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BCSEA comments on BC Hydro’s Draft Integrated Resource Plan

Bill Andrews, BCSEA’s lawyer in BCUC proceedings
Wednesday, September 1, 2021

BCSEA comments on BC Hydro’s Draft Integrated Resource Plan

September 1, 2021

BCSEA recently provided high-level comments on BC Hydro’s draft 2021 Integrated Resource Plan:

  1. BCSEA strongly supports BC Hydro's conventional DSM activity and commends BC Hydro for including "Higher Energy Efficiency" in planned resources. (Conventional demand-side management refers to energy conservation and efficiency, as distinct from low-carbon electrification which has recently come under the umbrella of DSM.)
  2. BCSEA acknowledges that BC Hydro will include a 5-year Electrification Plan in the upcoming F2022-F2025 Revenue Requirement Application. However, BCSEA believes the IRP should do more than merely treating low-carbon electrification as an uncertainty factor affecting the load forecast. Rather, BCSEA believes the IRP should identify long-term low-carbon electrification targets that correspond to achievement of the BC Government's climate action objectives.
  3. BCSEA is concerned that the draft IRP puts too much reliance on energy and capacity savings from rate design initiatives without adequate analysis of factors such as free-ridership, price elasticity, and non-participant bill impacts. BCSEA certainly supports rate design reform initiatives aimed at electrification or deferral of capital investments. However, in BCSEA's view the draft IRP exaggerates the likely quantitative impact of these initiatives.  
  4. BCSEA senses that the draft IRP shies away from mentioning potentially controversial topics such as Site C, UNDRIP, net metering, Aboriginal utilities, RIB (residential inclining block) rate, heat pumps, etc. BCSEA suggests that these topics should be mentioned in the IRP with an explanation of how they are dealt with in the IRP or where they are dealt if they are addressed elsewhere.  

BC Hydro describes the IRP as “a guidebook for what, when, why and how to meet customers’ evolving electricity needs” over a 20-year timeframe. BC Hydro hasn’t had a new long-term resource plan since 2013. BC Hydro is scheduled to file its proposed new Integrated Resource Plan with the BC Utilities Commission in December 2021. The BCUC will then conduct an in-depth public review proceeding. BCSEA expects to intervene. BCSEA also serves on BC Hydro’s Technical Advisory Committee for the 2021 IRP.

To get on BC Hydro’s 2021 IRP update list, click here.