floor, 1111 west georgia street ~ fortisbc- …...types of primary thermal energy source(s) and...
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10th Floor, 1111 West Georgia Street Vancouver, B.C. V6E 4M3 FAES Regulatory Affairs Correspondence Email: [email protected]
March 12, 2020 British Columbia Utilities Commission Suite 410, 900 Howe Street Vancouver, BC V6Z 2N3 Attention: Mr. Patrick Wruck, Commission Secretary and Manager, Regulatory Support Dear Mr. Wruck: Re: British Columbia Utilities Commission (BCUC) Review of Thermal Energy
Systems Regulatory Framework Guidelines (TES Framework)
Project No. 1599043
FortisBC Alternative Energy Services Inc. (FAES) Response to Final Terms of Reference – Exhibit A-7
FAES writes with respect to the BCUC’s correspondence of March 9, 2020 (Exhibit A-7), enclosing the Final Terms of Reference for this proceeding. Specifically, FAES responds to the following paragraph:
BCSEA submits that the inclusion of energy sources at a descriptive level would be useful for the Review. Both the City of Abbotsford and Mr. Flintoff support BCSEA’s suggestion. By letter dated March 5, 2020, BCSEA clarified its submission, stating that it recommends information be provided on TES that have been approved by the BCUC to date. BCSEA notes that the BCUC’s website only provides information on Stream B TES. The Panel believes that it would be beneficial for participants in the Review to be able to view approved Stream A applications, therefore all approved Stream A applications to date will be filed as an A2 Exhibit in the proceeding, prior to the scheduled workshop. [footnote references omitted]
The British Columbia Sustainable Energy Association (BCSEA) in its clarification submission (Exhibit C4-3) stated that:
...the TES Guidelines Review would benefit from information regarding the types of Primary thermal energy source(s) and Peaking/Backup energy sources for Thermal Energy Systems under the Commission’s jurisdiction. BCSEA expects that the Commission would be in the best position to assemble and provide this information, as the Commission will have received this information under the TES Stream A Registration form and in CPCN Applications for Stream B TESs.1
1 Exhibit C4-3, page 1.
C2-3
~ FORTISBc-Alternative Energy Services
March 12, 2020 British Columbia Utilities Commission BCUC TES Regulatory Framework Guidelines Review FAES Submission on Exhibit A-7 Page 2
FAES’s understanding of the BCSEA request is to have the information regarding Primary and Peaking/Backup energy sources for projects registered with the BCUC under Stream A assembled, but not that it requires access to the approved Stream A applications and for those documents to be put on the record as exhibits in this proceeding. FAES has undertaken the assembly of the information requested by the BCSEA and included it in Appendix A to this letter. Appendix A is FAES’s most recently filed Stream A TES Annual Report2 with added columns to address the technology and fuel sources for each of its Stream A facilities. FAES believes that the information provided in Appendix A adequately addresses the BCSEA’s request as it relates to FAES’s Stream A TES projects. FAES notes that it is in receipt of an email from the BCUC received on March 11, 2020 at 4:02pm referencing Exhibit A-7, wherein the BCUC is providing applicants an opportunity to provide redacted public versions of their applications where necessary and to explain all confidentiality requests. FAES requests that the matter of whether it remains necessary to publicly disclose additional information about the Stream A projects be discussed further during the workshops if, after reviewing the information provided in Appendix A, the BCUC still deems it necessary. Further, FAES is of the view that it is not necessary to publish these documents in advance of the workshop discussions. Moreover, the format of the registrations and annual reports, along with the live question of whether all Stream A projects have actually been registered will be discussed during the workshops according to the final Terms of Reference issued in Exhibit A-7 sections 4, 5, 10, 12(a), 12(d)(i) and 12(d)(ii). Given that FAES has the most approved Stream A projects, FAES is making this request to discuss at the workshop whether public disclosure of further Stream A project information is necessary prior to undertaking the administrative burden involved in reviewing and redacting those documents. Nonetheless, FAES appreciates the opportunity to redact any of its commercially sensitive information prior to the BCUC publishing its approved Stream A registrations. If you require further information or have any questions regarding this submission, please contact Grant Bierlmeier at (604) 443-6548. Sincerely, FORTISBC ALTERNATIVE ENERGY SERVICES INC. Original signed: Lloyd Jacobs General Manager cc (email only): Registered Parties Attachment
2 FAES Stream A TES Annual Report for 2019, filed February 11, 2020.
~ FORTIS BC"
Appendix A
STREAM A TES – 2019 ANNUAL REPORT TECHNOLOGY & FUEL SOURCES
Stream A TES – 2019 Annual Report (Technology & Fuel Sources)
Applicant Information
Company Name: FortisBC Alternative Energy Services Inc. (FAES)
BC Business Registration No.: BC0746680
Contact Name: Grant Bierlmeier Contact Email: [email protected]
Contact Address: FortisBC Alternative Energy Services Inc. 10th Floor, 1111 West Georgia St. Vancouver, BC V6E 4M3
Contact Phone: (604) 443-6548
Name of Parent Company if applicable: FortisBC Holdings Inc.* 10th Floor, 1111 West Georgia St. Vancouver, BC V6E 4M3 *Note: A wholly-owned subsidiary of Fortis Inc.
Jurisdiction of Incorporation: British Columbia
Energy Delivered 2019
Stream A Facility Name
# of Customers Technology
Fuel Source (Primary/Peaking)
Energy Deliveries (GJ) Sales ($)
Flatiron1 1 GSHP Electricity/NG 2,866 132,253
Pomaria 1 1 GSHP Electricity/NG 4,732 93,385
The Hudson 1 1 GSHP Electricity/NG 5,515 60,513
Alysen Place 1 1 GSHP Electricity/NG 8,428 115,762
Waterstone Pier 1 1 GSHP Electricity/NG 5,863 114,000
Tsawwassen Springs1 1 GSHP Electricity/NG 3,127 61,127
Glen Valley1 1 GSHP Electricity/NG 3,200 62,358
Brant1 1 GSHP Electricity/NG 909 17,764
Camden Green1 1 GSHP Electricity/NG 1,523 31,631
Helen Gorman1 1 GSHP Electricity/NG 915 23,127
Artemisia 1 GSHP Electricity/NG 1,026 28,198
TELUS Gardens 3 DCWHR Electricity/Steam 55,180 2,309,423
Sovereign 3 HP Electricity/NG 29,326 811,817
Seylynn Phase 1 1 VRF Electricity/NG 5,930 269,170
Marine Gateway 4 GSHP Electricity/NG 38,078 1,303,389
SOLO Phase 1 2 GSHP Electricity/NG 15,593 774,357
Empire at QE Park 1 SHR Electricity/NG 7,343 248,597
Aperture 1 ASHP Electricity/NG 4,260 167,724
Seylynn Phase II 1 VRF Electricity/NG 5,930 195,373
Modello1 3 GSHP Electricity/NG 10,382 392,224
SOLO II Altus1 3 GSHP Electricity/NG 18,850 725,134
Chard Ellsworth1 1 ASHP Electricity/NG 3,402 116,388
Seylynn Phase III 1 VRF Electricity/NG 9,539 313,648
Lynn Valley I1 1 VRF Electricity/NG 4,270 147,236
Milano 1 ASVRF Electricity/NG 6,998 235,606
The Mahogany1 2 GSHP Electricity/NG 3,646 123,300
International Trade Centre1 2 HYD NG/Electricity 0 0
Imperial1 1 VRF Electricity/NG 2,747 92,313
Gold House North Tower1 2 ASVRF Electricity/NG 0 0
Gold House South Tower1 1 ASVRF Electricity/NG 0 0
Triomphe1 1 DHP Electricity/NG 0 0
Belpark1 1 HYD NG/Electricity 0 0
TOTAL STREAM A 47 259,578 8,965,817 1 Total Energy Deliveries estimated based on initial project studies
Attestations regarding Capital Reserve Provisions
I/We have determined the Capital Reserve Requirement and I/We have sufficient Capital Reserve Provisions as required; I/We will continue to maintain all records in the event of a complaint and an audit by the Commission. FAES has access to adequate resources to fund ongoing capital needs related to planned and unplanned replacement of assets. FAES has a growing portfolio of Thermal Energy Systems and plans for replacement capital in the forecast costs to provide the service. Also, FAES has access to capital as a wholly-owned subsidiary of Fortis Inc. As such, a capital reserve fund is not required.
Demand Side Management
I/We have taken demand-side measures during the period addressed by the report. If demand-side measures have been taken during the period addressed by this report, describe the effectiveness of those measures:
Technology Glossary:
ASHP – Air Source Heat Pump
GSHP – Ground Source Heat Pump
DCWHR – Data Centre Waste Heat Recovery
SHR – Sewer Heat Recovery
VRF – Variable Refrigerant Flow
DHP – Distributed Heat Pumps
HYD - Hydronic