Hydro- Québec Distribution R-3677-2008 Application CONTEXT, OBJECTIVES AND ORIENTATIONS OF THE DISTRIBUTOR’S RATE APPLICATION 2009-2010 Original : 2008-08-01 HQD-1, Document 1 Page 1 of 16 Hydro- Québec Distribution Original : 2008-08-01 R-3677-2008 Application HQD-1, Document 1 Page 2 of 16 Hydro- Québec Distribution R-3677-2008 Application TABLE OF CONTENTS 1. CONTEXT.........................................................................................................5 2. THE DISTRIBUTOR’S COST OF SERVICE ...................................................7 2.1 Supply Costs .............................................................................................8 2.2 The Transmission Bill ...............................................................................8 2.3 Distribution and Customer Service Costs ..............................................9 2.4 Efficiency of the Distributor ...................................................................10 2.5 Energy Efficiency Activities ...................................................................11 3. RATE STRATEGY..........................................................................................12 3.1 Level of the Increase...............................................................................12 3.2 Rate Structures........................................................................................14 3.3 Regulatory Streamlining.........................................................................15 Original : 2008-08-01 HQD-1, Document 1 Page 3 of 16 Original : 2006-07-06 HQT-12, Document 1 Page 4 of 16 Hydro- Québec Distribution R-3677-2008 Application 1. CONTEXT Hydro–Québec Distribution appears before the Régie to initiate the process that will lead to the establishment of electricity rates applicable to Quebec customers starting April 1, 2009. For the 2009 rate year, the rate increase required to allow the Distributor to recover its cost of service is 2.2%. This increase is essentially attributable to two factors: a modification to the accounting standard for the retirement of assets, which leads to additional amortizations totalling $94 million in 2009 (excluding the impact on the cost of capital), and recovering, in 2009, the portion of the variances in the weather normalization account associated with the previous temperature average, for a total of $62 million, which cannot be otherwise recovered. Combined, these two elements will allow customers to save $13 million in interest charges starting in 2009. Each element of the application reflects its surrounding context. The main elements of this application are the following: The Distributor projects a decrease of 1.6 TWh in electricity demand for 2009 compared with its 2008 rate application that is essentially attributable to the industrial sector, and which, a priori, reduces the pressure on supply costs. However, for a third consecutive year, the Distributor is faced with an important surplus of supply, totalling 6.1 TWh, related to the deliveries expected in its long-term contracts, while the projected demand that had initially justified their signing has not completely materialized. The Distributor intends to lessen the economic impact of these surpluses in 2009 by suspending the activities of the TransCanada Energy generating station in Bécancour that has been at its disposal since last year, and via agreements that make it possible to differentiate the energy associated to contracts with Hydro-Québec Production, thereby limiting the residual surpluses that the Distributor will have to manage to 0.5 TWh. Original : 2008-08-01 HQD-1, Document 1 Page 5 of 16 Hydro- Québec Distribution R-3677-2008 Application In rate decision D-2007-12, applicable to rates on April 1, 2007, the Régie ordered that the Distributor recover the balance of the deferral account for 2005 and 2006 transmission costs as quickly as possible, in particular by applying any credit balance of the pass on account to reduce the balance of the transmission costs deferral account. The anticipated variances for post-heritage supply show a credit totalling $90 million. 2008 marked the successful deployment of the last deliverable for the CIS project thereby making it possible to begin accruing efficiency gains associated with this project. In the last rate application, the Distributor had announced tightening measures totalling 30 M$ for 2008 in order to reduce the pressure resulting from the implementation of the CIS project. For 2009, the Distributor renews these measures, which are additional to the other commitments in its integrated efficiency plan. The proposed rate increase for 2009 is also part of a multiannual vision of rate stability, which takes into account the fact that Hydro-Québec will soon have to comply with international standards on financial reporting (International Financial Reporting Standards commonly referred to as IFRS). Hydro-Québec anticipates that the shift from Canadian accounting standards to the IFRS will potentially lead to considerable financial impacts in the years ahead. Therefore, based on current information, the Distributor estimates annual rate increases of 2% for period from 2009 to 2011, thereby ensuring rate stability for its customers. Original : 2008-08-01 HQD-1, Document 1 Page 6 of 16 Hydro- Québec Distribution R-3677-2008 Application 2. THE DISTRIBUTOR’S COST OF SERVICE Table 1 presents the Distributor’s cost of service for the 2009 test year. The Distributor’s cost of service totals $10,683 million, an increase of close to $141 million compared to the costs approved by the Régie for 2008. This increase is mainly attributable to the Distributor’s proposal to amortize, in 2009, all the costs pertaining to the retirement of assets, which are reflected in the line items Other Charges and Cost of Capital. Table 1 COMPONENTS OF THE REVENUE REQUIREMENT ($M) Historical 2008 2007 D-2007Base Year 024 DISTRIBUTOR’S COST OF SERVICE 10,265 10,542 10,413 PURCHASES Electricity Purchases Transmission services DISTRIBUTION AND CUSTOMER SERVICE COSTS Operation and Maintenance Costs Other Charges Cost of Capital RETURN ON THE RATE BASE Capital Structure Debt Equity Rate Debt Equity Rate Base (13 month average) 1 10,683 7,539 4,986 2,553 2,727 7,707 4,980 2,727 2,835 7,603 4,875 2,727 2,810 7,707 4,982 2,725 2,977 1,207 748 772 8.20% 1,252 801 783 7.81% 1,237 805 768 7.75% 1,262 961 753 7.65% 65% 35% 65% 35% 65% 35% 65% 35% 8.37% 7.88% 7.84% 7.74% 7.75% 7.74% 7.66% 7.63% 9,413.1 10,025.0 9,914.0 9,849.6 : Calculated on 4 months actual and 8 months projected. Original : 2008-08-01 Test Year 2009 HQD-1, Document 1 Page 7 of 16 Hydro- Québec Distribution R-3677-2008 Application 2.1 Supply Costs The 2009 supply costs total $4,982 million, which is almost equivalent to the amount approved by the Régie for 2008. Two different and opposed factors explain this result. On the one hand, supply costs have decreased by $69 million to reflect the reduction of 1.6 TWh of forecast demand for 2009 compared with the 2008 forecast included in the last rate application. Also, supply costs in 2009 benefit from a $90 million credit balance in the pass on account, largely because the growth in demand that characterised the year 2008 was slower than expected, whereas in the last rate application the pass on account also had a credit totalling $60 million. On the other hand, the adjustment for the variance between the revenue requirement for special contracts and the revenues that they generate in the current application is approximately $105 million lower than the one associated with the 2008 rate year. This adjustment is compensated by a significant increase in revenues from these contracts, spawned by an increase in the price of aluminium in particular. 2.2 The Transmission Bill In 2009, the transmission bill for native load in TransÉnergie’s rate application is $2,622 million, which is an increase of $96 million compared to the amount that was approved by the Régie for the Distributor in 2008. Moreover, the Distributor’s share of adjustments for point-to-point transmission services for 2007 and 2008 total $2 million (credit), thereby reducing the projected cost of service for transmission by an equivalent amount for 2009. Furthermore, in decision D-2007-12, the Régie asked the Distributor to recover the balance of the deferral account for 2005 and 2006 as quickly as possible and to give priority to the application of all subsequent credit balances in the pass on account to reduce the balance of the transmission costs deferral account. The balance of the latter as at December 31, 2008 will be $102 million. This amount is higher than the credit balance of the pass-on account on December 31, 2008. Original : 2008-08-01 HQD-1, Document 1 Page 8 of 16 Hydro- Québec Distribution R-3677-2008 Application Nonetheless, the distributor proposes to recover, in the current case, all retroactive transmission costs for 2005 and 2006 and to absorb the increase of the transmission bill associated with the native load forecast for 2009. In compliance with decision D-2007-12, which ordered the Distributor to include its best estimate of the cost of service for transmission, the Distributor includes the transmission costs that were included in the Transmission Provider’s own rate application. Therefore, in its cost of service, the Distributor included an estimated total for the 2009 transmission bill of $2,725 million. This projection is subject to a subsequent adjustment, as required, in compliance with the Régie’s decision for that application. 2.3 Distribution and Customer Service Costs Overall, in 2009, distribution and customer service costs will increase by $142 million, or 5%, compared with the approved amount for 2008. Had it not been for the complete amortization of the balance of net costs associated with the retirement of assets on December 31, 2008, the increase in these costs would have totalled only $47 million or 1.7%. The residual increase is primarily explained by the following reasons: The price of fuel required to meet the needs of remote communities is $33 million higher; Additional amortization costs of $19 million related to energy efficiency activities; An increase in operation and maintenance costs of 0.8% ($10 million) compared with the amount approved in 2008. It should be noted that a reduction of the capital tax and retirement charges, as well as the end of CIS stabilization activities, contribute to absorbing the additional pressure exerted on the Distributor’s operation and maintenance costs, particularly the evolution of costs related to inflation and to the increase in the Original : 2008-08-01 HQD-1, Document 1 Page 9 of 16 Hydro- Québec Distribution R-3677-2008 Application number of electricity service contracts in 2009, as well as the higher costs associated with the renewal of collective agreements for most of Hydro-Québec’s unionized units. The operation and maintenance costs also include new efficiency measures valued at $11 million. These are additional to the renewal of tightening and efficiency measures, valued at $40 million, that were announced last year. 2.4 Efficiency of the Distributor In 2009, the Distributor will continue to implement its integrated efficiency improvement plan. For a second consecutive year, the Distributor expects to reduce its operation and maintenance costs by 1% (or $11 million in 2009) through actions aimed at everyday management, thereby bringing these total gains to almost $21 million over the period 2008-2009. Structuring courses of action include efficiency gains associated with the deployment the CIS project. These efficiency gains will total almost $19 million in 2009, over an initial potential objective of $20 million. All these gains in no way jeopardize the quality of the electricity service and customer satisfaction. Moreover, Table 2 shows the evolution of the eight indicators used as reference points which provide a synthesis of the Distributor’s performance in terms of efficiency. Original : 2008-08-01 HQD-1, Document 1 Page 10 of 16 Hydro- Québec Distribution R-3677-2008 Application Table 2 Evolution of Efficiency Indicators Selected by the Distributor Years ended on 31 December Description Historical 2001 2005 D-2008024 Test Year 2008 2009 Average Annual Growth 2001-2009 2005-2009 Annual Growth 2008-2009 Distributor’s Overall Indicators 1- Total cost of Distribution and customer satisfaction ($) per contract 532 516 568 558 0.9% 1.9% -1.8% 2- Total cost of Distribution and customer satisfaction (¢) per normalized kWh 1.22 1.14 1.28 1.29 0.7% 3.2% 1.1% 3- NOC of Distribution and CS ($) per contract 4- CIM ($) per contract 264 257 284 288 1.1% 2.9% 1.2% 2,140 2,063 2,239 2,191 0.3% 1.5% -2.1% Customer Service Process Indicators 5- Total customer service cost ($) per contract 107 105 117 110 0.3% 1.3% -5.3% 6- Net Operating Cost of CS in ($) per contract 100 94 110 96 -0.5% 0.7% -12.5% Distribution Process Indicators 7- Total Cost of Distribution ($) per contract 422 406 436 442 0.6% 2.2% 1.4% 8- NOC of Distribution ($) per contract 163 162 173 188 1.8% 3.8% 8.6% The Distributor notes that the majority of efficiency indicators show an average annual increase that is similar to the inflation rate over the period 2005-2009. The encouraging results that are expected in 2009 contribute to this performance. 2.5 Energy Efficiency Activities In general terms, energy efficiency activities contribute to cutting consumers’ electricity bill by making it possible to reduce the supply that must otherwise be acquired at market prices. In December 2007, the Government of Quebec set the new target for electricity savings at 11 TWh by 2015. The new target is taken into account in the 2009 objectives of the Global Energy Efficiency Plan (PGEE). Therefore, the budget for the Distributor’s specific programs will increase by almost $51 million compared to the one authorised in 2008 and it will total over $262 million. Now the cumulated total in energy savings that Distributor expects to attain by the end of 2009 is 4.1 TWh. This will allow the Distributor to meet the new 2010 target for its programs and activities of 5.0 TWh. Original : 2008-08-01 HQD-1, Document 1 Page 11 of 16 Hydro- Québec Distribution R-3677-2008 Application The Distributor also continues its efforts to support low-income households. Therefore, in 2009 the Distributor expects to invest over $15 million for energy efficiency measures geared toward these customers, which represents 16% of the total residential budget. This is additional to the budget for low-income consumer programs offered by the Agence de l’efficacité énergétique. The Distributor also continues to pursue its action plan, presented in the last rate application, which is aimed at improving support for these customers. This plan was drawn up with a committee made up of different interest groups that are active with this customer segment. It is worth reiterating the orientations defined by this committee: Ensuring the accessibility of low-income households to electricity and services; Optimizing the electricity savings of low-income households all the while improving their comfort; and Making electricity as well as services affordable for all low-income households. In 2009, more than $5.5 million will be allocated to different actions that seek to adapt the Distributor’s commercial offer to the needs of this particular customer segment. Of this total, 80% (or $4.5 million) will be used to alleviate the financial burden of low-income households, in particular through bill payment support and the gradual elimination of debt for the most critical cases (this falls within courses of action 20 and 21 presented in application R-3644-2007). 3. RATE STRATEGY 3.1 Level of the Increase Table 3 summarizes the rate increase being requested, based on the Distributor’s cost of service. Original : 2008-08-01 HQD-1, Document 1 Page 12 of 16 Hydro- Québec Distribution R-3677-2008 Application Table 3 Evaluation of the Shortfall and the Rate Increase on April 1, 2009 ($M) Application R-3677-2008 2009 Sales Revenues (without rate increase) 10,458.8 Revenues Other than those from Electricity Sales 177.2 Amortization of Weather Normalization Account -75.3 Adjustment - 2009 Regulatory Provision -84.2 Total Revenues for Calculation of Additional Revenue Requirement 10,476.5 Revenue Requirement Purchases Electricity Purchases 4,982.4 Transmission Services 2,724.5 Distribution and Customer Service costs Operation and Maintenance Costs Other Charges Return on the Rate Base Revenue Requirement Additional Revenue Requirement at April 1st Sales Revenues before Increase, excluding Special Contracts 1,262.1 961.4 _________________753.1 10,683.5 -207.0 9,406.1 Increase Requested – April 1, 2009 2.2% 2009 Revenues from requested Increase 141.4 2009 Regulatory Provision Recovered in 2010 Original : 2008-08-01 65.6 HQD-1, Document 1 Page 13 of 16 Hydro- Québec Distribution R-3677-2008 Application The variance between revenues on the basis of current rates and the revenue requirement resulting from the cost of service is $207 million in 2009, which justifies an overall increase of 2.2% for all electricity rates. The regulatory provision for 2009 recovered in 2010, in compliance with the principle authorized by the Régie in decision D-2005-34, is $66 million. Moreover, revenues of $141 million are anticipated by this increase over the period April 1 to December 31, 2009. One singularity of the current application is the weather normalization mechanism for transmission and distribution revenues. The Distributor avails itself of this mechanism since January 1, 2006 in compliance with the terms set out in decision D-2006-34. However, given that, since the implementation of this mechanism the Distributor has revised the bases that define the average temperature, and that it has been able to measure the extent of the weather variances to which it is subject, the Distributor proposes to revise the terms of this account which will show a balance of $132 million as at December 31, 2008. Two adjustments are proposed, as described in exhibit HQD-4, document 2: The immediate recovery of $62 million which represents the portion of the levelling account that is associated with the previous average temperature, which the Distributor can never recover; The 5 year amortization of the residual balance of this account and the inclusion of future variances in the rate base. 3.2 Rate Structures In the last rate application, the Distributor received approval for a rate reform aimed at sending a better price signal while, at the same time, simplifying its commercial offer. In the current application Exhibit HQD-12, document 1 describes the terms for the implementation of this reform whose main goals are to eliminate the degressivity of energy rates for Rates G and M and to apply the Original : 2008-08-01 HQD-1, Document 1 Page 14 of 16 Hydro- Québec Distribution R-3677-2008 Application same principles to the capacity invoice of all its customers, except for Rate L customers. These terms essentially seek to amortize and smooth out the financial impacts and inconveniences associated with the proposed changes. In decision D-2008-024, the Régie asked the Distributor to complete its rate reform by including an analysis of the Rate DT structure. This analysis, presented in Exhibit HQD-12, document 1, makes it apparent that the recent evolution of fuel oil prices leads to fewer advantages for customers billed at this rate. Yet, this customer class contributes to shaving 810 MW from the system’s peak. In a context in which the Distributor has significant power requirements, it is important to consolidate the contribution of this customer class in the Distributor’s balance. The Distributor thereby proposes to apply all of the rate increase to the on-peak price and to monitor the evolution of this market in order to react promptly, as required. Finally, in line with the positions submitted to and approved by the Régie, the Distributor proposes to continue to apply differentiated rate increases to the rate components of each rate. This will make it possible to improve the price signal sent to each customer class. 3.3 Regulatory Streamlining The current rate application is the fifth submitted by the Distributor since its initial request for rate adjustments in 2004. Over the years, the Régie and intervenors have acquired a lot of knowledge on the Distributor’s strategic and operational issues. The regulatory process has also benefitted from significant efficiency gains, namely fostered by Application Guidelines that facilitate an improved preparation of regulatory applications. Generally speaking, the Distributor notes that its rate applications have reached a certain level of regulatory maturity that make the Distributor want to reflect on Original : 2008-08-01 HQD-1, Document 1 Page 15 of 16 Hydro- Québec Distribution R-3677-2008 Application the improvements that could be made to the regulatory process in order to further improve its efficiency, particularly given the context in which the regulatory schedule must now also make room for the Agence de l’efficacité énergétique whose activities will be subject to the Régie’s approval. The Distributor invites the Régie and intervenors to partake in this reflection. It is therefore proposed to set up a working group whose purpose it would be to revise the process of rate applications with streamlining of this process as a main objective. There are several possibilities to achieve this improvement. For example, we mention: Favouring the use of other processes for certain parts of the application: annual report, administrative follow-up, etc.; Streamlining text and prioritizing tables; Part of the application submitted every three or other number of years (eg: investments, PGEE); Negotiated agreement process for certain part of the application. Ideally, these possibilities, or some of them, can be included in the next rate application. Original : 2008-08-01 HQD-1, Document 1 Page 16 of 16