Hydro- Québec Distribution R-3677-2008 Application RATE CONTEXT AND STRATEGY (Chapter 1 and Excerpts of Chapters 2 and 3) Original : 2007-08-01 HQD-12, Document 1 Page 1 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE OF CONTENTS 1. CONTEXT OF THE APPLICATION .................................................................4 1.1 Follow-up of Decision D-2008-024 ..............................................................4 1.1.1 Customer Charge for Domestic Rates...............................................4 1.1.2 Analysis of the DT Rate Structure .....................................................5 1.1.3 Analysis of Customer Segmentation for Rates G, M and L ...............5 1.1.4 The “Heure Juste” Ratemaking Project .............................................6 1.1.5 Electricity Rates Applicable to the Schefferville System....................6 1.1.6 Differentiated Rate Increases............................................................7 2. RATE INCREASE AND CROSS-SUBSIDIZATION FOR 2008-2009...............8 2.1 Variances between Revenue Requirements and Projected Revenues for 2009 ..................................................................................................................8 2.2 Proposed Rate Increase and Impact on Cross-Subsidization .....................8 2.3 Domestic Rates .........................................................................................13 2.3.1 Rates and Customer Description ........................................................13 2.3.1.1 Rate D ..........................................................................................13 2.3.1.2 Rate DM .......................................................................................17 2.3.1.3 Rate DT........................................................................................20 2.3.1.4 Rate DH .......................................................................................22 2.3.1.5 Rates DA and DB .........................................................................23 2.3.2 Analyses Requested in Decision D-2008-024.....................................27 2.3.2.1 Rate D Customer Charge.............................................................27 2.3.2.1.1 Decision D-2008-024.................................................................27 2.3.2.1.2 Principles and Orientations .......................................................28 2.3.2.1.3 Contract Costs ..........................................................................29 2.3.2.1.4 Benchmarking ...........................................................................32 2.3.2.1.5 Scenarios Analyzed...................................................................34 2.3.2.1.6 Distributor’s Proposal ................................................................39 2.3.2.2 Analysis of the DT Rate Structure ................................................39 2.3.2.2.1 Profitability of the Structure of Rate DT from the Perspective of Society and of the Distributor ...................................................................39 2.3.2.2.2 Profitability of the Structure of Rate DT from Customers’ Perspective ..............................................................................................41 2.3.2.2.3 Proposed Rate Strategy on April 1, 2009 ..................................43 2.3.3 Proposed Adjustments to the Rate Structure and Implementation of the Reform.........................................................................................................47 2.3.3.1 Customer Charge .........................................................................48 2.3.3.2 Energy Rate Adjustment ..............................................................48 2.3.3.2.1 Benchmarking of Rates with Two Progressive Blocks in Canada .................................................................................................................49 2.3.3.3 Capacity Invoice ...........................................................................52 2.3.3.4 Evolution of Domestic Rates in the Short and Medium Terms .....55 2.3.3.5 Implementation of the Domestic Rate Reform..............................56 Original : 2007-08-01 HQD-12, Document 1 Page 2 of 67 Hydro- Québec Distribution R-3677-2008 Application 2.4 General Rates ...........................................................................................57 2.4.1 Rates and Customer Description ........................................................57 2.4.1.1 Rate L...........................................................................................57 3. IMPACTS OF THE RATE INCREASE ..........................................................59 3.1 Projected Revenues by Rate class and Component .................................59 3.2 Customer Bills ...........................................................................................60 3.2.1 Domestic Rates ..................................................................................60 3.2.1.1 Distribution of Rate Impacts .........................................................60 3.2.1.2 Impact on Monthly Bills ................................................................60 3.2.1.3 Impact on the Average Customer.................................................61 3.2.1.4 Impact on Typical Home Types ....................................................62 3.2.1.5 Impact on Low-Income Customers...............................................62 3.2.2 General Rates.....................................................................................66 3.2.2.1 Distribution of Impacts..................................................................66 Original : 2007-08-01 HQD-12, Document 1 Page 3 of 67 1. CONTEXT OF THE APPLICATION Hydro-Quebec Distribution’s current rates are described in the document entitled Distributor’s Rates and Conditions (hereafter, Rate Handbook) effective April 1, 2008, as approved on March 12, 20081 by the Régie in its decision D-2008-33, following decision D-2008-0242, as well as in its decision D-2008-0443. The current application pertains to rates for 2008-2009, as well as the resulting modifications to the Rate Handbook. 1.1 Follow-up of Decision D-2008-024 1.1.1 Customer Charge for Domestic Rates The customer charge covers the fixed costs incurred (customer service charges, metering charges, billing, etc.) to serve each customer. This amount is therefore independent from energy consumption. In its R-3644-2007 application, the Distributor proposes to renew the freeze of the customer charge, effective since April 1, 2005. HQD specifies that customers should pay for costs incurred to serve them, regardless of energy consumption. Two intervenors oppose this proposal: they believe that the customer charge is too high and that it should accurately reflect cost causality. It its decision D-2008-024, the Régie asks the Distributor to analyze the composition and the level of customer charge in the context of the current rate application. This analysis is found in Section 2.3.2.1. This analysis has previously been the subject of a working group meeting with intervenors and Régie technical staff that took place on June 25, 2008. 1 Decision on the approval of the Distributor’s rate grid applicable as of April 1, 2007. Application to set electricity rates for the year 2008-2009. 3 Decision approving the modifications to the Distributor’s Rates and Conditions pursuant to decisions D2008-028 and D-2008-042. 2 Original : 2006-07-06 HQT-12, Document 1 Page 4 of 67 Hydro- Québec Distribution R-3677-2008 Application . 1.1.2 Analysis of the DT Rate Structure The rate reform proposed by the Distributor in its R-3644-2007 application did not specifically broach the DT rate. In its decision, the Régie asks the Distributor to provide, in the current rate filing, an analysis of the DT rate structure, taking into account the current Quebec energy context as it relates to post-heritage supply costs. This analysis is presented in Section 2.3.2.2. 1.1.3 Analysis of Customer Segmentation for Rates G, M and L Given the reform of the general rates proposed by the Distributor in the R-36442007 application, the Régie notes that eventually, the biggest Rate G consumers should naturally migrate to Rate M, which would encompass customers with cost characteristics more similar to theirs than to those of the small Rate G customers. However, the number of Rate M customers will double, going from 12,600 to approximately 26,300 and will eventually consist of small customers (50 kW) and very big customers (over 4,000 kW). The Régie is concerned that given this new rate structure, customers with the same load factor (LF) will be billed at the same unit cost, independently of their annual energy consumption. In its decision D-2008-024, the Régie asks the Distributor to present, in the current rate filing, an analysis of the customer segmentation for the G, M and L general rates. This analysis should establish the link between the consumption characteristics of these customers, particularly the LF and the annual consumption volume, as well as the customers’ cost characteristics, particularly cost driver factors for capacity, energy, and the customer charge. Original : 2007-08-01 HQD-12, Document 1 Page 5 of 67 Hydro- Québec Distribution R-3677-2008 Application 1.1.4 The “Heure Juste” Ratemaking Project In its R-3644-2007 rate application, the Distributor proposed a time-of-use rate (TOU) pilot project to the Régie. In its decision D-2008-024, the Régie authorized the Distributor to complete the TOU project, as presented. The Régie, however, requests that the Distributor use the alternative version of the DB Rate, filed in response to a Régie question. The Régie also requests that a sample of Rate D customers be able to see in real-time, through the use of a display [translator’s note: presumably on the meter], the impacts of their consumption choices on their electricity bill. The follow-up of the pilot project, whose commercial name is heretofore, the “Heure Juste” (“Right Time”) ratemaking project, is found in Section 6. 1.1.5 Electricity Rates Applicable to the Schefferville System The decision D-2006-123 authorizes the Distributor to take on the customers of the Schefferville remote community, situated north of the 53rd parallel. In order to ensure that the Schefferville electricity rates, which are significantly lower than those of customers on the Distributor’s main grid, are harmonized with the main grid without creating a rate shock, the Distributor proposes to introduce, as of April 1, 2008, a transitional rate, over a period of five years, by applying a tapering rebate on the rates effective south of the 53rd parallel. The Distributor also proposes to modify the Rate Handbook to avoid the application of dissuasive rates, effective north of the 53rd parallel, to Schefferville system customers. The Distributor proposes to apply the rates and service conditions applicable south of the 53rd parallel be also applicable to the Schefferville system. Original : 2007-08-01 HQD-12, Document 1 Page 6 of 67 Hydro- Québec Distribution R-3677-2008 Application In its decision D-2008-024, the Régie accepts the Distributor’s proposal with respect to the introduction of a transition rate for customers in the remote community of Schefferville. However, the Régie does not indicate what type of rate to apply to this system. The Régie asks the Distributor to file, in the current rate case, a cost study for the Schefferville system in order to examine the opportunity of introducing a specific rate scheme for the customers of this system. This study is presented in Section 7. 1.1.6 Differentiated Rate Increases In its decision D-2007-12, the Régie indicates to the Distributor that as of the 2008 rate application, the Distributor could propose rate adjustments differentiated by customer class, in which each adjustment reflects the evolution of the costs attributed to the corresponding customer class. In setting the Distributor’s rates, the Régie will judge the just and reasonable nature of the requested rate increases, by taking into account the set of Sections of the Act, which apply in this case, including the Section pertaining to crosssubsidization of domestic customers. On December 19, 2007, as permitted in Article 10 of the 1st Paragraph of Section 49 of the Act, the government adopted Decree 1164-2007 to indicate its socio-economic concerns to the Régie: THAT the following economic, social and environmental concern, be indicated to the Régie de l’énergie, in order to foster a balanced evolution of the electricity rates among customer classes: THAT during the setting of the electricity rates, the rate adjustments among the customer classes should be allocated in such a way as to ensure stability in the evolution of the rates among customer classes.4 4 Decree 1164-2007 Concerning the economic, social and environmental concerns indicated to the Régie de l’énergie, in order to foster a balanced evolution of the electricity rates among customer classes, (2008) 140 G. O. II, 347. Original : 2007-08-01 HQD-12, Document 1 Page 7 of 67 Hydro- Québec Distribution R-3677-2008 Application (Unofficial translation of the Decree; translator’s version) In its decision D-2008-024, the Régie asks the Distributor to apply a uniform increase to all of the rates. Moreover, it asks the Distributor to file, in the next rate case, different scenarios of differentiated increases. These scenarios are found in Section 2.2. 2. RATE INCREASE AND CROSS-SUBSIDIZATION FOR 2008-2009 2.1 Variances between Revenue Requirements and Projected Revenues for 2009 Taking into account the current rates and the 2009 revenue requirement, the Distributor is projecting a shortfall of $207 million. 2.2 Proposed Rate Increase and Impact on Cross-Subsidization The Distributor asks the Régie to approve an overall rate increase of 2.2% starting April 1, 2009, in accordance with the rates proposed in HQD-12, Document 2 of this evidence. This increase will allow for $141 million in additional revenue between April 1 and December 31, 2009 as well as a regulatory provision of $66 million (see HQD-1, Document 1). Original : 2007-08-01 HQD-12, Document 1 Page 8 of 67 Hydro- Québec Distribution R-3677-2008 Application Figure 1 Evolution of Electricity Rates and of the Consumer Price Index Figure 1 shows the evolution, between 1998 and 2009, of the Consumer Price Index and the Distributor’s rates including the proposed increase. The projected annual inflation rate for 2008 and 2009 is 2.0%, which means that with the requested 2.2% increase, customers will be subject to an actual increase of 0.2%, on average. In return, over the period, customers will continue to benefit from an actual gain because the Consumer Price Index will have increased by 27.2%, while the Distributor’s rates will have increased by 19.3%. As described in Section 4 of the current document, Quebecers continue to benefit from the stability of electricity prices, while the prices of heating oil and natural gas have been subject to significant increases and great volatility. Thus, between May 1, 1998 and April 1, 2008, the energy for an average oil-heated Original : 2007-08-01 HQD-12, Document 1 Page 9 of 67 Hydro- Québec Distribution R-3677-2008 Application home increased by 246%, whereas the energy bill for a home heated by natural gas increased by 76%. The Distributor also proposes a uniform rate increase by customer class. Given this uniform rate increase, the cross-subsidization indices for 2008 remain relatively stable before and after the rate increase, as the following table demonstrates. TABLE 1 IMPACT OF A UNIFORM INCREASE ON THE CROSS SUBSIDIZATION INDEX Revenue Requirement 2009 ($M) 2009 Projected Revenues Before Increase ($M) CrossSubsidization Index Before Increase (%) Projected Revenues After Increase of Jan. 1, 2009 CrossSubsidization Index Following Increase (%) ($M) Domestic 5,312 4,317 81.9 4,412 81.9 Small Power 1,110 1,362 123.7 1,392 123.7 Medium Power 1,466 1,905 131.0 1,947 131.0 Large Power 1,592 1,820 115.3 1,860 115.3 Total – Regular Rates 9,480 9,405 100.0 9,612 100.0 1,053 1,053 N.A 1,053 N.A 49 1 N.A 1 N.A. 10,582 10,459 N.A 10,666 N.A Special Contracts Consumption Management and Back-Up Energy Source Rates Total Note: Results may not tally due to rounded data. In its decision D-2007-12, the Régie revisited the principle of maintaining the cross-subsidization as written in its Act. Original : 2007-08-01 HQD-12, Document 1 Page 10 of 67 Hydro- Québec Distribution R-3677-2008 Application As of the 2008 rate application, the Distributor could propose rate adjustments differentiated by customer class, in which each adjustment reflects the evolution of the costs attributed to the corresponding customer class.5 (Unofficial translation of the decision; translator’s version) While sharing the concerns articulated by the Régie in its decision, that is the reflection of true costs, as well as equity among customer classes, the application of differentiated rate adjustments remains a question of public interest that is best left to the Régie to arbitrate. The Distributor, however, submits in Table 2 potential differentiated rate increases by customer class that could reflect the variation in their cost of service6; the impact on the crosssubsidization levels is also shown. TABLE 2 IMPACT ON CROSS-SUBSIDIZATION OF A DIFFERENTIATED RATE INCREASE (VARIATION IN THE COST OF SERVICE) Cross-Subsidization 2009 2009 Rate increase Before increase After increase (%) (%) (%) Domestic Small Power Medium Power Large Power 3.6 2.6 0.2 0.7 81.9 123.7 131.0 115.3 83.0 124.2 128.4 113.6 Total 2.2 100.0 100.0 An examination of Table 2 reveals that the increases in the domestic and small power classes are much more important than those of medium and large power classes. 5 6 D-2007-12, page 94. See Appendix A for details regarding the calculations. Original : 2007-08-01 HQD-12, Document 1 Page 11 of 67 Hydro- Québec Distribution R-3677-2008 Application In its last decision, the Régie asked the Distributor to file in its next rate application different scenarios of differentiated increases. First off, the Distributor specifies that there is no recognized rule or principle in the field. Thus, the scenarios provided by the Distributor rely on a criterion of maximum deviation between the increase for each customer class and the average increase requested for all customers. For example, if the average increase was 5% and the maximum deviation set with respect to this average increase was 20%, the maximum increase that could be applied to a customer class would be 6%7; if the maximum deviation was 30%, the maximum increase would be 6.5%. The application of a criterion of maximum deviation assumes that in each rate case, the weight given to the “Cost increase” in the calculation of differentiated increases could be reduced while increasing the weight of the “Adjustments”, which are proportional to the revenues forecast before the increase for each customer class8. This also implies that when a customer class is subject to an increase which is lower than the increase based on the variation in the cost of service, then the other classes will be subject to increases that are higher than those that they would have undergone in a scenario based on the variation of this same cost. In return, from year to year, notwithstanding the increase in the revenue requirement specific to each customer class, the customers from a given class will be protected from a rate increase that is disproportionately high relative to the rest of the customers. This ensures stability in the evolution of rates among customer classes. In so doing, the criterion of maximum deviation could fulfill the government’s Decree 1164-2007. The following table presents scenarios of maximum deviation of 20, 30 and 40% for 2009, as well as their impacts on the cross-subsidization index. 7 That is, 5% + (20% * 5%). If the increase based on the variation of the cost of service is less than 6%, for example, 5.5%, the latter increase would prevail. 8 According to these scenarios, there would be a transfer of costs from Column e to Column g of Appendix A. Original : 2007-08-01 HQD-12, Document 1 Page 12 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 3 IMPACT ON CROSS-SUBSIDIZATION OF A DIFFERENTIATED RATE INCREASE (CRITERIA OF MAXIMUM DEVIATION) Key Column 1: Domestic Small Power Medium Power Large Power Total – Regular Rates Row 1: 20% Scenario; 30% Scenario; 40% Scenario Row 2: Cross-subsidization before the increase; Rate increase; Crosssubsidization after the increase; Rate increase; Cross-subsidization after the increase; Rate increase; Cross-subsidization after the increase. 2.3 Domestic Rates 2.3.1 Rates and Customer Description 2.3.1.1 Rate D Rate D is a rate that applies to a contract, for which the use of electricity is domestic, that is, exclusively for domestic purposes in a dwelling, apart from the exceptions described in the Rate Handbook. Electricity delivered to farms for the purposes of growing crop and animal farming is also subject to Rate D. Original : 2007-08-01 HQD-12, Document 1 Page 13 of 67 Hydro- Québec Distribution R-3677-2008 Application Rate D applies to dwellings for which electricity is metered separately. Therefore, for buildings with multiple housing units, Rate D is applied when the consumption for each housing unit is individually metered. This rate also applies since the termination of Rate DM on April 1, 2008, to apartment buildings or community residences with dwellings with bulk metering, for which construction began on or after April 1, 2008. The structure of Rate D, described in Table 4, consists of a customer charge (40.64¢/day) and two increasing prices for the energy consumed, that is, a lower price for the first 30 kWh per day (5.40¢/kWh), while consumption exceeding that volume is billed at a higher price (7.33¢/kWh). During the winter period, when the maximum power demand exceeds 50 kW, the excess portion is billed at the monthly price of $6.21/kW. TABLE 4 D Rate on April 1, 2008 Customer charge 40.64¢/day The first 30 kWh/day 5.40¢/kWh Remaining consumption 7.33¢/kWh Winter demand charge (exceeding 50 kW) $6.21/kW As shown in Table 5, a total of 2,974,730 Rate D contracts were included in the analysis covering the period between May 1, 2007 and April 30, 2008. The consumption and revenues associated with these contracts amount to 51.0 TWh and $3.7 billion, based on rates effective April 1, 2008. Among all contracts combined, only 2,562 were billed for a winter demand charge. Over two thirds of residential customers had an all-electric heating (AEH) system; the other third used a different heating system (non-AEH),9 such as natural gas, heating oil, wood or mixed. Over 42,800 contracts corresponded to farms whose activities of animal raising and growing crops made them admissible to Rate D. TABLE 5 9 Residential customers at the DT dual-energy Rate are discussed in Section 2.3.1.3. Original : 2007-08-01 HQD-12, Document 1 Page 14 of 67 Hydro- Québec Distribution R-3677-2008 Application Description of D Rate Customers Contracts Annual Consumption GWh Total Revenues M$ Residential customers All electric heating (AEH) Without capacity invoice With capacity invoice 2,108,968 2,107,786 1,182 39,593 39,227 366 2,839 2,810 28 Other types of heating Without capacity invoice With capacity invoice 822,936 822,589 347 9,755 9,639 115 724 715 9 Total residential customers 2,931,904 46,237 3,563 41,793 1,033 1,354 261 99 20 42,826 1,615 118 2,972,168 2,562 50,220 743 3,624 57 2,974,730 50,963 3,681 Farms Without capacity invoice With capacity invoice Total for farms All domestic customers Without capacity invoice With capacity invoice Total domestic customers at the D Rate Table 6 shows the revenue generated by rate component, derived from the reference data for Rate D. Original : 2007-08-01 HQD-12, Document 1 Page 15 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 6 Rate D: Revenue by Rate Component 2007-2008 Rates in effect April 1, 2008 Price $M Rate Components Customer charge (¢/day) 40.64 443 Energy 1st block (¢/kWh) 2nd block (¢/kWh) 5.40 7.33 1,401 1,834 Demand charge ($/kW) 6.21 3 Total 3 355 Table 7 shows the monthly bills of Rate D customers for the period between May 1, 2007 and April 30, 2008. Over that period, the average annual consumption for Rate D was 17,056 kWh and the average monthly bill was $103. For a consumption of 26,484 kWh per year, the average single-family home with an electric heating system had a monthly bill of $157. TABLE 7 Average Monthly Bills for Rate D Customers Rate on April 1, 2008 Average Annual Consumption (kWh) Average Monthly Bill ($) All Rate D customers All electric heating Not heated with electricity 17,056 18,953 12,576 103 113 78 Average single-family home heated with electricity (158 m2) 26,484 157 Original : 2007-08-01 HQD-12, Document 1 Page 16 of 67 Hydro- Québec Distribution R-3677-2008 Application 2.3.1.2 Rate DM Rate DM is a rate that is similar to Rate D but adapted to bulk metering (see Table 8). It is reserved to contracts that are subject to Rate DM on March 31, 2008, as well as to an apartment building or community residence with dwellings with bulk metering, for which construction began prior to April 1, 2008. The singularity of Rate DM resides in the multiplier applied to the number of dwellings, in the calculation of the customer charge, and in the level of the first block. The multiplier corresponds to the following: for an apartment building and community residence with dwellings: to the number of dwellings; for a community residence with both dwellings and rooms: to the number of dwellings in the community residence, plus o 1 for the first 9 rooms or less, plus o 1 for each additional room. The prices for the first and second blocks are 5.40¢/kWh and 7.33¢/kWh respectively. During the winter period, when the maximum power demand exceeds 50 kW, the excess is billed at the monthly price of $1.53/kW. TABLE 8 DM Rate on April 1, 2008 Customer charge 40.64¢/day X multiplier The first 30 kWh/day X multiplier 5.40¢/kWh Remaining consumption 7.33¢/kWh Winter demand charge (exceeding 50 kW) $1.53/kW Original : 2007-08-01 HQD-12, Document 1 Page 17 of 67 Hydro- Québec Distribution R-3677-2008 Application As shown in Table 9, a total of 20,351 Rate DM contracts were included in the analysis covering the period between May 1, 2007 and April 30, 2008. The consumption and revenues associated with these contracts amount to 2.3 TWh and $165 million, based on rates effective April 1, 2008. Among all contracts combined, only 3,080 were billed for a winter demand charge. Almost three quarters of residential customers at Rate DM had an all-electric heating (AEH) system; the other quarter used a different heating system (nonAEH), such as natural gas, heating oil, wood or mixed. TABLE 9 Description of Rate DM Domestic Customers (2007-2008) Contracts Annual Consumption GWh Total Revenues M$ Residential customers All electric heating (AEH) Without capacity invoice With capacity invoice 14,698 12,033 2,665 1,864 464 1,400 135 33 101 Other types of heating Without capacity invoice With capacity invoice 5,307 4,943 364 377 137 241 28 10 17 Total residential customers 20,005 2,242 163 295 51 21 15 1 1 346 36 3 17,271 3,080 622 1,656 45 120 20,351 2,278 165 Farms Without capacity invoice With capacity invoice Total for farms All domestic customers Without capacity invoice With capacity invoice Total domestic customers at Rate D Original : 2007-08-01 HQD-12, Document 1 Page 18 of 67 Hydro- Québec Distribution R-3677-2008 Application Table 10 shows the revenue generated by rate component, derived from the reference data for Rate DM. TABLE 10 Rate DM : Revenue by Rate Component 2007-2008 Rates in effect April 1, 2008 Price $M Rate Components Customer charge (¢/day) 40.64 28 Energy 1st block (¢/kWh) 2nd block (¢/kWh) 5.40 7.33 89 46 Demand charge ($/kW) 1.53 2 Total 165 Table 11 shows the monthly bills of Rate DM customers for the period between May 1, 2007 and April 30, 2008. Over that period, the average annual consumption for Rate DM was 111,920 kWh and the average monthly bill was $676. For a consumption of 124,160 kWh per year, the average single-family home with an electric heating system had a monthly bill of $730. TABLE 11 Average Monthly Bills for Rate DM Customers Rate on April 1, 2008 Average Annual Consumption (kWh) Average Monthly Bill ($) All Rate DM customers All electric heating Not heated with electricity 111,920 126,456 72,463 676 762 445 Average single-family home heated with electricity (158 m2) 124,160 730 Original : 2007-08-01 HQD-12, Document 1 Page 19 of 67 Hydro- Québec Distribution R-3677-2008 Application 2.3.1.3 Rate DT Rate DT is an optional rate that applies to all electricity consumption for any customer eligible for Rates D or DM, who uses a dual energy system, mainly for domestic purposes. A dual energy system is a system that is used for spaceheating or for space-heating and water heating, which has been designed such that electricity can be used as the main energy source with a fuel source as an auxiliary source. To be eligible for Rate DT, the dual energy system’s capability in both fuel mode and electricity mode must be sufficient to provide all the heating necessary for the designated space. Moreover, the heating energy sources should not be used simultaneously. The dual energy system should also be equipped with a switch, linked to a thermal sensor, which enables the rateswitching function on the meter and also provides for the automatic transfer from one source of energy to the other10. The goal of Rate DT is to reduce the heating costs at the peak period, as well as to shift consumption from the peak to the off-peak period. In contrast to the CII dual energy rate which was abrogated in 2006, the residential dual energy rate was never conceived as an option to encourage dumping of surplus energy. Rather, this option allows the Distributor to offer an alternative to acquisition of an all-electric heating system to customers using fuel as a heating source. The Distributor thus ensures that the heating load of the new DT Rate customers will not be present at the peak. In addition to the customer charge of 40.64¢/day, Rate DT is composed of two energy rates that vary according to exterior temperature: 4.33¢/kWh when the exterior temperature is equal to or above -12°C or -15°C, depending on the climatic zone, and 17.55¢/kWh when the temperature is below -12°C or -15°C (see Table 12 for the price structure and Table 13 for the zones, in which the 10 The customers can also use a manual switch to manage the transfer themselves from one source of energy to the other. Original : 2007-08-01 HQD-12, Document 1 Page 20 of 67 Hydro- Québec Distribution R-3677-2008 Application transfer temperature is -15°C). During the winter period, when maximum power demand exceeds 50 kW, the excess is billed at the monthly rate of $1.53/kW when bulk metering11 is applicable and $6.21/ kW in all other cases. TABLE 12 Rate DT on April 1, 2008 Customer charge Off-peak energy price Peak energy price Winter demand charge (exceeding 50 kW) Building with bulk metering All other cases 40.64¢/day 4.33¢/kWh 17.55¢/kWh $1.53/kW $6.21/kW TABLE 13 Zones in which the Rate DT Transfer Temperature is -15°C Noroît (Rouyn-Noranda, Val-d'Or, LG-2/Nemiscau) North of the de Lanaudière Region High-Laurentians Haute-Mauricie From St-Féréol-des-Neiges to the Saguenay River Saguenay Côte-Nord Îles-de-la-Madeleine Lower St-Laurent and Gaspésie1 Note 1) Except municipalities bordering (direct access) the River or the Baie des Chaleurs, between St-Fabien and Cascapédia River. Rate DT includes approximately 121,000 contracts, that is, approximately 4% of the residential market. Of these some 121,000 contracts, 103,284 were selected for the period between May 1, 2007 and April 30, 2008. These contracts generated sales of 2.4 TWh and revenues of $133 million. Rate DT also allowed the Distributor to shave 810 MW from the system’s peak. 11 Because the DM Rate is closed to new contracts since April 1, 2008, only dual energy customers considered eligible to the DM Rate are billed according to the payment methods associated with bulk metering. Original : 2007-08-01 HQD-12, Document 1 Page 21 of 67 Hydro- Québec Distribution R-3677-2008 Application The number of Rate DT customers has been relatively stable since the end of the subsidization programs in the 1990s. In fact, Distributor notes a slight net annual increase of approximately 500 contracts for Rate DT. In comparison, conversions to all-electric systems have risen to an average of 10,000 per year. These conversions are mainly comprised of customers who need to replace their heating systems. The high prices of heating oil could however encourage owners to change their heating systems earlier than planned. TABLE 14 Rate DT: Revenue by Rate Component 2007-2008 Rate Components Rates in effect April 1, 2008 Price $M Customer charge (¢/day) 40.64 16 Energy Off-peak (¢/kWh) Peak (¢/kWh) 4.33 17.55 101 16 Energy Off-peak (¢/kWh) Peak (¢/kWh) 6.21 1.53 0.4 0.0 Total 133 2.3.1.4 Rate DH The Rate DH is an experimental rate that is differentiated in time and which applies only to contracts eligible for Rate D. At the beginning of the 1990s, some intervenors expressed the desire for HydroQuébec to offer a time-of-use (TOU) rate to allow customers to reduce their energy bill by modifying their consumption habits at the opportune time. In return, this rate would allow Hydro- Québec to avoid costs in the peak period and to transfer the greater part of these savings to customers. Original : 2007-08-01 HQD-12, Document 1 Page 22 of 67 Hydro- Québec Distribution R-3677-2008 Application With this orientation, Hydro-Québec undertook a TOU pilot project in 1993, Rate DH. As indicated in Table 15, besides the customer charge of 40.64¢/day, Rate DH comprises two prices for energy consumed and these prices vary according to the period of consumption. The price for energy consumed off-peak is 4.38¢/kWh and the on-peak energy price is 14.64¢/kWh (in the winter period between 6 am and 11 am and between 3 pm and 10 pm, from Monday to Friday inclusively). TABLE 15 Rate DH on April 1, 2008 Customer charge Off-peak energy price Peak energy price 40.64¢/day 4.38¢/kWh 14.64¢/kWh Rate DH currently includes 155 customers, who generate $0.22 million in revenue on sales of 3 GWh. Rate DH was calibrated in 1993 in the context of integrated utility. Its current structure no longer reflects the avoided cost structure, as is the case for Rates DA and DB which are the subject of the following Section. In light of the results of the “Heure Juste” (“Right Time”) rate project, the Distributor will evaluate the possibility of gradually transferring current subscribers to a new dynamic rate or even of abrogating Rate DH while offering subscribers a transition period to mitigate the rate impacts. Given this perspective, the proposed increases will be more concentrated on off-peak energy prices than on-peak prices. 2.3.1.5 Rates DA and DB The DA and DB Rates are experimental rates that are differentiated according to time-of-use. They apply to any Rate D contract selected by the Distributor, subject to the customer’s acceptance of the invitation and subscription to the Original : 2007-08-01 HQD-12, Document 1 Page 23 of 67 Hydro- Québec Distribution R-3677-2008 Application Rate within the established deadlines. Rates DA and DB are applicable for a limited time, that is, until March 31, 2010 at the latest or until cessation of the customer’s commitment. Rate DA is presented in the following table. It comprises peak and off-peak prices, which each include a 1st block of 15 kWh, and, which vary in winter and summer periods. Moreover, the DA Rate includes a price for critical hours, that is, for 100 hours divided in blocks of four hours, which can be selected by the Distributor between 7 am and 11 am and between 5 pm and 9 pm, without taking into account of: Saturday and Sunday; December 24, 25, 26 and 31, January 1 and 2; as well as Good Friday and Easter Monday, when these days occur during the winter period. Original : 2007-08-01 HQD-12, Document 1 Page 24 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 16 Rate DA on April 1, 2008 Customer charge Energy price for the first 15 kWh consumed during the summer period 40.64¢/day 4.60¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday Energy price for the balance of the energy consumed during the summer period 6.56¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday Energy price for the first 15 kWh consumed during the winter period 3.55¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday December 25 and January 1 Energy price for the balance of the energy consumed during the winter period 5.50¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday December 25 and January 1 Energy price for the first 15 kWh consumed 6.10¢/kWh Between 6am and 10pm, Monday – Friday Energy price for the balance of the energy consumed 8.06¢/kWh Between 6am and 10pm, Monday – Friday Energy price for the critical hours 18.06¢/kWh Notice regarding the critical hours is sent to customers by email or by any other means determined by the Distributor on the evening prior to their occurrence. Rate DB is presented in Table 17. It comprises peak and off-peak prices, which each include a first block of 15 kWh, and, which vary in winter and summer periods. Original : 2007-08-01 HQD-12, Document 1 Page 25 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 17 DB Rate on April 1, 2008 Customer charge Energy price for the first 15 kWh consumed during the summer period 40.64¢/day 4.60¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday Energy price for the balance of the energy consumed during the summer period 6.56¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday Energy price for the first 15 kWh consumed during the winter period 4.29¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday December 25 and January 1 Energy price for the balance of the energy consumed during the winter period 6.27¢/kWh Between 10pm and 6am, Monday – Friday Saturday and Sunday December 25 and January 1 Energy price for the first 15 kWh consumed during the summer period 6.10¢/kWh Between 6am and 10pm, Monday – Friday Energy price for the balance of the energy consumed during the summer period 8.06¢/kWh Between 6am and 10pm, Monday – Friday Energy price for the first 15 kWh consumed during the winter period 6.52¢/kWh Between 6am and 10pm, Monday – Friday Energy price for the balance of the energy consumed during the winter period 8.50¢/kWh Between 6am and 10pm, Monday – Friday Original : 2007-08-01 HQD-12, Document 1 Page 26 of 67 Hydro- Québec Distribution R-3677-2008 Application Rates DA and DB are the subject of a pilot project which is explored in more detail in Section 6. 2.3.2 Analyses Requested in Decision D-2008-024 2.3.2.1 Rate D Customer Charge The customer charge is the fixed component of the domestic rates. This charge partly covers the costs that the Distributor incurs to establish a commercial relationship, specific to each contract, that is, the customer service costs (meter reading, billing, cash receipts, collections, electricity theft, telephone response, complaints and claims, community relations) and metering costs (acquisition, installation and maintenance of metering equipment). These costs are linked first and foremost to the number of customers served and are independent of energy consumption. The establishment of the level of the customer charge is carried out in the overall context of the Distributor’s rate strategy for the domestic rate. During previous rate applications, the Distributor’s objective was to improve the price signal and to reflect the marginal costs in the energy prices. Given this orientation, the adopted rate strategy was to increase the price of the second block more than the price of the first block and to freeze the customer charge. Moreover, given that the revenue requirement for the customer service and the metering of domestic customers was slightly under the customer charge, the freeze was also justified on a cost basis. 2.3.2.1.1 Decision D-2008-024 In its decision D-2008-024, the Régie notes that two intervenors oppose the Distributor’s strategy concerning the customer charge; they believe that the customer charge is too high and that it should accurately reflect cost causality. Original : 2007-08-01 HQD-12, Document 1 Page 27 of 67 Hydro- Québec Distribution R-3677-2008 Application Therefore, the Régie “judges it to be an opportune to review the costs included in the customer charge, in order to ensure that the amount attributed to this charge accurately reflects the fixed costs actually incurred to serve each customer”12. The Régie therefore requests that the Distributor analyze the components of the customer charge and present the results before hand to the Régie in a working group session13. 2.3.2.1.2 Principles and Orientations The establishment of the level of the customer charge is done through two different, but complementary exercises, cost allocation and rate strategy. The customer charge is therefore an element of the Distributor’s rate strategy and the exercise to set this charge takes into account several factors, including: the components and the level of contract costs; the stabilization of revenue; the rate structure; the price signal. The Components and the Level of the Contract Costs Cost causality guides the Distributor in its choice of cost components to be recovered via the customer charge. Certain costs are independent from consumption and are therefore associated with the fixed part of the rate. The energy prices, for their part, serve to recover costs related directly to consumption. The Distributor generally relies on the user pays principle. The customers generate costs before even having started to consume and these costs should be recovered in the fixed component of the rates. A departure from this orientation, in which the costs generated by certain customers would be borne by 12 13 D-2008-024, page 81 (unofficial translation; translator’s version). This working group session took place on June 25, 2008. Original : 2007-08-01 HQD-12, Document 1 Page 28 of 67 Hydro- Québec Distribution R-3677-2008 Application other customers, is not a winning solution in the long-term, even if such a solution relies on a principle of social equity. The customer charge should therefore be used to recover specific costs incurred by customers that are not a function of their own consumption. Stabilization of Revenue For domestic rates, the level of the customer charge plays an important role in the stability of revenue because the revenue associated with this charge is not subject to as much volatility as the revenue from energy consumption. The Rate Structure and the Price Signal Consideration must also be given to the fact that the customer charge component is part of a whole and that each of the rate components must be set according to the costs, but also as a function of an overall vision of the rate and rate-setting principles. As an example, the Distributor pursues the objective to improve the price signal associated with energy consumption by reflecting the marginal cost signal in the energy price for the domestic rate. From this point of view, the freeze of the customer charge since 2005 has allowed the Distributor to improve this price signal by applying more of the rate increase to the price of the second block. Finally, it must be noted that the establishment of the customer charge is not a one-dimensional exercise, and that there is no absolute rule on this subject. The Distributor should make choices by considering the different elements. 2.3.2.1.3 Contract Costs The contract costs that are normally considered in the calculation of the customer charge are those that are considered in cost allocation and those that are independent of energy consumption (see the following table). Original : 2007-08-01 HQD-12, Document 1 Page 29 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 18 Contract Costs Used in the Calculation of the Customer Charge Costs Considered Customer service: meter reading, billing, cash receipts, collections, electricity theft, telephone response, complaints and claims, community relations Costs Excluded Supply Transmission Distribution Metering costs: acquisition, installation and maintenance of metering equipment Others (PGEÉ (i.e. Energy Efficiency Plan), cash balance) Connection Minimum system The Distributor’s position, as expressed during the rate cases at the Régie since 2004, is to exclude connection and minimum system costs and to ensure that the customer charge covers the customer service and metering costs. The following table presents a detailed breakdown of the revenue requirement that is not related to either capacity or energy consumption and that can be taken into consideration in the establishment of the customer charge14. When the overall revenue requirement is considered, the contract cost per day is 64.37¢. This amount is relatively high because it includes all the connection and minimum system costs. 14 This is an updated version of the table that was presented during the working group session of June 25, 2008. Original : 2007-08-01 HQD-12, Document 1 Page 30 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 19 Detailed Breakdown of the Revenue Requirement Contract costs for domestic rates (R-3677-2008) Overall revenue requirements (millions$) (¢/day) references Current level of the customer charge Alternative scenario Customer service 431.9 33.43 33.43 19.52 Meter reading Billing Cash receipts Collections Electricity theft Telephone response Complaints and claims Community relations Remote communities – Others Revenue (fees for admin and opening file) Sales and marketing 84.1 98.7 8.8 120.6 5.9 127.3 10.3 4.1 4.5 6.51 7.64 0.68 9.33 0.46 9.85 0.80 0.32 0.35 (1) (2) (3) (4) (5) (6) (7) (8) (9) X X X X X X X X X X X X X* X* X* X X X -48.5 -3.75 (10) X X 16.1 1.24 X 70.8 329.0 5.48 25.46 (11) (12) X Metering System (Contract) 5.48 5.48 Connection Minimum System 44.2 284.8 3.42 22.04 Total 831.6 64.37 (13) (14) 1.73 40.64 25.00 * Partial amount. References: R-3677-2008, Exhibit HQD-11, Document 3 1) (Table 14B, column 2, rows 5 and 20) + [(Table 13B, column 2, rows 5 and 20) X (Table 1, column 3, row 20)] 2) (Table 14B, column 3, rows 5 and 20) + [(Table 13B, column 3, rows 5 and 20) X (Table 1, column 3, row 20)] 3) (Table 14B, column 4, rows 5 and 20) + [(Table 13B, column 4, rows 5 and 20) X (Table 1, column 3, row 20)] 4) (Table 14B, column 5, rows 5 and 20) + [(Table 13B, column 5, rows 5 and 20) X (Table 1, column 3, row 20)] 5) (Table 14B, column 6, rows 5 and 20) + [(Table 13B, column 6, rows 5 and 20) X (Table 1, column 3, row 20)] 6) (Table 14B, column 7, rows 5 and 20) + [(Table 13B, column 7, rows 5 and 20) X (Table 1, column 3, row 20)] 7) (Table 14B, column 8, rows 5 and 20) + [(Table 13B, column 8, rows 5 and 20) X (Table 1, column 3, row 20)] 8) (Table 14B, column 9, rows 5 and 20) + [(Table 13B, column 9, rows 5 and 20) X (Table 1, column 3, row 20)] 9) (Table 33, column 12, row 9) + [(Table 33, column 12, row 2) X (Table 1, column 3, row 20)] 10) (Table 27B, column 3, rows 5 and 20) + (Table 27B, column 4, rows 5 and 20) 11) (Table 25B, column 7, rows 5 and 20) + [(Table 24B, column 7, rows 5 and 20) X (Table 1, column 3, row 20)] + (Table 25B, column 10, rows 5 and 20) + [(Table 24B, column 10, rows 5 and 20) X (Table 1, column 3, row 20)] 12) (Table 7, column 13, row 5) + [(Table 6, column 12, row 5) X (Table 1, column 3, row 20)] Original : 2007-08-01 HQD-12, Document 1 Page 31 of 67 Hydro- Québec Distribution R-3677-2008 Application 13) (Table 7, column 9, row 5) + (Table 33, column 9, row 9) + [{(Table 6, column 8, row 5) + (Table 33, column 9, row 2)} X (Table 1, column 3, row 20)] 14) (Table 7, column 6, row 5) + (Table 33, column 6, row 9) + [{(Table 6, column 5, row 5) + (Table 33, column 6, row 2)} X (Table 1, column 3, row 20)] + (Table 7, column 8, row 5) + (Table 33, column 8, row 9) + [{(Table 6, column 7, row 5) + (Table 33, column 8, row 2)} X (Table 1, column 3, row 20)] During the 2008-2009 rate case, as reported by the Régie in decision D-2008024, an expert indicated that the level of the customer charge was too high. He proposed a reduction of this charge to 25¢/day in order to further increase the price of the second energy block. The Distributor therefore presents in Table 19 an alternative scenario proposed by the RNCREQ expert in the 2008-2009 rate filing, which excludes a portion of the costs associated with telephone response, collections and electricity theft, in addition to the exclusion of connection and minimum system costs15 2.3.2.1.4 Benchmarking It is interesting, at this point, to compare the customer charge applied by the Distributor with those of other electricity distributors in North America. For the purposes of comparison, Table 20 shows the level of customer charge for residential customers applied in April 2007 in selected North American cities. 15 R-3644, Document C-9-13, Expert report of Mr. Lazar (amended version). Original : 2007-08-01 HQD-12, Document 1 Page 32 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 20 Customer Charge for 30 Days on April 1, 2007 Residential Customers (1,000 kWh per Month) Cities Customer charge (¢/day) or Cdn$/month1 Canadian cities Montreal 40.64 12.19 Charlottetown, PE Edmonton, AB Halifax, NS Moncton, NB Ottawa, ON Regina, SK St. John's, NL Toronto, ON Vancouver, BC Winnipeg, MB 74.23 51.73 36.10 63.87 26.27 51.03 51.97 41.43 12.30 20.80 22.27 15.52 10.83 19.16 7.88 15.31 15.59 12.43 3.69 6.24 Canadian average 42.76 12.83 American cities Boston, MA Chicago, IL Detroit, MI Houston, TX Miami, FL Nashville, TN New York, NY Portland, OR San Francisco, CA Seattle, WA 24.78 34.22 24.28 0.00 19.92 32.33 45.40 28.90 17.09 11.25 7.43 10.27 7.28 0.00 5.98 9.70 13.62 8.67 5.13 3.38 American average 23.82 7.15 Average 33.74 10.12 Note 1: The exchange rate used is $0.8650 on April 1, 2007. Even if the Distributor’s customer charge was in the average range, the customer charge amounts differ widely and reflect differences with respect to the retained Original : 2007-08-01 HQD-12, Document 1 Page 33 of 67 Hydro- Québec Distribution R-3677-2008 Application cost components, with respect to the retained level of these costs , as well as with respect to the adopted rate strategy. In light of these differences, it is possible to conclude that there is no absolute rule with respect to the establishment of the customer charge. Moreover, the customer charge of a good number of Canadian distributors does not cover the totality of the contract costs. It is therefore clear that the customer charge is an element of the rate strategy and that factors other than costs are considered in setting this charge. 2.3.2.1.5 Scenarios Analyzed Notwithstanding the debate on what the customer charge should cover, the Distributor is of the opinion that the establishment of the customer charge rests more on elements such as the price signal and the overall rate structure, as well as impacts on customers. Therefore, in undertaking this analysis, the Distributor evaluated scenarios with increased and decreased customer charges and their impacts on the customer base. The increased customer charge scenario considers the overall revenue requirement retained, whereas the decreased customer charge scenario corresponds to the alternative scenario presented in Table 19. For each of these scenarios, the revenue deviation is compensated by a price adjustment, either of both energy blocks or of only one of the blocks. Increased Customer Charge Scenario If all of the fixed costs, including the connection and minimum system costs, were considered in the establishment of the customer charge, this charge would be in the order of 64¢/day. The Distributor presents in Table 21 what the domestic rate structure could look like if the revenue increase associated with the increased customer charge was compensated by a decrease in both energy prices or only by a decrease in the price of the first energy block. Original : 2007-08-01 HQD-12, Document 1 Page 34 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 21 Example of the Rate Structure for Rates D and DM and Dispersion of Rate Impacts Using Hypothesis of Constant Revenues - Rates D and DM Increase of the Customer Charge to 64 ¢/day - Customer charge (¢/day) Rate Structure st nd 1 block 2 block Ratio ¢/kWh 2 /1 nd st Dispersion of Rate Impacts Decrease Increase (Min ; Max) ( Min ; Max) April 1, 2008 40.64 5.40 7.33 1.36 Increase of the customer charge and equivalent decrease of the 2 blocks Increase of the customer charge and equivalent decrease of the 1st block 64.37 4.97 6.74 1.36 41% of customers 59% of customers 58.4% -8.0% -8.0% 0.00 (-8% ; 0%) (0% ; 58%) 64.37 4.40 7.33 1.67 63% of customers 37% of customers 58.4% -18.5% 0.0% 0.00 (-3% ; 0%) (0% ; 58%) In the first example, the customers affected by rate increases are the smaller customers and those with very low consumption levels. 59% of customers would be subject to bill increases of up to 58%. The impact on the annual bill for customers that do not have any consumption would be almost $87.16 In the second example, rate increases are mildly mitigated for small customers through a greater rate decrease for the 1st consumption block. However, the $87 annual increase for customers who do not have any consumption would remain the same under this scenario. In order to show the impacts of modifications associated with an increase of the customer charge, a simulation was carried out for a series of case study studies(see Table 22). The impacts are in line with those presented above. The scenario that includes an increase of the customer charge and an equivalent rate decrease of both energy rates has an upward impact on small customers. 16 365 days* ($0.6437 - $0.4064) = $86.60 Original : 2007-08-01 HQD-12, Document 1 Page 35 of 67 Hydro- Québec Distribution R-3677-2008 Application Apartments and customers in the first consumption block have respective increases of 4% and 5%, that is $33 and $39 annually. TABLE 22 Rate Impact by Case study Using Hypothesis of Constant Revenues - Increase of the Customer Charge to 64 ¢/day Average Rate D Customer 17 056 kWh Apartment April 1, 2007 $1,232 $817 $1,448 Increase of customer charge and equivalent decrease of both blocks $0 $33 0.0% 4.1% Increase of customer charge and equivalent decrease of 1st block $0 -$7 -$18 -$22 -$23 -$23 -$23 -$23 -$23 -$117 0.0% -0.8% -1.3% -1.2% -1.0% -0.7% -0.5% -0.1% -3.1% -1.3% Rates D and DM Small Home Large Home electricity32 054 kWh Very Large Home 42 818 kWh Imposing Home 62 840 kWh Large Customer 100 kW 411 700 kWh $1,879 $ 2,287 $3,076 $4,543 -$17 -$52 -$84 -$148 -1.2% -2.8% -3.7% -4.8% 11 590kWh 20 494 kWh Average Home -Heated with 26 484 kWh Customer st 1 Block Apartment Building 10 950 kWh 124 160 kWh $31,367 $740 $8,759 -$265 -$2 311 $39 -$110 -5.8% -7.4% 5.3% -1.3% Beyond the significant dispersion of rate impacts, an increase of the customer charge and a corresponding decrease of energy rates would lead to a deterioration of the price signal. In fact, from the moment in which a significant portion of the electricity bill is unduly fixed, customers have less interest in reducing their consumption or in making the right energy choices. Scenarios with a Reduction of the Customer Charge The alternative scenario that was examined involves a reduction of the customer charge to 25¢/day and an increase of the second consumption block to compensate the decrease in revenues. The objective of the RNCREQ expert was to arrive at the marginal price signal more quickly than the approach proposed by the Distributor. A reduction of the customer charge to 25¢/day would have an impact on the bill of all residential customers. In order to provide a concrete example of the impact resulting from these modifications, the Distributor shows, in Table 23, the structure of the domestic rate if the decrease in revenues associated with a Original : 2007-08-01 HQD-12, Document 1 Page 36 of 67 Hydro- Québec Distribution R-3677-2008 Application reduction of the customer charge were compensated by an increase in both energy rates or only by an increase in the rate of the second consumption block. When both energy rates are increased to compensate for the loss of revenue associated with a reduction of the customer charge, 41% of customers are subject to bill increases of up to 5%. When only the rate for the second consumption block is increased, the rate increases for larger customers are more significant (maximum 9%). TABLE 23 Example of the Rate Structure for Rates D and DM and Dispersion of Rate Impacts Using Hypothesis of Constant Revenues - Rates D and DM Reduction of the Customer Charge to 25 ¢/day - Customer charge (¢/day) Rate Structure st nd 1 block 2 block Ratio ¢/kWh 2 /1 nd st Dispersion of Rate Impacts Decrease Increase (min ; max) ( Min ; Max) April 1, 2008 40.64 5.40 7.33 1.36 Increase of the customer charge and equivalent decrease of the 2 blocks Increase of the customer charge and equivalent decrease of the 1st block 25.00 5.68 7.72 1.36 59% of customers 41% of customers -38.5% 5.3% 5.3% 0.00 (-38% ; 0%) (0% ; 5%) 25.00 5.40 8.01 1.48 62% of customers 38% of customers -38.5% 0.0% 9.3% 0.00 (-38% ; 0%) (0% ; 9%) In order to show the impacts of modifications associated with a decrease of the customer charge, a simulation was carried out for a series of case studies (see Table 24). The impacts of the scenario proposed by the expert Mr. Lazar are more dispersed, with respective bill decreases of up to 5% and 8% for apartments and customers in the first consumption block, while the increase for the average home would be 3% and the one for larger customers would range between 5% and 9%. It should be noted that customers who benefit from bill reductions have not made any effort to curtail their consumption. Moreover, these reductions could be perceived as weakening the price signal. Original : 2007-08-01 HQD-12, Document 1 Page 37 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 24 Rate Impact by Case study Using Hypothesis of Constant Revenues - Decrease of the Customer Charge to 25 ¢/day Average Rate D Customer 17 056 kWh Apartment April 1, 2007 $1,232 $817 Increase of customer charge and equivalent decrease of both blocks $0 -$22 $11 $34 0.0% -2.7% 0.8% 1.8% $0 -$42 $11 $49 0.0% -5.1% 0.8% 2.6% Rates D and DM Increase of customer charge and equivalent decrease of 1st block Small Home 11 590kWh 20 494 kWh $1,448 Average Home -Heated with 26 484 kWh $1,879 Large Home electricity32 054 kWh Very Large Home 42 818 kWh Imposing Home 62 840 kWh Large Customer 100 kW 411 700 kWh Customer st 1 Block Apartment Building 10 950 kWh 124 160 kWh $ 2,287 $3,076 $4,543 $31,367 $740 $8,759 $56 $97 $175 2.4% 3.2% 3.8% $1,523 -$26 $72 4.9% -3.5% 0.8% $87 160 $297 $2,674 -$57 $69 3.8% 5.2% 6.5% 8.5% -7.7% The Distributor believes that it is not justified to decrease the customer charge as a way to accelerate the process of improving the price signal because the current strategy of increasing the rate of the second consumption block twice as much as the first, coupled with a freeze of the customer charge already contributes to improving the progressivity of the rates17 and, as a result, the price signal. The rate of the second consumption block went from 5.97¢/kWh at the end of the rate freeze in 2003 to 7.33¢/kWh on April 1, 2008 and it comes closer to with longterm marginal costs. The Distributor proposes to maintain the current strategy rather than modifying the structure too quickly by reducing the customer charge to emphasize the price signal. This approach makes it possible to reach the marginal costs signal all the while minimizing the impacts on customers. In addition, reducing the customer charge would be unduly favourable to customers whose consumption is not regular throughout the year, particularly the 200,000 customers who have a cottage or those who spend part of the winter outside of Quebec. These contracts generate fixed costs associated with customer service and metering which would then be assumed by other customers. It would also be favourable to customers who use a different energy 17 The graph shown in Appendix B shows that the Distributor’s strategy for rate D, applied since 2005, has made the rate more progressive since April 2006. Original : 2007-08-01 HQD-12, Document 1 Page 38 of 67 0.8% Hydro- Québec Distribution R-3677-2008 Application source for space-heating as well as condominium owners since they rarely consume electricity in the second block. It must also be noted that, while not reducing customers’ bills as such, the freeze of the customer charge, which has been authorized by the Régie since 2004, corresponds to an actual decrease of 11.8%. 2.3.2.1.6 Distributor’s Proposal At its current level of 40.64¢/day, the customer charge remains slightly higher than customer service and metering costs for 2008 which total 38.91¢/contract/day. However, if we add service loop charges to this amount, the total cost increases to 42.33¢/contract/day. The Distributor therefore proposes to renew the freeze of the customer charge since it is possible to recover all the metering and customer service costs as well as a portion of the service loop charges. This rate freeze plays an important role in the residential rate strategy for domestic rates. 2.3.2.2 Analysis of the DT Rate Structure In decision D-2008-024, the Régie requested from the Distributor, in its next rate application, an analysis of the Rate DT structure which takes into account the Quebec’s current energy context in terms of post-heritage supply costs. This Section responds to that request. 2.3.2.2.1 Profitability of the Structure of Rate DT from the Perspective of Society and of the Distributor Because of a reduction in the heating load of 810 MW on the system’s peak,18 Rate DT is included in HQD’s supply plan as a consumption management tool. The analysis that follows makes it possible to evaluate the profitability of Rate DT. 18 R-3648-2007, HQD-1, document 2, Appendix 2A, page 63. Original : 2007-08-01 HQD-12, Document 1 Page 39 of 67 Hydro- Québec Distribution R-3677-2008 Application If Rate DT were abrogated, there would be a transfer of dual energy customers to Rate D. The transfer to all–electricity-heating (AEH) would lead to additional annual consumption of 500 GWh and would increase the heating load on the system by 810 MW.19 The magnitude of this additional load as well as its characteristics (high load factor during winter hours) would greatly increase and pre-empt the Distributor’s additional long-term winter capacity requirements. The avoided costs for this additional capacity are approximately $40.80/Winter-kW (increasing annuity, $2009).20 In addition to added capacity costs, the customer transfer would generate significant costs associated with supply, transmission, and distribution. On the basis of the avoided costs shown in table 25, the additional costs to the Distributor are approximately $115 million. Conversely, abolishing Rate DT would make it possible to reduce residential consumption of fuel oil. In addition to the avoided costs for fuel oil which total $53 million, abolishing Rate DT would reduce greenhouse gas emissions associated with residential furnaces, assuming the fuel oil is replaced by electricity generated by an emission-free energy source. Assuming CO2 credits are purchased at a price of $15/ton these avoided costs would total $2 million. Therefore, the total cost of abolishing Rate DT would be approximately $60 million. Therefore, it is not economically justified to abolish this rate from a societal perspective. 19 Considering current energy prices the Distributor assumes that dual energy customers would convert to electricity if Rate DT were abolished. 20 See HQD-14, document 1, Appendix D. Original : 2007-08-01 HQD-12, Document 1 Page 40 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 25 Evaluation of Abolishing Rate DT Abolishing Rate DT (+500 GWh and 800 MW) $M Profitability from the perspective of society HQD costs 1 114.8 Supply – Transmission Guaranteed Energy (7.1¢/kWh) 35.5 Supply – Transmission ($40.80/kW) 33.0 Transmission- Native Load ($41.90/kW) 33.9 Distribution ($15.16/kW) 12.3 Other costs Fuel Oil (average price 2007-2008 85.56¢/l) -52.9 GHG emissions ($15/ton) Residential Heating -2.0 Emission-Free Electricity Production 0.0 Total Cost 59.9 Profitability from the Distributor’s perspective HQD costs HQD Revenues (D vs DT) 114.8 2 HQD Net Costs (HQD Costs – HQD Revenues) 1 86.5 28.3 These are the costs for 2009 as shown in HQD-14, appendix D. 2 Rate DT revenues total $160 million (2,865 GWh at 5.58¢/kWh) whereas if rate DT were abolished revenues for rate DT would be $246 million (3 365 GWh at 7.32¢/kWh). For the Distributor, abolishing Rate DT is also not justified since the additional ensuing costs if the rate is abolished ($115 million), cannot be compensated by additional revenues that would result from a transfer of customers from Rate DT to Rate D ($86 million). 2.3.2.2.2 Profitability of the Structure of Rate DT from Customers’ Perspective Rate DT is calibrated to be neutral relative to Rate D for an average single-family home located in Montreal that consumes 26,484 kWh before load reduction, that is, for customers who only use electricity to meet heating requirements. Original : 2007-08-01 HQD-12, Document 1 Page 41 of 67 Hydro- Québec Distribution R-3677-2008 Application Therefore, any consumption management efforts made by customers translate as bill savings relative to Rate D. The savings on the electricity bill correspond to a credit equivalent to the peak price for every kWh that is shed when the exterior temperature is below the applicable transfer level. On the one hand, the off-peak rate is relatively low to provide an annual saving to customers using the dual energy mode and so customers may have an interest in using electricity during off-peak periods. On the other hand, the peak rate must be sufficiently dissuasive to encourage customers to use an alternative energy source for heating and to shift certain basic loads. At present, it is in the interest of dual energy customers to use electricity during off-peak periods as long as the off-peak price of fuel oil exceeds 35¢/litre, and to function with fuel oil during onpeak periods if the price of fuel oil is below $1.42/litre. Nonetheless, the annual savings achieved by Rate DT customers who use dual energy must also take into account fuel purchases and the difference in maintenance costs of a dual energy system relative to an electrical system. This total savings ultimately finances a portion of the differential cost of acquisition of a dual energy system relative to an electrical system. Since Rate DT energy rates are calibrated to be neutral relative to Rate D and since maintenance costs are stable from year to year, the total savings achieved mainly depend on the price of fuel oil paid in a year to function in dual energy mode. Under normal exterior temperature, Rate DT can result in savings to rate DT customers that range between 5% and 15% compared to Rate D, depending on the extent of their consumption management efforts and fuel oil prices. However, savings for Rate DT customers increase further if they consume more during off-peak periods by adding, for example, summer usages such as air conditioning and a pool-heater. Also, it is likely that climate warming increases savings for Rate DT customers by shifting a portion of the customers’ consumption from on-peak to off-peak period. Original : 2007-08-01 HQD-12, Document 1 Page 42 of 67 Hydro- Québec Distribution R-3677-2008 Application The recent increase in fuel oil prices has nonetheless decreased annual savings for Rate DT customers who use dual energy systems. It is estimated that with current Rate DT energy prices, a customer who lives in an average single-family home would no longer have any annual savings if the average price paid for the fuel-oil consumed in a year reaches 1.27$/litre.21 For example, as the following table shows, the price of fuel oil reached 1.06$/litre last April for savings of $81. TABLE 26 Annual Savings for Rate DT Customers According to Different Fuel Oil Prices Price of fuel oil DT Savings 50¢/litre 301$ 15% 73¢/litre 211$ 10% 90¢/litre 143$ 7% 106¢/litre 81$ 4% 127¢/litre 0$ 0% Although it would not be profitable for society nor for the Distributor to abolish Rate DT, it is ultimately the profitability for customers who adhere to this option which determines the peak load reduction associated with this rate. Yet the prices of fuel oil are such that customers get very little out of it and they could stop using the dual energy mode and ultimately leave Rate DT. Consequently, it is primarily this aspect which will determine the rate strategy proposed for April 1, 2009. 2.3.2.2.3 Proposed Rate Strategy on April 1, 2009 Rate Neutrality 21 As mentioned earlier, it is always in the interest of a dual energy customer to use fuel oil during peak periods when the price is below 1.42$/litre. Original : 2007-08-01 HQD-12, Document 1 Page 43 of 67 Hydro- Québec Distribution R-3677-2008 Application The Distributor proposes to continue calibrating Rate DT to Rate D in order to preserve neutrality between rates. The objective of calibrating is that the electricity bill before load reduction for a customer living in an average singlefamily home heated with a dual energy system should be the same as an AEH customer living in the same type of home. This neutrality is essential because if the bill at Rate DT before load reduction were lower than for Rate D, customers would achieve savings even before switching to fuel mode during peak periods. This situation would translate as a loss in revenue for the Distributor without a return on the cost of service, Conversely, if Rate DT bills are higher than Rate D bills prior to load reduction, customers risk paying more in dual energy mode even if they were to eliminate heating loads completely. The components of Rate DT will therefore continue to be set so as to ensure this neutrality. Customer Charge Despite the higher cost of double-register meters used to meter the consumption of dual energy customers, the customer charge has historically been set to the level of Rate D to reward all management efforts by customers. In fact, the Distributor does not wish to increase the customer charge for Rate DT to recover the cost differential because, to do so, it would have to sacrifice rate neutrality relative to Rate D. If rate neutrality had to be maintained while increasing the customer charge of Rate DT, it would be impossible to recover a greater portion of costs because additional revenue recovered from a higher customer charge would have to be compensated by a smaller increase in energy rates. The price signal for these customers would therefore deteriorate. Given these circumstances, it is therefore proposed to keep the customer charge at the same level as for Rate D. Price of Energy Original : 2007-08-01 HQD-12, Document 1 Page 44 of 67 Hydro- Québec Distribution R-3677-2008 Application In rate applications R-3579-2005 and R-3610-2006, the Distributor proposed to increase the off-peak rate more than the on-peak rate. This strategy was in line with the strategy followed for Rates D and DM and it sought to improve the price signal for all uses while preserving the annual savings of customers and without decreasing their interest to use fuel during cold weather. The rate strategy proposed by the Distributor in application R-3644-2007 was adapted to better reflect the new energy supply context. In a context where all kWh consumed cost approximately 10¢/kWh, it was necessary to improve the price signal further in order to avoid that the off-peak rate stimulate additional consumption. For this reason, the Distributor proposed to apply the entire rate increase to the off-peak rate. Compared to the fuel oil prices in effect at the time, the on-peak rate of 7.55¢/kWh was sufficiently dissuasive22 to encourage customers to use an alternative energy source for heating and to shift certain basic loads. This strategy did not compromise neutrality between Rate DT and Rate D, nor did it reduce actual savings following load reduction. In the current rate application, the evolution of fuel oil prices have compelled the Distributor to revise its short-term rate strategy. At the current peak rate of 17.55¢/kWh, customers have an incentive to use fuel oil if its price is below $1.42/litre. Yet, in April 2008, the price of fuel oil reached $1.06/litre. The Distributor’s margin to freeze peak rates on April 1, 2008 was practically nonexistent. Consequently, given the uncertain evolution of fuel oil prices on the short-term, the Distributor considers it prudent to increase only the on-peak energy rate for Rate DT. By including the proposed rate increase of 2.2%, the energy rate would therefore increase to 18.59¢/kWh, or the equivalent of $1.50/litre. This proposal also makes it possible to increase the savings of Rate DT customers living in an average single-family home from $81 to $115. Since Rate DT is an important consumption management tool for the Distributor, on the one hand it is necessary to preserve customers’ interest in using fuel oil 22 Equivalent to a fuel oil price of $1.42/litre while the fuel oil rate was approximately 70¢/litre for the 2006-2007 heating season. Original : 2007-08-01 HQD-12, Document 1 Page 45 of 67 Hydro- Québec Distribution R-3677-2008 Application during on-peak periods in order to ensure a reduction in the heating load. On the other hand, it is equally important to preserve a certain degree of savings for Rate DT customers without which it would be in their interest to convert their systems to electricity sooner or later. For these reasons, the Distributor will be sure to monitor the evolution of fuel oil prices and the dual energy market and it may, as required, revise its strategy within the year. Therefore, if fuel oil prices continue to rise, the Distributor could consider a reduction of off-peak rates in order to increase the on-peak rate further. For example, every decrease of 0.1¢/kWh in the off-peak rate makes it possible to increase the on-peak rate by 0.5¢/kWh (or 4¢/litre equivalent) and to increase savings by $16. Moreover, in the current context of high fuel prices, any modification to the structure of Rate DT could make the existing dual energy option more fragile and it could imperil its current contribution to the Distributor’s supply plan. Therefore, the Distributor asks the Régie to delay any major reform to the structure of Rate DT. Billing the Demand Charge Until very recently, no demand charge was applied to Rate DT. The absence of a demand charge that applied beyond 50 kW during the winter period made it impossible to ensure that this rate was adequately calibrated or to ensure an equitable treatment of Rate DT customers relative to Rate D and DM customers with similar consumption profiles. The Distributor therefore proposed to introduce an equivalent demand charge to the one applied to Rates D and DM. Given that the demand charges that are currently applied to Rate DT customers whose metering is respectively metered in bulk or individually are already equivalent to the demand charge for Rates D and DM, the Distributor proposes to Original : 2007-08-01 HQD-12, Document 1 Page 46 of 67 Hydro- Québec Distribution R-3677-2008 Application apply the same elements of the demand charge billing reform as Rates D and DM. 2.3.3 Proposed Adjustments to the Rate Structure and Implementation of the Reform In the 2008 rate application, the Distributor met the Régie’s demands set forth in decision D-2007-12 to present a proposal for the reform of domestic rates. This reform takes into account the importance of long-term marginal costs, the Régie’s orientations, and the implementation of the Government’s energy strategy.23 The Distributor proposes to begin this reform on April 1, 2009. In decision D-2008-024, “the Régie finds that the proposals for the reform of rate structures adequately meet the objectives set out in previous decisions and in the Energy Strategy 2006-2015 of the Government of Quebec. Over time, these reforms will lead to an improved price signal.”24 The Régie is satisfied with the way the rate reform has evolved for Rates D and DM. This rate reform provides a gradual and prudent incentive to the Distributor’s customers to optimize their electricity consumption due to an improved price signal and it progressively makes domestic rates more reflective of long-term marginal costs so electricity customers may have a greater interest in energy efficiency.25 The Distributor thereby initiates on April 1, 2009 the rate reform proposed in the 2008 rate application and approved by the Régie in decision D-2008-024. We note that this rate reform is in line with the rate strategy that was initiated in the 2005 rate application, recognized by the Régie in decisions D-2005-34, D-200634 and D-2007-12. The current section reiterates each element of the domestic rate reform approved by the Régie, as well as the Distributor’s proposals 23 D-2007-12, page 84. D-2008-024, page 4. The above is an unofficial translation, translator’s version. 25 D-2008-024, page 90. 24 Original : 2007-08-01 HQD-12, Document 1 Page 47 of 67 Hydro- Québec Distribution R-3677-2008 Application following the analyses requested in decision D-2008-024 regarding the customer charge and Rate DT. 2.3.3.1 Customer Charge For the reasons already expressed in section 2.3.2.1, the Distributor proposes to renew the freeze of the customer charge. 2.3.3.2 Energy Rate Adjustment In the analysis it submitted in 2007, the Distributor proposed to pursue its rate strategy and to increase the rate of the second consumption block twice as much as the first. This proposal seeks to improve the price signal and to promote energy efficiency in a context of high supply costs. In decision D-2008-024, the Régie found that this proposal respected the rate strategy that was initiated in the rate application R-3541-2004 and approved by the Régie in decisions D-2005-34, D-2006-34 and D-2007-12. Like the Distributor, the Régie noted that the increase in supply costs affects all consumption and, therefore, part of the rate increase must be applied to the first consumption block. The Régie approved the Distributor’s proposal to pursue the application of the strategy by which the rate of the second consumption block increases twice as much as the rate of the first.26 To favour energy efficiency and align the structure of domestic rates in the longterm, the second block rate must at least reflect the marginal cost of supply (supply and transmission) for heating. This cost is estimated at 10.97¢/kWh27 (constant annuity over 10 years). By 2018, the marginal cost for heating will increase to 13.80 ¢/kWh. These costs are relatively higher than the current rate of the second block. 26 27 D-2008-024, pages 82-83. See HQD-15, Document 1 Original : 2007-08-01 HQD-12, Document 1 Page 48 of 67 Hydro- Québec Distribution R-3677-2008 Application In a context where the second block rate has not yet reached the long-term marginal cost, the Distributor believes that pursuing this strategy remains relevant. First, the rate of the second consumption block remains the Distributor’s most important lever to promote efficient behaviour from its domestic customers. However, it remains equally important to increase the rate of the first block given that the increase in supply costs affects all consumption. Finally, the Distributor reiterates that it is prudent to increase the rate of the second block gradually both because of the context in which marginal costs continue to evolve and to avoid rate impacts that are too significant for customers. Regarding Rate DT, the Distributor proposes to apply the entire rate increase on the peak energy rate for the reasons provided in section 2.3.2.2. As for Rate DH, the Distributor proposes, as noted in section 2.3.1.4, a greater rate increase on the off-peak rate than the on-peak rate Finally, in regards to Rates DA and DB, the Distributor upholds the principle of rate neutrality relative to Rate D. Moreover, based on the updated avoided costs, it proposes to preserve the variance between on-peak rates and off-peak rates at 1.5¢/kWh and to maintain an avoided cost for capacity of $10/winter-kW. 2.3.3.2.1 Benchmarking of Rates with Two Progressive Blocks in Canada Recently, progressive two-block rates were either proposed or introduced in other Canadian jurisdictions. In Ontario, the progressive structure of the residential rates for supply has been in place since April 2004. The variance between the rates of both blocks for the supply portion only is 18%. The rate for supply is set at 5.0 ¢/kWh for the kilowatt-hours consumed in the first block and 5.9¢/kWh for the rest.28 The level of the first block varies according to the season: it is set at 1,000 kWh per month during the winter period and is reduced to 600 kWh during the summer period. 28 The rate is revised on May 1, every year and re-adjusted six months later if required. Original : 2007-08-01 HQD-12, Document 1 Page 49 of 67 Hydro- Québec Distribution R-3677-2008 Application In Manitoba, the Public Utilities Board, in a decision rendered on June 30, 2008, approved the introduction on July 1, 2008 of a two-block rate that is slightly progressive for Manitoba Hydro’s residential customers.29 The level of the first block is set at 900 kWh per month and the variance between both energy rates is almost 1%. The rate is set at 6.08¢/kWh for the kilowatt-hours consumed in the first block and 6.123 ¢/kWh for the rest. In an application submitted by the BCUC last February, BC Hydro proposed a two-block progressive rate for its residential customers with the aim of improving the price signal and, consequently, encouraging energy savings. The current one block rate of 6.55¢/kWh30 would be divided into two blocks with a consumption level of 1,600 KWh per two-month period. The variance between both energy rates is 11%, The rates proposed using constant revenues are 6.28¢/kWh for kilowatt-hours consumed in the first block and 6.98¢/kWh for the rest.31 BC Hydro proposes to increase the customer charge and the rate for the first energy block at the projected inflation rate and to set the rate of the second block so as to meet the revenue requirement. 32 The table that follows shows BC Hydro’s residential rate as applicable at the time of the proposal, the one for April 1, 2008 including an increase of 6.56%, as well as the progressive rate proposed considering, respectively, a rate increase of 8.21% on April 1, 2009,33 a hypothetical 5% increase on April 1, 2010 and excluding any correction for cross-subsidization. 29 Manitoba PUB, Order 90/08, June 30 2008, page 2. At the time the proposal was submitted, the analysis was based on the rate applicable on March 31, 2008. 31 http://bchydro.com/policies/rates/rates55221.html 32 For additional information : http://bchydro.com/rx_files/info/info55226.pdf 33 BC Hydro F09/F10 RRA. 30 Original : 2007-08-01 HQD-12, Document 1 Page 50 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 27 BC Hydro Progressive Rate Proposed Customer Charge 1st Energy Block (¢/day) (¢/kWh) Block (¢/kWh) Variance between the 1st and 2nd block On March 31, 2008 12.13 6.15 6.15 0% On April 1, 2008 12.93 6.55 6.55 0% Year 1 12.38 6.28 6.98 11% Year 2 12.64 6.41 8.53 33% Year 3 12.91 6.55 9.35 43% Residential Rates 2nd Energy The following table summarizes the Distributor’s rate structure as well as those of the companies mentioned previously. Original : 2007-08-01 HQD-12, Document 1 Page 51 of 67 Hydro- Québec Distribution R-3677-2008 Application Table 28 Progressive Residential Rates in Canada HQD Toronto Hydro1 Winter: 1000 Manitoba Hydro BC Hydro2 900 800 Level of 1st Energy Block (kWh per month) 900 Rate for kWh in the 2nd Energy Block 5.40¢ 9.38¢ 6.08¢ 6.28¢ Rate for kWh in the 2nd Energy Block 7.33¢ 10.28¢ 6.123¢ 6.98¢ Variance between rates 36% 10% 0.7% 11% Summer: 600 1) Only the supply component is progressive, all other components of the rate are applied uniformly, independently of the consumption level. 2) Constant revenues scenario proposed for October 1, 2008. 2.3.3.3 Capacity Invoice Since the demand charge plays the role of a third consumption block and is a component upon which the customer can act, the Distributor has chosen to emphasize the use of the demand charge since 2005. The rate strategy adopted at the time thereby consisted of increasing the demand charge by 75¢ per kilowatt for individually metered domestic customers and 18¢ per kilowatt for those who are collectively metered. The rate reform that was proposed in application R-3644-2007 continued to seek a better price signal, first, by compensating for the absence of an incentive for domestic customers whose consumption exceeds 50 kW to manage their capacity requirements in the summer period as there was only a very small variance between long-term marginal costs for summer and winter and, second, by compensating for the absence of an incentive to install capacitors to improve their power factors. The Distributor believes that these gaps create an upward pressure on costs which all of the Distributor’s customers ultimately have to Original : 2007-08-01 HQD-12, Document 1 Page 52 of 67 Hydro- Québec Distribution R-3677-2008 Application assume. To compensate for these gaps the Distributor therefore proposes a reform, starting April 1, 2009, which deals with many aspects of the capacity invoice. With the aim of improving the price signal to ensure better management of capacity requirements, the Distributor proposes to bill for capacity that exceeds 50 kW annually. This modification will then make it possible for the demand charge to fulfill its role throughout the year. To limit rate impacts, it is proposed to introduce a demand charge of 63¢/kW34 that would apply during the summer period starting April 1, 2009, and to increase this demand charge every year until it reaches the level of the winter demand charge. The projected annual increase is currently 63¢/kW; however, the Distributor does not exclude the possibility of accelerating this reform in accordance with customers’ consumption management efforts. In order for the summer demand charge to reach the level of the winter demand charge, the Distributor proposes to freeze the winter demand charge at the applicable rate on April 1, 2008. However, this freeze does not mean that the Distributor has renounced increases in the price signal of the winter demand charge. Rather, the Distributor prefers that this objective be achieved via the introduction of an automatic mechanism to set a minimum billing demand, equal to 65% of the maximum power demand that falls wholly in the winter period. When the summer demand charge reaches the level of the winter demand charge, it will be $6.21/kW throughout the year, which is equivalent to paying 1.84¢/kWh35 more for consumption that exceeds the second energy block. Billing for capacity on an annual basis therefore makes it possible to more rapidly improve the price signal of customers whose consumption exceeds 50 kW. For example, a demand charge applicable only during the winter period would have 34 10% of the winter demand charge applicable on March 31, 2009 under the condition that the result is divisible by 30. 35 Using a 47% load factor applicable to consumption exceeding 50 kW. Original : 2007-08-01 HQD-12, Document 1 Page 53 of 67 Hydro- Québec Distribution R-3677-2008 Application to be $18.73/kW to obtain an equivalent price signal. However, even at that level the demand charge would not provide any incentive to customers to manage their summer consumption. With the aim of eliminating the injustice created by the fact that, contrary to general rates, only actual power demand is billed under rate D, the Distributor recommends the introduction, starting April 1, 2009, of billing apparent power demand to customers whose power factor is below 90%. The Distributor also proposes that the capacity invoice for Rate DM be equivalent to the capacity invoice for Rate D. Therefore, the Distributor proposes to set the demand charge for Rate DM on April 1, 2009 to the level of the demand charge for Rate D and to apply the elements of the capacity reform proposed for Rate D.36 In addition to harmonizing the capacity invoices of Rates D and DM, the proposed reform also makes it possible to improve the price signal for capacity which will provide an incentive to apartment buildings to better manage their capacity. However, to limit the rate impacts resulting from an increase of the demand charge for customers billed at Rate DM, the Distributor proposes the introduction of a new level to the capacity invoice per dwelling. The demand charge for Rate DM would thereby apply when the maximum power demand exceeds the higher of the following values: 50 kW, or the product of the level per dwelling and the multiplier. The Distributor sets this level at 4 kW per dwelling to ensure the neutrality of revenues for capacity. In fact, the current demand charge for Rate DM applied to the portion exceeding 50 kW generates the same revenues for capacity as an equivalent demand charge for Rate D applied on the portion exceeding the higher of: 50 KW and the product of 4 kW and the number of dwellings. 36 Annual capacity invoice, introduction of an automatic mechanism to set minimum billing demand and billing apparent power demand. Original : 2007-08-01 HQD-12, Document 1 Page 54 of 67 Hydro- Québec Distribution R-3677-2008 Application In decision D-2008-024, the Régie found that an annual demand charge provides a better price signal because it adequately reflects the avoided costs for capacity and it gives customers more incentive to improve their power demand at all times. It also found that the rate impacts associated with such a reform were acceptable. The Régie selected the Distributor’s proposal for the reform of the capacity invoice. The Régie also selected the capacity reform proposal for Rate DM and it agreed to apply the elements of the capacity reform proposed for Rate D to Rate DM. Since the demand charges that apply to Rate DT for customers who are, respectively, metered individually or collectively are already equivalent to those of Rates D and DM, the Distributor proposes that the elements for the reform of the capacity invoice also be extended to Rate DT. 2.3.3.4 Evolution of Domestic Rates in the Short and Medium Terms The following tables show Rates D, DM and DT respectively on April 1, 2009 and they include a 2.2% increase as well as all the other elements of the domestic rate reform. The Distributor also shows the evolution of rates D and DM using the hypothesis of a 2% increase in 2010 and 2011. Original : 2007-08-01 HQD-12, Document 1 Page 55 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 29 Example of the Evolution of the Rate Structure for Rates D and DM Customer charge (¢/day) Rates D and DM Current- April 1 2008 40.64 st nd 1 bloc 2 Rate Structure bloc Ratio nd st 2 /1 ¢/kWh 5.40 D Demand DM Demand Charge Charge $/kW 7.33 1.36 D 6.21 DM 1.53 Winter Summer - Proposed RatesApril 1 2009 2.2% 40.64 0.0% 5.49 1.7% 7.56 3.1% 1.38 6.21 0.0% 0.63 - April 1 2010 – 2% 40.64 0.0% 5.57 1.5% 7.78 2.9% 1.40 6.21 0.0% 1.26 100.0% April 1 2011 – 2% 40.64 0.0% 5.65 1.4% 8.00 2.9% 1.42 6.21 0.0% 1.89 50.0% TABLE 30 Rate DT Proposed for April 1, 2009 Rate Structure Customer charge (¢/day) Peak Rate DT Current - April 1, 2008 Proposed Rates April 1 2009 – 2.2% Off-Peak ¢/kWh Ratio nd st 2 /1 Demand Charge $/kW 40.64 4.33 17.55 4.05 Individual Metering 6.21 40.64 4.33 18.59 4.29 Winter Summer 0.0% 0.0% 5.9% 6.21 0.63 Collective Metering 1.53 2.3.3.5 Implementation of the Domestic Rate Reform Contrary to the reform of general rates discussed in the following sections, there is no element of the domestic rate reform that involves the systematic transfer of customers from one rate to another. Thus, it is essentially the reform of the capacity invoice that requires special attention to its implementation. Original : 2007-08-01 HQD-12, Document 1 Page 56 of 67 Hydro- Québec Distribution R-3677-2008 Application As mentioned in rate application R-3644-2007, the Distributor believes that the impact of changes made to the capacity invoice can be minimized. The implementation the Distributor proposes consists of using targeted communication to advise domestic customers that will potentially be affected of how they may change their consumption behaviour to minimize the impact of the reform to the capacity invoice and to inform them that they can benefit from technical support from the Distributor’s representatives. These behaviours mainly consist in optimizing their power demand or installing capacitors if required. 2.4 General Rates 2.4.1 Rates and Customer Description 2.4.1.1 Rate L Rate L, shown in Table 31, applies to large power customers whose minimum billing demand is 5 000 kW or more. It is expressed in low voltage. Therefore, credits for supply at medium or high voltage are given to customers so that costs generated by lower voltage networks are not transferred onto customers using a higher voltage. TABLE 31 Rate L on April 1, 2008 Demand charge Price of energy Optimization charge (in winter) Daily Monthly limit $12.18/kW 2.91¢/kWh $7.11/kW $21.33/kW From May 1, 2007 to April 30, 2008, 236 contracts were used to analyse Rate L. Total annual consumption totalled 45.3 TWh, for annual revenues of $2.1 billion. Table 32 shows a summary description of customers subject to Rate L. Original : 2007-08-01 HQD-12, Document 1 Page 57 of 67 Hydro- Québec Distribution R-3677-2008 Application The latter part of section 2.4.1.1 until the end of section 2.4.3.4 are not included in the translated version of this document. Hereafter is a translated version of Chapter 3, sections 3.1 to 3.2.2.1 Original : 2007-08-01 HQD-12, Document 1 Page 58 of 67 Hydro- Québec Distribution R-3677-2008 Application 3. IMPACTS OF THE RATE INCREASE 3.1 Projected Revenues by Rate class and Component The proposed 2.2% increase allows for an overall increase of the Distributor’s revenue of $207 million in 2009 of which $141 million between April 1 and December 31, 2009. Table 59 shows the details of the $141 million by rate class. TABLE 59 Revenues by Rate Class in 2009 ($M)1 Without the increase on April 1, 2009 Including the increase on April 1, 2009 Difference Domestic 4,317 4,377 60 Small Power 1,362 1,384 21 Medium Power 1,905 1,936 31 Large Power 1,820 1,850 30 9,405 9,546 141 1,053 1,053 N/A 1 1 0 Total – Regular Rates Special Contracts Consumption management and Back-Up Energy Source Rates Total 10,459 10,6002 185 Notes: 1) Results may not tally due to rounded data. 2) Excluding the $65.6 million regulatory provision coming for the months of January to March 2009. Original : 2007-08-01 HQD-12, Document 1 Page 59 of 67 Hydro- Québec Distribution R-3677-2008 Application 3.2 Customer Bills 3.2.1 Domestic Rates 3.2.1.1 Distribution of Rate Impacts Table 60 shows a distribution of the rate impacts on domestic customers. Almost 91% of customers are subject to a rate impact that ranges between 1% and 3%. Moreover, the bill for 52% of customers, represented by small customers, will be subject to an annual increase of less than 2%. Appendix C shows a more complete distribution of the impacts on domestic customers. TABLE 60 Annual Impact of a 2.2 % Rate Increase: Rate D Variation of the annual bill (%) Less than 1 (min:0) From 1 to 2 From 2 to 3 From 3 to 4 From 4 to 5 From 5 to 6 6 and over (max: 9.8) Total Customer allocation (%) 9.3 42.7 47.9 0.1 0.0 0.0 0.0 100.0 3.2.1.2 Impact on Monthly Bills The following table shows the impact of the proposed rate increase on monthly bills for typical consumption levels. The bill increases observed range between 1.2% and 2.6%. Appendix D shows the impact by typical consumption level and by rate component. Original : 2007-08-01 HQD-12, Document 1 Page 60 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 61 Monthly Impacts Using Typical Consumption Levels – Rate D Energy Bill at the proposed rate $ Variance Variance kWh Bill at the current rate $ $ % 625 750 1 000 2 000 3 000 45.94 52.69 68.12 141.42 214.72 46.50 53.37 69.16 144.76 220.36 0.56 0.68 1.04 3.34 5.64 1.2 1.3 1.5 2.4 2.6 3.2.1.3 Impact on the Average Customer Table 62 shows the impact of the proposed increase on the electricity bills of domestic customers. For the average domestic customer, the monthly electricity bill increases by $2.27. TABLE 62 Impacts of the Proposed Increase on the Average Monthly Bill For Domestic Customers (Rate D) Average Annual Consumption Based on 2007-2008 Monthly Bill ($) Proposed rate incl. Current rate 2.2% increase Customer average (17 056 kWh) Customer average for customers heating with electricity (18 953 kWh) Customer average for customers not heating with electricity (12 576 kWh) Customer living a single-family home heated with electricity (26 484 kWh) Original : 2007-08-01 Increase ($) Increase (%) 102.66 104.93 2.27 2.9 113.27 115.81 2.54 2.2 77.70 79.29 1.59 2.0 156.59 160.39 3.80 2.4 HQD-12, Document 1 Page 61 of 67 Hydro- Québec Distribution R-3677-2008 Application 3.2.1.4 Impact on Typical Home Types As an example, Table 63 shows the impacts of the rate increase on certain typical homes. The table shows that customers that live in an apartment will be subject to an increase of 1.7% while customers that live in an imposing home will be subject to an increase of 2.8%. TABLE 63 Impact of the Proposed Increase on Typical Domestic Homes Rates D and DM Current-April 1, 2008 Proposed rateApril 1, 2009 Average Rate D Customer 17 056 kWh Apartment $1232 $817 $1,448 $36 $14 2.2% 1.7% 11 590kWh Small Home Average Home -Heated with 20 494 kWh 26 484 kWh Large Home electricity32 054 kWh Very Large Home 42 818 kWh Imposing Home 62 840 kWh Large Customer 100 kW 411 700 kWh $1,879 $ 2,287 $3,076 $4,543 $32 $46 $58 $83 $129 2.2% 2.4% 2.6% 2.7% 2.8% Customer 1st Block Apartment Building 10 950 kWh 124 160 kWh $31,367 $740 $8,759 $1,188 $10 $196 3.8% 1.3% 2.2% 3.2.1.5 Impact on Low-Income Customers As per the Government’s request in its energy strategy, the Distributor shows the impact of the rate increase on low-income customers. The Distributor has little data on the income of its residential customers and the data from surveys that were carried out for other ends is often incomplete and not valid as far as the respondents’ income is concerned. It is in fact a delicate question to which respondents are not always inclined to respond. Moreover, a household’s income is not the sole variable that determines whether or not a household is in need. Original : 2007-08-01 HQD-12, Document 1 Page 62 of 67 Hydro- Québec Distribution R-3677-2008 Application In order to evaluate the impact of the rate increase on low-income customers, the Distributor used the latest available data from Statistics Canada pertaining to household expenses (2006 data). This data provides the annual expense for several goods and services by income category. The Distributor asked Statistics Canada to carry out a distribution of electricity expenses according to the decile of the household’s income. Therefore, if all households are classified according to their income, from the lowest to the highest, the first decile includes the 10% of households that have the lowest income, the second decile includes the next 10% and so on. The following Table shows the deciles used for 2006 as well as average electricity expenses, including taxes, for the households that claimed to have electricity expenses. TABLE 64 Description of the Deciles Used Annual Household Income $ first decile second decile third decile 4th decile 5th decile 6th decile 7th decile 8th decile 9th decile 10th decile 15,180 or less 15,180 – 23,036 23,036 – 29,000 29,000 – 37,134 37,134 – 46,515 46,515 – 57,141 57,141 – 68,600 68,600 – 84,280 84,280 – 113,000 113,000 and over Average Annual Electricity Expenses 874 997 1,131 1,162 1,169 1,324 1,477 1,632 1,695 2,038 The Distributor also requested an index of the dispersion of electricity expenses for each decile. This allows it to evaluate the maximum impact by income level. The maximum level of expenses shows the upper bound that includes 95% of all respondents by decile. From this data, it is possible to draw an annual consumption profile (energy in the first and second blocks), which will be used to establish the impact of the rate increase by decile of income. Original : 2007-08-01 HQD-12, Document 1 Page 63 of 67 Hydro- Québec Distribution R-3677-2008 Application The following table very precisely shows the impact of the 2.2% rate increase by decile of income. The average impact on bills in the first four deciles ranges between 1.65% and 1.98%. Nevertheless, within each decile we note a variation in the impacts that reflects the variation in expenses. For example, for certain households within the first deciles for whom the energy bill is significant, the impact can exceed the average rate increase of all customers. The Distributor’s proposal to increase the second block twice as much as the first energy block means that households that have a large electricity bill – and thereby consume several kWh in the second block - will be subject to an increase that exceeds 2.2%. These are primarily households that have higher incomes. For their part, households that have lower electricity bills – and therefore consume fewer kWh in the second block – will be subject to a rate increase that is below 2.2%. It consists mainly of low-income households. On average, the Distributor’s proposal therefore attenuates the impact of the rate increase on lowincome households. Original : 2007-08-01 HQD-12, Document 1 Page 64 of 67 Hydro- Québec Distribution R-3677-2008 Application TABLE 65 Dispersion of Impacts of the 2009 Rate Increase Based on the Income Decile Increase of the Annual Bill 2009 vs. 2008 The strategy of applying a rate increase that is twice as significant for the second block began on April 1, 2006. The Distributor’s proposal for the 2009 rate year means that this strategy has been applied for four consecutive years. The following table shows the impacts for these four years based on 2005 expenses.37 It can be noted that, since 2005, the households in the first four 37 2005 data was used in rate application R-3644-2007 at Exhibit HQD-12, document 1. At the time the application was submitted, it was the most recent data available. Original : 2007-08-01 HQD-12, Document 1 Page 65 of 67 Hydro- Québec Distribution R-3677-2008 Application deciles have been subject to a cumulative rate increase below 12% while, over the same period, the households in the last deciles were subject to bill increases up to 15%. TABLE 66 Cumulative Dispersion of Impacts of the Rate Strategy Since 2005 Based on the Income Decile Cumulative Impact of the Rate Increase 3.2.2 General Rates 3.2.2.1 Distribution of Impacts For 2009, the Distributor proposes a rate increase only for the energy component. This choice is based on two main elements: the ratemaking reform Original : 2007-08-01 HQD-12, Document 1 Page 66 of 67 Hydro- Québec Distribution R-3677-2008 Application and the level of the requested rate increase. In fact, as per the rate reform, the elimination of the degressivity of Rates G and M requires a more significant increase of the rates in the second block starting in April 1, 2009. Because the level of the increase is relatively low the Distributor proposes an increase only in the energy component so that it may have enough latitude to apply a differentiated rate increase between both energy rates. Original : 2007-08-01 HQD-12, Document 1 Page 67 of 67