R-3709-2009 Application No. 2 Information Request Series by the Agence de l’efficacité énergétique to Option consommateurs NO. 2 INFORMATION REQUEST SERIES BY THE AGENCE DE L’EFFICACITÉ ÉNERGÉTIQUE TO OPTION CONSOMMATEURS (EXPERT HARPER) Original : 2010-01-22 AEE-12, Document 5.1 Page 1 of 7 R-3709-2009 Application No. 2 Information Request Series by the Agence de l’efficacité énergétique to Option consommateurs 1 1. References: (i) Evidence of Mr. Harper, pages 19 and 20: (ii) AEE-9, Document 8, Appendix 1. 2 3 4 Extract: 5 In ECS’s view there is still some confusion as to precisely what the AEÉ’s proposal is for the 6 allocation of Administration costs. Unfortunately the Appendix provided in response to the Régie 7 Staff interrogatory does not set out a separate allocation of Administration costs but rather 8 shows results that have embedded Administration costs (along with the cost of Monitoring, 9 Customer Service and Legal) in the remuneration costs of the other P/As. (our underlining) 10 11 Information request: 12 1.1 Please confirm that Administration costs included in the remuneration costs of non- 13 administrative Programs and Activities presented in Exhibit AEE-9, Document 8, 14 Appendix 1, do not include the revenue requirement of the Monitoring System cost 15 centre (page 9 of 10), and the Customer Service and Legal cost centres (page 10 of 16 10). 17 18 1.2 If yes, do you maintain the underlined comment in reference (i) in its entirety? 19 20 2. References: (i) Evidence of Mr. Harper, page 20: 21 22 Extract: 23 Subject to further clarification, ECS has limited its comments to the appropriateness of using 24 FD_GLOBAL_AEE 10-11 P as the allocation factor for Administration costs. 25 (ii) AEE-4, Document 2, page 10: 26 27 28 Extract: 29 The revenue requirement for the Agency’s administrative activities is integrated in the expenses 30 anticipated for remuneration for the non-administrative P/As as a lump sum by FTE. 31 Original : 2010-01-22 AEE-12, Document 5.1 Page 3 of 7 R-3709-2009 Application No. 2 Information Request Series by the Agence de l’efficacité énergétique to Option consommateurs 1 Information request: 2 3 Taking into consideration that the Agency’s proposal with respect to the approach to 2.1 4 use to allocate the revenue requirement for its administrative activities is the one 5 described in reference (ii), please confirm that the comments relative to the use of the 6 FD_GLOBAL AEE_10-11 P factor do not concern the new approach proposed. 7 . 8 3. Reference: (i) Harper Evidence, page 20, lines 13 to 21: 9 10 Extract: 11 With respect to Contingency costs, the AÉE states that these are based on 1.2% of the 12 Agency’s overall budget. As result, a more appropriate allocation factor for this cost element 13 would be one that reflects the allocation of all of the AÉE’s program costs to energy sources. As 14 a result, the allocation factor should also include Customer Service (P/A 1055), Régie Hearings 15 (P/A 160), Monitoring System (P/A 150) and Development of the Comprehensive Plan (P/A 16 110). It is unnecessary to include either Communications Support, Legal or Administration costs 17 in the allocation base as (based on ECS’s recommendations for these three P/As), they would 18 also be pro-rated using the costs from all of the other P/As. (our underlining) 19 (ii) AEE-9, Document 6, answer to question 40.1: 20 21 22 Extract: 23 The Contingency costs could be necessary specifically to compensate for the costs derived 24 from a higher than expected participation rate in programs or for any interesting requests or 25 projects submitted in the course of the year. Moreover, the Agency notes that the Contingency 26 costs are linked exclusively with programs and activities planned within the scope of the Quota. 27 Finally, the Agency emphasizes the conservative basis of these Contingency costs that do not 28 represent more than 1.2% of the overall budget of the Quota. (our underlining) 29 30 Information request: Original : 2010-01-22 AEE-12, Document 5.1 Page 4 of 7 R-3709-2009 Application No. 2 Information Request Series by the Agence de l’efficacité énergétique to Option consommateurs 1 3.1 Please indicate if the expression « budget global de la quote-part » [Note: overall 2 budget of the Quota] signifies for you « Agency’s overall budget ». [Note: these are the 3 AEE’s quotations with the quotation marks in the original French style]. 4 5 If yes, what difference do you make between the overall budget of the Quota (“le 3.2 6 budget global de la quote-part”) and the overall budget of the Agency (“le budget 7 global de l’Agence”). 8 9 4. Reference: (i): Harper Evidence, page 21, lines 16 to 18: 10 11 Extract: 12 In future filings, the AEÉ should provide a more detailed description of each allocation factor 13 and schedules setting out precisely how they were derived, including the data used and the 14 sources of such data. 15 (ii): AEE-10, Document 1, answer to question 1.1: 16 17 18 Extract: 19 In order to provide the Agency with a certain flexibility in carrying out its design phase activities 20 by sector, it was agreed during the working group sessions on the allocation factors that the 21 budget information relative to the sectoral activities in the design phase be presented in a single 22 block. This approaches also implies the presentation of a single allocation factor for the 23 activities in the design phase of each of the sectors. 24 25 Information request: 26 4.1 Please confirm that the intervenor, represented by Ms. Brigid Rowan of ECS, 27 participated in the working group sessions during which the discussion took place on 28 the grouping of the design phase programs in a single sectoral block, to which a single 29 allocation factor would be applied. 30 Original : 2010-01-22 AEE-12, Document 5.1 Page 5 of 7 R-3709-2009 Application No. 2 Information Request Series by the Agence de l’efficacité énergétique to Option consommateurs 1 4.2 Please confirm that the representative did not oppose the presentation of the design phase activities in a single block. 2 3 4 4.3 Please confirm that your suggestion of presenting all of the data in derivation of the 5 allocation factors used to allocate the revenue requirement of the sectoral blocks of 6 design phase activities is equivalent to distinctly presenting each of the design phase 7 activities. 8 9 5. Reference: (i) Harper Evidence, page 22, lines 1 to 3 10 11 Extract: 12 The lack of clarity is partly due to the fact that the AEÉ is unwilling to provide the details 13 regarding its overall budget as opposed to just that funded by the Quota. 14 15 Information request: 16 5.1 Please indicate whether the intervenor recognizes that the Agency cannot present the budget in its entirety before it is approved by the government. 17 18 19 5.2 Does the intervenor confirm that he will have access to sufficient details once he has access to the budget when it is made public? 20 21 22 6. Reference: (i) Evidence of Mr. Harper, page 17: 23 24 Extract: 25 In ECS’s view the costs for P/A 140 should be allocated using the same factor as is used for 26 P/As 110 and 160: FD_GLOBAL QP_10-11 P (excluding P/A 140). 27 28 Information request: 29 6.1 30 Is the intervenor aware that the factor associated with cost centre 140 was discussed during the working group meetings in which one of its representatives participated? 31 Original : 2010-01-22 AEE-12, Document 5.1 Page 6 of 7 R-3709-2009 Application No. 2 Information Request Series by the Agence de l’efficacité énergétique to Option consommateurs 1 6.2 Does the intervenor maintain its recommendation even if it goes against what was 2 convened in the working group meetings with respect to the allocation factor to 3 associate with cost centre 140? 4 Original : 2010-01-22 AEE-12, Document 5.1 Page 7 of 7