Decision 2011-490
EPCOR Distribution & Transmission Inc.
2010-2011 Phase II Distribution Tariff Refiling
December 14, 2011
The Alberta Utilities Commission
Decision 2011-490: EPCOR Distribution & Transmission Inc.
2010-2011 Phase II Distribution Tariff Refiling
Application No. 1607746
Proceeding ID No. 1484
December 14, 2011
Published by
The Alberta Utilities Commission
Fifth Avenue Place, Fourth Floor, 425 First Street S.W.
Calgary, Alberta
T2P 3L8
Telephone: 403-592-8845
Fax: 403-592-4406
Web site: www.auc.ab.ca
Contents
1
Introduction ........................................................................................................................... 1
2
Background ........................................................................................................................... 2
3
Issues ...................................................................................................................................... 2
3.1 EPCOR refiled 2010 and 2011 DAS rates ..................................................................... 2
3.1.1 2010 DAS rates – revenue to cost ratios ........................................................... 2
3.1.2 EPCOR 2011 SAS revenue requirement .......................................................... 3
4
Other refiling directions from Decision 2011-375 .............................................................. 7
5
Other matters ........................................................................................................................ 8
6
Order ...................................................................................................................................... 9
Appendix 1 – Proceeding participants ...................................................................................... 11
Appendix 2 – Summary of Commission directions .................................................................. 12
Appendix 3 – Summary of Commission directions from Decision 2011-375 ........................ 13
List of tables
Table 1.
Actual operating reserve (OR) costs/revenue ........................................................... 5
AUC Decision 2011-490 (December 14, 2011) • i
The Alberta Utilities Commission
Calgary, Alberta
Decision 2011-490
Application No. 1607746
Proceeding ID No. 1484
EPCOR Distribution & Transmission Inc.
2010-2011 Phase II Distribution Tariff Refiling
1
Introduction
1.
In compliance with Decision 2011-375,1 EPCOR Distribution & Transmission Inc.
(EPCOR or EDTI) , on October 7, 2011, filed an application with the Alberta Utilities
Commission (AUC or the Commission)2 requesting approval of its 2010-2011 Phase II
distribution tariff refiling (refiling).
2.
On October 11, 2011, the AUC issued a notice of application which required interested
parties to submit a statement of intent to participate (SIP) by 2 p.m. on October 25, 2011. In their
SIPs parties were required to provide an explanation for their support of or objection to the
refiling and their rationale for any requirement for further process.
3.
On October 25, 2011, the AUC received SIPs from the Office of the Utilities Consumer
Advocate (UCA), the Consumers’ Coalition of Alberta (CCA) and the University of Alberta
(U of A).
4.
The UCA submitted that it was in the process of reviewing the refiling. The CCA
submitted that it would like to have EPCOR respond to written information requests before
commenting on whether or not it supported or objected to the refiling. The U of A stated that,
while it had concerns regarding EPCOR’s analysis of the Alberta Electric System Operator’s
(AESO) distribution transmission service (DTS) operating reserve charge, it did not require
additional information from EPCOR.
5.
In consideration of the above comments from parties, the Commission determined that
the refiling should be considered by way of a written process set out in the following schedule.
Process step
Information requests to EPCOR
Deadline date
2 p.m., November 7, 2011
Information responses from EPCOR
2 p.m., November 16, 2011
Argument
2 p.m., November 23, 2011
Reply argument
2 p.m., November 30, 2011
6.
In reaching the determinations set out within this decision, the Commission has
considered all relevant materials comprising the record of this proceeding. Accordingly,
references in this decision to specific parts of the record are intended to assist the reader in
1
2
Decision 2011-375: EPCOR Distribution & Transmission Inc. 2010-2011 Phase II Distribution Tariff
Application, Application No. 1606833, Proceeding ID No. 980, September 15, 2011.
The AUC refers to the Alberta Utilities Commission as an organizational entity; Commission refers to the AUC
Commission members as a collective body or panel.
AUC Decision 2011-490 (December 14, 2011) • 1
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
understanding the Commission’s reasoning relating to a particular matter and should not be taken
as an indication that the Commission did not consider all relevant portions of the record with
respect to that matter.
2
Background
7.
EPCOR had filed its 2010-2011 Phase II distribution tariff application (original
application) with the AUC on December 6, 2010. In the original application EPCOR requested
approval of:
(a)
(b)
(c)
(d)
(e)
(f)
(g)
2010 and 2011 rates for distribution access service (DAS)
2010 and 2011 rates and riders for system access service (SAS)
fees as set out in Schedule A to the materials filed with the original application
distribution connection services (DCS) terms and conditions
DAS terms and conditions
distribution tariff (DT) policies
certain modifications to its transmission charge deferral account (TCDA)
8.
On September 15, 2011, the Commission issued Decision 2011-375 approving EPCOR’s
fees and terms and conditions for implementation in its distribution tariff on a final basis.
However, the Commission ordered that “EPCOR Distribution & Transmission Inc. submit, by
October 7, 2011, a Phase II compliance filing incorporating the relevant findings and directions
in this decision.”3
9.
EPCOR addressed directions 1, 2, 6, 7 and 8 in the refiling. EPCOR submitted that the
remainder of the directions will, as directed, be addressed in its next Phase II tariff application.
All directions from Decision 2011-375 are contained in Appendix 3.
10.
Accordingly, EPCOR requested Commission approval of the following:
(a)
(b)
(c)
3
EPCOR’s refiled 2010 and 2011 DAS rates
EPCOR’s refiled 2010 and 2011 SAS rates
EPCOR’s DAS terms and conditions, DCS terms and conditions, and distribution tariff
policies
Issues
11.
In this section, the Commission will deal with directions 6, 7 and 8.
3.1
EPCOR refiled 2010 and 2011 DAS rates
3.1.1
2010 DAS rates – revenue to cost ratios
12.
In Direction 6 of Decision 2011-375, the Commission directed EPCOR to re-design the
2010 DAS rates in its refiling so that the revenue-to-cost ratios equal 100 per cent for all
customer classes.
3
Decision 2011-375, paragraph 213.
2 • AUC Decision 2011-490 (December 14, 2011)
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
13.
EPCOR submitted that it had re-designed the 2010 DAS rates so that the revenue-to-cost
ratios were 100 per cent for all customer classes and provided the results in the DT 2010 Cost of
Service Study, Schedule “DT-6.3.1: Revenue to Cost Ratios.”4
14.
The UCA pointed out that EPCOR’s response to information request CCA-EDTI-02 (a),
indicated that revenue to cost ratios were 100.36 per cent for all classes except for “50 to
149 kVA [rate class] which has a revenue to cost ratio of 96.2%.”5 Accordingly, the UCA
submitted that the revenue to cost ratios were not 100 per cent as directed by the Commission
and EPCOR has not complied with Direction 6. However, in the interests of achieving regulatory
efficiency, the UCA did not object to the revenue-to-cost ratios for this proceeding.
Notwithstanding, the UCA recommended that the Commission direct EPCOR to ensure that the
revenue-to-costs ratios are 100 per cent in EPCOR’s upcoming 2012 Phase II application, which
will form the going-in rates for EPCOR’s performance based regulation plan.
15.
EPCOR submitted that the UCA had misinterpreted the response to the CCA’s
information request. EPCOR pointed out that “CCA-EDTI-02 (a) (and the attachment CCAEDTI-02a), to which the UCA referred, asked what the revenue-to-cost ratios in 2010 would be
if EPCOR used the original proposed rates design with the approved 2010 Revenue Requirement
of $124.66 million, i.e., the approved Revenue Requirement with the rate cap.”6 EPCOR
submitted that it had complied with this directive and removed the rate cap, thereby achieving
the 100 per cent revenue-to-cost ratios. EPCOR submitted that Schedule DT 6.3.1 of the refiled
DAS 2010 model7 confirms that EPCOR has set revenue-to-cost ratios to 100 per cent as directed
by the Commission.
Commission findings
16.
The Commission has reviewed the updated DT schedules in the refiled 2010 and 2011
DAS cost of service models and the underlying calculations.8 The Commission finds that
EPCOR has redesigned its 2010 DAS rates so that the revenue-to-cost ratios equal 100 per cent
and therefore has complied with Direction 6 of Decision 2011-375.
3.1.2
EPCOR 2011 SAS revenue requirement
17.
Directions 7 and 8 of Decision 2011-375 required EPCOR to amend its applied-for 2011
SAS revenue requirement to reflect the effects of the AESO’s new demand transmission service
(DTS) tariff, which was approved in Decision 2011-275.9
4
5
6
7
8
9
Exhibit 7, DT Schedules 2010 DAS COSS.
Exhibit 40, paragraph 6.
Exhibit 45, EDTI reply argument, paragraph 8.
Exhibit 7. DT Schedules 2010 DAS COSS.
Exhibits 7 and 8.
Decision 2011-275: Alberta Electric System Operator Compliance Filing Pursuant to Decision 2010-606 and
2011 Tariff Update, Application No. 1607003, Proceeding ID No. 1074, June 24, 2011.
AUC Decision 2011-490 (December 14, 2011) • 3
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
18.
EPCOR confirmed that it had amended its applied-for 2011 SAS revenue requirement
based on the approved 2011 AESO DTS rates. In respect of its submission EPCOR stated that it
had:
(a) updated its pool price forecast from $64.37/MWh to $64/MWh, based on the AESO’s
latest 2011 forecast,10 and
(b) reflected the Fortis charges at each EPCOR annex point.11
19.
EPCOR also submitted that it had updated its SAS operating reserve percentage to reflect
the AESO’s new operating reserve rate calculation, which became effective on July 1, 2011.
EPCOR stated that it used the latest available operating reserve charge information for initial
settlement for July and August 2011 from the AESO to calculate a two-month weighted average
percentage. EPCOR submitted that the calculation “supports an AESO operating reserve charge
to EPCOR equivalent to 7.25% (from July 1, 2011 onward).”12
20.
To support its proposal to set its SAS operating reserve rate to 7.25 per cent, EPCOR
pointed out that under the AESO’s DTS tariff, which took effect July 1, 2011, the operating
reserve charge is calculated by the AESO as follows:
4(1) The operating reserve charge equals the sum, over all hours in the settlement period,
of the amount calculated in each hour as the product of:
(a) metered energy for the Rate DTS market participant in the hour; and
(b) the total cost of operating reserves in the hour divided by the total metered
energy for all Rate DTS and Rate FTS market participants in the hour.
4(2) If the operating reserve charge is unable to be calculated for a settlement period in
accordance with subsection 4(1) above, the operating reserve charge will be estimated as
the sum, over all hours in the settlement period, of the amount calculated in each hour as
the product of:
(a) metered energy for the Rate DTS market participant in the hour; and
(b) pool price in the hour multiplied by 2.35%.13 [highlights omitted]
21.
EPCOR submitted that it had attempted to design its SAS operating reserve charge to
match the charges from the AESO to the SAS revenues it collects from EPCOR’s customers.
However, based on its analysis of actual results for the period from July 1, 2011 to October 31,
2011,14 EPCOR pointed out that using the 2.35per cent operating reserve rate would significantly
understate the actual operating reserve charges from the AESO:
… if EDTI were to use the 2.35% operating reserve rate in its SAS rate design [over the
period from July 1, 2011 to October 31, 2011], only 31% of the actual operating reserve
charges would be collected through base rates, leaving the majority (69%) of the
shortfall, totaling $13.297 million to be collected through the Transmission Charge
Deferral Account…15
10
11
12
13
14
15
Exhibit 2, paragraph 12.
Exhibit 2, paragraph 14.
Exhibit 2, paragraph 13.
Exhibit 37.02, AUC-EDTI-01(b).
Exhibit 37.03, AUC-EDTI-01 Attachment.
Exhibit 37.02, AUC-EDTI-01(b).
4 • AUC Decision 2011-490 (December 14, 2011)
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
22.
EPCOR also pointed out that the 2.35 per cent operating reserve rate is not normally used
in calculating the operating reserve charge. The 2.35 per cent is only used when the AESO is
unable to calculate the operating reserve charge “under its typical approach,”16 as set out in
section 4(1) of its DTS tariff.
23.
Moreover, as illustrated in the following table, EPCOR submitted that, over the four
months since the new AESO tariff came into effect, “the actual operating reserve charges from
the AESO [are] fairly close to the calculated SAS operating reserve”17 which was based on
EPCOR’s proposed operating reserve rate of 7.25 per cent.
Table 1.
Actual operating reserve (OR) costs/revenue
Month, 2011
A
AESO actual
OR costs
July
August
September
October
Total
3.176
6.745
5.763
3.532
19.216
B
EPCOR OR revenues calculated
using the 7.25% rate
$ millions
3.359
6.404
5.111
3.386
18.260
C=A-B
D
Variance
Actual operating reserve
(%)
6.86
7.64
8.18
7.56
(0.183)
0.341
0.652
0.145
0.956
24.
In further support of its proposal, EPCOR submitted that to set its SAS operating reserve
rate to 7.25 per cent was consistent with the AESO’s objective to “significantly reduce, and
potentially eliminate, variance between operating reserve costs and revenues that required
collection or refund through deferral accounts”18 as it would collect costs through the base rates
rather than through the TCDA. Furthermore, the proposal would allow the bulk of the operating
reserve charges to be flowed through to customers in the same month they were charged by the
AESO, instead of months later through the TCDA mechanism.
25.
EPCOR submitted that the shortfall stemming from the under-collection of operating
reserves was a significant component of EPCOR’s TCDA. For example, in its current TCDA
application,19 EPCOR submitted that the majority of the applied for $9.512 million charge was
due to reconciling the actual operating reserve costs. Furthermore, if the 7.25 per cent operating
reserve rate had been in place, the TCDA application would not have met the $2.5 million
threshold and therefore would not have been necessary.20
26.
The U of A, in its SIP stated that it had concerns regarding EPCOR’s analysis in that
EPCOR had not provided enough information to demonstrate that it should deviate from the
2.35 per cent operating reserve rate used by the AESO when the operating reserve charge is
unable to be calculated for a settlement period in accordance with Section 4(1) of the tariff.
However, upon reviewing EPCOR’s information responses to AUC-EDTI-01, the U of A
submitted that EPCOR’s analysis would at least facilitate a more efficient reconciliation of 2011
deferral account balances. However, the U of A cautioned that the scope of the analysis was not
sufficient and reasonable for prospective tariff applications and would do nothing to minimize
16
17
18
19
20
Ibid.
Ibid.
Ibid.
Application No. 1607846, Proceeding ID No. 1536, EDTI Transmission Charge Deferral Account True-up
Application.
Exhibit 37.02, AUC-EDTI-01, page 5 of 9.
AUC Decision 2011-490 (December 14, 2011) • 5
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
future deferral account balances over the long-run. The U of A therefore, recommended that the
Commission provide clarification in its decision that the response to AUC-EDTI-01 does not set
any precedent for future applications.21
27.
Responding to the U of A’s recommendation, EPCOR submitted its proposed
7.25 per cent operating reserve rate was developed out of the only data available at the time in
developing its SAS rates for this refiling. Furthermore, its response to AUC-EDTI-01,
demonstrated that EPCOR had used the best, up-to-date and appropriate data to support its
proposed 7.25 per cent operating reserve rate.”22
Commission findings
28.
With respect to the AESO tariff, which became effective July 1, 2011, the Commission
notes that the 2.35 per cent operating reserve rate is only to be used when the operating reserve
charge is unable to be calculated for a settlement period in accordance with Section 4(1) of the
tariff. The Commission acknowledges EPCOR’s efforts to design its SAS operating reserve
charge to closely match the charges from the AESO with the SAS revenues from EPCOR’s
customers. As indicated in the analysis in Table 1, over the four months since the new AESO
tariff has been in place, the actual operating reserve charges from the AESO are fairly close to
EPCOR’s calculated operating reserve revenue based on the 7.25 per cent operating reserve rate.
29.
The Commission considers the use of interim rates to be helpful in ensuring customer’s
rates for a given period reflect to the extent possible, the costs associated with that period. In this
regard, if EPCOR’s proposal were to be accepted, operating reserve charges would be flowed
through to customers in the same period as the AESO charges are incurred, instead of months
later through the TCDA mechanism. Furthermore, the Commission acknowledges EPCOR’s
submission, referred to in paragraph 25, that its current TCDA application would not have been
necessary had the 7.25 per cent operating reserve rate been in place.
30.
In respect of the U of A’s comment that the scope of the analysis is not sufficient and
reasonable for prospective tariff applications, the AESO’s new operating reserve rate calculation
became effective on July 1, 2011 and EPCOR’s analysis made use of all data available using the
new method Furthermore, EPCOR’s analysis used data from four of the remaining six months
for which the final 2011 SAS rates will be in place.
31.
Considering the above, the Commission finds EPCOR’s proposal to update its operating
reserve rate to 7.25 per cent in order to reflect the AESO’s new operating reserve rate calculation
to be reasonable and approves the proposal to set its SAS operating reserve rate to 7.25 per cent.
32.
The Commission, in Direction 7 of Decision 2011-375, directed EPCOR to update its
pool price forecast using the latest 2011 forecast in its refiling. EPCOR submitted that it had
updated its pool price forecast from $64.37/MWh to $64/MWh, based on “the AESO’s latest
2011 forecast released at a Stakeholder Review Meeting document dated September 8, 2011.”23
Notwithstanding EPCOR’s submission, the Commission is mindful that the AESO, at a
21
22
23
Exhibit 41, U of A argument.
Exhibit 45, EDTI reply argument, paragraph 6.
Exhibit 2, paragraph 12.
6 • AUC Decision 2011-490 (December 14, 2011)
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
stakeholder meeting presentation dated September 22, 2011, updated its 2011 pool price forecast
to $83.32/MWh.24
33.
The Commission notes that pool price is a component of calculated operating reserve
charges that EPCOR charges its customers through its SAS rates. The Commission accepts
EPCOR’s submission that differences between the forecast and actual operating reserve charges
are reconciled through EPCOR’s TCDA.25 EPCOR, in its latest TCDA application,26 has
requested Commission approval to true-up amounts for the period from July 2011 to September
2011. Considering the above, the Commission finds EPCOR’s updated $64/MWh 2011 forecast
pool price to be reasonable and will not require EPCOR to update its 2011 pool price forecast to
$83.32/MWh. Accordingly, the Commission approves EPCOR’s updated 2011 pool price
forecast.
34.
The Commission has also reviewed EPCOR’s refiled 2010 and 2011 distribution tariff
DAS and SAS rate schedules as well as EPCOR’s refiled DAS and SAS cost of service
schedules. The Commission accepts that EPCOR has complied with directions 7 and 8.
35.
Based on the Commission’s findings respecting EPCOR’s compliance with directions 7
and 8, the Commission approves EPCOR’s final 2010 and 2011 DAS and SAS rates as reflected
in this refiling application.
4
Other refiling directions from Decision 2011-375
36.
In this decision, the Commission has only provided comments and determinations with
respect to the Commission directions from Decision 2011-375, where parties or the Commission
had concerns or issues with the specific direction response. The Commission has reviewed all of
EPCOR’s responses to the remaining directions from Decision 2011-375 and is satisfied that
EPCOR has adequately addressed and responded to these directions.
37.
The Commission in Direction 1 of Decision 2011-375, directed EPCOR to confirm the
status of its proposal to introduce a mechanism in its next Phase II application, which would
allow a customer to elect to either increase or reduce the contracted minimum demand at a site.
Direction 2 of the same decision, directed EPCOR to reflected the approved DAS revenue
requirements for 2010 and 2011, $124.66 million and $132.34 million respectively, in its
refiling. The Commission finds that EPCOR has complied with directions 1 and 2 from
Decision 2011-375.
24
25
26
Proceeding ID No. 1497, EPCOR 2012 interim SAS tariff application, Exhibit 36.03.
Exhibit 38, UCA-EDTI-02 (c).
Proceeding ID No. 1536, EPCOR Q1 2012 TCDA true-up rider application.
AUC Decision 2011-490 (December 14, 2011) • 7
2010-2011 Phase II Distribution Tariff Refiling
5
EPCOR Distribution & Transmission Inc.
Other matters
38.
With respect to EPCOR’s request that the Commission approve EPCOR’s DAS and DCS
terms and conditions and DT policies, the Commission notes that these were approved in
Decision 2011-375. Minor revisions to the DCS terms and conditions were subsequently
approved in Decision 2011-426.27 The approved terms and conditions, and tariff policies shall
continue to be in effect until EPCOR files an application requesting that changes be made to
these documents. Therefore, it is not necessary to re-approve the terms and conditions, and DT
policies.
39.
Further, the Commission acknowledges EPCOR’s proposal to file another application
requesting approval to collect the difference between the revenue collected under EPCOR’s
interim 2010 and 2011 DAS and SAS rates and the revenue that would have been collected under
the approved final 2010 and 2011 DAS and SAS rates over the period from January 1, 2010 to
December 31, 2011. EPCOR proposed to true-up:
(a) the DAS difference over a three-month period from April 1, 2012 to June 30, 2012,
(b) the SAS differences over a six-month period from April 1, 2012 to September 30, 2012
40.
The Commission therefore, directs EPCOR that prior to submitting its application
requesting approval of a rider to true-up the difference between the revenue collected under
EPCOR’s interim 2010 and 2011 DAS and SAS rates and the revenue that would have been
collected under the approved final 2010 and 2011 DAS and SAS rates, EPCOR should ensure
that billing has been completed up to December 31, 2011.
41.
Moreover, with respect to the proposed timing to begin collections of the DAS and SAS
differences, the Commission further directs EPCOR to submit the application, including the
proposed implementation date for the true-up rider, so as to allow sufficient time for a complete
review of the proceeding as set out in AUC Bulletin 2010-16.28
27
28
Decision 2011-426: EPCOR Distribution & Transmission Inc., Revised 2011 Interim Rates for Distribution
Access Service, Application No. 1607541, Proceeding ID No. 1372, October 28, 2011.
Bulletin 2010-16, Performance Standards for Processing Rate-Related Application, April 26, 2010.
8 • AUC Decision 2011-490 (December 14, 2011)
2010-2011 Phase II Distribution Tariff Refiling
6
42.
EPCOR Distribution & Transmission Inc.
Order
It is hereby ordered that:
(1)
EPCOR’s final 2010 and 2011 DAS and SAS rates are approved as reflected in
this refiling application.
(2)
Prior to submitting its application requesting approval of a rider to true-up the
difference between the revenue collected under EPCOR’s interim 2010 and 2011
DAS and SAS rates and the revenue that would have been collected under the
approved final 2010 and 2011 DAS and SAS rates, EPCOR is directed to ensure
that billing has been completed up to December 31, 2011.
(3)
With respect to the proposed timing to begin collections of the DAS and SAS
differences, EPCOR is directed to submit the application, including the proposed
implementation date for the true-up rider, so as to allow sufficient time for a
complete review of the proceeding as set out in AUC Bulletin 2010-16.
Dated on December 14, 2011.
The Alberta Utilities Commission
(original signed by)
Carolyn Dahl Rees
Vice-Chair
(original signed by)
Kay Holgate
Commission Member
(original signed by)
Bill Lyttle
Commission Member
AUC Decision 2011-490 (December 14, 2011) • 9
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
Appendix 1 – Proceeding participants
Name of organization (abbreviation)
counsel or representative
EPCOR Distribution & Transmission Inc. (EPCOR)
D. Tenney
P. Wong
ATCO Electric Ltd. (AE)
B. Yee
Consumers’ Coalition of Alberta (CCA)
J. A. Wachowich
A. P. Merani
Office of the Utilities Consumer Advocate (UCA)
C.R. McCreary
S. Mattuli
B. Shymanski
R. Bell
University of Alberta (U of A)
M. Turner
A. Da Silva
The Alberta Utilities Commission
Commission Panel
C. Dahl Rees, Vice-Chair
K. Holgate, Commission Member
B. Lyttle, Commission Member
Commission Staff
S. Russell
B. Clarke
O. Vasetsky
J. Olsen
AUC Decision 2011-490 (December 14, 2011) • 11
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
Appendix 2 – Summary of Commission directions
This section is provided for the convenience of readers. In the event of any difference between
directions in this section and those in the main body of the decision, the wording in the main
body of the decision shall prevail.
1.
The Commission therefore, directs EPCOR that prior to submitting its application
requesting approval of a rider to true-up the difference between the revenue collected
under EPCOR’s interim 2010 and 2011 DAS and SAS rates and the revenue that would
have been collected under the approved final 2010 and 2011 DAS and SAS rates,
EPCOR should ensure that billing has been completed up to December 31, 2011.
.......................................................................................................................... Paragraph 40
2.
Moreover, with respect to the proposed timing to begin collections of the DAS and SAS
differences, the Commission further directs EPCOR to submit the application, including
the proposed implementation date for the true-up rider, so as to allow sufficient time for a
complete review of the proceeding as set out in AUC Bulletin 2010-16. ...... Paragraph 41
12 • AUC Decision 2011-490 (December 14, 2011)
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
Appendix 3 – Summary of Commission directions from Decision 2011-375
(return to text)
1.
In addition to these seven outstanding items, at paragraph 70 of Decision 2009-103 it was
noted that EPCOR had agreed to propose a mechanism, in its next Phase II distribution
tariff application, by which a customer may elect to either increase or reduce the
contracted minimum demand at a site. As this matter was not explicitly addressed in the
application, the Commission directs that EPCOR confirm the status of this proposal in its
compliance filing. ........................................................................................... Paragraph 20
2.
Accordingly, the Commission directs EPCOR to reflect the approved forecast DAS
revenue requirement for 2010 and 2011 of $124.66 million and $132.34 million,
respectively, as approved by the Commission in Decision 2011-315, in its Phase II
compliance filing. ........................................................................................... Paragraph 36
3.
The Commission acknowledges the UCA’s submission that there may be added
complexity designed into EPCOR’s STARS system to accommodate the needs of both
interval and cumulative metered customers. EPCOR is directed to conduct an analysis to
determine: (a) if there was a higher level of complexity designed into the STARS system
to accommodate the needs of both interval and cumulative metered customers, and (b) if
that increased level of complexity has caused any increased costs for smaller customers,
and to submit that analysis in its next Phase II application. EPCOR is also directed in its
next Phase II application to provide a calculation of the billing costs per site for
residential and small commercial customers. ................................................. Paragraph 57
4.
Accordingly, the Commission directs EPCOR to conduct minimum system and/or zero
intercept studies for the poles, towers and fixtures and transformer asset types within its
secondary distribution system and submit those studies in its next Phase II distribution
tariff application. The Commission also directs EPCOR to provide an assessment of the
pros and cons of utilizing the results of those studies in classifying costs for these asset
types to customer and demand related classification categories in its distribution cost of
service study as compared to EPCOR’s current approach. ............................. Paragraph 83
5.
The Commission considers that EPCOR’s proposed allocator is an improvement over the
previous return based allocator and therefore approves the proposed general O&M
allocator as filed. However, the Commission directs EPCOR to conduct a review of the
allocation of its general O&M costs and the common overhead allocator and submit this
review, along with the justification for the chosen method of allocating general O&M
costs, as part of EPCOR’s next Phase II application. In particular, EPCOR is directed to
address the concerns expressed by the UCA regarding current capital expenditures
impacting the allocation of general O&M to rate class in its review. ........... Paragraph 100
6.
Accordingly, the Commission directs EPCOR to re-design the 2010 DAS rates in its
refiling so that the revenue to cost ratios equal unity for all customer classes.
........................................................................................................................ Paragraph 148
7.
EPCOR stated that it would amend its applied for SAS rates once the Commission
approved the AESO’s 2011 DTS rates. The Commission approved the AESO’s 2011
DTS rates in Decision 2011-275. Accordingly, the Commission directs EPCOR
to amend its applied for SAS revenue requirement based on the approved 2011
AESO DTS rate in its compliance filing. The Commission also directs EPCOR
AUC Decision 2011-490 (December 14, 2011) • 13
2010-2011 Phase II Distribution Tariff Refiling
EPCOR Distribution & Transmission Inc.
to update its pool price forecast based on the latest 2011 forecast in its
compliance filing. Finally the Commission directs EPCOR to reflect the Fortis
charges at each EPCOR annex point, as provided in the response to AUC-EDTI21(a), in its compliance filing.
........................................................................................................................ Paragraph 159
8.
As discussed in Section 7.1 of this decision, the AESO’s compliance filing was dealt with
in Decision 2011-275 issued on June 24, 2011, which was after the close of record in this
proceeding. Therefore, the Commission directs EPCOR to file revised 2011 SAS rates
reflecting the approved AESO rates with its compliance filing. .................. Paragraph 197
14 • AUC Decision 2011-490 (December 14, 2011)