FEI-FEVI 2010 EEC Report filed March 31, 2011 - FortisBC

March 31, 2011
British Columbia Utilities Commission
FEI and FEVI 2010 EEC Annual Report
Page 2
Companies wish to have this addressed at the earliest possible date for the reasons
discussed below.
In the Decision accompanying Order No. G-6-11, dated January 14, 2011, relating to the
interim approval of a Compressed Natural Gas service agreement with Waste Management,
the Commission raised an issue about the Companies’ provision of incentive funding for
NGV initiatives. The Companies are of the view that NGVs are a part of the approved
incentive funding for the innovative technologies program area, and the use of incentive
funding for NGVs meets the requirements established by the Commission to ensure EEC
funding is cost-effective. However, it has been necessary for the Companies to hold up new
EEC incentive funding for NGV pending clarification of this issue. It is important that the
Companies and the Commission reach concurrence on this issue in a timely manner, so that
we can move forward on new projects that provide benefits to existing natural gas customers
and fleet owners while helping to meet the energy objectives of the provincial government.
The Report (at page 201) provides additional explanation that was not available in the record
of the NGV application proceeding as to why the Companies believe they have acted
according to past Commission decisions. In this regard:
• We have made specific reference to past decisions, and have explained how the
incentive funding was subjected to a transparent review process to ensure its costeffectiveness.
• We have also obtained input from stakeholders involved in the EEC review process
established to oversee the use of EEC funding that were aware of, and endorse, the
use of incentive funding for NGVs. When this issue was discussed at the most recent
EEC stakeholder group meeting (March 15, 2011), a number of participants at the
meeting again verbally expressed support for the Companies’ position and a desire
for the Companies to proceed with cost-effective funding for NGV. Members of the
EEC stakeholder working group and customer groups have since provided letters
contained within the Report supporting the Companies’ position that EEC funds for
NGV have been used appropriately, within the established guidelines (Please see
letters of support included in Appendix F).
It is the hope of the Companies that, with the benefit of this additional information, the
Commission will be able to quickly provide confirmation of the Companies’ compliance with
past orders without additional process. Alternatively, if the Commission is unable to provide
this confirmation, the Companies respectfully request that the Commission provide its
concurrence for the Companies to proceed with EEC incentive funding to customers to offset
the incremental cost of buying an NGV over a standard gasoline or diesel vehicle. The
Companies respectfully submit that this concurrence to proceed could also be provided
without additional process since the benefits of EEC incentive funding for NGV are clear,
accord with Commission-approved EEC principles, exceed the Commission-approved tests
for evaluating EEC funding, and have the support of stakeholders.