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

“[a]ttribution of savings from codes and standards should be evaluated on a case‐by‐case basis”
and that “the attribution rate should reflect the level of support for market transformation”,
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arguing that Terasen’s “position on attribution goes against this approach.” (BC Hydro Argument, p.
17)
BCOAPO states “. . . the DSM regulation 4(7) allows for the Commission to include a proportion of
the benefit that, in the Commission’s opinion (not the Applicant’s) will increase market share only
between the time that a specified standard has been announced, and the time that it commences.
Any attribution beyond that will, predictably, distort program design.” (BCOAPO Argument, p. 13)
(emphasis in original)
In its Reply, Terasen notes that “BCOAPO and BCSEA‐SCBC have made submissions on attribution of
benefits. This issue is not relevant to the assessment of the proposed portfolio, as the assessment
does not include any attribution of benefits. With respect to the assessment of future portfolios,
the Terasen Utilities repeat and rely on the submissions made in paragraphs 109 to 111 of the
Initial Submissions” (which argue for the inclusion of attribution savings.)
(Terasen Reply, p. 20)
Commission Determination
The Commission Panel notes Terasen’s comment that the attribution issue is not relevant to this
Application as the assessment does not include any attribution of benefits. However, as in the case
of free riders, the Commission Panel does consider that this issue is likely to become a factor as the
DSM initiatives of Terasen become more fully developed and refined, and therefore should be
addressed in this Decision.
The Commission Panel accepts the position of BC Hydro that attribution of savings from codes and
standards should be evaluated on a case‐by‐case basis and that the attribution rate should reflect
the level of support for market transformation. The Commission Panel shares the BCSEA‐SCBC’s