IPPs request review of Integrated Electricity Plan
May 26, 2004
Mr. Robert Pellatt
Secretary,
British Columbia Utilities Commission
Sixth Floor, 900 Howe Street, Box 250
Vancouver, BC V6Z 2N3
Dear Mr. Pellatt
Re: Request for Public Planning Review of BC Hydro Integrated Electricity
Plan
The Independent Power Producers association of BC (IPPBC) requests that the BCUC conduct public a written and oral review that would focus on BC Hydro's current Integrated Electricity Plan.
Background: The government has amended the BCUC act requiring the commission to implement a review process for utility planning activities. BC Hydro has filed an Integrated Electricity Plan with the BCUC in March 2004.
There is some uncertainty as to how this Plan will be reviewed by the BCUC, particularly as it was submitted to the BCUC at the same time as the BCUC is conducting a hearing on BC Hydro's current rate application.
During this current rate application it is not clear whether interested parties can get their issues addressed where they concern BC Hydro's planning activities.
Many planning issues are not appropriately addressed as part of this rate hearing.
Justifications: A BCUC public review is needed so that the following issues can be properly addressed.
. Long term planning based on a high probability of power imports versus planning profile based on a high probability of power exports
. Cost premium for BC Clean power purchases.
. Cost and risk of obtaining power from conservation versus alternatives.
. The use of the Burrard Thermal Plant.
. The appropriate method for dealing with Gas Price risk, for gas power
purchases.
. The risks between large long-term projects like Site C and large numbers
of small IPP projects.
. The choice between upgrading transmission systems to Lower Mainland and
Vancouver Island versus providing incentives for IPPs to locate in Lower Mainland and Vancouver Island.
Many of these issues touch directly on cornerstones or Action Plans from the governments Energy Plan. If they are not adequately addressed in a public process that gives them sufficient attention (rather than being swept under the rate application process), key elements of the Energy Plan will falter.
Yours truly,
Steve Davis
President,
cc Intervenor List - BC Hydro Rate Application Hearing
Posted by Arthur Caldicott on 31 May 2004