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FortisBC Inc. (FortisBC) Application for a Certificate of Public ...

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Response:<br />

<strong>FortisBC</strong> <strong>Inc</strong>. (<strong>FortisBC</strong> or the Company)<br />

<strong>Application</strong> <strong>for</strong> a <strong>Certificate</strong> <strong>of</strong> <strong>Public</strong> Convenience and Necessity<br />

<strong>for</strong> the Advanced Metering Infrastructure Project<br />

Response to British Columbia Utilities Commission (BCUC or the Commission)<br />

In<strong>for</strong>mation Request (IR) No. 1<br />

Submission Date:<br />

October 5, 2012<br />

Page 16<br />

<strong>FortisBC</strong> has not applied <strong>for</strong> temporary permission from Measurement Canada pursuant to the<br />

Policy on Granting Temporary Permission to Use Electricity Meters Without Reverification <strong>for</strong><br />

verification and sealing requirements. This is due to the timing <strong>of</strong> the expected CPCN approval<br />

and the timing <strong>of</strong> the AMI deployment which alleviates the need to apply <strong>for</strong> dispensation from<br />

Measurement Canada.<br />

If the AMI Project is not approved, <strong>FortisBC</strong> will need to keep its compliance and retest program<br />

going through 2013, so an application now <strong>for</strong> “temporary permission” is premature.<br />

The AMI Project, if approved, will have the first meter exchanged in mid-2014 and the last meter<br />

exchanged toward the end <strong>of</strong> 2015. <strong>FortisBC</strong> intends to keep its current retest and compliance<br />

program intact through 2013 (which tests meters with seal expiration in 2014), so there will be<br />

no exposure to overdue meters in 2014. The retest and compliance program can be<br />

discontinued in 2014 since all remaining meters will be replaced in 2015.<br />

If <strong>FortisBC</strong> did apply <strong>for</strong> temporary permission pursuant to the Measurement Canada Policy on<br />

Granting Temporary Permission to Use Electricity Meters Without Reverification, it would not be<br />

without cost. The policy states that an electricity contractor must:<br />

a. ensure that the integrity and accuracy <strong>of</strong> electricity meters are maintained;<br />

b. provide objective evidence to support a decision to keep electricity meters in<br />

service without reverifying the subject meter types, models and/or groups <strong>of</strong><br />

meters; and<br />

c. provide a plan that will include conditions to mitigate the risk <strong>of</strong> inaccurate meters<br />

remaining in service.<br />

<strong>FortisBC</strong> does not know why BC Hydro decided to apply <strong>for</strong> temporary permission, but assumes<br />

that it may relate to a longer deployment timeframe that increased the risk <strong>of</strong> non-con<strong>for</strong>mance.<br />

7.0 Reference: Project Need<br />

Exhibit B-1, Tab 3.0, Sec. 3.1, p. 18 &<br />

Exhibit B-1, Tab 5.0, Sec. 5.3.4, pp. 92-94<br />

“For clarity, the accelerated replacement <strong>of</strong> meters to comply with Measurement<br />

Canada’s new sampling requirements will have to take place either via the proposed<br />

AMI Project, or, absent approval <strong>of</strong> the AMI project, via a separate project as

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