SANGRA MOLLER LLP

Barristers & Solicitors1000 Cathedral Place925 West Georgia StreetVancouver, British ColumbiaCanada V6C 3L2

Telephone (604) 662-8808Facsimile: (604) 669-8803www.sangramoller.com

December 18,2009

VIA EMAIL & COURIER

BRITISH COLUMBIA UTILITIES COMMISSION6th Floor, 900 Howe StreetVancouver, B.C.V6Z2N3

Attention: Erica M. Hamilton, Commission Secretarv

Dear Madam:

Reply Attention of:

K.c. MollerOur File No.:

5000 II7

Direct Line:

(604) 692-3020

Email:

kmoller@sangramoller.com

Re: FortisBC Inc. ("Fortis") - 2009 Rate Design Application and Cost of Service Study (Project No.

We enclose herewith Zellstoff Celgar Limited Partnership's Information Request No. I to Fortis.

Yours truly,

SANGRA MOLLER LLP

Per:K.C. Moller

KCMlrtEnclosure

ce. ClientDistribution List

C13-2

Zellstoff Celgar Limited Partnership("Celgar")

Information Request No.1

Friday, December 18, 2009

FortlsBC Inc.2009 FortlsBC Rate Design Application ("RDA")

Issue: Separation of RS31 and RS33 customers Into separate rate classes

1.0 Reference: Exhibit B-1, Section 12.2, p. 67

"Time-based rates were considered for large General Service - Transmission customerssince these rates would be desirable from a demand-conservation perspective, andcurrent metering is capable of providing the data required for these rates. However,consistent with the treatment of the majority of customers, FortlsBC proposes to leavethe large General Service Transmission Rate Schedule 33 optional TOU for largeGeneral Service transmission customers at this time."

1.1 How many large general service ("LGS") customers have currently opted to receive service underRate Schedule 33? Is Celgar the only current Rate Schedule 33 customer?

1.2 How many LGS customers have currently opted to receive service under Rate Schedule 31?

1.3 The referenced statement suggests a customer in a given rate class can choose amongstavailable rate schedules for that rate class. Please describe when and why this triggers a changein the customer's rate class.

1.4 Does FortisBC consider LGS customers that opt for service under Rate Schedule 33 to constitutea separate "Rate Class" from those LGS customers that opt to receive service under RateSchedule 31? If not, why not?

1.5 Please explain why separate rate classes are not proposed for the Residential, Small GeneralService, General Service Secondary, LGS Primary, and various Wholesale customers based ontheir choice of Time of Use rates.

2.0 Reference: exhibit B-1, Appendix A, p. 12

2.1 Please describe the characteristics that distinguish Rate 31 customers from Rate 33 customers.What characteristics justify the creation of a separate class of service?

3.0 Reference: exhibit B-1, Appendix A, Schedule 8.2, p. 2 of 3

3.1 Please explain why the System Coincidence Factor is the same for the Rate 33 Industrial class asfor the Rate 31 Industrial Class.

3.2 What studies were performed to establish the System Coincidence Factor for the Rate 33

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Industrial class? Please provide a copy of any applicable studies.

4.0 Reference: Exhibit 8-1, Appendix A, Schedule 8.3

4.1 Please explain why the Primary Line Losses factor is the same for the Rate 33 Industrial class asfor the Rate 31 Industrial Class.

5.0 Reference: Exhibit 8-1, Appendix I, p. 8

5.1 FortisBC lists "Call for meeting" as the method of contact for Celgar. Please provide the specificsof when and to whom the call was placed.

5.2 Please identify when in the consultation process, if at all, Celgar was notified that Rate Schedule33 customers may be allocated the full burden of reapportionment of costs over the LGS class,to the exclusion of other members of the LGS class through the establishment of a new rateclass.

6.0 Reference: Exhibit 8-1, Appendix I, p. 30

6.1 Please explain why the Rate 33 LGS ratepayers were not identified as a separate rate class in thetable on Slide 18 of the presentation dated May 2009, but instead appears to have beenincluded in the "Industrial Transmission" rate class.

7.0 Reference: Exhibit 8-1, Appendix I, p. 44

7.1 Please explain why the Rate 33 LGS ratepayers were not identified as a separate rate class in thetable shown on Slide 5 of the referenced presentation, but instead appear to have been includedin the "Industrial Transmission" rate class.

7.2 When was the referenced presentation prepared?

8.0 Reference: Exhibit 8-1, Appendix I, p. 63

8.1 Please explain why the Rate 33 LGS ratepayers were not identified as a separate rate class in thetable shown in the referenced Discussion Guide, but instead appear to have been included in theUlndustrial Transmission" rate class.

8.2 When was the referenced Discussion Guide prepared?

9.0 Reference: Exhibit 8-1, Appendix I, p. 84

9.1 Please explain why the Rate 33 LGS ratepayers were not identified as a separate rate class in thetable shown in the report "An Assessment of Public Reactions to the Rate Rebalancing and RateDesign Options" dated September 4, 2009, but instead appear to have been included in the

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Illndustrial Transmission" rate class.

9.2 Please provide a copy of the first instance in which FortisBC identified that Rate Schedule 33customers were proposed to be treated as a stand-alone rate class for the purposes of theproposed rate rebalancing. When did such classification and/or reallocation occur?

10.0 Reference: EXCEL Spreadsheet Attachment to Exhibit B-1, "Cover" Worksheet

10.1 The "Cover" Worksheet identifies in Row 46 this version of the spreadsheet as the "Revised FinalVersion". Please provide working copies of the "Final Draft" and "Final Version" identified inRows 44 and 4S, and the dates those versions were prepared or issued.

11.0 Reference: 1997COSA

11.1 Please provide the total revenue from Rate Schedule 31 customers (or equivalent) in the 1997CGSA, and identify the percentage and amount of revenue that was assumed to come from theCelgar facility in Castlegar, and also identify the Revenue to Cost Ratio for that rate class.

11.2 Please provide the values for the total energy delivered to Rate Schedule 31 customers (orequivalent) in the 1997 CGSA, and identify the percentage and amount of energy that wasassumed to be delivered to the Celgar facility in Castlegar.

11.3 Please provide the actual values for the total energy delivered to Rate Schedule 31 customers(or equivalent) in the 1997, and identify the percentage and amount of energy that wasdelivered to the Celgar facility in Castlegar.

11.4 Please provide a table showing the annual amount of energy purchased by the Celgar facility inCastlegar for each year between 1992 and 2008, and if different, please also provide in the tablethe annual plant load for each year and the difference between the two values. If the value haschanged over time, please explain why, and if FortisBC's energy sales to the Celgar facility inCastlegar have not increased along with increases in plant load, please explain why.

Issue: Design of Rate Schedule 33

12.0 Reference: Exhibit B-1, Section 14.3, p. 73

12.1 Please provide a comparison ofthe charges an LGS customer would pay for service under Rate

Schedule 31 as compared to service under Rate Schedule 33 where:- maximum monthly demand is 10 MW- during one day in each month electricity is drawn at the 10 MW rate, while the rest of thehours in the month are at a constant load to achieve the specified load factorProvide comparisons for a customer load factor of 90 percent, 7S percent and SS percent.Please show the monthly charges for winter, summer and shoulder months as well as the annualtotal. Ifthe calculation methodology is not readily apparent in the hardcopy of the response,please also provide the analysis in electronic spreadsheet format.

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12.2 In the above scenario, please identify the load factor required to cause the annual totals for thetwo rate schedules to be equal to one another. For load factors higher than this, what wasFortisBC's intent in having the Rate Schedule 33 amounts exceed those of Rate Schedule 31?

12.3 Please explain if the original design of the energy charges of Rate Schedule 33 included anembedded demand charge, or assumed a particular load profile or load factor of a typicalcustomer that would elect to take service under that rate. Please describe if the original designof the energy charges of Rate Schedule 33 included an adjustment for higher system losses inthe on-peak charge, and lower system losses in the off-peak charge. Please provide the detailsof all the assumptions used in the design of Rate Schedule 33.

12.4 Please confirm that Mr. George Isherwood: (i) was instrumental in designing the original RateSchedule 33; and (ii) is currently contracted to FortisBC. Please advise as to whether Mr.Isherwood has been consulted with regard to questions 12.1 through 12.3, inclusive.

13.0 Reference: Exhibit B-1, Section 8.1, Table 8.1a, p. 48

13.1 FortisBC identifies an annual "Total Rate % Increase" for large General Service Transmission 33often percent in each offive years. Please provide numerical values (not percentages) forthecomponents of that rate in each of the five years as well as the assumed monthly energy usageand kVA demand.

14.0 Reference: Exhibit B-1, Section 8.1, Table 8.1b, p. 49

14.1 FortisBC shows the revenue to cost ratio for large General Service Transmission 33 rising from23.S percent to 29.7 percent over a period offive years. Please provide the numerical values forthe components of the rate, the customer monthly and annual load demand, the customermonthly and annual load energy, and the monthly and annual revenues from the customer ineach of the five years. Please calculate and provide the overall average cost per MW.h for eachof the five years. Please advise as to how the annual increments reflect the 10 percent annualcap increases contemplated by the rate reapportionment allocated to Celgar.

14.2 Can FortisBC confirm that the "all-in" average cost of energy for BC Hydro's pulp and papercustomers is approximately $39/MW.h? If not, please provide whatever information FortisBChas regarding this average energy cost.

15.0 Reference: Exhibit B-1, Section 10.1, p. 58

"Given the potential for a higher Basic Charge to have a detrimental effect onconservation (Principle 31 the Company does not propose to increase it at this time.This decision is consistent with the discussion of the Principles in Section 5 where itwas noted that if there were a conflict between Principles, Principle 3 would be givenadditional weight."

15.1 Was one of the original objectives of Rate Schedule 33 to promote conservation? If so, has RateSchedule 33 been effective in achieving that objective? If Rate Schedule 33 has been effective inpromoting conservation, please advise as to how such objective has been met or promoted and

S

how FortisBC measures the effectiveness and quantifies the benefits of Rate Schedule 33 indoing so.

1S.2 Was one of the original objectives of Rate Schedule 33 to reduce peak demand? If so, has RateSchedule 33 been effective in achieving that objective? If Rate Schedule 33 has been effective inreducing peak demand, please describe how Rate Schedule 33 has achieved or promoted suchobjective and how FortisBC measures the effectiveness of Rate Schedule 33 in doing so.

1S.3 Please explain why and how the wires-based demand charge proposed for Rate Schedule 33 isconsistent with Principle 3 referenced in Exhibit B1, Section 10.1, p. S8 and Exhibit B-1, SectionS.O, p.33 and with the additional weight given to conservation, as suggested in Exhibit B-1,Section S.O, p. 34.

16.0 Reference: Exhibit B-1, Appendix B- Amended Rate Schedules, Rate Schedule 33, Sheet 12

"SCHEDULE 33 - LARGE COMMERCIAL SERVICE - TRANSMISSION - TIME OF USEAPPLICABLE: In ail areas served by the Company for supply at 60 hertz, three phasewith a nominal potential of 60,000 volts or higher as available. Applicable to industrialCustomers with loads of S,OOO kVA or more, subject to written agreement. This rate isapplicable to Customers with satisfactory, as determined by the Company, LoadFactors. Service under this Schedule is available for a minimum of 12 consecutivemonths after commencement of Service,"

16.1 Please describe the criteria and characteristics of a satisfactory load factor.

16.2 Please describe the criteria and characteristics of an unsatisfactory load factor.

16.3 Please describe if the criteria and characteristics described above are the same for RateSchedules 2A, 22A, 32, 33, 40A, 40B, 40C, 40D, 40E, 40F, 43 and 61.

16.4 Please explain how the phrase "as determined by the Company" is to be applied by FortisBC,without providing criteria upon which the concept "satisfactory Load Factors" is to be assessed.Does FortisBC have an internal list of such criteria upon which they intend to rely? If so, whatare they? If not, what assurances do ratepayers have that they will be able to continue to accessRate Schedule 33 and that FortisBC's "determination" will be consistently, and not arbitrarily,applied over time?

16.S Please explain how a customer that is successful in shifting all energy consumption to off-peakhours, as the Time of Use rate incents the customer to do, will be addressed by FortisBC in itsinterpretation of a satisfactory load factor.

16.6 Please describe how FortisBC intends to address a customer with low contract demand duringon-peak hours and high contract demand during off-peak hours.

16.7 Please explain why FortisBC is not proposing the introduction of a wires charge for the Time ofUse Rate Schedules 2A and 22A.

16.8 If a residential customer conserves electricity through shulling off lights and turning electricheat down by 2 degrees does this reduce a customer's load factor? Is this not considered

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conservation? Please explain how FortisBC will discriminate between conservation and anunsatisfactory load factor when allowing access to Time of Use rates.

16.9 Please explain if and how reduced load factors that come about as a result of conservation couldrequire higher per unit energy rates in order to preserve full recovery of costs. Is this notcontradictory to achieving conservation?

16.10 If a residential customer installs a small wind turbine and a solar panel roof, thereby reducingthe customer's load factor to S percent, would this customer be refused access to theconservation focused Time of Use rate?

16.11 If a number of residential customers made this shift to distributed generation (wind turbines andsolar panel roofs) would Fortis need to create a new rate class as these customers would nowhave a low cost recovery. Please explain.

Issue: Assignment of costs to Rate Schedule 33

17.0 Reference: Exhibit 8-1, Appendix A, Schedule 1.1

17.1 Please explain why the Rate 33 Industrial customer should attract any Distribution-RelatedCosts.

18.0 Reference: Exhibit 8-1, Appendix A, Schedule 1.3

18.1 Please explain why the Rate 33 Industrial customer attracts $304,196 for Distribution Customercharges, and what this charge is meant to represent.

18.2 Please quantify the number of FortisBC employee-hours that are spent per month reading itsRate Schedule 33 customer's meter.

18.3 Please quantify the number of FortisBC employee-hours that are spent per month preparing itsRate Schedule 33 customer's bill for Rate Schedule 33 energy purchases.

18.4 What is the average cost per hour of an employee who reads Celgar's meter and what is theaverage hourly cost of an employee who prepares Celgar's monthly bill?

18.S Please give five examples of advertising directed at Rate Schedule 33 customers, and itemize thecost of this advertising.

19.0 Reference: Exhibit 8-1, Appendix A, Schedule 2.1

19.1 Please explain the basis for the 480,000 Total kVA Contract value for the Rate 33 Industrialcustomer in Schedule 2.1.

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19.2 Please provide all contracts which specify the demand service FortisBC has with the Rate 33Industrial customer.

19.3 Please provide the actual monthly maximum demand amounts for 2007 and 2008 for the Rate33 Industrial Customer, and reconcile these against the values for Total Demand (kW) and TotalkVA Contract in Schedule 2.1.

19.4 Please provide any information FortisBC has regarding the demand rate with was used in BCHydro's most recent cost-of-service study for industrial customers with self-generation. Pleasedescribe whether BC Hydro used the maximum potential load for industrial customers with self­generation when setting the demand rate, or some lower amount.

20.0 Reference: Exhibit B-1, Appendix A, Scheduies 6.3 and 6.4

20.1 When did the Rate 33 Industrial customer first access service under Rate Schedule 33?

20.2 Since the Rate 33 Industrial customer first took service under Rate Schedule 33, please provide ahistory of the number of hours, by month, that the customer had a demand of 40,000 kVA ormore, separately for on-peak hours and off-peak hours. Also express this as a percentage of thetotal hours in the month and per calendar year.

20.3 Please provide a history of the demand of the Rate 33 Industrial customer since it first tookservice under Rate Schedule 33 at the time of the FortisBC system peak for the months ofJanuary, February, July, August, November and December of each year. In how many instancesdid the customer's demand meet or exceed 40,000 kVA at the time of the FortisBC system peakin each of those months?

21.0 Reference: Exhibit B-1, Appendix A, pp. 17-1B

"To develop the classification split for FortisBC, the output from the Kootenay Riverplants was priced as if it were purchased at the 3808 tariff to determine the equivalentsplit in costs between demand and energy. This split was then applied to actual costsof these projects for purposes of classification. The resulting split was roughly 20%demand-related and 80% energy-related."

"However, in looking at the underlying classification of costs to the transmission classof BC Hydro, the generation split is equivalent to the 80% demand and 20% energyresuiting from the full Rate 3808."

21.1 Please provide the source information FortisBC used to identify the classification of BC Hydrogeneration costs.

22.0 Reference: Exhibit 8-1, Appendix A, p. 31

"The demand allocation method was selected after consideration of past precedent,FERC and OEB tests, comparisons of load shapes and growth of winter and summerpeaks. The 12CP approach was rejected as FortisBC does not have a fiat load shape

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over the year. The 2 CP approach was selected rather than a 1 CP or 4CP approachbecause FortisBC has a significant summer peak. While the summer peak is not at thesame level as the winter peak, it Is growing faster than the winter peak and willincreasingly have a larger impact on the system:'

22.1 As FortisBC is a winter-peaking utility, please provide further justification as to why the summerpeak is afforded the same weight as the winter peak for transmission cost allocation.

22.2 Please provide justification as to why the 1 CP approach is not the more appropriate method fortransmission cost allocation.

23.0 Reference: EXCEL Spreadsheet Attachment to Exhibit B-1, "Rate Base" Worksheet, Cells AH51 toAH61

23.1 Please describe the substation assets in service between the Celgar facility and theinterconnection of the FortisBC and BCTC/BC Hydro transmission system, and please identify theownership of these substation assets.

23.2 Please assign a cost to each of the FortisBC substation assets described in the previous questionand assign a "percentage utilization" of the substation assets to the Celgar facility.

23.3 Please describe the FortisBC transmission line infrastructure assets between the Celgar facilityand the Brilliant Terminal Station, and identify the book value and replacement cost of theseassets. Please assign a "percentage utilization" of the transmission line infrastructure assets tothe Celgar facility.

23.4 There are two 63 kV transmission lines between the Celgar facility and the Castlegar substation.Please identify all customers connected to the transmission lines "downstream" of the Castlegarsubstation.

23.S There are two 63 kV transmission lines between the Celgar facility and the Castlegar substation.If Celgar decided to be served by only one of the transmission lines, please describe the changesto the Transmission Plant Rate Base Cost Allocation assigned to the Rate 33 Industrial customer.

Issue: Impact of potential changes to Rate Schedule 33

24.0 Reference: Exhibit B-1, Section 14.3, p. 73

"The revenue-to-cost ratio for this rate ciass is only 24 percent, largeiy due tosignificant under collection of wires-related costs. Therefore, the introduction of afull-cost wires-based demand charge with a corresponding downward adjustment ofTOU energy rates was not deemed to be in compliance with cost-based or energyefficiency principles. Therefore, in this extraordinary situation, FortisBC proposes toprice the wires-based demand charge at $0 per kVA to begin, with all rebalancingincreases for this rate schedule to be applied solely by increasing this demand charge.

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The current Basic Charge and TOU energy rates will be left unchanged to begin, thensubject only to any annual general rate increases."

24.1 Please provide a calculation that shows the blended cost per MW.h for each usage period in theTime of Use Rate Schedule 33 if a wires-based demand charge is incorporated in an amount thatbrings the revenue to cost ratio to 100 percent as calculated in this Application. In other words,keeping the wires-based demand charge at $0 per kVA, please identify the equivalent energyrates required to achieve a revenue to cost ratio of 100 percent for the Rate Schedule 33customer. Please provide the calculation in electronic spreadsheet format if the calculationprocedure is not readily apparent in printed format.

24.2 Please identify the total revenue received from the Rate 33 Customer for the question above ona monthly and annual basis, and compare this with the revenue being received at present rateson a monthly and annual basis. Please include your assumptions for energy consumption anddemand.

Issue: Transmission Standby Service Rate Schedule

2S.0 Reference: Exhibit B-1, Appendix A, p. 33

"It is standard utility practice to charge for standby service for customer-ownedgeneration and is therefore appropriate for FortisBC to make this change in both theallocation of costs within the COSA and in setting rates for customers with their owngeneration in lieu of a specific standby charge."

25.1 Please provide five Canadian Utility references for FortisBCs claim that it is standard utilitypractice to charge for standby service for customer-owned self-generation.

25.2 Please provide a copy of BC Hydro's applicable electricity tariff rate schedule for standby serviceprovided to industrial transmission-connected customers with self-generation.

25.3 Please discuss the operation of BC Hydro's applicable electricity tariff rate schedule for standbyservice provided to industrial transmission-connected customers with self-generation, and whatsuch a similar Rate Schedule would be for FortisBC using the same principles.

25.4 If a charge for standby service is standard utility practice, please explain why FortisBC does nothave a rate schedule for standby service.

Issue: Assignment of O&M Costs

26.0 Reference: Exhibit B-1, AppendiX A, p. 24

"A&G was first assigned to each function on the basis of labour ratios. These amounts

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were then classified on the same basis as the rate base for each of the three functions.The rate base was used because the employees are more closely tied to the size of theasset value of the three functions as opposed to the O&M associated with eachfunction."

26.1 On what evidence does FortisBC rely in support of the statement that employees are moreclosely tied to asset value rather than operations and maintenance.

26.2 Please identify the number of employee-hours engaged in operations and maintenance in eachof the three functions, and the percentage this represents of total employee-hours in each ofthe three functions, as well as for the company as a whole, and provide for reference the assetvalue of each function.

Issue: Classification of Assets in the Minimum System Study

27.0 Reference: Exhibit B-1, Appendix A, p. 20

"Substations, including land and station equipment. These costs are classified asdemand-related as they are sized on the basis of the peak load for the area served."

27.1 Please explain how the costs for the land, the control building, the grounding system, thesecurity system, and the protection and control equipment are different for a single transformer5 MVA substation as compared to a single transformer 25 MVA substation.

27.2 Please justify the appropriateness of classifying all substation costs as demand related ratherthan classifying some portion as customer-related that is required independent of the level ofdemand.

27.3 For each substation in the FortisBC system, please identify the size and cost of substation thatwould be required if each customer's demand was limited to the PLCC of 1.0 kW per customer.

Issue: Customer Bypass Opportunities

28.0 Reference: None

28.1 Does FortisBC believe that an opportunity for a specific customer to bypass the transmissionportion of the FortisBC infrastructure (for which it has been allocated a cost in the COSA)through a customer-funded investment should be addressed in the overall exercise of ratedesign in order to incent the customer to abandon the customer-funded investment and chooseto continue to utilize the FortisBC infrastructure and not implement the customer-fundedinvestment. Please explain.

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Issue: Order No. G-48-09

29.0 Reference: Decision Accompanying Order No. G-48-09, pp. 30-31, 34

"The Commission Panel directs BC Hydro, in consultation with FortisBC, to identify andsubmit to the Commission an agreed methodology to monitor "net of load" energywithin 90 days of the date of this Decision."

"For its part, BC Hydro is to prOVide a report to the Commission that will summarizethe terms and conditions of its contractual arrangements with any of its industrialcustomers with self-generation capacity who may sell power on a basis which isinconsistent with the "net of load" concept as enunciated in this Decision."

"FortisBC is requested to file a written statement within 90 days of the date of thisDecision as to its intentions to prOVide such transparency."

29.1 Please provide a copy of BCUC Order No. G-48-09 and the accompanying Decision.

29.2 Please provide copies ofthe FortisBC methodology, the BC Hydro report, and the FortisBCstatement referenced in the introduction to this Information Request.

29.3 Prior to BCUC Order No. G-48-09, please confirm whether FortisBC agrees that the regulatoryenvironment within the FortisBC service area allowed for a customer with self-generation topurchase all of its required electrical load while allowing its onsite generator to produceelectricity for export to third parties.

29.4 Please confirm that FortisBC had signed a contract with Zellstoff-Celgar that was subject to BCUCacceptance that would have resulted in FortisBC supplying all of the electrical power for the loadat Celgar's industrial plant in Castlegar.

30.0 Reference: None

30.1 Please explain the concept of Generator Baseline ("GBl") and how this would apply to anindustrial facility with self-generation capability.

30.2 Please explain if and how, prior to May 2009, FortisBC determined the GBl for customers withself-generation capability such as the Celgar facility in Castlegar. If no such determination wasmade, please explain why not.

30.3 Please confirm that FortisBC had no reason to seek to determine a GBl for a customer with self­generation capability prior to the date upon which BCUC Order No. G-48-09 was issued.

30.4 Please confirm if and how BC Hydro establishes a GBl for an industriai customer with self­generation when that customer makes changes to the self-generation capability.

31.0 Reference:

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Exhibit 8-1, Section 2.2, Table 2.2, p. 13

31.1 Please re-calculate the COSA Revenue to Cost Ratios found in Table 2.2 on the basis that theCelgar facility in Castlegar was able to purchase all of its electricity needs from FortisBC with anannual demand of 43,000 kVA at 100 percent power factor and 9S percent load factor. Pleaseprovide the requested calculation both for service taken under Rate Schedule 31 and for servicetaken under Rate Schedule 33.

31.2 Please re-calculate the COSA Revenue to Cost Ratios found in Table 2.2 on the basis that theCelgar facility in Castlegar had a GBl of 3 MW, but had a facility load such that it was stillnecessary to purchase electricity from FortisBC with an annual demand of 40,000 kVA at 100percent power factor and 9S percent load factor. Please provide the requested calculation bothfor service taken under Rate Schedule 31 and for service taken under Rate Schedule 33.

31.3 Please re-calculate the COSA Revenue to Cost Ratios found in Table 2.2 on the basis that theCelgar facility in Castlegar had a GBl of 10 MW, but had a facility load such that it was stillnecessary to purchase electricity from FortisBC with an annual demand of 33,000 kVA at 100percent power factor and 9S percent load factor. Please provide the requested calculation bothfor service taken under Rate Schedule 31 and for service taken under Rate Schedule 33.

31.4 Please re-calculate the COSA Revenue to Cost Ratios found in Table 2.2 on the basis that theCelgar facility in Castlegar had a GBl of 20 MW, but had a facility load such that it was stillnecessary to purchase electricity from FortisBC with an annual demand of 23,000 kVA at 100percent power factor and 9S percent load factor. Please provide the requested calculation bothfor service taken under Rate Schedule 31 and for service taken under Rate Schedule 33.

32.0 Reference: Exhibit 8-1, Section 8.1, Tables 8.1a and 8.1b, pp. 48-49

32.1 Please re-calculate Tables 8.1a and 8.1b on the basis that the Celgar facility in Castlegar was ableto purchase all of its electricity needs from FortisBC with an annual demand of 43,000 kVA at100 percent power factor and 9S percent load factor. Please provide the requested calculationboth for service taken under Rate Schedule 31 and for service taken under Rate Schedule 33.

32.2 Please re-calculate Tables 8.1a and 8.1b on the basis that the Celgar facility in Castlegar had aGBl of 3 MW, but had a facility load such that it was still necessary to purchase electricity fromFortisBC with an annual demand of 40,000 kVA at 100 percent power factor and 9S percent loadfactor. Please provide the requested calculation both for service taken under Rate Schedule 31and for service taken under Rate Schedule 33.

32.3 Please re-calculate Tables 8.1a and 8.1b on the basis that the Celgar facility in Castlegar had aGBl of 10 MW, but had a facility load such that it was still necessary to purchase electricity fromFortisBC with an annual demand of 33,000 kVA at 100 percent power factor and 9S percent loadfactor. Please provide the requested calculation both for service taken under Rate Schedule 31and for service taken under Rate Schedule 33.

32.4 Please re-calculate Tables 8.1a and 8.1b on the basis that the Celgar facility in Castlegar had aGBl of 20 MW, but had a facility load such that it was still necessary to purchase electricity fromFortisBC with an annual demand of 23,000 kVA at 100 percent power factor and 9S percent load

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factor. Please provide the requested calculation both for service taken under Rate Schedule 31and for service taken under Rate Schedule 33.

33.0 Reference: Decision Accompanying Order No. G-48-09, p. 30

"Similariy, Zellstoff Ceigar refers to the failure of its 3.5 MW generator in 1993 and itsreplacement with a 52MW generator in 1994. This was followed in 2008 with aninvestment decision to purchase a 48 MW generator scheduled for installation in2009."

"Are these Increases in generation capacity to be considered incremental energygeneration or new generation? What portion of the increased generation capacityshould be available for export by the owners? The Panei believes that on the basis ofthe record in this proceeding, it has insufficient evidence on which to base any setnumericai answer to the questions,"

33.1 Please explain the effect that establishing a GBL of 3 MW for the Celgar facility in Castlegarwould have on the CGSA and on the Revenue to Cost Ratio, if the facility continued to takeservice under Rate Schedule 33 with an annual demand of 40,000 kVA at 100 percent powerfactor and 95 percent load factor.

33.2 Please explain the effect that establishing a GBL of 10 MW for the Celgar facility in Castlegarwould have on the CGSA and on the Revenue to Cost Ratio, if the facility continued to takeservice under Rate Schedule 33 with an annual demand of 33,000 kVA at 100 percent powerfactor and 95 percent load factor.

33.3 Please explain the effect that establishing a GBL of 20 MW for the Celgar facility in Castlegarwould have on the CGSA and on the Revenue to Cost Ratio, if the facility continued to takeservice under Rate Schedule 33 with an annual demand of 23,000 kVA at 100 percent powerfactor and 95 percent load factor.

Issue: Comparable BC Hydro Rates

34.0 Reference: None

34.1 Please provide a comparison table of all FortisBC rates against the comparable BC Hydro rates,including the costs under each rate.

34.2 Please identify those FortisBC or BC Hydro rates for which no comparable rate exists in the otherutility, including the costs under each such rate.

Issue: Other

35.0 Reference:

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Exhibit B-1, Appendix I, p. 84

"Despite some Issues surrounding the derivation of Rate 3808, It does reflect themarket price paid by FortlsBC for a large part of Its power supply. To some extentFortlsBC faces the decision to generate with Its own hydro plants as opposed topurchasing from BC Hydro under Rate 3808.

35.1 Please describe any credible situation or circumstance in which FortisBC would choose to takeservice under Rate 3808 rather than generate with its own hydro plants.

35.2 Is Rate 3808 a market-based rate, and if so, what market does it reflect?