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

to evidence of theft. As a consequence, it may be that thefts will take place in a larger
percentage of grow operations than the 5 per figure suggested by Fortis. Additionally, it
is possible that the technology of AMI will be able to be subverted by innovative countertechnologies
designed to disguise the “footprint” of the grower.
Additionally, one must acknowledge that there is a significant range of individuals
involved in marijuana production. While many are not involved in any kind of crime
other than marijuana production, there are some who have longstanding involvements in
crime, and may steal, simply to increase the profitability of their cultivation, irrespective
of either risk, or the ability to pay for their consumption. The 2005 study of 25,000 grow
operations noted that 47 per cent of identified suspects had criminal records, and that
those with prior criminal records had an average of seven previous convictions. 5
If no more than 5 per cent of growers are stealing – because the risks of detection and
arrest are simply overwhelming -- then it follows that there may not be any increase in
marijuana grows in the Fortis region, but perhaps even a decrease in the number of sites,
contrary to the projections made by the company. If growers who steal (currently
estimated to be about 20 to 30 per cent within this region) are faced with a 95 per cent
probability of detection and arrest, a certain percentage will go off the grid to generators,
invest in alternative energy sources, or relocate to areas without AMI. This will lead,
accordingly, to a relative drop in the total number of grow operations, somewhat below
the modest growth projected from 2012 to 2032 within the Fortis BC territory.
One additional comment needs to be made in relation to the deployment of AMI. If the
local governments within the area served by Fortis BC adopt the approach made possible
by the Act of 2006, attempting to legislatively entrap all commercial growers through the
combination of the AMI technology and collection of data regarding high payload
customers, we may see a significant percentage of growers consider the theft of
alternative forms of energy – gas and propane, along with off the grid possibilities such
as generators. In this circumstance public safety will be placed at greater risk, as more
risky forms of energy use replace electricity use, and a significant segment of the industry
itself moves, metaphorically at least, underground, with fewer opportunities for oversight.
Finally, with respect to the financial model advanced by Fortis BC, I will make the
following observations. Without AMI in place in the Fortis area (and in place elsewhere
in the province), it is likely that theft will remain close to current levels (in the range of
20 to 30 per cent of all sites), as there are no data or evidence to suggest that this crime
will be more easy to detect than it is at present. Further, as noted earlier, there will be
some influx of growers, seeking to avoid AMI, and these growers may come to Fortis,
with the intent of continuing their past practice of theft. With AMI in place in all
jurisdictions within the province, theft will decrease, but the number of sites and the
revenue produced by these sites may also decrease, given fears of detection that prompt
going off the grid and/or changes in growing technology that permit reductions in energy
consumption. If AMI is in place, and the local governments within Fortis BC do not
5 See note 4, above, Plecas, Malm and Kinney, pages 35 to 39.
Appendix BCUC IR1 86.1
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