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

Terasen submits that it is reasonable to include attribution savings in a cost‐benefit test,
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particularly in light of the newly issued DSM Regulation. The Regulation permits the Commission to
include in the benefit of measures proposed a proportion of the savings resulting from the
increased market share of a regulated item because of the commencement and application of a
specified standard with respect to the regulated item. (Terasen Argument, p. 39; Exhibit B‐1, p. 12;
Exhibit B‐1, p. 16)
The attribution rates proposed by the Company, for which it is seeks approval with this Application,
for any such future regulation are outlined below.
Intervenor Positions
Table 6
Attribution Rates
Regulation Percentage of Savings
Year Attributed to Program
1 50
2 40
3 30
4 20
5 10
Source: Exhibit B‐1, p. 87
BCSEA‐SCBC’s concern with respect to the attribution concept is based on Mr. Plunkett’s evidence
that it can distort program design. As with the free‐rider factor, BCSEA‐SCBC favours the use of net‐
to‐gross ratios. (BCSEA‐SCBC Argument, p. 20)
BC Hydro submits that “Terasen Utilities' position on attribution of savings from codes and
standards to utility DSM programs is arbitrary and will result in an unrepresentative view of the
benefits (higher or lower) associated with some programs.” BC Hydro further submits that