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

concern, as detailed in Mr. Plunkett’s evidence, that the attribution concept can distort program
design.
The Commission Panel rejects the Attribution to Regulatory Change proposal made in the
40
Application and refers this issue back to Terasen to redesign and resubmit with its next annual EEC
report to the Commission, giving consideration to a modified version of the Application’s
attribution proposal reflecting the provisions of the DSM Regulation which come into effect for
Terasen on June 1, 2009. The Commission Panel directs Terasen to address, in the modified
version, the matters raised by BC Hydro and BCSEA‐SCBC, and also to give consideration to factors
such as the length of time a particular program element has been operative at the time any
applicable regulation is introduced and how compatible the program initiative is with the new
regulation (e.g. if a regulation is introduced with a higher or lower threshold or standard than the
program design).
3.4 Carbon Pricing
As part of the Application, Terasen seeks an order approving certain changes to the benefit‐cost
analysis undertaken in respect of EEC expenditures, including recognizing the impact of carbon
pricing as one of the inputs to the benefit‐cost tests. (Exhibit B‐1, pp. 15‐16)
Terasen proposes that additional customer bill savings from the implementation of the tax should
be included in the benefit‐cost analysis for EEC programs. Terasen proposes that the activities
supported by the EEC Application will contribute to consumer education and provide consumers
with tools to help them reduce the impact of the proposed carbon tax on their energy
expenditures. (Exhibit B‐1, p. 41)
Terasen summarises its position with respect to the carbon tax matter in Argument as follows: “The
customers will also enjoy a benefit associated with reduced Carbon Tax costs. Customers that
install an efficient appliance or design a more efficient building as a result of Terasen's EEC
initiatives will use less gas, and will therefore pay less Carbon Tax. Therefore, the avoided Carbon