Round 1
Round 2
Matter 529 - NB Power Rate Design - Filing of Responses to Interrogatories to the Public Intervener
Chiasson, Alain (OAG/CPG)<Alain.Chiasson2@gnb.ca> |  Wed, May 17, 2023 at 9:39 AM | ||||||||||||||||||||||||||||||||||||||||||
| To: "Mitchell, Kathleen"<Kathleen.Mitchell@nbeub.ca>, Melissa Curran <Melissa.Curran@nbeub.ca>, NBEUB/CESPNB <General@nbeub.ca> | |||||||||||||||||||||||||||||||||||||||||||
| Cc: "ceo@fermenbfarm.ca"<ceo@fermenbfarm.ca>, "louis-philippe.gauthier@cfib.ca"<louis-philippe.gauthier@cfib.ca>, "frederic.gionet@cfib.ca"<frederic.gionet@cfib.ca>, "Ron.marcolin@cme-mec.ca"<Ron.marcolin@cme-mec.ca>, "David.Raymond.Amos333@gmail.com"<david.raymond.amos333@gmail.com>, "Sollows, David (DNRED/MRNDE)"<David.Sollows@gnb.ca>, "hanrahan.dion@jdirving.com"<hanrahan.dion@jdirving.com>, Nancy G Rubin <nrubin@stewartmckelvey.com>, "Conor R. O'Neil"<coneil@stewartmckelvey.com>, Leona Clements <lmclements@stewartmckelvey.com>, "pbowman@bowmaneconomics.ca"<pbowman@bowmaneconomics.ca>, "Brianne E. Rudderham"<brudderham@stewartmckelvey.com>, "JohnFurey@fureylegal.com"<JohnFurey@fureylegal.com>, "jpetrie@nbpower.com"<jpetrie@nbpower.com>, "NBPRegulatory@nbpower.com"<NBPRegulatory@nbpower.com>, "lgordon@nbpower.com"<lgordon@nbpower.com>, "SWaycott@nbpower.com"<SWaycott@nbpower.com>, "George.Porter@nbpower.com"<George.Porter@nbpower.com>, "kevgibson@nbpower.com"<kevgibson@nbpower.com>, Veronique Otis <Veronique.Otis@nbeub.ca>, "Young, Dave"<Dave.Young@nbeub.ca>, "Colwell, Susan"<Susan.Colwell@nbeub.ca>, "Aherrington@lawsoncreamer.com"<Aherrington@lawsoncreamer.com>, "bhavumaki@synapse-energy.com"<bhavumaki@synapse-energy.com>, "mwhited@synapse-energy.com"<mwhited@synapse-energy.com>, "prhodes@synapse-energy.com"<prhodes@synapse-energy.com>, "alawton@synapse-energy.com"<alawton@synapse-energy.com>, "jwilson@resourceinsight.com"<jwilson@resourceinsight.com>, "pchernick@resourceinsight.com"<pchernick@resourceinsight.com>, "Chiasson, Alain (OAG/CPG)"<Alain.Chiasson2@gnb.ca>, "rdk@indecon.com"<rdk@indecon.com>, "tammy.grieve@mcinnescooper.com"<tammy.grieve@mcinnescooper.com>, "paul.black@twinriverspaper.com"<paul.black@twinriverspaper.com>, Len Hoyt <Len.Hoyt@mcinnescooper.com>, "tyler.rajeski@twinriverspaper.com"<tyler.rajeski@twinriverspaper.com>, "darcy.ouellette@twinriverspaper.com"<darcy.ouellette@twinriverspaper.com>, "dan.murphy@umnb.ca"<dan.murphy@umnb.ca>, "jeff.garrett@sjenergy.com"<jeff.garrett@sjenergy.com>, "shelley.wood@sjenergy.com"<shelley.wood@sjenergy.com>, "dan.dionne@perth-andover.com"<dan.dionne@perth-andover.com>, "pierreroy@edmundston.ca"<pierreroy@edmundston.ca>, "ryan.mitchell@sjenergy.com"<ryan.mitchell@sjenergy.com>, "sstoll@stollprofcorp.com"<sstoll@stollprofcorp.com>, "pzarnett@bdrenergy.com"<pzarnett@bdrenergy.com> | |||||||||||||||||||||||||||||||||||||||||||
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Hello,
Please find enclosed the Responses of the Public Intervener to the Interrogatories to the Public Intervener in Word and PDF format. This email will serve as notice of filing for theses responses.
Please let me know if you have any questions.
Cheers,
Alain Chiasson
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Office of the Public Energy Advocate
Description and Background
The Province of New Brunswick will establish and appoint a full-time
public energy advocate to replace the system of ad hoc appointment of
public intervenors.
Utility consumer advocacy arose with the rise of regulation of energy
utilities. The traditional role of consumer advocates is to challenge
proposed rate increases by intervening in formal regulatory cases.
Consumer advocates may also focus on consumer protection issues, such as
service quality, reliability and price stability.
There is no single model for utility consumer advocacy. Our current
model provides for the ad hoc government appointment of a practicing
lawyer as a public intervenor to represent rate payer interests. A
public intervenor remains independent of government influence and
conducts the intervention according to his or her discretion. Other
advocacy models provide for cost recovery for advocacy groups appearing
at regulatory proceedings or the establishment of a dedicated consumer
advocate.
Public intervenor costs are direct expenses, paid by the utility,
which usually include professional fees and the costs of experts
employed to assist with evidence. In complex rate cases, costs can be
significant. Although they are passed on to the utility, they are
ultimately recovered from utility customers as part of the revenue
requirement.
The current public intervenor model has a number of weaknesses:
- There is no particular requirement for knowledge, experience or expertise in relation to energy or regulatory matters.
- There is no guarantee of continuity of appointments, especially between government mandates.
- There is little or no oversight over costs.
- Appointments are limited to particular proceedings. There is no inter-proceeding advocacy role, nor is there an avenue by which public oncerns, complaints or issues are brought to light.
- There is no guidance of the particular role or position to be taken
at utility interventions, nor is there any clear definition of the
stakeholder group (if any) that the public intervenor is mandated to
represent.
The appointment of a full-time Public Energy Advocate would correct these limitations by:
- Ensuring a consistently high standard of competence and experience.
- Delivering services responsibly, effectively and efficiently.
- Providing accountability for an equitable allocation of costs.
- Providing continuous services, including information resources, complaint resolution and public advocacy in matters not tied to specific regulatory proceedings.
- Providing a clear mandate for the scope of the interests being served.
Key Objectives Served by this Action
Low and Stable Energy Prices– A key role of a Public Energy
Advocate would be to challenge all utility rate applications in a way
that assists the EUB in arriving at decisions that are just and
reasonable.
Effective Regulation– The establishment of a Public Energy Advocate would offer better protection and new services for under-represented energy consumers in relation to utility rates and services and may result in a more
Board nixes special intervener to defend residential users in NB Power hearings
Energy and Utilities Board concludes it does not have authority to appoint a residential intervener
"The board finds that it does not have jurisdiction to grant intervener funding," it wrote in a three-page decision released late last week.
NB Power is involved in a rate design hearing, which could dramatically change the prices charged by the utility.
Peter Hyslop, a Hartland-based lawyer, argued in June that homeowners and apartment dwellers are NB Power's largest customer group and should be independently represented at hearings.
"Rate design is going to have significant impact on residential ratepayers," Hyslop said at the June 15 meeting.
There is no question that Mr. Hyslop would bring a meaningful contribution to the proceedings.
- Energy and Utilities Board
"The argument and position of residential ratepayers should be before this board."
NB Power is responsible for the expenses of electricity hearings and would have been the one to pay for the bills of a lawyer representing residential customers.
In its decision, the EUB said there is nothing in its governing legislation or in precedent-setting court rulings that allow for that arrangement.
"There is no question that Mr. Hyslop would bring a meaningful contribution to the proceedings," it wrote.
"However, the board concludes that it cannot be implied that intervener funding is of practical necessity in order to accomplish its jurisdiction."
Year-long hearing to reshape bills
Heather Black is the public intervener at the Energy and Utility Board's looking into NB Power's rate design application. (Robert Jones/CBC)Heather Black, who is now the public intervener, is responsible for representing "the public interest" at the EUB hearings and is barred from advocating for any single group like residential customers.
Hyslop suggested that mandate, which was changed by the Alward government in 2013, meant Black would be unable to represent the best interests of residential customers in the way public interveners used to.
- EUB delays ruling on intervener for NB Power residential ratepayers
- Former public intervener asks to represent NB Power's residential ratepayers
NB Power is in the middle of a year-long EUB proceeding that is looking at reshaping how the utility bills various customers for electricity.
Some of the most significant proposals are aimed at homeowners and apartment dwellers, including higher than average rate increases for that group, premium prices for electric heat and the possible adoption of different rates at different times of the day, different days of the week or different months of the year.
ABOUT THE AUTHOR
Now, let’s look at the present rate structure (May, 2017). As a residential customer, I pay 10.81p per kWh versus 13.07p and 9.27p above 5000 kWh for a business customer. This is me gouging businesses? $540.50 versus $653.50 on the first 5000 kWh is not ‘gouging’. And, after the first 5000 kWh, I am subsidizing business customers. As for industrial customers, I won’t get into that rate structure except to note the following. Some of these large scale customers produce power. When they produce more power than they use, the excess power is sold to NB Power at a higher rate than these customers pay for power from NB Power when they need more power than they produce. So, who is being subsidized? Not the residential OWNERS of NB Power. Exactly the opposite.
We, the taxpayers, own NB Power. We are not customers and we do not underpay. We subsidize commercial customers. The cost of power is part of running a business. I don't run a business here. This is where I sleep.
NEW BRUNSWICK ENERGY and UTILITIES BOARD
COMMISSION DE L’ENERGIE ET DES SERVICES PUBLICS N.-B.
Matter 529
IN THE MATTER of an application by the New Brunswick Power Corporation with respect to proposed changes to its rate structure, rate classes and rate design
Held on June 1, 2023 via Zoom Video
Members of the Board:
Mr. Christopher Stewart
Ms. Stephanie Wilson
Ms. Heather Black
............................................................
MR. STEWART: Good afternoon, everyone. I think we will begin now. Thanks for everyone’s patience in terms of getting ourselves all attached to this electronic meeting.
My name is Chris Stewart. I am a member of the Energy & Utilities Board and I am joined this afternoon by my colleagues on the Board, Stephanie Wilson and Heather Black.
This public forum has been scheduled to allow members of the public to make submissions or provide commentary to the Board with respect to NB Power’s pending rate design application, scheduled to be heard by the Board beginning on June 7th through to June 20th.
As a result, the Board wanted to provide an opportunity for members of the public and ratepayers to share their thoughts and positions in a less formal setting than our traditional hearing. We all recognize that not everyone has the desire or the ability to attend formal sessions, but the Board still wanted to provide an opportunity for anyone to make a comment, should they wish.
I guess I should remind everyone this session is to receive comments, the points in issue in the rate design proceeding. And I ask that you limit your comments to those issues or the issues that are alive in that matter. The Board has and will continue to hold public sessions like this one to receive comments from ratepayers as other major applications come before it. But today our agenda is the matters involved in the rate design application.
So a few housekeeping items I would like to cover. I will chair this session and I will call on you individually to speak. After each person is finished, I may have a question or some clarification and I will call on Ms. Black or Ms. Wilson if they have any questions or would need any clarification from you.
Again, our intent is to hold a somewhat informal session and anyone presenting should not necessarily be concerned about formalities. We are really here to hear your views.
I would ask that anyone or when you speak that you make sure that you have your camera turned on and of course your microphone. But otherwise when you are not speaking, I would be grateful if you would mute your microphones to avoid background noise while others may be speaking.
We of course expect participants to be respectful and courteous and we will endeavour to allow everyone an opportunity to speak, should they wish to do.
You may address the Board in either English or French. Simultaneous translation is available. So if you look -- put your cursor down toward the bottom of the screen where all of the icons are, there is one marked interpretation and you may click on that at any time to hear English in French or French in English, whatever is being interpreted and that is there and available for your use throughout today’s session.
So with that brief introduction complete, my understanding is that we have only one attendee who wishes to make a presentation this afternoon. And I believe Ms. Thorne-Dykstra -- I see that you have joined us. And I am wondering if I could call upon you -- thank you for turning your camera on and unmute your microphone. And I am wondering if you are ready to proceed?
MS. THORNE-DYKSTRA: Yes, Mr. Stewart. Thank you very much for this opportunity. I appreciate having the chance to have a say about energy because it does impact all of us in New Brunswick. And I am speaking on behalf of myself and my husband and our three sons who are farming with us. And we are dairy farmers in our province and we operate three dairy farms. Each of my sons has 100 cow herd and we are working close together. They work independently on each of those facilities to milk the cows and then we share crop and equipment in the fields to be able to collectively work the land and share the labour costs as well as the equipment costs, which have skyrocketed.
Also with regard to dairy farming -- and I don’t expect anyone here on this call to understand my business, that’s why I am giving a little bit of a background. We have been facing a lot of extra costs and especially over -- well I guess everything changed with the COVID situation that happened in supply chains and such. So we have been experiencing almost double the cost in fertilizer, in feed pricing and things that we have to use on a daily -- regular daily basis. And of course energy is one of those pieces as well. So when it comes to any kind of increases, we do -- we do pick up our heads. I will say this time of year is a horrible time for your farmers to be trying to make their points heard because everyone is so busy right now planting crops and harvesting right now. But I felt it important to share kind of this perspective with regard to any consideration of energy -- energy increases.
I guess the recommendation we would have -- there is three pieces I guess to what I have to present. And one has to do with any contemplation of increasing our rates. As farmers we aren’t the large industrial users as we understand there is a need for support and help for those who use a great deal of energy in the province. But we do use more than the average consumer. And we do because we are -- we are operating a pretty good sized facilities today and much of the work done in barns today is mechanized which again needs energy. So we are impacted by any particular rates that may be put on us.
So we are recommending from our farm to just keep it at the status quo for now until some studies can really look at how this will impact farming and our regular input costs, because as I said before, there are so many other areas that have gone up. We really would like to see that some kind of a determination has been made on how it will impact the farmers of the -- of the area.
The second piece is with regard to renewable energy. And there is a lot of push and drive right now for renewable energy and green energy. And we think that’s a good thing. And I know there is a number of people in the dairy world who are looking at different ways that they can capture energy and use energy from our own operations, and biogas is one that has been considered by many and are looking at the possibility of that type of infrastructure to be able to create their own. And I know a number that have wind farms now as well and solar panels. So it’s -- you know, we are certainly looking at that aspect of things. I guess with regard to that, we would love to be able to have the possibility of -- if we do all the investment to put up these types of infrastructure, that we could also be able to connect to the grid and be able to get a payment back if we don’t use all the energy that we produce to help in two ways. It’s supposed to supply energy for others in the province and green energy. So that we -- as we shut down coal fired plants and not so -- you know, cause of energy sources that we have depended on over the years that we could help contribute to that. And we understand that other provinces do have opportunities, like Ontario, to put their power on the grid and be compensated for it. This would be a real -- I think a real push and driver for farmers to be really at the table of doing green energy if they could get back the same -- you know, the rates, like the 11. -- or the .11 -- 114 11 cents basically a kilowatt hour for their power that they had in excess that could go onto the grid.
We are looking for different sources of how to offset all those extra costs that we are incurring and that certainly would be something that would be appealing to the industry.
The third piece that I have is with regard to net metering. And again, with the significant investment it takes to do net metering and get the infrastructure in place for our types of small businesses -- smaller businesses, we are looking at the idea of maybe having some type of a compensation clause, because sometimes problems do happen and we see it every day on the farm. You can’t control the weather, you can’t control certain things. That if something unforeseen happened in our businesses that there would be still the same compensation given to the producer for any power that is being used at that reasonable rate, the same as before metering. So that was -- that’s kind of the other piece that we are thinking with regard to energy that would make sense.
But really that’s all I have, in terms of trying to give another perspective, I guess, on how energy affects maybe a different clientele than, you know, used to having. I know that our numbers aren’t huge in the province but we do a significant business with the GDP of the province and both from export as well as from, you know, our own internal.
The only other thing I might add is with the renewable energy purchase program that the large industrial users industry has, to me that’s not a new concept. You know, it’s something that is there for the large industrial users to do renewable energy, have them paid back. But also because it’s so hard to compete with other provinces, it’s hard to compete with them on many different levels. And when you take something as basic as your power infrastructure, when you have to compete significantly from province to province, even within your own country, that’s a real thing.
I understand why the large industrial energy -- renewable energy purchase program is in place and we would love to see maybe not at that same rate or whatever but at least some type of a category where that could be implemented maybe for businesses of our size.
So that’s it I guess and I again -- once again thank you so much for this opportunity.
MR. STEWART: You are welcome, Ms. Dykstra. I did just -- just one really quick question from -- because I am not sure I really understood. You were talking about a compensation clause or something. Could you just --
MS. THORNE-DYKSTRA: With regards to the net metering?
MR. STEWART: -- expand on that a little bit? Yes.
MS. THORNE-DYKSTRA: Yes. Yeah, basically --
MR. STEWART: So sorry, compensation for that --
MS. THORNE-DYKSTRA: -- with respect --
MR. STEWART: -- and what circumstances?
MS. THORNE-DYKSTRA: Yeah. Basically with regard to if there was, you know, something unforeseen happening on our farms that, you know, the net metering is impacted by it that we wouldn’t be negatively impacted but that there would be some type of a clause, a compassionate type of clause that would be established under the net metering to keep it so that the farmers wouldn’t be negatively impacted by, you know, something that would affect it. So that we would still be able to be compensated for any power at a reasonable rate.
MR. STEWART: So when you say compensated, you mean not compensated for a loss but compensated for the sale of the power that you might have?
MS. THORNE-DYKSTRA: Right.
MR. STEWART: Oh, okay. No, that’s fine. I just was trying to understand.
MS. THORNE-DYKSTRA: Yeah.
MR. STEWART: Thank you very much. And just before I go to Ms. Black and/or Ms. Wilson to see if they have any questions for you, I neglected at the outset, forgive me, to make it clear to you, Ms. Dykstra, and anyone else who may speak, that there are representatives of NB Power here today. And I suspect they are probably here, like the Board, here to listen. But, you know, your comments and anyone else’s comments will be directly heard by them. And I also note Maître Chiasson, the Public Intervener, is also present at our session today. And so he is here also, like the Board, to hear your comments at this session.
So, Ms. Black, do you have any questions or anything for Ms. Dykstra?
MS. BLACK: No questions. Just thank you very much for your presentation.
MR. STEWART: And Ms, Wilson?
MS. WILSON: I had one maybe small clarification regarding your second point. And I appreciate your presentation and thank you for taking the time today. I know it is probably a very busy time for you and your family on -- at this time of year and lots of stuff going on. But with regard to some of the other jurisdictions, you mentioned Ontario in particular. So -- and obviously there would be some discussion with other types of industries like yourself in other jurisdictions.
Is there something else that you wanted to add about some models in some of the other provinces that you thought were appropriate? I know you mentioned Ontario, and I am not sure if you have anything to kind of add to what that model looks like that is appealing or that is -- you know, that is of interest for you and your family?
MS. THORNE-DYKSTRA: Well thank you for that question. I do know when they first started this opportunity for farmers to be part of putting energy onto the grid, they were looking at really incentivizing to have this done so that more farmers would do it. So my understanding was they were actually paying farmers four times the amount of costs that it would be normally to get power off the grid to the farmers for any extra power that they would have to be able to put onto the grid. And that really stimulated that. I am not sure it was sustainable to continue that way and I do believe that after a period of time, they did change the amount that came back to the farmers. But it was a stimulus basically to try to encourage people to invest, because it is a huge investment, whether you go biogas, whether you go solar or you go wind. There are huge investments there that have to be made and carried for -- from the -- from the numbers I have seen with regard to wind farms and solar, at least, you are -- you are paying about 20 years out. So I mean, it’s not something that you would just do overnight and it has to make sense economically to do it. Because quite frankly, we just have too many places to put any kind of income we are generating now monies toward to try to, you know, keep things going. So that’s how my understanding the Ontario program was set. But they still, the last I heard, were -- you know, they were receiving an income back equivalent, if not a little better than what the average rate was.
So that’s the one I know best. I don’t know about everybody else. But I -- I know what it did do in Ontario, it really did stimulate farmers to go down this road and I think that that’s a positive thing I think as we keep hearing the push for -- toward green energy and we see the signs of climate change, there is -- there is a value in doing that. Thank you.
MS. WILSON: Thank you for those comments. I have no other -- no other questions. Thank you for your time today as well.
MS. THORNE-DYKSTRA: Yeah.
MR. STEWART: I will make it unanimous with the thank yous, Ms. Thorne-Dykstra. I really appreciate you taking the time and sharing your -- your thoughts and views and input on the issues that you have raised. The Board, you know, takes these sessions very seriously. And input like yours, you know, helps us -- helps inform us when it comes time to make all of the decisions that we will need to make in this proceeding.
I would just like to sort of, you know, canvass the electronic room, so to speak. I know that we did have a few individuals who had sort of signed up as observers, that they wanted to attend and hear what was being said. But I am just going to ask generally whether there is anyone else who would like to make some comments or submissions to the Board at this time in this session. If so, turn on your camera, turn on your microphone and we would be happy to receive your comments, whatever they might be.
I guess hearing from no one or seeing no cameras turned on or no microphones unmute, I guess that’s it. And really, once again appreciate you, Ms. Dykstra. We certainly appreciate everyone else, the Public Intervener, representatives of the utility and otherwise for attending what I guess turned out to be a brief session. Whether one person comes or 50 people come, the Board finds these sessions very helpful and we will be continuing to do them. And so that -- Ms. Wilson, Ms. Black, is there anything else we should cover before we adjourn? No. All right.
MS. BLACK: No.
MR. STEWART: Well thank you. So seeing nothing, I guess I will call this session to an end. Thank you, everyone, for attending. And with that, I guess we stand adjourned. Thank you.
(Adjourned)
Certified to be a true transcript of the proceedings of this Public Forum, as recorded by me, to the best of my ability. Henneberry Reporting Service
"The only other thing I might add is with
the renewable energy purchase program that the large industrial users
industry has, to me that’s not a new concept. You know, it’s something
that is there for the large industrial users to do renewable energy,
have them paid back. But also because it’s so hard to compete with
other provinces, it’s hard to compete with them on many different
levels. And when you take something as basic as your power
infrastructure, when you have to compete significantly from province to
province, even within your own country, that’s a real thing.
I
understand why the large industrial energy -- renewable energy purchase
program is in place and we would love to see maybe not at that same
rate or whatever but at least some type of a category where that could
be implemented maybe for businesses of our size."
Large Industrial Renewable Energy Purchase Program
Description and Background
The Province of New Brunswick will bring qualifying large industrial
companies’ electricity costs in line with their Canadian competitors by
implementing a Large Industrial Renewable Energy Purchase Program.
Under the proposed Large Industrial Renewable Energy Purchase Program
(LIREPP), NB Power will purchase electricity from renewable sources,
such as biomass and river hydro, from qualifying large industrial
customers who have renewable electricity generating facilities located
in New Brunswick. The revenue from renewable energy sales will assist
these qualifying customers to reduce their net electricity costs and
thereby increase their competitiveness in the global market.
The LIREPP is designed to address the need for long-term stable and competitive electricity costs for New Brunswick’s largest industries. The program is the result of more than 18 months of public-private sector collaboration through the work of a task force and the efforts of the Energy Commission.
This is a New Brunswick-based solution to our industries’widely recognized energy and competitiveness challenges, effectively reducing electricity costs to be in line with the average costs of competitors across Canada. The retention of anchor industrial operations and facilities will support the overall sustainability of our major industrial employers, particularly the forestry sector and the rural and northern economies most affected by it. Furthermore, retaining these large base-load electricity customers will enable NB Power to avoid a significant loss of income which would occur if large industrial customers were to leave New Brunswick as some have done in recent years. This income loss would have to be recovered from NB Power’s remaining residential, commercial and industrial customers through higher rates.
Financial impacts for NB Power associated with losing large energy loads
Large industrial facilities are not only key employers in their
communities but significant customers for NB Power. A shut down of
either of the two largest of these companies would result in a
significant income loss for NB Power that could lead to rate increases
of upwards of 3% for all NB Power customers.
Key Objectives Served by this Action
Low and Stable Energy Prices– The Large Industrial Renewable Energy
Purchase Program will result in energy cost competitiveness and
stability to qualifying large industrial customers. This will ensure
these core businesses remain in New Brunswick, providing much needed
employment and economic opportunities to our local communities and
suppliers. In addition, procuring a supply of less price-volatile
renewable electricity from LIREPP participants and maintaining base load
industrial customers will assist NB Power in maintaining stable rates
for all its customers.
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