qc d c j d w christopher michael vaughan karen ......wilhdm e ireland, qc douglas r johnson+ alan a...

Wilhdm E Ireland, QC Douglas R johnson+ Alan A Frydenlund"- •

james L CarpICk+ Michael P Vaughan

Heather E Maconachle Michael F Robson +

Zachary J Ansley Pamela E Sheppard

Carl j Pines, ASsOCiate Counsel-'-

D Barry Kirkham, QC+ Josephine M Nadel+ Alhson R Kuchta+ Christopher P \Veafer+ Gregory J Tucker+ Terence W Yu+ james H McBeath+

Susan C Gilchrist George J Roper

R Keith Thompson, Associate Counsel'" Rose~Mary L Bashdm, QC, Associate Counsel+

Hon Walter 5 Owen, OC, QC, LLD (1981) John I Bird, QC (2005)

June 27, 2012

VIA ELECTRONIC MAIL

Robin C Macfarlane+ James D Burns+ Daniel W Burnett+

Paul J Brown+ Karen 5 Thompson+ Harley J Harris-'Paul A Brackstone+

Edith A Ryan Daniel H Coles

British Columbia Utilities Commission 6th Floor, 900 Howe Street Vancouver, B.C. V6Z 2N3

J David Dunn+ Duncan J Manson+ Harvey S Delaney+ Patrick J Haberl+ Gary M YaHe+ jonathan L Williaffis+ Scott H Stephens'" jdmes W Zaitsoff

+ Law Corporation

Also of the Yukon Bar

·B IRD

PO Box 49130 Three Bentall Centre 2900-595 Burrard Street Vancouver, BC Canada V7X lJ5

Telephone 604688-0401 Fax 604688-2827 Website www.owenbird.com

Direct Linc: 604691-7557

Direct Fax: 604 632-4482

E-mail: [email protected]

Our File: 23841/0077

Attention: Alanna Gillis, Acting Commission Secretary

Dear Sirs/Mesdames:

Re: FortisBC Alternative Energy Services Inc. Application for a Certificate of Public Convenience and Necessity for the Approval for the PCI Marine Gateway Thermal Energy Project and Approval of Rates for Thermal Energy Service to PCI Developments Inc., Project No. 3698677

We are counsel for the Commercial Energy Consumers Association of British Columbia (CEC). Attached please find the CEC's first set of Information Requests pertaining to the above-noted matter.

A copy of this letter and attached Information Requests have also been forwarded to FortisBC and registered interveners bye-mail.

If you have any questions regarding the foregoing, please do not hesitate to contact the undersigned.

Yours truly,

OWEN BIRD LAW CORPORATION

CPW/jlb cc: CEC cc: FortisBC Energy Inc. cc: Registered Interveners

CPW21017 D INTERLAW MEMBER Or INTr:RLAW, AN INTERNATIONAL ASSOCIATlON

OF !NI1El'EJ'.:DFNT I AW FIRMS IN MAJOR WORLD CENTRES

C5-2

markhuds

FAES PCI Marine Gateway TES CPCN

COMMERCIAL ENERGY CONSUMERS ASSOCIATION OF BRITISH COLUMBIA ("CEC")

INFORMATION REQUEST #1

FortisBC Alternative Energy Services Inc. Application for a Certificate of Public Convenience and Necessity for the Approval

for the PCI Marine Gateway Thermal Energy Project and Approval of Rates for Thermal Energy Service to PCI Developments Inc.

Project No.3698677

1. Reference: Exhibit B-1, Page 9 the choice of energy system F AES has applied fOL Even though this CPCN Application is regarding a for the Deve!opment only, the energy system will be designed to be connect8ble to the energy systems of the other developments as part of the City's rezoning conditions. While techniC8!1y feasible, FEI will re-examine the expansion once more detailed inform8tion is 8vailable for the adjoining sites.

1.1. Does the cost estimate for the thermal energy system include costs to make the system expansion possible?

1.2. Does the future expansion include both the heating and cooling components? 1.3. Could FAES please provide the quantity breakdown between the TES required for

PCI Marine and the facilitation of future expansion? 1.4. Please discuss the issues involved in being prepared for a future integration with

other sites.

2. Reference: Exhibit B-1, Page 9

The CoV 8pproved PCl's rezoning apphcatlon in July of 20'1'!. The approval contains a number of conditions regarding the energy systern for the Developrnent The most significant of those conditions are the Co\!"s requirements that 70~·o of tile annual space heating and domestic hot water energy requirements for tfle Development are to be provided through renewable energy sources (which excludes electricity and natural gas according to the CoV), and that the system shall reduce the GHG emissions by 8 minimum of 50'1'0 relative to business os usual (which the Co\/ prescribed as 0 natural gas boiler systern).

2.1. Is the Co V requirement of 70% requirement from renewables set at the most costeffective point for trade-off between natural gas peaking and investment in the renewable sources?

2.2. Please describe quantitatively where the most cost-effective tradeoff between renewables and natural gas peaking service is?

2.3. Please discuss the relationship between the 50% GHG reduction requirement and the 70% renewables requirement in terms of whether the 70% renewables criteria

2

essentially the driver of the GHG reduction at 60% and therefore the 50% requirement is determinative.

2.4. Is the business as usual heating for such residential towers typically all natural gas boiler sourced or is this market typically electrically heated for space heating?


The PCI Marine Gateway Project encompasses approxirnately 8! ,000 m2 of developed floor area, as per the development permit appl ication of September 2011. The site houses a '15-storey, 63.4 m office tower; a 77.6 m residential tower and a 35-storey, 10'1.8 m residential tower (Development Permit Staff Committee Report of Nov. 2, 20'11 \ The total residential floor area is 30,783 rn2 Commercial-Retail Units including theatres are located on the iower levels of the three towers, covering 46,877 nl':!. The Development is expected to be completed in January 20'15.

Residential Commercial Total Floor Area m3 30783 46877 77660 Units # 464 464 Heat Energy GJ 13255 17489 30744 Cool Energy GJ 72 6372 6444 Heat GJ/Unit 28.567 Heat GJ/M3 0.431 0.373 Cool GJ/M3 0.002 0.136

3.1. Please identify whether or not the difference between the total residential and commercial space and the total developed floor area is common area.

3.2. Please confirm the CEC calculations above or provide revised calculations which would be more relevant to a discussion of the conservation and efficiency base line assumed in the estimation of the heating and cooling loads.

3.3. Please compare the expected heating costs per unit and per m3 to those of buildings in the end use studies done by FortisBC or any others which may be relevant.

3.4. Please describe the conservation and efficiency standards built into the PCI Gateway project and how they may relate to target conservation and efficiency standards.

3.5. Are there potential improvements to the conservation and efficiency base line assumed, which F ortisBC could be addressing?

3

3.6. Is there any heat recovery planned from the commercial, grocery & restaurant uses?

3.7. Please discuss the degree to which FortisBC has been able to integrate its TES

designs with the building and tenant facility designs.

3.8. To what extent has BC Hydro's new building programs under Power Smart participated in looking at conservation and efficiency for electrical consumption?

3.9. Is there an assumption made with respect to the heat available from electrical

lighting and equipment and if so please provide the quantities and discuss what

effect future conservation and efficiency relative to those loads might have as an effect?

3.10. What are the base line assumptions about hot water recirculation pumping?

4. Reference: Exhibit B-1, Page 15 The CoV required that the "energy node" include sites \"lithin a 500 meter radius of the Development that were considered to have the potential to form part of a larger TES in the vicinity of Cambie and rvlarine. The sites, ttleir relationship to tile I\'larine Drive and Cambie Street intersection and their estimated floor space were as follows:

4.1. Is the 500 meter criterion as a guideline the boundary of economic

interconnection benefits?

4.2. Did FortisBC look beyond the 500 meter radius?

4.3, Would a more appropriate criterion for FortisBC to use be based not only on distance but also the energy density currently and prospectively of proximate

sites?

5. Reference: Exhibit B-1, Page 19 Table 3-6: Summary of Four Options

Option AtteJ-native Total Total Unit Annual Fin;t Ye~n' Energy SOll,'ce Capital ,,'-n.nual GUG En~issions Rate

Cost O&M Costs lC02e/TJ $/GJ ($OOO) ($000) (tC02e/G\'Vh) ($ tr.nVh)

I'CI B}\U None 3,765 693 63.9 (2'\0) 25.0 (90) PCI1 Open Loop GHX 5.173 443 1Ll (40) 21.7 (78) PCI2 \Vaste\vater 5,655 438 11.1 (40) 23.1 (83) (>C13 ·····Bionla;;sTllel~l:;:l······· 7.g~2 32:; 6.5 (23) 26.6 (96) PCI4 Natural Gas Cog en 9.045 597 85.3 (307) 32.5 (117) M&C Notiej Ncme- 5_002 1,166 (>:l.') (230) 2:3.1 (H3) BAU M&C Node 1 Lo'\¥ 'letup Open 9,285 706 10.8 (J9) 222 (SO)

LoopGHX M&C Node:!. High Temp Open 12~932 925 8.3 (30) 303 (109)

LoopGHX M&<: Nod£' 3 Low-Teo,np !0,5&9 705 10 .. 8 (59) 24.2 (&Y)

"\\>l" nsf t?\vnter 1\1&C Nolle <I- Hi.gh Temp 12,,766 908 8.3 (30) 30 (lOS)

"Va stewatel' M&c Node 5 Biomass Thel"fl1a1 13.,598 555 66(24) 27 .. 8 (100) M&<: Node6 Natu,."l Ga>;; Cog"''' 15402 1 ,one 253 (307) :n:\ (120)

M&C Node 7 'VTE The:m:wl 31,398 753 73.6(265) ":"t59

Source: Study (Appendix A) by DEC Consultants Ltd.. Please note that the O&M in this report included fuel inputs. studies mentioned in subsequent sections included only annual repairs and maintenance as FAES has conducted the fuel cost estimates instead of the consultants.

4

5.1. What assumption was made with respect to PCI 4 in regard to the value for the electricity sales from the generation component of the Cogen?

5.2. Given that the assumptions include a 20 year project life was any consideration given to the terminal condition differences between the alternatives?

5.3. Please discuss qualitatively the terminal condition values for each of the alternatives.

5.4. What were the assumptions made to determine the annualized values for capital investments?

5.5. Were there any adjustments to the analysis as a consequence of some of the systems being compared being capable of providing both heating and cooling versus just heating and is so what were they.


Table 3·7: GHG Emissions for Four Options

PCI Bi\U

PCll P(12 PO 3 P(14 M&C Node BAU M&CNode 1 M&C Node 1. M&C Node 3

M&CNode5 M&C Node 6 M&CNode7

Source Screening Study {Appendix A) by DEC ConsliHants Ltd"

6.1. Does the annual emission intensity factor have a cost tradeoff value for use in determining whether or not it should be a factor in selecting between alternatives?

5


The key conclusions of the Screening Study are as follows:

1.. The open loop geo-exchange, wastewater ane! biomass energy source options show significant reductions in annual GHG emission intensity compared with the BAU approach.

2. The unit capital costs for open-loop geo-exchange and wastewater heat recovery systems are the lowest of oil screened renewable energy options.

3. The levelized energy rates for open-lOOp geo-exchange and wastewater heat recovery alternatives are lov<ler than BAU.

7.1. Were any sensitivities run with respect to the different inputs to the analysis for making the screening selection and if so what did they show?


technology and approvals. Although it is FAES's understanding that Ivletro Voncouver has been examining heat-recovery potential from its sewer system, there are currently no existing CoY policies, contractuol terms and connection cost information for se\ver heat in the Lower r.,lainlane!. As a result this option presented too much uncertainty for the e!eveloper and was rejected accordinglY Sewer Ilea! recovery will continue to be explored with the CoY in the future for nearby developments should they nmterialize.

8.1. Is it not true that the City of Vancouver Neighbourhood Energy Utility serving the South False Creek area is based on Sewer Heat recovery?

8.2. Has FortisBC investigated the City of Vancouver NEU to determine what problems and issues it has as well as what benefits it may provide?


Table 3-8: Cost Comparison of Energy System Options from July 13, 2010 Memo

Energy Option Capital Cost O&M Natural Gas Cost Eltilctrldty Cost Total GHG Emission

$COO $COO $COO $COO $COO tCOle

BAU SA86 76 476 354 90S 911 Open Loop GHX 6.057 49 61 252 362 215 Closeclloop GHX 6,106 41 61 274 376 279 Sewer Heat Recovery (SHY) ill 6,311 48 61 234 343 271

9.l. What is the cost of electricity used in this analysis?

6


Table 3-9: Summary of Energy Sourcing

PCI Annual Heating GJ MWh (%) Heating from in-building simultaneous cooling 2,437 677 8<'A, Heating from tn-buHding refrigeration 6,084 1,690 2O'7Q Heating from GSHX 13,032 3,620 42% Heating from boiters 9.191 2. 553 30?tb

Total Heating 30,744 8,540 11)()%

PCICooUng GJ MWh (%)

Cooling from in-building simultaneous heating 1,829 SOB 12%

Cooling from in-buiiding use of refrigeration for heating 4,561 1,267 3O'7Q -6,390 1,775 42%

PCI Cooling + Electrical Compressor Heat CooHng from GSHX 5,940 1,650 39% Cooling from fluid coofer 2,848 791 19%

8,788 2,441 ,

58%

Total Cooling 15,178 4,216 100%

Source: Tech Iv~mo No.3, dated March 21,2012 in Appendix H, prepared by DEC.

10.1. In its discussions with PCI did FortisBC have any discussions about elements of building design which could contribute to the economics of the Heating and Cooling solutions and if so please discuss them?

10.2. Has FortisBC looked at possible areas of building design which it could discuss with developers to make the Heating and Cooling solutions more economical?

10.3. Has FortisBC had discussions with its consultants with respect to the potential for integration of Heating and Cooling systems designs and the building designs?

lOA. Does the Natural Gas Boiler sizing enable it to meet the entire heating load on its own and if not what percentage of the load can be met by the Natural Gas Boiler?


Fluid within the boreholes extracts heat from the ground providing an ambient temperature heat source to the fleat purnps which in turn, through a refrigemtion compression cycle, generate higher temperature heat for use at heatlng colis in air-handling units, fan-coil units and specialized base-board heaters or in-slab radiation system.

11.1. What kind of 'in unit' controls are anticipated for the specialized base-board heaters and in-slab radiation systems?

11.2. Has FortisBC considered how to optimize its design with the 'in unit' controls and air management approaches?

7


If an external source of supplemental peak heat \vith lower GHG-emissions than tile natural gas boilers becomes available, a connection to supplernental piping by-passing the internal boilers can be made.

12.1. Might such a source be a solar thermal source derived from the building or some other source options at some point in the future?

12.2. Has FortisBC examined any particular forms of solar thermal assistance for this project and if so what would the potential costs of such an option be and what kind of assistance or cost reductions might be achieved?


Domestic hot water supply is norma!!y set between 40'T and 50<'C for delivery at faucets and showers. The geo-exchange system is expected to provide a minimum of 7::/+0 of Ule domestic IIOt water heating requirement Reheat of the water to a higher temperature, as required, wil! be accomplished by a boiler.

13.1. Has F ortisBC examined the potential for the building design to incorporate heat recovery from the building sewer connection or water outlets before dumping into the City sewer systems?


In order to effectively respond to such demand. the equipment in the EC wi!! be controlled to provide hot water, cflilled water and domestic flot water at sufficjent quantity and quality Signals from the HVAC Gontrols system \-vil! generate a response to the EC Gontrols system assisted by internal and ambient temperature sensors, temperature forecasters and other variables, such as time of day, and building mass temperature.

14.1. Has the control system supply been determined or has the specification for the control system been determined?

14.2. To what degree is the control system expected to influence the performance of the entire system in terms of its efficiency? Please discuss this as between the best in class systems and the average.

14.3. What is the lag expected to be between unit demand for heating and cooling and the system's expected ability to respond?

14.4. How integrated if at all is the control system expected to be with the 'in unit' control systems.

8


Service to tile customers noted above creates a diversity of heating and cooling requirements. Through system design work carried out in consultation with PCI, energy SOllrces for heating and cooltn~l are described as follows:

15.1. What are the heating and cooling losses expected to be, how are the mitigated and what is the cost trade-off involved in determining how to avoid waste in getting from the Energy Center to the 'units'.


4.6.1 AND

,,) provides that FAES will design and construct the Project as required by PCI to meet development and bllilding permits;

o provides that the Project wm be completed as agreed by PCI and FAES; and

o provides that PCI will enter into Service Agreements related to the provision of thermal energy for the four types of clistor-ners and will cause the Service Agreements to assigned the end customers.

16.1. Do the agreements allow for the fact that F AES will require a CPCN approval from the BCUC and do the agreements allow for the possibility of any conditions from the Commission?


o The Rate will be set at predetermined levels for the first three years of the Service Agreement to enable a predictable, stable and competiUve introductory rate, and then in the fourth and subsequent years, rates are determined by the forecast cost of service as discussed in Section 6 Cost of Service and Rate Design.

17.1. Is it possible that the rate differential in the fourth year could be significantly different from the first three?

17.2. Does FortisBC think it would be advisable to avoid a large rate swing in the fourth year if the performance seemed like it would require a large change?

17.3. Would a phase in of changes around a fixed target price make more sense and avoid possible abrupt changes.

9


Table 5-1: Summary TES Class 3 Cost Estimate

Total 8,227,000

18.1. Are there any communication costs and or software costs related to any kind of

building energy management system or is this included in the above estimates?

10


Table 5-4: Development Costs

PC! Marine Gateway Development Costs - As at February 28,2012

Feasibility Study and Concept Design

Design Development

Construction Documents

Tender

Construction Administration

Project Closeout

Disbursements

Total Development Costs as at february 28, 2012

Estimated costs until Project Completion

Total Development Costs to be Capitalized

$70,387 $108,288

$194,918 $10,828

$146,188

$10,828

$584,752

$94,000 $678,752

19.1. Are there regulatory costs related to the deVelopment of the proj ect and if so are

they included above or somewhere else?


• the rates developed for the first three yems me mutually agreed upon rates of $0.109/k\A/11 for 20·!5. $0.115ikWh for 2016 and $0.'120/kWh for 20'17. The rate will

transition to cost of service in the fourth year and will include amortization of the deferral

account Once the rute is trunsitioned to cost of service. FAES will forecast annually the cost of service for providing thennal ener!::JY service to the development. based on the inputs described above, and the anticipated demand, to derive a thermal energy rate per k\Nh;

20.1. Please compare these rates with the equivalent potential rates for electric

resistance heating. 20.2. Please provide a comparison of these rates with rates for other regulated AES type

regulated heating approaches.

11


Table 6-1: Depreciation Rates l1

ec Equipment

Mechanical Room Piping

Pumps, Heat Pumps and Exchanger Equipment

Boilers high CCA

Structures· Cooling Towers

I ntrasystem Pip' ng

Loop Field (Ground Source Heat Exchanger)

Meters

Sustaining Capital

Capitalized Overhead

Depreciation

inVears

50 22

35 22 50 50

15 29 29

21.1. What is the expected life of the buildings?

Annual

Depredation Rate

2.00% 4.63%

2.86% 4.63%

2.00% 2.00% 6.67%

3.48% 3.48%

21.2. Gi ven the extended life expectation for a number of the components and the

modest levels of capital which may be required to manage keeping the thermal energy system up to date are rate for customers expected to decline from year 20

on into the future? 21.3. Is it likely that a complete overhaul of the entire heating and cooling system will

be required by about year 50 or is it more likely that many of these systems may

be able to achieve extended lives beyond the depreciation life assumptions?


Following the methodology directed in Commission Order No. G-3'1-12 in the Delta School District Project, FAES has derived a cost of debt for providing thermal energy service to PCI !\!larine Gateway of 5.91'10, which is different from the FEI corporate rate of 6.9'1'0. This is consistent with an entity with a 888 rating (investment grade) including an additional premium to reflect the extra cost to arrange an incrementa! small debt issue as of I\'larch '14, 2012.

22.1. Please confirm that F AES will receive its debt financing from FortisBC Inc. or

explain where the actual financing of the debt will come from. 22.2. If the F AES and this project are including a cost of debt of 5.91 % for a BBB rated

entity but F AES receives its funds from an affiliate borrowing at lower costs, will

the excess spread accrue to the entity providing the financing?

12


Table 6-5: Revenue Requirement

forthBC Altematfv" Energy Services Inc.

m:e!mdl En(;!r:g:l S()Iu:tion~

PC! Oni,' Cio,ed GfOx

Thermal Energy SoiutiMs; i!eWfllJe fieqlJrrement

{SOCl(}\}, ullll!:!5 c>the!wile $(oteo Schedule 1

Une Part'""I" ... ms. 20'16 21117 201S .wl! ~ 2031 21111 ml3 2!l34 1 R.eVt!rtue Reqoirement

2 Co,! ·of Natura,1 Ci., 1m 107 114 120 124 171 174 178 1&2 185 Cost of Electricity 212 229 235 241 148 336 343 349 356 364

4 Operdtion ar'~d f<t:.-aint£n3!1ct! 132 134 137 140 141 177 181 1&4 18& 192

5 Property Tax~s 14 15 16 23 24 24 2.';, 25

6 De:pr{:tc~ation E::':peflsc 3C3D :131 332 332 333 ~J 410 4Z0 431 442

7 Amortizatton £xpa'nSf! 13 13 13. 13 13 13 13 B 13 13

S incti-me Ta>:0s 19 195 192

9 Earned Retum 692 &79 655 &31 GOO ;\73 4G3 453 443 434

10

11 "nnuill RewAu" Re<:tulremer\t 1,489 1,493 1,499 1,493 1,483 1,$3 1,001 1,641 U3! 1,846

23.1. Because the cost of service revenue requirement is composed largely of fixed cost items does this mean that setting rates will be very dependent upon the use per account?

23.2. Is this fixed and variable cost structure reflected in the rate determination or is the customer essentially all on a variable use per account $/KWh charge basis.


Table 6-6: Benchmark Rates

Year

Step 1 BCH Residential $ Step 2. BCH Residential $

50% Step 1 & 50% Step 2 S 10% Basic Charge added as per

2012 0.068

0.102.

0.085

BCUC Orde r G-141-11 S 0.008 -------S 0.093

24.1. Please provide the explanation and justification for using 50% Step 1 and 50% Step 2.

13


Table 6-8: Thermal Energy Rates

forthOC,.v\;!~ ffl<1i'¥ S<!t\lk~ It!(.

Tnt/fro' (""iF! ",IUb<l<" PCI (h~' (bsei GHa

T/w1!!I1t!lqyS,Ott!O<ll:RoItJlr3igll

t$alJ~), tntbs otfitTIVY$t stft!1:'tf

k~fd"i!l'

Att·l!.d~j iilitmf.? ~(P fJ:clklg {MW*!i

f7""'1'Jr"'uij~

26 lL't.1t1 A.Nlu.cl R(iV&~!1.M

27 ?rtu1!~ Vd.i{':

fY ~15

lO,31a j().!,3?l 9JiC3

1.1.11

15,494 1,{}18

llll6 .1 W liJ,l2$ ill,3la l1ma &5:iU UOJ ~n)

1,l!l3 1..142 1,29]

1,(Qj 3'1.1 g;rj

~ lmlI llSl ;Wl! llS3 2ll* :C,m: 10,32& lCi3lll lD,J2N ~~m: mm: ~Il9 1m 1.3'1.1 2,,1&\ 25", 441l US; 1,923 1,9Gl 2,001 ~()ll l;ffi9

JIG t\Ul S)[) 540 sU 47(i

25.1. Please discuss the certainty and or uncertainty around the annual volume forecast. 25.2. Please discuss details of what the potentials for higher than forecast and lower

than forecast volumes may be.


Table 6·9: Deferral Account

FortlsllC I\ltemlltive Energy Scf'll",.ln"

Th€fmaf Enero 5.a!utions.

PC! Only Ckxi<d GfO~

The""al Energy Solutions:: Deferred Charges ($iXiJS), tiTtleS:; 0 therwi~e stated ScheduLe: 11

lirle Particulars 2015 21)16 2tl11 201S 2019 2030 2031 2032 2033 ~

Deferred C"",,*- Non,Rate Ba." Opening Sa:."e" .374 719 U132 1,302 USl 993 693 368 171 Opening Sa%af'.lc~, Adj'<Jstment

Gro'Ss Additions ;62 309 257 194 126 133C~1 (354) (3Gl) 12C'B) (193)

Tax

1 AFUDC &. Actj ustme nts 12 35 56 75 91 72 54 34 1& 15 -- -- --a NetAdditiors 374 345 313 270 217 12SS) (300) (325) {l~J1) (188)

9 Amortitatfon E~pens,e

1G Clo<;'ing Bat3nCe 374 719 1,()32 1,302 1,519 !J'l3 693 36S 177

26.1. Is there a possibility that occupancy in the first year may be staggered based on the move in rate for owners and tenants?

26.2. Are some of the sold out residential units owner by investors and therefore are likely to be rented units and if so can the percentage of investor owned units be provided?

14

26.3. Would rented units be expected to have a certain rate of vacancy particularly between rental tenants and therefore potentially affect the volumes and hence the deferral amounts?

26.4. Please provide the sensitivity of the deferral account amounts to a $.01 change in the rate being charged.


Table 6-11: Levelized Thermal Energy Rate based on Monte Carlo Analysis

Percentiles The rmal Energy Rate

CY7f. 0.135

10% 0.146

2CY7f. 0.148

30% 0.150

40% 0.151

5CY7f. 0.152

6CY7f. 0.153

70'?10 0.154

80% 0.155

r90% 0.157

100% 0.174

The Monte Carlo results indicated that rates are competitive in ai! scenarios when compared to

other thermal energy systems recently approved by the BCUC.

27.1. Please provide the comparisons used to supp0l1 this statement. 27.2. This analysis shows an expectation for 90% of the potential variability to be

within 10% of the expected value over the 20 year time frame, is this

interpretation incorrect and if so is this reasonable?