19900 84th Avenue Langley, British Columbia

Canada V2Y 3C2

T 604.455.3600 F 604.455.3628

www.corix.com

1

January 12, 2021

British Columbia Utilities Commission Suite 410, 900 Howe Street Vancouver, British Columbia V6Z 2N3

Attention: Marija Tresoglavic, Acting Commission Secretary

Dear Ms. Tresoglavic: Re: British Columbia Utilities Commission Review of Thermal Energy Systems Regulatory Framework Guidelines Corix Multi-Utility Services Inc. Submission on Further Process

On December 11, 2020, the British Columbia Utilities Commission (“BCUC”) issued a letter (Exhibit A-21)

regarding the written submissions by interveners in the subject proceeding. In the December 11th letter

the BCUC requested interveners comment on the merits of the following:

1. Undertaking the Review in two stages, specifically:

a. Addressing items 1 to 3 of the Updated Terms of Reference (Part One);

b. Addressing the remaining items 4 through 13 (Part Two); and

2. Holding one or more further workshop(s) to review draft proposals for addressing items in Part One and/or Part Two.

Corix hereby provides it submissions on the two items.

(1) Undertaking the Review in two stages

While a two-stage process would increase the efficiency of the review, it is important to note that some

topics in items 4 through 13 of the Updated Terms of Reference1 (“TOR”) are interconnected with topics

in items 1 through 3 of the TOR. Due to this interconnected nature, it would not be appropriate to make

any determinations on items 1 through 3 without taking into consideration submissions on all topics (1

through 13). Adequate consideration of the Scaled Framework (item 1), Exemption Thresholds (item 2)

or Stream A Exemption (item 3) relies on consideration of the rate setting principles (item 7), complaint

processes (item 8) and issues with the current extension tests for each class of TES (item 9). For

example, the manner in which complaints or extension requests are addressed for Stream A Thermal

Energy Systems (“TES”) may support or negate an issue or solution raised with respect to any of the

items 1 through 3.

1 BCUC Review of Thermal Energy Systems Regulatory Framework Guidelines, Appendix A to Exhibit A-14.

C11-4

cor1x®

19900 84th Avenue Langley, British Columbia

Canada V2Y 3C2

T 604.455.3600 F 604.455.3628

www.corix.com

2

Corix submits that any determinations on the Scaled Framework (item 1), Exemption Thresholds (item 2)

or Stream A Exemption (item 3) should consider all relevant information, some which would be found in

items 4 to 13 of the TOR. Undertaking the review in two separate and distinct stages, where early

determinations on items 1 through 3 do not consider submissions on items 4 through 13 could lead to

suboptimal determinations that do not appropriately address issues raised in the proceeding.

Further Process

Given the above, Corix considers that the following two-stage approach could increase the efficiency of

the review while ensuring that adequate consideration is made prior to any determinations in this

proceeding.

Stage 1

i. Interveners make submissions on all topics in the TOR (items 1 through 13).

ii. The BCUC Panel issues a partial decision (or early determinations) addressing items 1 through 3 and any other items the Panel deems appropriate.

Stage 2

i. The BCUC provides a strawman draft containing proposed updates to the TES Guidelines which include wording to address:

a. Early determinations; and b. Intervener submissions on all outstanding items that did not receive an early

determination.

ii. BCUC Workshop to review the strawman draft with proposals to update the TES Guidelines (discussed below).

iii. Interveners make submissions on the strawman draft TES Guidelines.

iv. The BCUC Panel issues a final decision approving the updates to the TES Guidelines.

Corix has presented a high-level approach and notes that each stage could allow for intervener

evidence, information requests and final submissions.

(2) Future Workshop(s)

A future workshop to review draft proposals for the TES Guidelines would be helpful to increase

participants’ understanding of the draft proposals.

Many TES Providers are effectively small utilities with limited resources, some of which are working on

multiple BCUC proceedings simultaneously. As such, Corix respectfully requests that participants be

provided a copy of the draft TES Guidelines, with proposals as tracked changes, at least 3 weeks prior to

the corresponding workshop. This provides interveners time to review the proposals and prepare for the

workshop.

cor1x®

19900 84th Avenue Langley, British Columbia

Canada V2Y 3C2

T 604.455.3600 F 604.455.3628

www.corix.com

3

All of which is respectfully submitted, Corix Multi-Utility Services Inc.

Per:

Errol South Senior Regulatory and Financial Analyst, Energy Services Canada

COrlX®

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