BC Hydro writes in compliance with BCUC Order No. G to provide, as Exhibit B-3, its responses to BCUC Information Request No. 1.

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1 Janet Fraser Chief Regulatory Officer Phone: Fax: October 25, 2013 Ms. Erica Hamilton Commission Secretary British Columbia Utilities Commission Sixth Floor 900 Howe Street Vancouver, BC V6Z 2N3 Dear Ms. Hamilton: RE: British Columbia Utilities Commission (BCUC) British Columbia Hydro and Power Authority (BC Hydro) Electric Tariff and Open Access Transmission Tariff Application to Replace S&P Dow Jones Mid-Columbia Indices Responses to BCUC Information Request No. 1 BC Hydro writes in compliance with BCUC Order No. G to provide, as Exhibit, its responses to BCUC Information Request No. 1. For further information, please contact Gordon Doyle at or by at bchydroregulatorygroup@bchydro.com. Yours sincerely, Janet Fraser Chief Regulatory Officer ch/ma Enclosure (1) 2/ British Columbia Hydro and Power Authority, 333 Dunsmuir Street, Vancouver BC V6B 5R3

2 October 25, 2013 Ms. Erica Hamilton Commission Secretary British Columbia Utilities Commission Electric Tariff and Open Access Transmission Tariff Application to Replace S&P Dow Jones Mid-Columbia Indices Responses to BCUC Information Request No. 1 Page 2 of 2 Copy to: AMPC Attention: Richard Stout roninconsult@live.com Attention: Brian R. Wallace rbw@bht.com BCPSO Attention: Tannis Braithwaite ltbraithwaite@bcpiac.com Capital Power Corporation Attention: Daniel Jurijew djurijew@capitalpower.com Cargill Attention: Philip Pauls Philip_Pauls@cargill.com Attention: Robert Walker Robert_Walker@cargill.com Clean Energy Association Attention: David Austin daustin@securitieslaw.bc.ca Commercial Energy Consumers Association of BC Attention: Christopher Weafer cweafer@owenbird.com Enmax Attention: Darren Gogol dgogol@enmax.com Morgan Stanley Attention: Deborah Hart deborah.hart@morganstanley.com Attention: Jasper D Wright Jasper.D.Wright@morganstanley.com Attention: Murray Margolis murray.margolis@morganstanley.com Attention: Sabrina Kikkert Sabrina.Kikkert@morganstanley.com Attention: Steve Huhman Steven.Huhman@morganstanley.com Attention: Lisa Cherkas Lisa.Cherkas@morganstanley.com NorthPoint Energy Attention: Dean K. Krauss dkrauss@northpointenergy.com Attention: Dean Jones djones@northpointenergy.com Partner, The Progressive Group Attention: Cynthia Burton cynthia.burton@shaw.ca Powerex Attention: Mike MacDougall mike.macdougall@powerex.com Attention: Mark Thompson mark.thompson@powerex.com Attention: Michael McWilliams michael.mcwilliams@powerex.com Attention: Dan O Hearn dan.ohearn@powerex.com Attention: Tom Bechard tom.bechard@powerex.com REMC Rainbow Energy Marketing Corporation Attention: Bob Friessen b.friesen@rainbowenergy.com Teck Metals Ltd Attention: Richard Deane Richard.Deane@teck.com TransAlta Attention: Marcy Cochlan marcy_cochlan@transalta.com TransCanada Attention: Regulatory Department tce_regulatory@transcanada.com

3 ERICA HAMILTON COMMISSION SECRETARY web site: SIXTH FLOOR, 900 HOWE STREET, BOX 250 VANCOUVER, BC CANADA V6Z 2N3 TELEPHONE: (604) BC TOLL FREE: FACSIMILE: (604) Log No VIA bchydroregulatorygroup@bchydro.com October 18, 2013 Ms. Janet Fraser Chief Regulatory Officer British Columbia Hydro and Power Authority 16 th Floor, 333 Dunsmuir Street Vancouver, BC V6B 5R3 Dear Ms. Fraser: BCH ELECTRIC TARIFF /OATT PRICE INDICES REPLACEMENT EXHIBIT A 2 Re: British Columbia Hydro and Power Authority Transmission Tariff S&P Dow Jones Mid Columbia Further to your September 9, 2013 application noted above, enclosed please find Commission Information Request No. 1. In accordance with the Regulatory Timetable, please file your responses electronically with the Commission by Friday, October 25, Yours truly, /yl Enclosure cc: Registered Interveners (BCH OATT Indices RI) Erica Hamilton PF/BCH Tariff OATT Price Indices/GC/A 2_BCUC IR No. 1

4 BRITISH COLUMBIA UTILITIES COMMISSION INFORMATION REQUEST NO. 1 TO BC HYDRO British Columbia Hydro and Power Authority Transmission Tariff S&P Dow Jones Mid Columbia 1.0 Reference: SPDJI, PLATTS, POWERDEX AND ICE INDICES Miscellaneous 1.1 Please confirm which indices providers other major utilities in Washington, Oregon and Idaho use for obtaining Mid C prices. How do they use Mid C prices in their OATT and Electric Tariffs? 1.2 How long has each of the proposed indices providers been in existence, and how long have they been providing Mid C indices? 1.3 Please list which indices providers, if any, BC Hydro supplies Mid C transaction data. 2.0 Reference: PLATTS, POWERDEX AND ICE MID C ELECTRICITY PRICE INDICES Exhibit B 1, Section 2.4.2, p. 6, Section 2.6.2, p. 9 Subscription Costs On pages 6 and 9 of the Application, BC Hydro explains: Platts has not yet established the subscription cost for the [Platts] indices; however, BC Hydro does not expect the subscription to exceed the USD $4500/year that it currently pays for the SPDJI indices., and BC Hydro expects that the subscription fee for the use of the Powerdex indices would be in the amount of USD $2000/year. 2.1 Please confirm if Platts has established a subscription cost, and if so, please provide the actual subscription cost. Please also confirm if the subscription fee for using Powerdex is USD $2000/year. If not, please provide the actual subscription fee. Lastly, please confirm, otherwise explain, if BC Hydro would receive a pro rated rebate, if BC Hydro cancelled the subscription to Platts. 3.0 Reference: PLATTS, POWERDEX AND ICE MID C ELECTRICITY PRICE INDICES Exhibit B 1, Section 2.6.2, p. 9, and Section 2.7.2, p. 11 IT Costs On page 9 of the Application, in regards to the Powerdex indices, BC Hydro states: Data is available in Comma Separated Value (CSV) format; however, BC Hydro expects IT costs would be required to develop a parsing methodology to allow auto population into MODS. The expected cost of this work is expected to be $5,000 to $10,000. On page 11 of the Application, in regards to the ICE indices, BC Hydro states: BC Hydro OATT & Tariff Price Indices Replacement 1 BCUC Information Request No. 1

5 Data is available in Comma Separated Value (CSV) format; however, BC Hydro expects IT costs would be required to develop scraping and parsing methodologies to allow auto population into MODS. The expected cost of this methodology could be $15,000 to $20, Please explain why the Powerdex data requires parsing whereas the ICE data requires scraping and parsing, when both sets of data are said to be available in CSV format. Please elaborate on why the scraping and/or parsing requirements for Powerdex and ICE would lead to the different costs. In what format is data from SPDJI and Platts provided? 4.0 Reference: PLATTS MID C ELECTRICITY PRICE INDICES Exhibit B 1, Section 2.5, pp. 6 7 On Peak and Off Peak Hours On pages 6 and 7 of the Application, BC Hydro describes the hours Platts uses for their definitions of onpeak and off peak: On Peak Hours: Daily index of hourly average $/MWh for On Peak (HLH) transactions at Mid C (HE ) Off Peak Hours: Daily index of hourly average $/MWh for Off Peak (LLH) transactions at Mid C (HE ) 4.1 Please confirm if the Platts on peak Mid C electricity price indices are calculated based on transactions that take place daily, Monday to Saturday, between the hours starting 0700 and 2200, excluding NERC holidays. If not, please explain. 4.2 Please confirm if the Platts off peak Mid C electricity price indices are calculated based on transactions that take place daily, Monday to Saturday, early morning, and late night, 0100 to 0600, and 2300 to 2400, excluding NERC holidays. If not, please explain. 5.0 Reference: PLATTS MID C ELECTRICITY PRICE INDICES Exhibit B 1, Section 2.5, p. 7 Sunday and NERC Holiday Hours On page 7 of the Application, BC Hydro explains how Sunday and NERC holiday index prices would be determined if Platts is adopted: There is currently no Sunday and NERC holiday index calculated by Platts. Sunday prices are currently included in the next day off peak prices. During discussions with BC Hydro, Platts has stated that they intend to establish a Sunday and NERC Holiday Daily index of hourly average $/MWh for Mid C, prior to September 13, BC Hydro would utilize this index, or if not available, the appropriate off peak pricing for these periods as required to calculate charges BC Hydro OATT & Tariff Price Indices Replacement 2 BCUC Information Request No. 1

6 5.1 Please confirm if Platts has established a Sunday and/or a NERC holiday daily index of hourly average $/MWh for Mid C, and if so, please explain which hours of trade data Platts will use to calculate both of these indices. If not, please explain how BC Hydro proposes to determine the appropriate index pricing for Sundays and NERC holidays, and, specifically, please explain which hours of trade data will be used to calculate both index prices. 6.0 Reference: SPDJI AND PLATTS MID C ELECTRICITY PRICE INDICES Exhibit B 1, Section 2.4.1, p. 6 and Section 2.5.1, p. 7 Flow Date vs. Trade Date On page 6 of the Application, BC Hydro explains: [SPDJI] index prices are published on the flow date. On page 7 of the Application, BC Hydro explains: [Platts] index prices are published on the trade date. 6.1 Please explain the difference between flow date and trade date, and please explain the significance of publishing index prices on the trade date versus publishing index prices on the flow date. 7.0 Reference: SPDJI AND PLATTS MID C ELECTRICITY PRICE INDICES Exhibit B 1, Section 2.4.1, p. 6, Section 2.5.1, p. 7 Section 2.6.1, p. 9, and Section 2.7.1, p. 10 MWh vs. MW Of the methodologies BC Hydro reviewed, Platts is the only provider that uses MW in their calculations. 7.1 Please confirm if transactions over a period less than one hour will be included in Platts, Powerdex or ICE calculations. Were these types of transactions included in SPDJI s calculations? How would each index treat a 1000MW request for 45 minutes in their index calculation? 8.0 Reference: PLATTS, POWERDEX AND ICE MID C ELECTRICITY PRICE INDICES Exhibit B 1, Section 2.5.3, p. 8, Section 2.6.3, p. 10, and Section 2.7.3, p. 11 Suitability of Platts, Powerdex and ICE for BC Hydro Purposes On pages 8, 10 and 11 of the Application, BC Hydro states: The Platts indices have a high degree of correlation with the equivalent SPDJI indices. The Powerdex data correlation with the equivalent SPDJI indices is not as good as Platts., and The ICE data correlation with the equivalent SPDJI indices is also not as good as Platts. 8.1 Please provide the correlation coefficients, confidence intervals and sample sizes for the comparisons of Platts, Powerdex and ICE indices with the SPDJI indices, for on peak, off peak, Sunday and NERC holidays for the August 1 to 13, 2013 test period, and for a two month test period August 1, 2013 to September 30, BC Hydro OATT & Tariff Price Indices Replacement 3 BCUC Information Request No. 1

7 Information Request No Dated: October 18, Reference: SPDJI, PLATTS, POWERDEX AND ICE INDICES Miscellaneous Please confirm which indices providers other major utilities in Washington, Oregon and Idaho use for obtaining Mid-C prices. How do they use Mid-C prices in their OATT and Electric Tariffs? BC Hydro reviewed the Retail Electric Tariff (where applicable) and/or Open Access Transmission Tariff (OATT) documentation of several major utilities in Washington, Oregon and Idaho (Utilities), including relevant business practices. The Utilities included Avista Corporation (Avista), Bonneville Power Authority (BPA), Idaho Power Company (IP), Pacificorp, Portland General Electric Company (PGE) and Puget Sound Energy Inc. (PSE). Other than the examples outlined below, BC Hydro did not identify examples where the other Utilities reference Mid-Columbia indices. Electric Tariff: PGE revised several of its retail tariff rate sheets to reflect the discontinuation of the Dow Jones Mid-Columbia indices and replacement with equivalent IntercontinentalExchange, Inc. (ICE) indices. OATT: Of the OATT ancillary service rate schedules and the tariff supplement that were included in BC Hydro s Application to Amend the Electric Tariff and Open Access Transmission Tariff (Energy Imbalance Service, Loss Compensation Service and Network Economy), only energy imbalance service appears to be directly comparable for all of the Utilities and BC Hydro. For energy imbalance settlements (including generator imbalance as applicable), Avista, IP and PSE are currently using ICE indices while BPA, Pacificorp and PGE are using Powerdex Inc. (Powerdex) Indices. Where the Utilities refer to price indices for other ancillary services in their OATT documentation, such references are consistent with the above based on BC Hydro s review.

8 Information Request No Dated: October 18, Reference: SPDJI, PLATTS, POWERDEX AND ICE INDICES Miscellaneous How long has each of the proposed indices providers been in existence, and how long have they been providing Mid-C indices? Platts, McGraw Hill Financial (Platts) was established in 1909 and has been providing Mid-C indices since Powerdex was established in 2001 and has been providing Mid-C indices since ICE was established in 2000 and has been providing Mid-C indices since 2003.

9 Information Request No Dated: October 18, Reference: SPDJI, PLATTS, POWERDEX AND ICE INDICES Miscellaneous Please list which indices providers, if any, BC Hydro supplies Mid-C transaction data. BC Hydro does not supply Mid-C transaction data to any indices providers.

10 Information Request No Dated: October 18, Reference: PLATTS, POWERDEX AND ICE MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.4.2, p. 6, Section 2.6.2, p. 9 Subscription Costs On pages 6 and 9 of the Application, BC Hydro explains: Platts has not yet established the subscription cost for the [Platts] indices; however, BC Hydro does not expect the subscription to exceed the USD $4500/year that it currently pays for the SPDJI indices., and BC Hydro expects that the subscription fee for the use of the Powerdex indices would be in the amount of USD $2000/year Please confirm if Platts has established a subscription cost, and if so, please provide the actual subscription cost. Please also confirm if the subscription fee for using Powerdex is USD $2000/year. If not, please provide the actual subscription fee. Lastly, please confirm, otherwise explain, if BC Hydro would receive a pro-rated rebate, if BC Hydro cancelled the subscription to Platts. Platts has not established a subscription cost for the Mid-C indices for BC Hydro. BC Hydro expects that Platts will do so closer to BC Hydro s subscription renewal in July No additional cost has been incurred by BC Hydro to date for the Mid-C indices as a result of the switch from SPDJI to Platts. BC Hydro confirms that the subscription fee for the Powerdex service is in United States dollars. The Platts subscription terms do not expressly address how subscription fees will be dealt with in the event of a mid-term termination. In the event that BC Hydro uses an index other than Platts, it would approach Platts about obtaining a pro-rated rebate.

11 Information Request No Dated: October 18, Reference: PLATTS, POWERDEX AND ICE MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.6.2, p. 9, and Section 2.7.2, p. 11 IT Costs On page 9 of the Application, in regards to the Powerdex indices, BC Hydro states: Data is available in Comma Separated Value (CSV) format; however, BC Hydro expects IT costs would be required to develop a parsing methodology to allow auto population into MODS. The expected cost of this work is expected to be $5,000 to $10,000. On page 11 of the Application, in regards to the ICE indices, BC Hydro states: Data is available in Comma Separated Value (CSV) format; however, BC Hydro expects IT costs would be required to develop scraping and parsing methodologies to allow auto population into MODS. The expected cost of this methodology could be $15,000 to $20, Please explain why the Powerdex data requires parsing whereas the ICE data requires scraping and parsing, when both sets of data are said to be available in CSV format. Please elaborate on why the scraping and/or parsing requirements for Powerdex and ICE would lead to the different costs. In what format is data from SPDJI and Platts provided? Parsing of data is needed for the Powerdex and ICE indices because the data format of the CSV files from Powerdex and ICE is different from that provided in the SPDJI and Platts files, which have the same format. For example, the date format in the CSV file from Powerdex is DD/MM/YY (e.g., 25/10/13), for ICE is MMM DD, YYYY (e.g., Oct 25, 2013) and for SPDJI and Platts is YYYYMMDD (e.g., ). In addition, the Powerdex and ICE off-peak and on-peak prices are provided on different rows in the CSV file whereas these prices are on the same row but in different columns for SPDJI and Platts. A parsing methodology change would therefore be required to read the data from Powerdex and ICE CSV files so that it can be auto populated into BC Hydro s MODS system which currently requires YYYYMMDD date format. While ICE does provide the data in CSV format, an additional automated process is also required to scrape the data because ICE provides the CSV files through a web interface instead of through a File Transfer Protocol (FTP) server. BC Hydro s systems are not set up to extract the indexing data from a web interface so this functionality would need to be implemented which is the reason for BC Hydro s estimated higher cost.

12 Information Request No Dated: October 18, Reference: PLATTS MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.5, pp. 6-7 On-Peak and Off-Peak Hours On pages 6 and 7 of the Application, BC Hydro describes the hours Platts uses for their definitions of on-peak and off-peak: On-Peak Hours: Daily index of hourly average $/MWh for On-Peak (HLH) transactions at Mid-C (HE ) Off-Peak Hours: Daily index of hourly average $/MWh for Off-Peak (LLH) transactions at Mid-C (HE ) Please confirm if the Platts on-peak Mid-C electricity price indices are calculated based on transactions that take place daily, Monday to Saturday, between the hours starting 0700 and 2200, excluding NERC holidays. If not, please explain. BC Hydro confirms that the Platts on-peak Mid-C electricity price indices are calculated based on on-peak trading that is done daily Monday to Friday for power delivered Monday to Saturday from HE 0700 to HE 2200, excluding NERC holidays.

13 Information Request No Dated: October 18, Reference: PLATTS MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.5, pp. 6-7 On-Peak and Off-Peak Hours On pages 6 and 7 of the Application, BC Hydro describes the hours Platts uses for their definitions of on-peak and off-peak: On-Peak Hours: Daily index of hourly average $/MWh for On-Peak (HLH) transactions at Mid-C (HE ) Off-Peak Hours: Daily index of hourly average $/MWh for Off-Peak (LLH) transactions at Mid-C (HE ) Please confirm if the Platts off-peak Mid-C electricity price indices are calculated based on transactions that take place daily, Monday to Saturday, early morning, and late night, 0100 to 0600, and 2300 to 2400, excluding NERC holidays. If not, please explain. BC Hydro confirms that the Platts off-peak Mid-C electricity price indices are calculated based on off-peak trading that is done daily Monday to Friday for power delivered Monday to Saturday early morning (HE 0100 to HE 0600) and late night (HE 2300 to HE 2400), and all day on Sundays and NERC holidays (HE 0100 to HE 2400).

14 Information Request No Dated: October 18, Reference: PLATTS MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.5, p. 7 Sunday and NERC Holiday Hours On page 7 of the Application, BC Hydro explains how Sunday and NERC holiday index prices would be determined if Platts is adopted: There is currently no Sunday and NERC holiday index calculated by Platts. Sunday prices are currently included in the next day off-peak prices. During discussions with BC Hydro, Platts has stated that they intend to establish a Sunday and NERC Holiday Daily index of hourly average $/MWh for Mid-C, prior to September 13, BC Hydro would utilize this index, or if not available, the appropriate off-peak pricing for these periods as required to calculate charges Please confirm if Platts has established a Sunday and/or a NERC holiday daily index of hourly average $/MWh for Mid-C, and if so, please explain which hours of trade data Platts will use to calculate both of these indices. If not, please explain how BC Hydro proposes to determine the appropriate index pricing for Sundays and NERC holidays, and, specifically, please explain which hours of trade data will be used to calculate both index prices. Platts has established Sunday and NERC holiday on-peak, off-peak and 24-hour indices. These use the same hours of trade data as are described in BC Hydro s responses to BCUC IRs and BC Hydro will use Platts 24-hour index pricing for Sundays and NERC Holidays to be consistent with historical practice.

15 Information Request No Dated: October 18, Reference: SPDJI AND PLATTS MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.4.1, p. 6 and Section 2.5.1, p. 7 Flow Date vs. Trade Date On page 6 of the Application, BC Hydro explains: [SPDJI] index prices are published on the flow date. On page 7 of the Application, BC Hydro explains: [Platts] index prices are published on the trade date Please explain the difference between flow date and trade date, and please explain the significance of publishing index prices on the trade date versus publishing index prices on the flow date. Flow date is the day on which the energy was delivered. Trade date is the day on which the contract was traded, which is normally the day before the flow date but could be earlier depending on holiday schedules. The significance is that publication of index prices on the flow date would allow additional time for verification and cross-checking.

16 Information Request No Dated: October 18, Reference: SPDJI AND PLATTS MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.4.1, p. 6, Section 2.5.1, p. 7 Section 2.6.1, p. 9, and Section 2.7.1, p. 10 MWh vs. MW Of the methodologies BC Hydro reviewed, Platts is the only provider that uses MW in their calculations Please confirm if transactions over a period less than one hour will be included in Platts, Powerdex or ICE calculations. Were these types of transactions included in SPDJI s calculations? How would each index treat a 1000MW request for 45 minutes in their index calculation? None of Platts, Powerdex, or ICE include transactions that are less than one hour in their index calculations so a 1000 MW request for 45 minutes would not be included in any of their indices. BC Hydro is unable to confirm whether SPDJI would have included transactions of less than one hour in their index calculations.

17 Information Request No Dated: October 18, 2013 of Reference: PLATTS, POWERDEX AND ICE MID-C ELECTRICITY PRICE INDICES Exhibit B-1, Section 2.5.3, p. 8, Section 2.6.3, p. 10, and Section 2.7.3, p. 11 Suitability of Platts, Powerdex and ICE for BC Hydro Purposes On pages 8, 10 and 11 of the Application, BC Hydro states: The Platts indices have a high degree of correlation with the equivalent SPDJI indices. The Powerdex data correlation with the equivalent SPDJI indices is not as good as Platts., and The ICE data correlation with the equivalent SPDJI indices is also not as good as Platts Please provide the correlation coefficients, confidence intervals and sample sizes for the comparisons of Platts, Powerdex and ICE indices with the SPDJI indices, for on-peak, off-peak, Sunday and NERC holidays for the August 1 to 13, 2013 test period, and for a two-month test period August 1, 2013 to September 30, BC Hydro provides the requested information in the following table. However, since SPDJI data is not available after September 13, 2013, BC Hydro has modified the two-month test period to be from July 13, 2013 to September 13, The sample sizes are based on the entire population of samples in each of the test periods and correlation coefficients are determined based on comparison of the index values from each index provider to the equivalent SPDJI value in each of the test periods. BC Hydro did not provide the confidence intervals in the form requested. Since, the confidence intervals on the sample data populations would demonstrate the range of expected index values at a specified level of confidence, BC Hydro believes this would not be informative for the Commission. BC Hydro has instead included the 95 per cent and 90 per cent confidence intervals for the variance between the index value of each index provider and the corresponding SPDJI value for the entire sample population in each test period.

18 Information Request No Dated: October 18, 2013 Page 2 of 2 Test Period August 1 August 13, 2013 July 13 September 13, 2013 Index Provider Platts ICE Powerdex Platts ICE Powerdex Sample Size Correlation coefficient % Confidence Interval on Variance from SPDJI Value (i.e., 95% Confident Variance will be in Range) ($) to to to to to to % Confidence Interval on Variance from SPDJI Value (i.e., 90% Confident Variance will be in Range) ($) to to to to to to +0.25