Via Email
February 28, 2011
To: British Columbia Hydro and Power Authority
Registered Interveners
Re: British Columbia Hydro and Power Authority
Project No. 3698592/Order G‐47‐10
F2011 Revenue Requirements Application
Participant Funding/Cost Award Budgets – Order G-72-07
In a letter dated January 5, 2011, the Joint Industry Electricity Steering Committee (JIESC) submitted its Participant Funding/Cost Award (PACA) funding claim for the British Columbia Hydro and Power Authority (BC Hydro) F2011 Revenue Requirements Application (F11 RRA Application). The letter noted that the Negotiated Settlement Process (NSP) came late in the process after the review of a complex application with serious issues, multiple rounds of Information Requests (IRs) and significant preparation for the hearing. The JIESC stated that the usual 2 to 1 formula of preparation days to hearing days was not commensurate with the effort required by Interveners and its costs were significantly higher than its submitted claim. The JIESC also requested that if the British Columbia Utilities Commission (Commission) were to vary from the usual formula, it be given the opportunity to resubmit its application.
In its letter of January 27, 2011, the Commission requested BC Hydro to comment on the PACA applications from the participants in the F 11 RRA proceeding. In its response, BC Hydro noted that it had filed over 30,000 pages of evidence in response to the 3 rounds of IRs and that the number of proceeding days (6.06 as advised by Commission staff) is reflective of the comparative brevity of a negotiation process as compared to an oral hearing. With respect to this, BC Hydro commented that “The BCUC may want to give some consideration as to whether the ratio of preparation days to proceeding days as prescribed in the BCUC PACA Guidelines (2 to 1) should be increased slightly in recognition of the substantial effort that had already occurred prior to the NSP, both in duration and scope of the proceeding.”
The Commission Panel acknowledges that the amount of effort required to review the materials in their entirety was time consuming, given the significant volume of information and the complex issues. As a consequence, the Commission Panel finds that the standard of two days preparation for each proceeding day is not reasonable in this instance and a ratio of 2.3:1 is more appropriate. This finding results in the Commission Panel setting a maximum eligibility of 20 days (13.94 for preparation and 6.06 for hearings) per participant to be considered for PACA cost awards.
In addition, the Commission Panel grants the request of the JIESC with respect to resubmission of its PACA application. Further, the option to resubmit PACA claims with justification and supporting invoices as a result of this change is open to all Interveners. Any such resubmissions must be made no later than Thursday, March 3, 2011.
Yours truly,
Erica M. Hamilton
DAC/ac