro system.

The VFPA will further cause the cruise ship owners to permit 13.C, Hydro to Inspect the protective devices aboard the cruise ships from time to tif!le to determine that the protective devices complywlth the requirements of this section.

9 RESALE OF .ELECTRICITY

In respect of any resale of Shore Power by the VFPA as Port Electricity to cruise ship operators, the VFPA agrees that the price It will charge for the supply of Port l=lectricity to cruise ships docked at Canada Place Wharf during any Cruise Season wfll not exceed the price payable to B.C. Hydro for the Shore Power supplied during that Cruise Season. The rates and charges for Port Electricity may be set by the VFPA on a different basis from the rates and charges payable to B.C. Hydro for Shore Power, for instance to permit the VFPA to recover the charges payable to B:C. Hydro under sections 5.3 and 5.4 of this Agreement pro rata from cruise ship operators, so long as the rates and charges set by.the VFPA are designed to recover only the overall price payable to BC Hydro for Shore Power supplied during that cruise Season. ·

B·10



Ill BC Hydro

Accepted: December 18, 2008 . order Np. G-197-08

Electric Tariff

Supplement No. 76


10 GENERAL CONDITIONS

10.1 Terms and Conditions of Agreement:

Except to the extent inconsistent with the terms and conditions of this Agreement, In which case the terms and conditions of this Agreement shall prevail, the supply and taking of electricity is subject to the terms and conditions of the B.C. Hydro's Electric Tariff (including amendments thereto or replacements thereof) as filed· with and approved by the BCUC. The VFPA may Inspect B.C. Hydro's Electric Tariff during normal business hours at 8.C .. Hydro's Head Office or Its other general offices and such right to inspect Is sufficient notice of the terms and condttions contained therein. · · ·

10.2 Assignment: ·

Neither Party wlll assign this Agreement or its rights hereunder without the prior written consent of the other Party, not to be unreasonably withheld. ·

10.3 Law:

This Agreement is governed by the laws of British Columbla and the laws of Canada applicaJ>le therein, without regard to conflict of laws rules that would lead the Proposal of any other law.

11 NOTICES

11.1 N()tices:

All notices specified in this Agreement, to be given for record purposes must be provided as · outlined below.

11.2 Address for Notice

All written notices, stat~ments or payments will be made to the addresses and. or facsltnile. numbers speolfied below.

B-11



Accepted: December.18, 2.008 Order No. G-197-08

Commission ~ecref.U"Y _,

If to the VFPA:

Vancouver Fraser Port Authority

100 The Pointe

999 Canada Place

Vancouver, B.C., V6C 3T4

Facsimile:

lfto B.C. Hvdro:

B.C, Hydro Customer Care and Power Smart

900 ..,. 4555 Klngsway

Burnaby, British Columbia VSH 4T8

Facsimile: (604) 453-6285

BC Hydro

Electric Tariff

Supplement No .. 713


A Party may change Its address by p·rovldlng notice ofsame In accordance with this Section_.

11.3 Deliverv of Notices

Notices required to be In writing will be delivered by letter, facsimile or other documentary form .. Notice by mall will be deemed received on the date of actual delivery, Notice by facsimile or courier delivery· will be deemed received on the Business Day on which It was · transmitted (sender having received evidence of successful transmissiqn) or delivered (unless delivered after the close of the Business Day In which case It will be deemed received on the next Business P~y); ·

10.4 VFPA Authorized Aqen~

The VFPA may appoint a third party as Its authorized agent to act on the VFPA's behalf in connection with any of the matters or things to be done or performed by the VFPA under this Agreement, and may delegate such .Powers to Its authorized agent as It deems advisable, provided that the VFPA shall at all times remain responsible for performance of its obligations hereunder, an~ for all breaches or defaults In its obligations and for any llabilitles arising therefrom. The VFPA may change its authorized agent from time to time as it sees fit. The VFPA sha.11 give prompt noti.ce In writlryg to B.C, Hydro of the appointment of an authorized

8·12



Ill BC Hydro


Electric Tariff .

Supplement No. 76

~· Commission Secretary . .


agent, and of any changes there~o, and shall ~Isa notify B.C. Hydro In wrltlhg of the powers delegated to Its. authorized agent from time to 1ime.

12 MISCELLANEOUS

12.1 General

This Agreement constitutes the entire agreement between the Parties relating to the subject matter contemplated by this Agreement. No amendment or modification to this Agreement' will be enforceable unless retjuced to writing and executed by botli Parties.

12.2 No Third Partv Beneficiaries

This Agreement will not Impart any rights enforceable by any third-party (other than a permitted successor or assignee bound 1o this Agreement).

12.3 Waiver

No waiver by a Party of any default by the other Party will. be construed as a waiver of any other default. No waiver shall be valid and effective unless it Is in writing signed by the Party giving the waiver.

12.4 Relationship

Nothing ln this Agreement wlll be construed to create an association, trust, partnership or joint venture between the Parties or impose a trust or partnership covenant, obligation or liablllty on or with regard to any on~ or more of the Parties. ·

12.5 s·everabilitv

Any provision declared or rendered unlawful by any applicable court of law or regulatory agency or deemed unlawful· because of a statutory change . Will not otherwise· affect the remaining lawful obligations that arise under t~ls Agreement. ·

9.13·



Ill Accepted: D.ecember 18,· 2008 Order No. G-197-08


12.6 Signing In Counterpart

BC Hydro

Electrfc Tariff

. Supplement No. 76


The Parties ·may execute this Agreement In one or more counterparts to be construed as one, effectlye as of the Effective Date.

The Parties have executed this Agreement.

Name: ---'"""'-"--'-..;;__,;;;.,_;~~-=----"-,--"'--~~

Title: SI('. ~----~~--....._~~~~~~

VANCOUVER FRASER PORT AUTHORITY · 1 . }~/1__-r-By: ~~~-~~.--~~~~~~~~

Naine: {;~(,(- lAJi/1..T2-

Tltle: MA IVAC-f rt, 11'94x I)~ i//;,:,li,,1F'l//Jl';v T

B·14




Page 1 of 1


Exhibit: B-2

2.0 Reference: Exhibit B-1, Application, Section 1.2 p. 1-3

Tariff Supplement (TS) 76

TS 76 is the existing non-firm Shore Power Rate for Port Metro Vancouver’s Canada Place cruise ship terminal.

On page 1-3 of the Application, BC Hydro states that shore power facilities at Canada Place were installed in 2008 and the Commission approved TS 76 in December 2008, the approval of which was granted in accordance with the Ministerial Order BC Regulation 291/2008, also known as the Shore Power Regulation. On page 2-9 of the Application, BC Hydro describes the new Shore Power Rate as similar to TS 76 and discusses the design features of TS 76.

1.2.2 Please provide a copy of Order G-197-08 and Ministerial Order M 252 in your response to this question.

RESPONSE:

A copy of the Shore Power Regulation, B.C. Reg. 291/2008 (Ministerial Order No. M252), is provided as Attachment 1 to this response.

A copy of Commission Order No. G-197-08 is provided as Attachment 2 to this response.

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Enabled RegulationsUtilities Commission Act, RSBC 1996, c 473 31 Regulations

Current version: as posted on Feb 16, 2009

Link to the latest version: http://canlii.ca/t/859tStable link to this version: http://canlii.ca/t/jk7f

Citation to this version: Shore Power Regulation, BC Reg 291/2008, <http://canlii.ca/t/jk7f> retrieved on 2015-04-28

Currency: Last updated from the BC Laws site on 2015-04-21Share: CLOSE TABLE OF CONTENTS1Definitions2Purpose3Required rates

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M252/2008

Utilities Commission Act

SHORE POWER REGULATIONNote: Check the Cumulative Regulation Bulletin 2012 and 2013

for any non-consolidated amendments to this regulation that may be in effect.

Definitions

1 In this regulation:

"Act" means the Utilities Commission Act;

"shore service" means service provided by the authority to the Vancouver Fraser Port Authority to enable it to provide port electricity;

"port electricity" means electricity delivered by the Vancouver Fraser Port Authority to cruise ships docked at Canada Place wharf in Vancouver.

Purpose

2 This regulation is made for the purposes of section 58 (2.1) (a) of the Act.

Required rates

3 (1) Subject to subsection (2), the commission must set a shore service rate that

(a) is designed to encourage operators of cruise ships docked at Canada Place wharf in Vancouver to use port electricity instead of on-board, diesel-generated electricity, and

(b) includes the condition that port electricity may be provided only at a price not exceeding the price for shore service.

(2) In setting the rate for shore service, the commission must ensure that the rate allows the authority to collect sufficient revenue in each fiscal year to enable the authority to recover costs incurred as a result of providing the shore power service.

[Provisions of the Utilities Commission Act, R.S.B.C. 1996, c. 473, relevant to the enactment of this regulation: section 125.1 (4) (f)]

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SIXTH FLOOR, 900 HOWE STREET, BOX 250 VANCOUVER, B.C. V6Z 2N3 CANADA

web site: http://www.bcuc.com

TELEPHONE: (604) 660‐4700 BC TOLL FREE: 1‐800‐663‐1385 FACSIMILE: (604) 660‐1102

. . ./2

BRIT ISH COLUMBIA

UTIL IT IES COMMISSION ORDER NUMBER G‐197‐08

IN THE MATTER OF the Utilities Commission Act, R.S.B.C. 1996, Chapter 473

and

An Application by British Columbia Hydro and Power Authority Application for Approval of Electric Tariff Supplement No. 76 – Agreement for Provision

of Shore Power Service to Canada Place

BEFORE: L.F. Kelsey, Commissioner P.E. Vivian, Commissioner December 18, 2008 D.A. Cote, Commissioner

O R D E R

WHEREAS: A. On October 15, 2008, the Provincial Government issued Ministerial Order No. M252 – The Shore Power

Regulation to the British Columbia Utilities Commission (“Commission”) stating that the Commission must set a shore service rate that is designed to encourage operators of cruise ships docked at Canada Place in Vancouver to use port electricity instead of on‐board, diesel generated electricity and includes the condition that port‐electricity may be provided only at a price not exceeding the price for shore service; and

B. The Shore Power Regulation also stated that in setting the rate for the shore service, the Commission must

ensure that the rate allows the authority to collect sufficient revenue in each fiscal year to enable the authority to recover costs incurred as a result of providing the shore power service; and

C. On October 31, 2008, British Columbia Hydro and Power Authority (“BC Hydro”) filed an application

pursuant to sections 58 to 61 the Utilities Commission Act for approval of Electric Tariff Supplement No. 76, an agreement for the provision of non‐firm electricity available for shore power use by the Port Metro Vancouver (“PMV”) at the Canada Place Wharf; and

D. By letter dated November 12, 2008, the Commission requested that BC Hydro provide some additional

information with respect to the Application; and E. On December 2, 2008, BC Hydro responded to the Commissions request for additional information; and F. The Commission has reviewed the Shore Power Regulation, the Application and the additional information

provided by BC Hydro and concludes that the application complies with the requirements of the Shore Power Regulation and that approval of the Application is in the public interest.



2

Orders/G‐197‐08_BCH‐TS#76 Shore Pwr Agrmt Canada Place

BRIT ISH COLUMBIA

UTIL IT IES COMMISSION ORDER NUMBER G‐197‐08

NOW THEREFORE the Commission approves for BC Hydro, Electric Tariff Supplement No. 76, effective the date of this Order. DATED at the City of Vancouver, in the Province of British Columbia, this 19th day of December 2008. BY ORDER Original signed by: L.F. Kelsey Commissioner




Page 1 of 1


Exhibit: B-2

3.0 Reference: Exhibit B-1. Application, Section 1.2.1, Page 1-3;

Appendix B-9 Workshop Summary p. 3 of 6 TS 76

Page 1-3 of the Application says that TS 76 applies to “a specific customer (PMV), one location (Canada Place), one vessel type (cruise ships) and is available only during May to October cruise ship season.”

The term of agreement of TS 76 is for a period of ten years from the effective date of December 19, 2008 and either one of the signatory parties, BC Hydro or the Vancouver Fraser Port Authority are entitled to terminate the agreement at any time with 30 days’ advance notice.

The following is an excerpt from TS 76 Section 1.0:

1.1 Definitions



1.3.1 Can BC Hydro confirm that the Definitions section of TS 76 defines the cruise season as “The months of April, May, June, July, August, September and October” during any year of this Agreement? If confirmed, can BC Hydro reconcile the difference between the cruise season definition used in TS 76 and the description of the cruise season in the Application?

RESPONSE:

Confirmed; refer to section 1 of TS 76 which is provided as Attachment 1 to the response to BCUC IR 1.2.1. The Application erroneously identified the Cruise Season in TS 76 as the period from May to October (inclusive), whereas it should have indicated April to October (inclusive).


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.1.1 Does this discrepancy have any effects on the input assumptions used in Tables 2-1 and 2-2? If so, please update the tables.

RESPONSE:

There is no impact to either Table 2-1 or Table 2-2 of Exhibit B-1 as both tables provide calculations covering a one-month period.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.2 Have cruise ships taken shore power outside the Cruise Season? Have other vessels taken shore power at Canada Place? If so, under which rate schedule(s) did they take electricity service?

RESPONSE:

There have been no connections outside the Cruise Season (April – October as defined in section 1 of TS 76). The definition of Shore Power in section 1 of TS 76 provides that only cruise ships can take non-firm shore power service at Canada Place wharf. Accordingly no other vessel types have taken non-firm shore power service at Canada Place.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.3 Has BC Hydro considered terminating TS 76 and moving the provision of shore power service to cruise ships at Canada Place wharf to be served under an all-encompassing TS 86? If not, why not?

RESPONSE:

Once BC Hydro is in receipt of a Commission decision concerning its Shore Power Rate Application, BC Hydro can give further consideration to this issue including engagement with PMV, the Port Customer served under TS 76 in respect of Canada Place wharf. As noted in BC Hydro’s response to BCUC IR 1.10.2, there is not much difference between TS 76 and RS 1280/TS 86.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.4 Total energy sales under TS 76 were 3.6 GWh in 2014 (page 1-4). Please discuss the energy sales in terms of BC Hydro’s gross and net revenues.

RESPONSE:

Gross revenues from TS 76 during 2014 were $298,000, including Administrative Charges but excluding taxes and the rate rider.

For the purpose of responding to the net revenues question, BC Hydro uses the average monthly Mid-C price as a proxy for energy cost. Under that assumption, the total cost of energy is estimated $124,000, and revenues net of energy costs were in the order of $174,000 during 2014.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.4.1 Based on the PMV forecast on annual load (MWh) and PRPA forecast on container ship visits (Appendix B-3), what is the likelihood that BC Hydro would be required to make market electricity purchases in order to provide shore services under TS 86 in the short term and in the long term (e.g., 8- to 10-year horizon)?

RESPONSE:

Nothing in RS 1280, RS 1891 or TS 86 requires BC Hydro to make electricity market purchases for purposes of providing shore power service. Special Condition 1 of both RS 1280 and RS 1891 state: “BC Hydro agrees to provide Electricity under this Rate Schedule to the extent that it has the energy and capacity to do so”. Section 4.1 of TS 86 provides that shore power service is non-firm electricity service and that the physical delivery of shore power service “may be interrupted, curtailed or suspended at any time and for any reason”. Shore power service is non-firm, can be interrupted and is not included in BC Hydro’s energy or peak demand load forecasts. Accordingly, BC Hydro has no plans to acquire market energy for purposes of providing shore power service under TS 86 and RS 1280 or RS 1891.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.4.2 Under TS 76, the Vancouver Fraser Port Authority pays an Administrative Charge of $150.00 per month per account in the cruise season. Does this charge recover all the incremental billing and administrative costs which was the intent of the Administrative Charge? Please provide, by year since the implementation of TS 76, any under- or over-collection?

RESPONSE:

BC Hydro does not track the work activities directly associated with the administration of TS 76, which include any efforts associated with billing and scheduling. Labour costs associated with these activities are minor, and the TS 76 Administrative Charge of $150 per month for the seven month Cruise Season would appear to be reasonable although it is difficult to say with certainty whether this amount under or over recovers actual labour costs.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.4.3 Does the monthly Administrative Charge recover other costs not related to billing and administrative costs? If so, please itemize those costs.

RESPONSE:

No. Please also refer to BC Hydro’s response to BCUC IR 1.3.4.2.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.4.4 Please describe the incremental OM & A costs of the transmission and distribution systems as a result of providing shore power services.

RESPONSE:

Please refer to BC Hydro’s response to BCUC IR 1.1.5.2.


Page 1 of 1


Exhibit: B-2






1.1 Definitions



1.3.4.5 Please comment on how the gross and net revenues from sales and the monthly Administration Charge under TS 86 would be included in BC Hydro’s revenue requirements application for F16 and beyond?

RESPONSE:

BC Hydro respectfully submits that “how the gross and net revenues from sales and the monthly [Administrative] Charge under TS 86” would be included in BC Hydro’s RRAs for F2016 and beyond is not relevant because this information cannot assist the Commission with its decision concerning the Application under section 61 of the UCA.


Page 1 of 1


Exhibit: B-2

4.0 Reference: Exhibit B-1, Application, Section 1.2.2, p. 1-5; Appendix B-3;

Appendix C1 Customer requests for Shore Power Rate


1.4.1 Has the Greater Victoria Harbour Authority also expressed interests or make any plans known to BC Hydro to have shore power available at its facilities? Will a potential request from Greater Victoria Harbour Authority be served under TS 86 or TS 76? Please explain your answer.

RESPONSE:

Greater Victoria Harbour Authority (GVHA) has in the past expressed interest in making shore power available at its Ogden Point cruise ship facility. BC Hydro understands that GVHA decided not to pursue shore power at this time.

If GVHA were to request service under the Shore Power Rate, as a new shore power Port Customer connected at distribution voltage, the applicable tariff would be RS 1280 and TS 86 assuring the proposed Shore Power Rate is approved by the Commission.


Page 1 of 1


Exhibit: B-2




1.4.2 In its letter of support, Prince Rupert Port Authority (PRPA) indicates that it has 200 container ships calling annually and this is projected to increase to 350 visits with the planned expansion of Fairview Container Terminal that will also utilize additional shore power connections. In BC Hydro’s view, does the PRPA currently have the spare capacity to serve the demand of these 350 eligible vessel visits? Where will BC Hydro get this energy?

RESPONSE:

Since shore power service is provided on a non-firm “as available” basis, unlike a firm rate, under the proposed Shore Power Rate BC Hydro is not required to ensure sufficient energy or capacity is available to provide service whenever requested by the Port Customer; refer to Special Condition 1 of RS 1891 which would be applicable to PRPA for Fairview Container Terminal purposes. There may be times when PRPA or any other RS 1280/RS 1891 Port Customer requests shore power service and capacity is unavailable.

Nothing in the proposed Shore Power Rate requires BC Hydro to acquire energy for purposes of serving Port Customers. Please refer to BC Hydro’s response to BCUC IR 1.3.4.1.


Page 1 of 1


Exhibit: B-2




1.4.3 Special Condition 3 in the proposed RS 1280 and RS 1891 states that a Port Customer that provides port electricity under RS 16xx and RS 1823 is not eligible to take port electricity under the RS 1280 and RS 1891. Have any of these customers made a Shore Power Rate request to BC Hydro?

RESPONSE:

There are not currently any Port Customers that provide port electricity under RS 16xx or RS 1823. Therefore no such Port Customer has made a Shore Power Rate request to BC Hydro.


Page 1 of 1


Exhibit: B-2

5.0 Reference: Exhibit B-1, Application, pp. 1-8 and 1-9, Table 1-3

Comparison with ports and utilities in other jurisdictions

The Application states that the major ports in North America have shore power rates in effect and that the majority of the ports/electric utilities provide shore power on a non-firm basis with no demand charge.

The Application also says that RS 1823 and RS 16xx are the relevant BC Hydro firm rate comparators given the Port Metro Vancouver and Prince Rupert Port Authority requests.

Table 1-3 describes current shore power rates in effect from BC Hydro’s survey of ports/electric utilities. Rates are obtained from each utility’s current tariff as of April 1, 2015. For PMV/BC Hydro (2009), the energy charge for distribution customer is described as 8.796 cents/kWh (F2016) based on RS 1823 Tier 2 energy rate grossed up by distribution loss.

1.5.1 According to TS 76, the applicable rate is RS 1880. Please explain why the TS 76 applicable energy rate is not used to indicate the current Shore Power Rate in effect.

RESPONSE:

Consistent with other RS treatment, RS 1280 and RS 1891 expressly set out the energy charges:

The RS 1891 energy charge is the RS 1823 Tier 2 energy price which for F2016 is 8.503 cents/kWh;

The RS 1280 energy charge is the RS 1823 Tier 2 energy price adjusted for distribution losses which is 8.796 cents/kWh for F2016.

The RS 1880 energy charge is also the RS 1823 Tier 2 energy price which for F2016 is 8.503 cents/kWh. The TS 76 energy charge is the RS 1823 Tier 2 energy price adjusted for distribution losses which is 8.796 cents/kWh for F2016. Section 5.1 of TS 76 provides that the energy charge is “set out in BC Hydro’s [RS] 1880 and multiplied by (iii) 1.0344 to account for distribution losses”. This is the same loss factor used for RS 1280; refer to page 2-13, lines 19-23, of Exhibit B-1.


Page 1 of 1


Exhibit: B-2






1.5.2 According to page 1-4 in the Application, the missed connection due to BC Hydro available capacity issue was 5 percent. In BC Hydro’s view, does the fact that the existing Shore Power Rate is limited to a defined Cruise Season help in lowering the missed connection statistic?

RESPONSE:

Since the BC Hydro system and specifically the downtown area is winter peaking, the defined TS 76 seven month April through October Cruise Season somewhat reduces the probability that non-firm shore power service will be unavailable due to a lack of energy and/or capacity. Please also refer to BC Hydro’s response to BCUC IR 1.7.1.


Page 1 of 1


Exhibit: B-2






1.5.2.1 Among the ports and utilities surveyed and presented in Table 1-3, how many of them apart from BC Hydro has a shore power rate that is seasonal in its availability?

RESPONSE:

Of the ports and utilities surveyed and presented in Table 1-3 of Exhibit B-1 and which have a published shore power rate, only Nova Scotia Power offers a shore power rate that is seasonal in its availability because Port of Halifax’s request was with respect to cruise ships.


Page 1 of 1


Exhibit: B-2






1.5.3 For those ports and utilities that have no demand charges, do they serve the shore power rate only during the off-peak months? Please provide examples in your response.

RESPONSE:

At this time, for those ports and utilities that have no shore power-related demand charges:

Port of Juneau, PMV/BC Hydro and Port of Halifax provide shore power service during the cruise season months, which exclude the peak winter months; and

Port of Oakland provides shore power service year round, which includes the peak months.

BC Hydro does not have information on the availability of Port of San Francisco’s shore power rate.


Page 1 of 1


Exhibit: B-2






1.5.4 For those ports and utilities that have no demand charges, how many of them vary their energy charge?

RESPONSE:

Port of Halifax/Nova Scotia Power is the only port/utility in the IR defined category that varies the energy charge – in this case according to voltage level.


Page 1 of 1


Exhibit: B-2






1.5.4.1 Are their respective energy charges based on a blended demand/energy rate to maintain revenue neutrality and to recover full cost?

RESPONSE:

The energy charges for the ports/utilities in the IR defined category do not include asset-related demand costs since their shore power rates are non-firm.


Page 1 of 1


Exhibit: B-2






1.5.4.2 Are their respective energy charges based on a standby rate, such as an RS 1880 equivalent?

RESPONSE:

As set out in BC Hydro’s response to BCUC IR 1.5.1, the energy charges in RS 1280 and RS 1891 are based on the RS 1823 Tier 2 energy rate.

BC Hydro is only able to confirm the basis of Port of Halifax/Nova Scotia Power’s shore power related energy charges. The respective energy charges for Port of Halifax/Nova Scotia Power’s shore power rate is based on incremental or avoided fuel cost, which is also used in Nova Scotia Power’s GR&LF Back-up rate which enables self-generation.


Page 1 of 1


Exhibit: B-2






1.5.4.3 Are their respective energy charges based on the energy only component of a rate that comprises demand and energy charges similar to BC Hydro’s transmission stepped service rate or LGS conservation rate?

RESPONSE:

BC Hydro is only using the RS 1823 Tier 2 energy rate to set the non-firm shore power energy charge. With respect to the issue of the Shore Power Rate and demand costs please refer to BC Hydro’s response to BCUC IR 1.1.5.2.

With respect to how the four jurisdictions other than BC Hydro with no shore power service-related demand charge set their respective energy charges, please refer to BC Hydro’s responses to BCUC IRs 1.5.4.1 and 1.5.4.2.


Page 1 of 1


Exhibit: B-2

6.0 Reference: Exhibit B-1, Application, p. 1-14 Table 1-4

Load per visit

The cruise ships have peak load of 10 to 12 MW per visit and other vessels have peak load of 2 to 5 MW per visit.

1.6.1 Has power factor been addressed in serving the cruise ships at Canada Place wharf under TS 76? If so, please describe how it is being addressed and how BC Hydro expects it to be addressed in the expanded version.

RESPONSE:

Section 12.1 of TS 86 provides that the terms and conditions of the Electric Tariff apply for purposes of providing non-firm shore power service under the proposed Shore Power Rate unless there is a conflict with the shore power rate. Section 7.2 of the Electric Tariff contains the power factor provisions with respect to distribution service. This is also the case for TS 76 except that section 5.7 of TS 76 replicates the Electric Tariff power factor provisions.

Section 12.1 of TS 86 also provides that the terms and conditions of any ESA between BC Hydro and a Port Customer applies for purposes of providing non-firm shore power service under the proposed Shore Power Rate unless there is a conflict with the Shore Power Rate. Clause 8 of ESAs contain contains the power factor provisions with respect to transmission service.


Page 1 of 1


Exhibit: B-2

7.0 Reference: Exhibit B-1, Application, Sections 2.2 pp. 2-1 to 2-3

Factors considered in developing Shore Power Rate

The Application lists three factors being considered in the development of the proposed Shore Power Rate: (a) characteristics of the prospective shore power load; (b) shore power rates offered in other jurisdictions; and (c) TS 76 and port customer preference.

Page 2-3 states that:


1.7.1 According to the Application, one of the characteristic of shore power is that it is naturally interruptible. Would the year-round offer of the Shore Power Rate subject eligible vessels to more frequent misconnection since ships seeking the Shore Power Rate under TS 86 will also be requesting shore power during the winter peaking months from November to March at BC Hydro?

RESPONSE:

Given that BC Hydro’s system is a winter peaking system, BC Hydro would generally expect that there would be more frequent interruptions to vessels seeking to connect in the winter months than ships connecting in the seven month, April through October Cruise Season set out in TS 76 (in this regard please refer to the response BCUC IR 1.5.2). However, the level of interruption will be influenced by the particular system characteristics serving the load.


Page 1 of 1


Exhibit: B-2

7.0 Reference: Exhibit B-1, Application, Sections 2.2 pp. 2-1 to 2-3

Factors considered in developing Shore Power Rate

The Application lists three factors being considered in the development of the proposed Shore Power Rate: (a) characteristics of the prospective shore power load; (b) shore power rates offered in other jurisdictions; and (c) TS 76 and port customer preference.

Page 2-3 states that:


1.7.2 Please comment if there is a hierarchy of interruption for non-firm customers. In the event of capacity or energy constraint, which interruptible customers (or a group of customers) are disconnected before others?

RESPONSE:

For distribution, the only existing non-firm services are non-firm shore power service under TS 76 and Dual Fuel Interruptible Service (E-Plus) available under RS 1105 (Residential), RS 1205, RS 1206 and RS 1207 (General Service). There is no established hierarchy of interruption for non-firm service. BC Hydro would develop a non-firm hierarchy of interruption if there were multiple non-firm customers served by the same common assets.

For transmission, non-firm service is offered under non-firm shore power service, RS 1852 – Modified Demand, RS 1853 – IPP Station Service, and RS 1880 – Standby and Maintenance Supply. There is no established hierarchy of interruption for non-firm service. BC Hydro would develop a non-firm hierarchy of interruption if there were multiple non-firm customers served by the same common assets.


Page 1 of 2


Exhibit: B-2

8.0 Reference: Exhibit B-1, Application, Section 2.3, pp. 2-3 to 2-7

Rate options and comparison of rates

BC Hydro determined that port customers do not require firm service and shore power load can be interrupted given that ships are equipped with on-board generators.

Based on a scenario where three vessel visits per month is assumed for a cruise ship, a container ship and a bulk carrier, Table 2-2 presents the comparison of charges under TS 76 with charges under RS 1823.

1.8.1 According to footnote 23 on page 2-7, the demand charge component for RS 16xx recovers 53 percent of demand-related cost and the demand component of RS 1823 recovers 65 percent of the fixed costs. Since the demand charges currently do not recover in full the fixed cost, please provide: (a) by how much the energy charges are increased in the existing rate schedule to recover the demand-related cost, and (b) an estimate of the increase in energy charges (RS 1823 and RS 16xx) in order to recover the proposed removal of demand charge.

RESPONSE:

(a)

BC Hydro respectfully submits that the trade-offs inherent in setting the level of fixed cost recovery through firm service rate demand charges such as those in RS 1823 and RS 16xx, and among other things sending an efficient price signal through firm service rate energy charges in the context of revenue neutrality is not relevant because this information cannot assist the Commission with its decision concerning the Application under section 61 of the UCA. BC Hydro submits that these kinds of firm service rate trade-offs should be addressed in the 2015 RDA.

To provide context, BC Hydro offers that: (1) to date, participants in BC Hydro’s 2015 RDA engagement process have not indicated that the RS 1823 and RS 16xx demand fixed cost recovery levels referenced in the IR above are problematic; and (2) the above mentioned trade-off with respect to LGS RS 16xx will be addressed in 2015 RDA Workshop 11 scheduled for June 25, 2015.

(b)

The proposed Shore Power Rate energy charges do not have to be increased “to recover the proposed removal of demand charge” because there is no Shore Power Rate demand charge for the reasons summarized in section 1.3 of Exhibit B-1: shore power service is non-firm and can be interrupted (refer to section 4.1 of TS 86, copy at Appendix C-1 of Exhibit B-1); shore power load is not


Page 2 of 2


Exhibit: B-2

included in either BC Hydro’s energy or peak demand load forecast; and interruptible service does not drive investment in transmission or distribution infrastructure. There are no transmission or distribution-related asset costs to be recovered through the proposed Shore Power Rate (refer to section 2.5.2.2 of Exhibit B-1, including the references to TS 86).

Please also refer to BC Hydro’s response to BCUC IR 1.8.1.1.


Page 1 of 1


Exhibit: B-2





1.8.1.1 In BC Hydro’s view, if there is no demand charge (or if the demand charge is discounted) in the proposed RS 1891 and RS 1280, by how much the energy charges be raised to reflect a recovery of the change in demand profile or increase in capacity utilization in order to recover investment costs?

RESPONSE:

The proposed energy charges set out in RS 1280 and RS 1891 do not need to “be raised to reflect a recovery of the change in demand profile or increase in capacity utilization … to recover investment costs” because there are no investment costs to recover. As set out in section 1.3 of Exhibit B-1:

Non-firm shore power service is only provided where BC Hydro has available energy and capacity to do so. Refer to Special Condition 1 of RS 1280 and RS 1891, and section 4.1 of TS 86 (copies at Appendix C-1 of Exhibit B-1);

Port Customers are responsible for all capital costs that arise out of the incremental infrastructure associated with the provision of non-firm shore power service. Refer to section 2.1 of TS 86.

BC Hydro notes that as discussed in the response to BCUC IR 1.5.1, the RS 1891 energy charge is the RS 1823 Tier 2 energy price which for F2016 is 8.503 cents/kWh and the RS 1280 energy charge is the RS 1823 Tier 2 energy price adjusted for distribution losses which is 8.796 cents/kWh for F2016. There is an argument that the reference for the cost of providing energy for non-firm service should be the spot market. As described in BC Hydro’s response to BCOAPO IR 1.2.1, section 5.6 of the 2013 IRP contains BC Hydro’s electricity market forecast. The mid-electricity market forecast price is about $33/MWh in 2020 (Real 2016 $CDN) which is well below the RS 1823 Tier 2 energy price. Accordingly, it is BC Hydro’s view that existing ratepayers benefit from the proposed RS 1280 and RS 1891 energy charges as these charges are set well above spot market prices.


Page 1 of 1


Exhibit: B-2





1.8.2 Please confirm that the rates used in the assumptions in Table 2.2 are F2016 rates pursuant to Appendix B of Direction No. 6 to the BCUC (BC Regulation 29/2014).

RESPONSE:

Confirmed.


Page 1 of 1


Exhibit: B-2





1.8.3 On page 2-5, the Application refers to the blended rates under TS 1823 as ranging from $100/MWH to $349/MWh compared to $85/MWh under TS 76. For LGS service, blended rates range from $132/MWh to $490/MWh based on the load characteristics identified in Table 2-2. Would BC Hydro please confirm that ‘blended’ rate refers to blending the different tiers of energy rates? For example, the RS 1823 blended energy rate per MWH of 43.03 is based on 90 percent consumption at $38.36/MWh and 10 percent consumption at $85.03?

RESPONSE:

Confirmed.


Page 1 of 1


Exhibit: B-2





1.8.3.1 In Table 1-3 on page 1-11, the Application describes the Port of San Diego & San Diego Gas and Electric as having a blended 18-21 cents/kWh (by season for cruise ship). Please explain whether, in this instance, the ‘blended’ rate refers to the blending of different tiers of energy charges or whether it refers to blending energy and demand charge components such that there will be no separate demand charge.

RESPONSE:

As noted on Table 1-3 of Exhibit B-1, page 1-11, “[n]o further breakdown of the blended rate [offered by Port of San Diego] can be provided”.

PMV provided information concerning Port of San Diego shore power-related service, which is interruptible. The rate appears not to be publicly accessible and PMV reported that Port of San Diego was unwilling to provide a further breakdown of the blended rate.


Page 1 of 3


Exhibit: B-2



According to Table 2-2, a container vessel operator would:

If taking service at transmission voltage, receive savings of $14.74/MWh per month ($85.03–$99.77) under the proposed TS 86 instead of taking service under RS 1823; the tier 2 energy price of RS 1823 being the same as RS 1880; and

If taking service under distribution voltage, receive savings of $47.31/MWh per month ($85.03–$132.34) under the proposed TS 86.

1.8.4 Based on the same assumptions used for Table 2-2, please calculate: (a) the gross revenue per monthly/billing period and, if possible, annually) for BC Hydro, (b) the costs (e.g., cost of energy, OM & A expenses, depreciation and amortization, taxes, finance charges, allowed net income), and (c) the net revenue per monthly/billing period and, if possible, annually for BC Hydro.

RESPONSE:

Based on the F2014 FACOS, revenues and costs by component are identified in the table below for firm service under either RS 1823 or RS 16xx. According to the study, the Revenue to Cost ratio is 97.3 per cent for the Transmission rate class and 101.5 per cent for the LGS rate class.

For the purposes of calculating net revenues under the Shore Power Rate, energy costs are based on the average Mid-C forward price for calendar 2016. Since the Shore Power Rate is non-firm, only the cost of energy is included in the determination of net revenues. With respect to O&M associated with non-firm shore power service under the proposed Shore Power Rate, please refer to BC Hydro’s response to BCUC IR 1.1.5.2.

Vessel Type

Cruise Ship

Container Bulk

A. Per Billing Period/Month RS 1823

Energy Charge ($) 11,360 11,134 2,905 Demand Charge 80,751 14,682 5,506 Gross Revenues ($) 92,111 25,816 8,410 Cost of Energy ($) 36,603 10,259 3,342 OM&A 16,609 4,655 1,517


Page 2 of 3


Exhibit: B-2

Vessel Type

Cruise Ship

Container Bulk

A. Per Billing Period/Month Depreciation and Amortization 14,151 3,966 1,292 Taxes 4,779 1,339 436 Finance Charges 11,573 3,244 1,057 Return on Equity 10,945 3,068 999 Total ($) 94,660 26,530 8,643 Net Revenues ($) (2,549) (714) (233)

Large General Service Energy Charge ($) 14,362 14,092 4,281 Demand Charge 115,100 20,150 6,963 Gross Revenues ($) 129,462 34,242 11,244 Cost of Energy ($) 41,099 10,871 3,569 OM&A 24,324 6,434 2,113 Depreciation and Amortization 20,559 5,438 1,786 Taxes 6,345 1,678 551 Finance Charges 18,080 4,782 1,570 Return on Equity 17,099 4,523 1,485 Total ($) 127,506 33,725 11,074 Net Revenue ($) 1,956 517 170

RS 1280/RS 1891/TS 86 Gross Revenues ($) 22,448 22,002 5,740 Cost of Energy 8,376 8,210 2,142 Net Revenues ($) 14,071 13,792 3,598

Vessel Type

Cruise Ship

Container Bulk

B. Per Year RS 1823

Energy Charge ($) 79,519 133,608 34,854 Demand Charge 565,257 176,184 66,069 Gross Revenues ($) 644,776 309,792 100,923 Cost of Energy ($) 256,218 123,104 40,104 OM&A 116,265 55,861 18,198 Depreciation and Amortization 99,060 47,595 15,505 Taxes 33,454 16,074 5,236 Finance Charges 81,009 38,922 12,680 Return on Equity 76,614 36,810 11,992


Page 3 of 3


Exhibit: B-2

Vessel Type

Cruise Ship

Container Bulk

B. Per Year Total ($) 662,621 318,366 103,716 Net Revenues ($) (17,844) (8,574) (2,793)

Large General Service Energy Charge ($) 100,531 169,108 51,374 Demand Charge 805,700 241,800 83,550 Gross Revenues ($) 906,231 410,908 134,924 Cost of Energy ($) 287,695 130,448 42,833 OM&A 170,268 77,204 25,350 Depreciation and Amortization 143,915 65,255 21,427 Taxes 44,416 20,139 6,613 Finance Charges 126,557 57,384 18,842 Return on Equity 119,690 54,271 17,820 Total ($) 892,541 404,700 132,886 Net Revenue ($) 13,690 6,207 2,038

RS 1280/RS 1891/TS 86 Gross Revenues ($) 157,135 264,018 68,874 Cost of Energy 58,635 98,518 25,700 Net Revenues ($) 98,500 165,500 43,174


Page 1 of 1


Exhibit: B-2

9.0 Reference: Exhibit B-1, Application, pp. 2-7 to 2-9

Rate options


Firm rates would force port customers to pay a premium for firm service they have not requested and do not need.

A CBL or HBL-based design will likely require more effort by customers to manage their bills.

There is no basis for requiring eligible vessels to take service under the firm rates given the Commission-approved TS 76.


1.9.1 Is the argument of non-suitability of RS 1880, i.e., the intent of standby rate is to enable self-generation, also valid for cruise ships’ shore power at Canada Place wharf? If not, why not?

RESPONSE:

Yes. As set out in section 2.3.2, page 2-8, lines 9 to 13, of Exhibit B-1, while RS 1880 can be seen as enabling self-generation, the service sought by PMV and PRPA is essentially the opposite: “[i]t aims to displace vessel self-generation with BC Hydro grid electricity”. This observation also holds for TS 76 and the provision of shore power service at Canada Place wharf.


Page 1 of 1


Exhibit: B-2


Rate options






1.9.2 Please confirm, otherwise explain, that a customer who has access to RS1880, incurs demand charges.

RESPONSE:

Not confirmed for purposes of TSR customers taking service under RS 1880.

There is no RS 1880 demand charge; like TS 76 and the proposed Shore Power Rate, RS 1880 contains energy and administrative charges. The reason why there is no RS 1880 demand charge is because: RS 1880 is “a non-firm rate for naturally interruptible load – Transmission Service customers with self-generation”; RS 1880 service is not included in BC Hydro’s energy and peak demand load forecasts; and thus there are no transmission or other infrastructure costs to recover; refer to Exhibit B-1, page 2-8, lines 2 to 8. The Commission approved RS 1880 without a demand charge pursuant to Commission Order No. G-19-06.


Page 1 of 2


Exhibit: B-2


Rate options






1.9.3 Please provide a sample one line diagram of an RS 1880 customer. Please identify the point of interconnection, the BC Hydro supply to the customer, the customer’s meters, the customer self-generation and meters, and the asset ownership. Please compare this sample one-line to the one line for vessels/Port Customers previously requested.

RESPONSE:

Figure 1 below identifies a one line diagram for RS 1880 customer. For illustration, Figure 1 includes four generator configurations:

G1 The customer’s on-site generation is behind one of one of the loads. Without an EPA with BC Hydro, metering between the generator and the load is not required;

G2 The customer’s on-site generation is behind one of one of the loads. It is assumed that the customer has an EPA with BC Hydro which necessitates a meter between the generator and the customer load;

G3 The customer’s generator is parallel to the loads. Without an EPA with BC Hydro, there isn’t a need for a separate meter;

G4 The customer’s generator is parallel to the load. An EPA with BC Hydro necessitates a meter between the generator and the customer load.


Page 2 of 2


Exhibit: B-2

Figure 1


Page 1 of 1


Exhibit: B-2


Rate options






1.9.4 Please confirm, otherwise explain, that RS 1880 customers use spare capacity of existing supply and receive non-firm service, and vessels are anticipated to use spare capacity of existing supply and receive non-firm service.

RESPONSE:

Confirmed. Please also refer to BC Hydro’s responses to BCUC IRs 1.9.1 and 1.9.2.


Page 1 of 1


Exhibit: B-2


Rate options






1.9.5 Please provide a sample calculation showing the Port Customer charges for supplying eligible vessels if incurred under RS 1880 and compare these charges to the scenario where the Port Customer and vessels meters were in series and to where they were in parallel.

RESPONSE:

There would be little difference in the applicable charges for electricity supplied under RS 1880 and electricity supplied under RS 1280 / RS 1891, whether metered in series or in parallel; the energy charges for RS 1880, RS 1280 and RS 1891 are all based on the RS 1823 Tier 2 price; and the Administrative Charge is $150 in all cases but is applied on a different basis for RS 1880 as compared to RS 1280/RS 1891.


Page 1 of 1


Exhibit: B-2


Rate options






1.9.6 If the requested TS 86 is approved, would BC Hydro also seek to amend RS 1880 as the applicable energy rate in TS 76?

RESPONSE:

With respect to TS 86, please refer to BC Hydro’s response to BCUC IR 1.5.1.

The IR appears to question whether TS 76 references RS 1880 as the applicable energy rate. BC Hydro notes that section 5.1 of TS 76 provides that the energy charge is “set out in BC Hydro’s [RS] 1880 and multiplied by (iii) 1.0344 to account for distribution losses”.


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Exhibit: B-2


Shore Power Rate Bonbright assessment

Table 2-10 of the Application summarizes the assessment of the Shore Power Rate with the conclusion that the rate performs well against all eight Bonbright criteria. Specifically, it recovers the cost of energy, all incremental costs of serving Port Customers, and that it aligns with TS 76 and rate design approaches in other jurisdictions that offer shore power services.

The Application states that the shore power load is not included in BC Hydro’s load forecast and does not advance any future delivery infrastructure projects.

1.10.1 Does BC Hydro use, as inputs in its long term load forecast, the projected demand and energy from Port Customers?

RESPONSE:

BC Hydro uses projected energy and capacity demand from Port Customers in its long-term load forecast for non-shore power service requests only. As set out in section 1.3, page 1-17, line 13, of Exhibit B-1, “[s]hore power load is not included in BC Hydro’s load forecast” because it is non-firm service.


Page 1 of 1


Exhibit: B-2





1.10.1.1 Page 1-6 of the Application refers to the BC Hydro 2013 Integrated Resource Plan which includes an ‘action’ to work with the BC government, ports and industry to expand availability of shore power to shipping at BC ports. Please confirm the Port of Vancouver was evaluating port-side electrification for vessels using shore-side electrical power while berthed rather than diesel power as far back as 2007.1 How much has BC Hydro invested since 2007 in system improvements or contributions to system extensions in anticipation of the port’s requirement?

RESPONSE:

The reference in the IR and accompanying footnote should be to BC Hydro’s 2008 Long-Term Acquisition Plan, Appendix B-1, which is a copy of the B.C. Government’s 2007 Energy Plan. Page 21 of the 2007 Energy Plan (page 24 of 84 of Appendix B-1) states: PMV “is … evaluating port-side electrification which would see vessels using shore-side electrical power while berthed rather than diesel power”. BC Hydro confirms that PMV was evaluating port-side electrification for vessels using shore-side electrical power while berthed rather than diesel power as far back as 2007.

Since 2007, BC Hydro has made no BC Hydro’s Contributions, and has made no “system investments” (defined for purposes of this response to mean Extensions for the purpose of increasing capacity of BC Hydro’s distribution system and System Improvement Costs in the Distribution context and System Reinforcements in the Transmission context) in anticipation of PMV’s shore power-related requests. (The definitions of the terms “BC Hydro’s Contributions” and “System Improvement Costs” contained in BC Hydro’s Electric Tariff, and of “System Reinforcements” contained in TS 6, are set out at footnotes 27, 26 and 28 respectively at paged 2-16 and 2-18 of Exhibit B-1).

BC Hydro offers the following with respect to the shore power facility at Canada Place wharf. The Canada Place wharf shore power facility is served via connection to four BC Hydro standby circuits. PMV was allocated the cost to extend three of the four standby circuits from manhole (MH) 2443 to PMV’s service entrance equipment. PMV was also allocated the cost to extend the fourth standby circuit and some associated civil work from MH3529 to the service entrance.

1 BC Hydro’s 2007 Long Term Acquisition Plan, Appendix B1, page 24 of 84


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Exhibit: B-2





1.10.2 The assessment in Table 2-4 concludes that the Shore Power Rate incorporates non-firm rate design and pricing principles for TS 76 (and for RS 1880); these principles are Commission approved. Does the year round nature of TS 86 make this tariff supplement distinct from the energy availability for “non-peaking months only” of TS 76? If, hypothetically, the cruise ships of Greater Victoria Harbour are served under TS 86, would this be considered undue discrimination since the cruise ships of Canada Place wharf are served under TS 76 and under different features?

RESPONSE:

RS 1280, RS 1891 and TS 86 closely resemble TS 76, with the primary difference being expanded Port Customer and vessel eligibility. RS 1280, RS 1891 and TS 86 do not contain the definition of “Cruise Season” (the seven months of April, May, June, July, August, September and October) found in section 1 of TS 76 because vessels other than cruise ships do not have a defined season. In BC Hydro’s view, recognizing that vessels other than cruise ships do not have a defined season does not make RS 1280, RS 1891 and TS 86 unduly discriminatory as compared to TS 76. BC Hydro is simply recognizing the relevant vessel characteristics in its Shore Power Rate proposal.

There are three main differences between TS 76, and RS 1280, RS 1891 and TS 86 which in BC Hydro’s view do not constitute undue discrimination:

(1) Applying the $150 Administrative Charge to each month of the year due to expanded vessel eligibility (RS 1280 and RS 1891; refer to section 2.5.1.3 of Exhibit B-1). This change recognizes there is no defined season for most eligible vessels, and in particular for the container and other non-cruise ship vessels that are the subjects of PMV’s GCT Deltaport and Centerm facility requests, and PRPA’s Fairview Container Terminal request;


Page 2 of 2


Exhibit: B-2

The remaining two differences are not the result of expanded vessel eligibility but rather provide additional existing ratepayer protection:

(2) Providing for a migration rule (RS 1280 and RS 1891 Special Condition 3; refer to section 2.5.1.2 of Exhibit B-1);

(3) Providing additional certainty that BC Hydro is not required to construct an Extension for the purpose of increasing the capacity of BC Hydro’s distribution system to provide shore power service, and that BC Hydro is not required to undertake System Reinforcements for purposes of providing transmission related non-firm shore power service (RS 1280 and RS 1891 Special Condition 3 and section 2.1 of TS 86).

Please also refer to BC Hydro’s response to BCUC IR 1.3.3.


Page 1 of 1


Exhibit: B-2

11.0 Reference: Exhibit B-1, Application, Section 2.5, p. 2-12: Appendix C1 RS

1280 and RS 1891 Availability


1.11.1 Is BC Hydro referring to the first request which initiates the Power Service Agreement or is BC Hydro also referring to discrete requests from time to time?

RESPONSE:

BC Hydro will determine if it has capacity available to provide shore power service to the Port Customer for every request.


Page 1 of 1


Exhibit: B-2




1.11.2 Assuming that the preamble refers to a Port Customer’s request for shore power service to enter into the Power Service Agreement, what are the consideration factors in BC Hydro’s determination as to whether it can, or cannot, provide the non-firm service?

RESPONSE:

Upon a request for non-firm service, BC Hydro will evaluate the capacity of the substation facilities upstream of the Port Customer’s site and shore power will only be accommodated where the existing substation facilities have the capacity to accommodate the shore power load on an interruptible basis. In addition, BC Hydro will evaluate the rated capacity of distribution system facilities between the substation and the Port Customer’s site. BC Hydro would also have to identify any infrastructure necessary to extend the distribution system to the Port Customer Point of Interconnection. The cost of any identified necessary infrastructure will be paid for by the Port Customer in accordance with section 2.1 of TS 86.

Note also that every shore power connection is subject to the conditions of a LOO. In this regard please refer to section 2.5.2.6 of Exhibit B-1.


Page 1 of 1


Exhibit: B-2




1.11.2.1 Is the existing wire capacity leading to the port interconnection a consideration?

RESPONSE:

Yes, existing wire capacity with respect to any potential Port Customer shore power service site is a consideration.


Page 1 of 1


Exhibit: B-2




1.11.2.2 Is further upstream reinforcement to the BC Hydro system a consideration?

RESPONSE:

BC Hydro is unclear as to what the reference to “upstream reinforcement” means, however, BC Hydro can say that it will not make any investments in infrastructure to support non-firm shore power service and a Port Customer will not be granted shore power service if there is insufficient capacity to provide the service.


Page 1 of 1


Exhibit: B-2

12.0 Reference: Exhibit B-1, Application, Section 2.5.1.2, p. 2-12; Appendix C1

RS 1280 and RS 1890 Shore Power Rate migration

BC Hydro states that Port Customers that opt for firm service for shore power under the applicable default rate are not eligible to migrate to the non-firm Shore Power Rate.

The reason for Special Condition 3 is that the Port customer’s load will have been factored into the load forecast, infrastructure improvements will have been made to provide firm service and BC Hydro will likely have provided a contribution toward the infrastructure.

1.12.1 To the best of BC Hydro’s knowledge, how many customers will be affected by this Special Condition 3?

RESPONSE:

BC Hydro is not aware of any Port Customer who is providing shore power service using BC Hydro’s default firm service rates. BC Hydro will not speculate as to whether Port Customers will be affected by Special Condition 3 in RS 1280/RS 1891. Please also refer to BC Hydro’s response to BCUC IR 1.12.2.


Page 1 of 1


Exhibit: B-2





1.12.2 Please describe the circumstances where a Port Customer will “opt for” firm service. Is this option being presented to Port Customers who have shore power capabilities? Are Port Customers given a period of time to exercise an option?

RESPONSE:

The circumstances by which a Port Customer may opt for firm service will vary on a case-by-case basis. A Port Customer may determine that it is more cost-effective to take service under the default firm tariff rather than the proposed Shore Power Rate because it expects frequent and consistent ship traffic which in Port Customer’s view would mitigate the financial impacts of the applicable firm service rate demand charge that occur with low, unpredictable ship traffic.

As described in section 1.5 of Exhibit B-1, PMV and PRPA have requested non-firm shore power service and are in favour of the proposed Shore Power Rate. In the future, assuming the Commission approves the proposed Shore Power Rate, Port Customers can choose either the applicable firm service rate or the proposed Shore Power Rate, bearing in mind Special Condition 3 of RS 1280/RS 1891.


Page 1 of 1


Exhibit: B-2





1.12.2.1 In the most recent BC Hydro annual load forecast report, how much demand (MW) and energy (GWh) out of the total are projected annual sales to Port Customers, say, for 2016 and 2021?

RESPONSE:

As set out in sections 1.3 and 2.4 of Exhibit B-1, no shore power-related service load under TS 76 or under the proposed Shore Power Rate is included in BC Hydro’s energy and peak demand load forecasts. All TS 76 load is non-firm; and the PMV and PRPA requests that form the basis of the proposed Shore Power Rate are for non-firm service. Please also refer to BC Hydro’s response to BCUC IR 1.10.1.

The quoted Special Condition 3 contained in RS 1280 and RS 1891 addresses a future situation in which a Port Customer requests shore power service on a firm basis. In that situation, Special Condition 3 prevents the Port Customer requesting and taking firm shore power service under the applicable firm rate (RS 1823 or RS 16xx) from migrating to non-firm shore power service under the Shore Power Rate for the reasons set out in the IR references.


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Exhibit: B-2

13.0 Reference: Exhibit B-1, Application, Section 2.5.1.4, p. 2-13

Energy Rate

BC Hydro proposes to charge the same energy rate for non-firm shore power service as the RS 1823 Tier 2 energy rate. For distribution Port Customers, the Shore Power Rate energy charge would be adjusted by the primary distribution loss factor. RS 1823 consists of a demand charge and energy charge and the demand charge recovers 65 percent of the demand-related cost according to footnote 23 in the Application.

1.13.1 Has BC Hydro explored other rate schedule options to apply the Shore Power Rate under TS 86 where: (a) there would be a demand charge to reflect the utilization of capacity and the change in demand profile; (b) there would be a discounted demand charge to reflect the utilization of capacity and the non-firm energy; and (c) the would be no demand charge for ease of customer understanding but the demand-related cost will be recovered by increases to the energy component of RS 1823? If the analyses of the options were carried out, please provide them in the response; if not, why not?

RESPONSE:

BC Hydro considered and rejected options (a) and (b) set out in the IR above because demand charges are intended to recover some portion of distribution and/or transmission asset costs, and there are no such costs associated with the provision of non-firm shore power service under the proposed Shore Power Rate. Consistent with Commission-approved TS 76 and RS 1880, there is no basis for a demand charge (discounted or otherwise) in a non-firm rate that does not trigger any distribution and transmission asset costs that are not paid for directly by the Port Customer pursuant to section 2.1 of TS 86. There are no distribution or transmission asset costs to recover under the Shore Power Rate. In this regard, RS 1280, RS 1891 and TS 86 align with the majority of jurisdictions that offer shore power service.

BC Hydro did not consider but rejects option (c) since there are no demand-related asset costs to recover in an increased RS 1823 Tier 2 energy charge applicable to shore power service. Please refer to BC Hydro’s response to BCUC IR 1.1.5.2 regarding demand-related O&M costs.


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Exhibit: B-2

14.0 Reference: Exhibit B-1, Application, Section 2.5.2.2 pp. 2-16 to 2-18

Infrastructure costs

Page 2-16 of the Application states that there will be no System Improvements Costs as a result of providing shore power to a distribution voltage Port Customer site such as DPWW Centerm. If a Port Customer request triggers System Improvement costs, the Port Customer will not be permitted to take service under the Shore Power Rate and must instead take service under the default General Service rate.

Page 2-18 of the Application states that under Special Condition 1 of RS 1891, BC Hydro will not be required to construct System Reinforcement under TS 6 to provide Shore Power Services.

1.14.1 Under the scenario where a customer of BC Hydro who is not a Port Customer triggers System Improvement costs, and if later the Port Customer seeks shore power service, then the Port Customer is permitted take service under the Shore Power Rate. Does BC Hydro agree with this interpretation?

RESPONSE:

Yes. However, the service under the Shore Power Rate is non-firm and if firm customers use up the capacity, the Port Customer taking shore power service will be interrupted.


Page 1 of 2


Exhibit: B-2





1.14.2 Would BC Hydro please comment if the proposed infrastructure cost treatment in section 2.5.2.2 generally complies with the existing transmission and distribution extension policies? Please discuss the similarities and differences.

RESPONSE:

The application of BC Hydro’s Distribution and Transmission Extension policies for Shore Power Rate purposes is expressly addressed at pages 2-16 to 2-18 of Exhibit B-1. In summary:

Distribution Extension Policy

Section 12.1 of TS 86 provides that the supply and taking of shore power service under the Shore Power Rate is subject to the terms of BC Hydro’s Electric Tariff, including the Distribution Extension provisions contained in section 8 of the Electric Tariff, except to the extent they are inconsistent with TS 86 in which case TS 86 governs; and

Section 2.1 of TS 86 provides that Extension-related costs and responsibilities are governed by section 8 of the Electric Tariff, with two main exceptions given the non-firm nature of the shore power service offering: (1) any Extension will be ineligible for BC Hydro’s Contribution because shore power service is non-firm and there is no demand charge; and (2) BC Hydro is not required to construct an Extension for the purpose of increasing the capacity of BC Hydro’s distribution system. Refer to footnote 27 of Exhibit B-1, page 2-16 for the section 1 Electric Tariff definitions of the terms “Extension” and “BC Hydro’s Contribution”.


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Exhibit: B-2

Transmission Extension Policy

Exhibit B-1, page 2-17, lines 18 to 27 explain that the only additional infrastructure required for non-firm service at Transmission voltage sites (PRPA’s Fairview Container Terminal and PMV’s CGT Deltaport) would be for enhanced substation protection and control equipment, and metering;

Any substation protection and control equipment costs are addressed by section 9.1 of TS 86, and metering costs are addressed by section 6 of TS 86 (Exhibit B-1, page 2-18, lines 9 to 13); and

There will be no System Reinforcement as a result of the non-firm nature of the shore power service offering; refer to Special Condition 1 of RS 1891. Thus the TS 6 provisions regarding System Reinforcement are not applicable (Exhibit B-1, page 2-18, lines 14 to 18). Refer to footnote 28 of Exhibit B-1, page 2-18 for the TS 6 definition of the term “System Reinforcement”.


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Exhibit: B-2





1.14.2.1 Can BC Hydro confirm that the existing transmission and distribution extension policies are subject to review in the 2015 rate design application scheduled for filing in September 2015?

RESPONSE:

BC Hydro can confirm at this time that it is proposing to include review of the existing Distribution Extension policy as part of Module 2 of the 2015 RDA, anticipated to be filed with the Commission in 2016 once BC Hydro is in receipt of a Commission decision on 2015 RDA Module 1 (to be filed with the Commission on or about September 17, 2015).

BC Hydro can also confirm that if the Lieutenant Governor in Council (LGIC) requests Commission investigation of BC Hydro’s Transmission Extension policy pursuant to section 5 of the UCA, at this time BC Hydro is proposing to include review of the existing Transmission Extension policy as part of Module 2 of the 2015 RDA. As a result of subsection 3(2)(a)(i) of Direction No. 7 (the Commission “must ensure the rates for [BC Hydro] transmission service customers are subject to … the terms and conditions found in Supplements 5 and 6 of [BC Hydro’s] tariff”), the Commission cannot unilaterally change TS 6, which governs interconnections at transmission voltage, under its section 58 to 61 UCA rate setting power. The Commission can only be given jurisdiction to review and make recommendations concerning this issue through a section 5 UCA inquiry review process, and only the LGIC can refer this matter to the BCUC under section 5 of the UCA.


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Exhibit: B-2

15.0 Reference: Exhibit B-1, Application, Appendix A1

The Application and draft order seek approval of RS 1280 and RS 1891 and TS 86 for the provision of non-firm shore power service. TS 86 is based on the previously approved 76 and expands port customer and vessel eligibility.

1.15.1 Is BC Hydro amenable to the Commission narrowing the scope of the review of this Application to issues related to expansion on port customer and vessel eligibility and place the design of the shore power rate structures, and their accompanying distribution and transmission extension policies to the 2015 RDA?

RESPONSE:

BC Hydro is not amenable to the Commission narrowing the scope for the review of the Application to the issue of the expansion of Port Customer and vessel eligibility from TS 76, and leaving material determinations concerning the actual Shore Power rate structures to Module 1 of the 2015 RDA for a number of reasons:

Module 1 of the 2015 RDA has an indeterminate timeline for review and for a Commission decision. Bifurcating the review of the Application in the manner suggested in this IR will cause unnecessary uncertainty for PMV and PRPA who have in good faith made requests for non-firm shore power service. Both PMV and PRPA have confirmed this with BC Hydro;

The review of all aspects of the proposed Shore Power Rate at this time is important to providing PMV and PRPA with the confidence to undertake significant investments in infrastructure at their facilities related to shore power connections. Limiting the scope to the narrow issue concerning eligibility would not provide PMV and PRPA with the confidence needed to make such investments as critical issues such as charges and applicable extension policies would not be settled. Any delay will potentially impact PMV and PRPA’s ability to take advantage of Transport Canada funding for investments to support shore power. This includes funding as described in PMV’s January 31, 2015 letter (Appendix B-1 to Exhibit B-1) that will expire on December 31, 2015.

Documents

Geoffrey Higgins Acting Chief Regulatory Officer ......HBL Historic Baseline load – a measure of historical ... Further to your April 10, 2015 application on the above noted matter,