BC Hydro writes in compliance with Exhibit A-4 to provide its Final Submission in respect of the Application (Exhibit B-1).

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1 Ken Duke Solicitor & Counsel Phone: Fax: April 30, 2014 Sixth Floor 900 Howe Street Vancouver, BC V6Z 2N3 Dear Ms. Hamilton: RE: (BCUC) British Columbia Hydro and Power Authority (BC Hydro) Final Submission BC Hydro writes in compliance with Exhibit A-4 to provide its Final Submission in respect of the Application (Exhibit B-1). In the Application, BC Hydro asked the BCUC to approve three amendments to RS 1289: 1. Increase the capacity of an eligible RS 1289 Generating Facility from 50 kw to 100 kw 2. Allow BC Hydro to recover from RS 1289 customers the incremental costs caused by generators larger than 50 kw 3. Clarify that BC Hydro may recover incremental costs associated with synchronous generators and customers taking service at a primary potential, consistent with BC Hydro s practice since 2012 (the BCUC already approved the recovery of costs from these customers in 2012; BC Hydro is just proposing to clarify that these are intended to be incremental costs) The Application includes a brief background (pages 1 to 4) and describes stakeholder consultation leading up to the filing (page 4). The proposed capacity increase to 100 kw is discussed in section 4 of the Application (pages 4 to 9), including a discussion of the three BCUC criteria described in the 2012 Net Metering Decision, the general purpose of the Net Metering program, and the principle of rate simplicity. Section 5 of the Application sets out the reasons why BC Hydro has limited the size of eligible RS 1289 Generating Facilities to 100 kw. British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3

2 Final Submission Page 2 of 9 As expected, most of the Information Requests (IRs) and letters of comment received prior to this Final Submission focused on the proposed increase in the maximum capacity of an eligible RS 1289 Generating Facility. A number of the comments expressly state that the generator size should be increased beyond 100 kw (e.g., 250 kw or 500 kw). In the Application, BC Hydro evaluates the proposed increased in the capacity of Generating Facilities in the context of the three evaluation criteria set out in the 2012 Net Metering Decision, the purpose of RS 1289, and the objective of keeping the rate as simple as possible. The Application reflects a balance of all of these considerations. 1 BC Hydro will not repeat the details of the Application in this Final Submission. Instead, the Final Submission will focus on two key issues: 1. BC Hydro s current and proposed suite of small-scale (1 MW or less) distributed generation (DG) opportunities 2. The reason why BC Hydro limited the size of RS 1289 Generating Facilities to 100 kw Small-Scale Distributed Generation Opportunities for Customers Currently, BC Hydro customers who wish to install small-scale DG have the following opportunities: 1. Self-Generation Interconnection: Customers may install DG to supply part or all of their electricity needs without participating in a rate, program or energy procurement offer, provided they comply with BC Hydro s relevant interconnection requirements and pay any interconnection-related costs RS 1289: Customers may participate in RS 1289, provided the proposed generation uses a clean or renewable resource (as defined in the Clean Energy Act (CEA)) and the generator has a nameplate capacity of 50 kw or less and is installed at the customer s premises. Under this option, the customer may net their self-generation delivered to BC Hydro against electricity delivered by BC Hydro to the customer. The customer is paid for any net annual surplus self-generation delivered to BC Hydro based on the Energy Price in RS The Energy Price is approved by the BCUC and, in accordance with B.C. Government energy policy, is generally consistent with the Standing Offer Program (SOP) prices. All the terms and conditions of service are set out in the Electric Tariff; there is no separate interconnection agreement, electricity purchase agreement or load displacement agreement. 3. Standing Offer Program: Customers may apply to participate in the SOP, provided the proposed generation uses a clean or renewable resource (as defined in CEA), the nameplate capacity of the project is 15 MW or less, the customer s project is fully 1 2 Exhibit B-4, response to BCUC IR Exhibit B-4, response to BCUC IR

3 Final Submission Page 3 of 9 permitted and the customer meets all of the other requirements of the SOP. If successful, applicants enter into an electricity purchase agreement with BC Hydro (20 to 40-year term). This suite, or spectrum, of DG opportunities is currently available to BC Hydro s customers. As such, generator size is clearly not a barrier to the installation of small-scale DG in BC Hydro s service area. BC Hydro is aware that some larger customers, including local governments and First Nations, would like the opportunity to install larger generators to offset more of their electricity consumption and to sell more surplus electricity under RS BC Hydro is also aware, through consultation with customers and project developers, that there are concerns about the SOP, particularly in the context of small-scale DG. The concerns tend to focus on the complexity of the SOP (due diligence process, contracts etc.) and associated costs, particularly interconnection costs. Some of the written submissions filed in this proceeding illustrate these concerns. 3 In its 2013 Net Metering Evaluation Report No. 3 (2013 NM Report; Exhibit A2-1), BC Hydro proposed two actions in the context of small-scale DG to address the issues raised by customers, First Nations and stakeholders. First, BC Hydro proposed increasing the maximum capacity of an eligible Generating Facility in RS 1289 from 50 kw to 100 kw. Second, BC Hydro proposed the creation of a streamlined and simplified micro-sop for projects of 1 MW or less within the existing SOP. These action items were ultimately included in BC Hydro s 2013 Integrated Resource Plan (IRP), which was approved by the B.C. Government. The Application addresses the first action item. BC Hydro is currently working on the micro-sop and plans to launch it later in BC Hydro expects that the implementation of these two actions will address most of the concerns raised in respect of small-scale DG opportunities in BC Hydro s service area. Rationale for Limiting Capacity of RS 1289 Eligible Generators to 100 kw BC Hydro anticipates that there will be no significant opposition to the Application to increase the RS 1289 generator size and the real issue of debate is whether or not the increase to 100 kw is sufficient. The remainder of this Final Submission addresses why BC Hydro is not proposing a larger generator size for RS Context: Since RS 1289 was established in 2004, the maximum size of eligible generators has been 50 kw. Ten years later, more than 70 per cent of RS 1289 customers use generators of 5 kw or less and more than 90 per cent use generators with a capacity of 25 kw or less. BC Hydro has received only a few enquiries from customers who wish to install generators larger than 50 kw Exhibit A Net Metering Evaluation Report and Exhibit B-1 at page 2-3. Exhibit B-1 at page 1.

4 Final Submission Page 4 of 9 BC Hydro does not expect that an increase in the maximum eligible generator size to 100 kw will have an appreciable effect on the amount of RS 1289 installed capacity or self-generated energy. 5 As noted in the Application and responses to IRs, the vast majority of RS 1289 customers are residential and use photovoltaic (PV) solar electricity generation. PV solar will likely continue to be the predominant technology used by RS 1289 customers to self-generate electricity. Other than cost, a key barrier to PV solar installation is the size of the customer s premises (e.g., the area of a customer s residential roof on which the customer may install PV solar panels). BC Hydro is advised that about 30 to 60 square meters is required per kw of installed PV solar capacity. 6 Clearly, this is a limiting factor on the size of generator used by residential customers, regardless of the maximum eligible capacity in RS The main beneficiaries, therefore, of an increase in generator size will likely be larger general service customers with large premises (e.g., commercial, industrial, institutional, local governments and First Nations) and those who are proposing to use technologies other than PV solar. Other Jurisdictions: BC Hydro notes that the proposed increase in RS 1289 eligible generator size would place BC Hydro at the higher end of net metering programs in Canada. 7 Purpose of RS 1289: As noted in the Application and IR responses, the primary purpose of RS 1289 is to provide customers the opportunity to offset part or all of their electricity demand in a simple and cost-effective manner. In BC Hydro s view, the customer s decision to participate in RS 1289, and the size of the generator the customer installs, is largely determined by total project costs (primarily, the cost of the installed generator and any related interconnection costs) relative to the customer s avoided electricity bill costs and considerations related to the specific technology such as the size of the customer s premises. The Energy Price paid for annual surplus deliveries is also relevant, but very few customers actually sell electricity to BC Hydro under RS As discussed, the vast majority of RS 1289 customers are residential customers. The current 50 kw capacity limit is three or four times larger than is necessary to allow a residential customer to offset all of the customer s average annual electricity consumption which likely explains why more than 90 per cent of RS 1289 generators are less than 25 kw Exhibit B-5, responses to BCPSO IRs and 1.4.4, responses to BCSEA IRs and Exhibit B-5, response to BCSEA IR Exhibit A2-1 at page 27. Exhibit B-4, response to BCUC IR

5 Final Submission Page 5 of 9 The proposed 100 kw limit is also generally sufficient to allow Small General Service (SGS) to offset all or most of their average annual electricity consumption. 100 kw is sufficient for Medium General Service (MGS) customers provided the capacity factor for their generators is about 20 per cent or more. BC Hydro notes that First Nations and local governments are typically in the SGS and MGS class. 9 The proposed 100 kw capacity limit is not sufficient, however, for Large General Service (LGS) customers to offset their average annual electricity consumption (generators would have to be sized between 0.5 and 2.0 MW depending on capacity factor assumed). 10 Again, BC Hydro notes that there is no general prohibition against, for example, a General Service customer connecting a 0.5, 1.0 or 2.0 MW generator at its premises to allow it to self-generate electricity for its own consumption, provided the customer satisfies BC Hydro s interconnection requirements and pays any associated interconnection costs and system upgrades. Alternatively, the customer could apply to participate in the SOP, provided the customer complies with the SOP rules and requirements. The customer cannot, however, participate in RS 1289 with generators of this size. Projects over 100 kw typically attract more due diligence, commercial and interconnection complexities that are not compatible with the simple RS 1289 rate but which can be accommodated through other processes, such as the proposed micro- SOP. The following discussion particularly focuses on the interconnection complexities. Interconnection Requirements: Interconnection requirements and costs for generators that wish to interconnect to BC Hydro s distribution system are independent of RS 1289 or the SOP. These requirements are very important and have been developed to ensure that generators connecting to BC Hydro s system do so safely and without adversely affecting system reliability. Generally, interconnection requirements are different depending on the size of the generator; the rate, program or offer is not relevant. The Net Metering Interconnection Requirements for 50 kw and Below (NMIR/50) for example, are simplified requirements that apply to all generators that are 50 kw or smaller, regardless of whether the generator is participating in RS 1289 or not. Generators larger than 50 kw are subject to more complex and generally more costly interconnection requirements due to their larger potential impact on the safety and reliability of BC Hydro s distribution system. Larger generators may be required, for example, to undertake system impact studies. These studies may be time consuming, costly, and may require the customer or developer to pay significant interconnection and system upgrade costs to ensure that 9 10 Exhibit B-4, response to BCUC IR Exhibit B-4, response to BCUC IR

6 Final Submission Page 6 of 9 the generators do not adversely affect the safety and reliability of BC Hydro s system and the electricity service enjoyed by other BC Hydro customers. 11 Increasing the eligible generator size in RS 1289 does not change the interconnection requirements applicable to the generator. If BC Hydro s interconnection requirements mandate that a 0.5 MW generator requires a system impact study or certain system upgrades at the customer s cost, the study and upgrades would be required regardless whether the generator participates in RS 1289 or the SOP. As noted at page 9 of the Application, BC Hydro is proposing to adapt the current NMIR/50 interconnection requirements (which apply to all generators up to 50 kw, regardless whether or not they participate in RS 1289) so they apply, with some amendments, to generators up to 100 kw. The current interconnection requirements applicable to generators up to 50 kw have significantly contributed to the simplicity and efficiency of RS 1289 because they streamline the review and approval process for very small generators that wish to interconnect to BC Hydro s distribution system. The application of these interconnection requirements to generators up to 100 kw (with some modifications) is a major reason why BC Hydro is comfortable proceeding with the Application to increase RS 1289 eligible generator capacity to 100 kw. Section 5 of the Application (pages 11 to 14) sets out some of the technical and safety reasons why the proposed simplified interconnection requirements are not being applied to generators larger than 100 kw. The issue is also discussed in some detail at pages 35 to 39 of the 2013 NM Report. Generally speaking, generators above 100 kw have a greater risk of affecting the safety and reliability of BC Hydro s system, and thus other customers, and therefore may require more study, more time and effort, and potentially considerably more cost to the customer. Finally, while the size of generators generally determines which interconnection requirements apply, the location of the generator is also very important. It is possible, for example, for a 0.5 MW or 1.0 MW generator located in location A to pass through BC Hydro s screening process with minimal study requirements and costs while the exact same size generators in location B may require significant studies and costs. These locational differences are very important. 12 It is BC Hydro s view that location is much less likely to be a major issue for generators 100 kw and less because of their small size and typical impact on the system. Rate Simplicity: As discussed in the Application, BC Hydro, participating customers and other stakeholders appear to agree that a significant benefit of RS 1289 is the Exhibit B-1, pages 11 to 40, Exhibit B-4, responses to BCUC IRs and , Exhibit B-5, responses to BCSEA IR and MGH IR 6.0. Exhibit B-4, response to BCUC IRs , and , Exhibit B-5 responses to BCPSO IRs and

7 Final Submission Page 7 of 9 simplicity of the rate: it is inexpensive for BC Hydro to implement and administer; the interconnection requirements applicable to RS 1289 eligible generators are straightforward; and the application process is low cost, efficient and timely. As discussed above, BC Hydro is proposing to adapt the current NMIR/50 interconnection requirements so they apply to generators up to 100 kw. These adapted interconnection requirements will ensure that the simplicity of RS 1289 is not affected by an increase in the generator size. Generators larger than 100 kw increase the risk of system impacts. If such generators were allowed to participate in RS 1289, the associated interconnection process would be more complex, time-consuming and potentially more costly. It is BC Hydro s view that these interconnection requirements would adversely affect the simplicity of RS 1289 by significantly lengthening and complicating the application process. RS 1289 generators would not be approved to participate in RS 1289 unless and until all of the interconnection requirements, studies and upgrades were completed with all costs paid by the customer. 13 Also, as noted in section 5 of the Application, if the eligible RS 1289 generator size is increased, BC Hydro may have to import various commercial, development and risk mitigation measures and terms and conditions from the SOP into RS 1289, which may further compromise the simplicity of the rate. Electricity Sales under RS 1289: Some of the comment letters submitted in this proceeding indicate that there may be a misunderstanding about electricity sales under RS The primary financial benefit of RS 1289 to customers is reduced electricity bills. If the customer delivers more electricity to BC Hydro in a month than BC Hydro delivers to the customer, the difference is banked and applied against future bills. The customer is only paid the Energy Price on an annual basis if there is a net credit balance in the customer s energy account at the end of the year. That is, if a customer delivers more electricity to BC Hydro over the course of a full year than BC Hydro delivers to the customer, BC Hydro pays the customer for the net amount of electricity at the Energy Price in the Electric Tariff (9.99 cents per kwh). This payment is only made once per year at the customer s anniversary date in the Net Metering program and not on a monthly basis, as it would be the case under an electricity purchase agreement. Very few BC Hydro customers are paid the Energy Price because very few offset all of their annual electricity deliveries from BC Hydro. BC Hydro expects that the structure of the Net Metering program, the lack of a long-term contractual commitment, and the once-per-year payment of the Energy Price may not provide the commercial certainty customers require to finance larger projects (e.g., 0.5 or 1.0 MW) where the customer does not have the resources to self-finance or does not have access to government funding or subsidies. 13 Exhibit B-4, response to BCUC IR 1.7.2, Exhibit B-5, response to BCSEA IR

8 Final Submission Page 8 of 9 The purpose of the Net Metering program is not to incent or encourage surplus electricity sales to BC Hydro. BC Hydro submits that the BCUC should not, and in fact cannot, mandate an increase in the eligible capacity of RS 1289 generators if the primary purpose is to sell more customer-generated electricity to BC Hydro. The decision whether or not to purchase electricity from a customer, an independent power producer or anyone else is a BC Hydro management decision. The SOP is the appropriate program for customers who wish to develop DG for the primary purpose of selling electricity to BC Hydro. 14 Micro-SOP: As noted above and in the IRP, the Application and BC Hydro s responses to IRs, BC Hydro is in the process of developing a micro-sop as part of the existing SOP. The micro-sop will be available to generators up to 1 MW that meet the eligibility requirements of the new program. It is hoped that the micro-sop will streamline the application and pre-contract award processes, reduce the complexity of existing contracts, and lower transaction costs. BC Hydro is also reviewing its interconnection processes applicable to generators less than 1 MW. 15 As discussed earlier, interconnection requirements are independent of the BC Hydro rate, program or offer. The micro-sop will be launched in 2014 and BC Hydro expects that it will address a number of concerns relating to the SOP, while providing the commercial certainty necessary to projects that may require third party financing or support. BC Hydro submits that it would be premature to consider further increases to the RS 1289 generation capacity beyond the proposed 100 kw size until BC Hydro and customers have some experience with the micro-sop. Rate Design and Pricing A number of IRs focused on the pricing of Net Metering energy and other rate design issues. In BC Hydro s submission, pricing and rate design are not within the scope of the Application. Nonetheless, BC Hydro endeavoured to answer all of the IRs, even if they were out of scope. BC Hydro makes the following brief comments on RS 1289 rate design and pricing: Under RS 1289, the customer s retail credit is basically a bill reduction based on the customer s retail rate for electricity from BC Hydro, consistent with the structure and purpose of Net Metering. The Energy Price is based on SOP prices consistent with B.C. Government policy. The design of RS 1289 and the Energy Price were not determined based on the energy value to BC Hydro Exhibit B-5, response to BCSEA IR Exhibit B-4, response to BCUC IR , Exhibit B-5, responses to BCSEA IRs and

9 BChgdro April 30, 2014 Final Submission "' "' Page 9 of 9 The energy delivered from the Net Metering program is uncertain given the absence of a delivery obligation and its intermittent nature. BC Hydro has not studied the characteristics of energy delivered from this program to determine its value because of the minimal energy volumes (i.e., 1.6 MW of installed capacity with capacity factors of between 10 to 40 per cent). Nevertheless, BC Hydro expects the value to be less than 10 cents per kwh. Given the minimal energy volumes from the Net Metering program, BC Hydro does not currently have any price-related concerns regarding RS1289. However, BC Hydro may need to address capacity cost recovery issues and the value of RS 1289 energy in the future should the energy volumes become material. 16 Conclusion In summary, BC Hydro's customers currently enjoy a seamless suite, or spectrum, of DG opportunities. They may install generators to self-supply electricity outside of a BC Hydro rate, program or offer; they can participate in RS 1289; or they can participate in the SOP. BC Hydro is proposing in the Application to increase the maximum capacity of an eligible RS 1289 from 50 kw to 100 kw, which may primarily benefit General Service customers (local governments and First Nations in particular) who wish to offset more of their electricity demand while, at the same time, maintaining a simple and efficient rate. BC Hydro is also in the process of developing a "micro-sop" component within the existing SOP for generators less than 1 MW for those who wish to install small-scale DG for the purpose of selling electricity to BC Hydro. The intent of the micro-sop is to streamline pre-contract award processes and reduce transactional costs. These two actions should, in BC Hydro's view, address concerns raised by some customers, First Nations and small-scale DG developers. For further information, please contact the undersigned. uke Solicitor & Counsel kd/ma Copy to: BC Hydro Application to Amend RS 1289 for Net Metering Service Registered Intervener Distribution List. 16 Exhibit B-4, responses to BCUC IRs 1.4.1, 1.4.3, and

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