January 16, 2015 Attn: Ms Erica Hamilton Commission Secretary, BCUC Complaint Against B.C. Hydro by XXXX DOUBLE BILLING THE LEGACY CHARGE Introduction I am a residential customer of B.C. Hydro and qualify for the Meter Choices Program. I have two legacy meters House Account No. xxxxx Barn/Workshop Account No. yyyyyy My wife and I are both retired seniors. Documentary References Order in Council #391, Sept 24, 2013 Direction #4. B.C. Hydro Application for approval of charges related to Meter Choices program. Final submission of B.C. Hydro, January 24, 2014. Preamble The BCUC has set the Legacy Meter charge of $32.40 per month based on B.C. Hydros estimate of qualified participating residential customers with one meter. I am part of a small sub-group within this (larger) group with two legacy meters located on my “postage stamp” at ______________. I have been remitting the legacy meter charge for my residence (under protest) since December 2, 2013. This December 2014, B.C. Hydro “remembered” that a second meter was installed many years ago and promptly started billing for this meter retro-actively to December 2, 2013. I am challenging this action by B.C. Hydro as being unfair and discriminatory. Submission My argument is based on the responses provided by B.C. Hydro in its Final Submission to BCUC, signed by lawyer Ian Webb for B.C. Hydro. It describes the contractual relationship between the qualified residential customer with “a meter”, and B.C. Hydro then goes on to detail the determination of a fair and equitable cost-sharing charge for the customer of the Meter Choices Program. Quoting from B.C. Hydros Final Submission (bolding is my own): Para 6 - “proposed charges for eligible customers who retain a legacy meter” Para 8 - “approved the proposed charge of $35/month to be applied to customers that have a legacy meter” Para 15 - “Section 3 (1) (a) of Direction No. 4 requires the BCUC to set rates for B.C. Hydro that allows B.C. Hydro to recover costs from eligible customers at premises where a legacy meter is installed”. Para 18 - “The new charges are proposed to be applied on a postage stamp basis across the service territory, wherein total incremental costs to provide the service are divided by the appropriate number of units (in the case of the legacy meter charges, the number of customers forecast to choose the particular option)” Conclusions The incremental costs of the Meter Choices Program have been calculated to be borne equally by each participating residential customer. I have read and reread the 24 page Submission and I can find no reference to the single residential customer with more than one meter. ( An oversight on the part of B.C. Hydro?) As it reads, the intent of Direction No.4 to the BCUC was to establish the qualifying criteria for a residential customer with a meter. The existence of a small sub-group with two meters within the larger group of qualified residential customers was not addressed. The intention of Direction No.4 to “allow the authority to establish a regulatory account for the recovery of costs” (Rates 3 (2)) is the fair and equitable apportionment of program costs to each program participant on a postage stamp basis. I submit that billing a single qualified residential customer for two legacy meters is discriminatory and blatantly unfair: it was not the intent of the Lt. Governor in Council, Order No.391, September 24, 2013. Signed: X cc - L.F. Kelsey, BCUC Panel Chair - D.M. Morton, BCUC Commissioner - N.E. MacMurchy, BCUC Commissioner - W.R. Bennett, Minister of Energy & Mines - M. Polak, Presiding Member of the Executive Council - R. Aldeguer, Senior Vice President, Corporate Services & General Council
Posted on: Thu, 22 Jan 2015 08:15:18 +0000
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