included in the survey is published in the Quarterly Reports and the Budget and Fiscal Plan.

Transcription

1 Information Request No (a) Dated: 5 April Reference: BC Hydro letter of March 29, 2004 indicating, among other things, that BC Hydro is prepared to call Mr. Robert Fairholm to testify on foreign exchange and interest rate issues, and BCUC letter L requesting parties planning to contest the interest assumptions to give notice of that intent by April 22, (a) A table or tables showing the first three fiscal years of all forecasts issued by the provincial government from January, 994 to January 22, 2004 for each of: Canadian short-term interest rates; U.S. short-term interest rates; Canadian long-term interest rates; U.S. long-term interest rates; and U.S./CAD FX rate. The tables below show short- and long-term interest rates and US/Canadian exchange rates drawn from forecasts produced by Treasury Board Staff of the Province of BC. The rates reflect forecasts released publicly in conjunction with Provincial Budgets and quarterly updates or reports, along with forecasts that were not originally released publicly (marked "Internal"), which were issued by Treasury Board Staff and used by BC Hydro as part of its budgeting processes. All interest rates provided are a forecast of Government of Canada or United States treasury bills or long-term (0 years) bonds by Treasury Board Staff. Except where indicated, all forecasts are annual averages over a calendar year. Where possible, the source of the forecast is indicated in the table title. Treasury Board Staff use private sector forecasts of interest rates and exchange rates as a benchmark in producing their own forecasts for these financial variables. This also helps ensure consistency between exchange rate and interest rate forecasts. In the past, staff judgement has also been an input into the forecast, partly to allow for discussion and consensus building amongst different areas of government (e.g. Provincial Treasury), but largely as an attempt to predict how the private sector average may be evolving. Given recent uncertainty in currency markets, Treasury Board Staff have used a strictly consensus based methodology for their recent forecasts. This change also increases the transparency of the interest rate and exchange rate forecasts used in the Budget process. Beginning in September 2003, the process became one of basing the forecast directly on an average of forecasts produced by private sector forecasters at a particular date. The exchange rate forecasts of the private sector individuals

2 Information Request No (a) Dated: 5 April included in the survey is published in the Quarterly Reports and the Budget and Fiscal Plan.

3 Information Request No (a) Dated: 5 April Winter Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate March Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate August Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate December Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate March Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

4 Information Request No (a) Dated: 5 April August Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate December Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate April Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate September Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate Spring Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

5 Information Request No (a) Dated: 5 April August Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate December Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate March Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate BC Economic Review and Outlook - March Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

6 Information Request No (a) Dated: 5 April September Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate Budget March Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate First Quarterly Report 2000/0 - September Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate Provincial Budget - March Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate Economic and Fiscal Update - July Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

7 Information Request No (a) Dated: 5 April Second Quarterly Report 200/02 - September Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates No forecast No forecast US/Canadian exchange rate "Internal" Interest Rate Forecast - October 200 F200/02 F2002/03 F2003/04 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate "Internal" Interest Rate Forecast January 2002 F2002/03 F2003/04 F2004/5 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate Budget and Fiscal Plan February Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

8 Information Request No (a) Dated: 5 April "Internal" Interest Rate Forecast August 2002 F2002/03 F2003/04 F2004/05 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate First Quarterly Report 2002/03 September Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate "Internal" Interest Rate Forecast November 2002 F2002/03 F2003/04 F2004/05 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate "Internal" Interest Rate Forecast January 2003 F2002/03 F2003/04 F2004/05 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

9 Information Request No (a) Dated: 5 April Budget and Fiscal Plan February Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate "Internal" Interest Rate Forecast August 2003 F2003/04 F2004/05 F2005/06 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate First Quarterly Report 2003/04 September Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate "Internal" Interest Rate Forecast November 2003 F2003/04 F2004/05 F2005/06 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

10 Information Request No (a) Dated: 5 April "Internal" Interest Rate Forecast January 2004 F2003/04 F2004/05 F2005/6 Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate Budget and Fiscal Plan February Canadian short-term interest rates US short-term interest rates Canadian long-term interest rates US long-term interest rates US/Canadian exchange rate

11 Information Request No (b) Dated: 5 April Reference: BC Hydro letter of March 29, 2004 indicating, among other things, that BC Hydro is prepared to call Mr. Robert Fairholm to testify on foreign exchange and interest rate issues, and BCUC letter L requesting parties planning to contest the interest assumptions to give notice of that intent by April 22, (b) A table showing actual experienced rates (average or a range) for each of: Canadian short-term interest rates; U.S. short-term interest rates; Canadian long-term interest rates; U.S. long-term interest rates; and U.S./CAD FX rate for each fiscal year from 994 to and including fiscal The tables below show the economic variables requested in the question above. The interest rates provided are on the same basis as in BC Hydro's response to JIESC IR #2.23.0(a). Please note: (a) All information is from Bloomberg and is based on closing rates as recorded by Bloomberg. (b) All rates are based on applicable Government 3 month Treasury Bill and 0 year Treasury Bond yields as proxies for short-term and long-term interest rates and to remain consistent with the Treasury Board forecasts as shown in BC Hydro's response to JIESC IR #2.23.0(a). The Province of BC, through the Treasury Board, provides forecasts for 3 month treasury bills and 0 year Government Treasury Bonds periodically through the year for budgeting and economic review purposes. (c) Average rates are based on the average of the daily closing rates for the fiscal year.

12 Information Request No (b) Dated: 5 April Canadian 3 Month Treasury Bill Rates F994 F995 F996 F997 F998 F999 F2000 F200 F2002 F2003 F2004 High Low Average U.S. 3 Month Treasury Bill Rates F994 F995 F996 F997 F998 F999 F2000 F200 F2002 F2003 F2004 High Low Average Canadian 0 Year Treasury Bond Rates F994 F995 F996 F997 F998 F999 F2000 F200 F2002 F2003 F2004 High Low Average U.S. 0 Year Treasury Bond Rates F994 F995 F996 F997 F998 F999 F2000 F200 F2002 F2003 F2004 High Low Average U.S./CAD FX Rate F994 F995 F996 F997 F998 F999 F2000 F200 F2002 F2003 F2004 High Low Average

13 Information Request No (c) Dated: 5 April Reference: BC Hydro letter of March 29, 2004 indicating, among other things, that BC Hydro is prepared to call Mr. Robert Fairholm to testify on foreign exchange and interest rate issues, and BCUC letter L requesting parties planning to contest the interest assumptions to give notice of that intent by April 22, (c) A table giving the impact on BC Hydro s F2006 Revenue Requirement of a 00 basis point change for each of: Canadian short-term interest rates; U.S. short-term interest rates; Canadian long-term interest rates; U.S. long-term interest rates; and U.S./CAD FX rate for each fiscal year 994 to and including fiscal BC Hydro actively manages its interest rate exposure relative to established benchmarks. The impacts on the F2006 finance charges shown in the table below are based on a 00 basis point change in F2006 for each factor in isolation. It is anticipated that BC Hydro would be able to mitigate some or all of the impact through active management of its interest rate exposure. The impact in F2006 of the various factors was calculated based on a change during F2006 only, and not cumulatively from F994. It is not possible to model the different scenarios or reactions to the various changes in response to changes in each of the economic variables on a cumulative basis over the 0-year period. Impact on F2006 Finance Charges of a 00 Basis Point Change Canadian short-term interest rates Increase or decrease by approximately $4 million from the revised April 2, 2004 financials. US short-term interest rates Increase or decrease by approximately $3 million from the revised April 2, 2004 financials. Canadian long-term interest rates Increase or decrease by approximately $5 million from the revised April 2, 2004 financials. US long-term interest rates No impact to net income from the revised April 2, 2004 financials. US/CDN foreign exchange rate Increase or decrease by approximately $2.5 million from the revised April 2, 2004 financials.

14 Information Request No (c) Dated: 5 April Notes: The impact on finance charges is estimated only by changes in interest rates. There may be other impacts, such as the impact on economic or customer activity and the resulting flow-through impact on revenues and domestic load. For Canadian long-term debt, the amount is determined from change in longterm debt interest expense for two new forecasted issues in Assumed that the new issues would have been issued at % higher or lower than the rate used in the plan. For US long-term debt, there are no new US Dollar long-term debt issues planned so the impact would be zero. For the US/Canadian exchange rate, the amount is determined from finance charges along with Powerex forecasted activity.

15 Information Request No (a) Dated: 5 April Reference: Application, Responses to BCUC IRs Explanation: The Application and responses to information requests refer to consultant and contractor charges. Additional information is required as to the level and nature of the costs and the services provided (a) Provide an explanation of the services and the distinction in the services that are referred to as contractor charges and the services referred to as consulting charges. There are three categories within "External Services - Other" on the "D" Schedules that should be reviewed as a group. These are Consultants, Contractors, and Outside Services. The generally used definitions for these three categories are: Consultants covers the cost of external engineering, management and business consulting services; and includes development of standards, designs and specifications for civil, mechanical and electrical maintenance and construction of the electric system. Contractors covers the cost of work done on the overhead and underground electrical system by contractors on a fixed price, cost plus contract or unit price contract. It includes work done on an "Offer to Perform Work" but does not apply to contributions-in-kind. This also includes civil work, right-of-way clearing, grooming associated with electrical installations, helicopter costs when transporting equipment and debris clearing when a contractor is paid directly by BC Hydro. Outside Services covers other services provided by contractors not covered by other resource codes. Examples include: general maintenance, crane service, janitorial, snow plowing, and record storage. It includes freight and cartage charges only if not identified with the item purchased.

16 Information Request No (b) Dated: 5 April Reference: Application, Responses to BCUC IRs Explanation: The Application and responses to information requests refer to consultant and contractor charges. Additional information is required as to the level and nature of the costs and the services provided (b) Provide a summary schedule of consulting and contractor charges by year by Line of Business and Business Unit for 2003 to 2006 with a description of the type of services provided. This information request falls outside the scope of the third round of information requests allowed by the Commission in Letter No. L and Order No. G Further, the burden of responding in writing to approximately 250 further information requests received at this late stage of the written phase of the hearing would jeopardize BC Hydro's ability to adequately prepare for the oral phase of the hearing. For these reasons BC Hydro declines to respond to this information request.

17 Information Request No (a) Dated: 5 April Reference: Application Update; Application, 9-64 Explanation: BC Hydro entered into the ABS contract and as a Founding Partner may recover Northstar project costs and share in revenues. The Application updates do not make any reference to an update to the Accenture costs and credits (a) Confirm the level of credits from ABS included in the original and updated Application and the treatment of the credits. Please see BC Hydro s responses to BCUC IR #2.63.(a) through BCUC IR #

18 Information Request No (b) Dated: 5 April Reference: Application Update; Application, 9-64 Explanation: BC Hydro entered into the ABS contract and as a Founding Partner may recover Northstar project costs and share in revenues. The Application updates do not make any reference to an update to the Accenture costs and credits (b) If BC Hydro has a current forecast of credits or range of expected credits from ABS, provide the current forecast. Please see BC Hydro s responses to BCUC IR #2.63.(a) through BCUC IR #

19 Information Request No (a) Dated: 5 April Reference: Application Update, 2A-2; Application Update R, 2A-4, 2A-3 Explanation: The original Application update dated February 20, 2004 shows BC Hydro earning 4.40% in 2005 vs. 3.9% allowed and 5.28% in 2006 vs. 3.9 allowed. With the revised Application update and the effects of lower water levels, BC Hydro is forecasting earnings slightly below the allowed returns (a) Provide an explanation of why in the original Application update BC Hydro was forecasting earnings above the allowed ROE in 2005 and Both the original Evidentiary Update (filed February 20, 2004) and the Revised Evidentiary Update (filed April 2, 2004) reflect the same changes in a number of key assumptions since BC Hydro s Revenue Requirement Application was filed on December 5, These changes include the use of updated snowpack conditions and updated interest and foreign exchange rate assumptions as detailed on page 2A- of the Revised Evidentiary Update. The impact of these changes is a significant reduction in the net income (before deferral account transfers) from the Revenue Requirement Application. The higher ROE shown in the original Evidentiary Update is based on the net income after deferral account transfers. Before the transfers to the deferral accounts, the ROE in the original Evidentiary Update would be below the allowed ROE of 3.9%. It was assumed in the original Evidentiary Update that the increase in costs related to the Heritage Payment Obligation as a result of lower than normal snowpack would be transferred to deferral accounts, however, the decrease in costs as a result of improved interest and exchange rate forecasts not related to Heritage assets would not be flowed through deferral accounts. This translated into higher net income and return on equity after taking into account deferral account transfers. This assumption was made because at the time of filing the original Evidentiary Update, BC Hydro had not concluded its consideration of what deferral account mechanisms would be appropriate in determining BC Hydro s rates. BC Hydro has now concluded its consideration of the design of the deferral accounts and filed its proposal as Chapter 2B on April 2, As indicated in the Revised Evidentiary Update, BC Hydro proposes that the forecast included in the Revised Evidentiary Update be used as the basis for determining rates. As a result, the Revised Evidentiary Update does not show any transfers into the deferral accounts. The revised Evidentiary Update shows a return on equity below the allowed return on equity in F2005 as the additional.67% increase requested to

20 Information Request No (a) Dated: 5 April meet BC Hydro s Revenue Requirement, if approved, will not become effective until after the BCUC s decision on the Application is issued. For the purposes of the filing, BC Hydro assumed that the additional.67% rate increase will take effect on November, 2004.

21 Information Request No (b) Dated: 5 April Reference: Application Update, 2A-2; Application Update R, 2A-4, 2A-3 Explanation: The original Application update dated February 20, 2004 shows BC Hydro earning 4.40% in 2005 vs. 3.9% allowed and 5.28% in 2006 vs. 3.9 allowed. With the revised Application update and the effects of lower water levels, BC Hydro is forecasting earnings slightly below the allowed returns (b) Confirm that the variance or error is not reflected in the forecast Net Income and ROE in the revised Application update. Please see BC Hydro s response to JIESC IR #3.26.0(a).

22 Information Request No (a) Dated: 5 April Reference: Internal Audit Report, Water Use Plans; Application, 5-49, 5-50 Explanation: BC Hydro is incurring significant costs for water use planning with costs estimated at $26 million. Where water use plans result in a reduction in generation, the additional energy costs are recovered against the water rental costs. There is a reference to future remissions for implementation costs (a) Is BC Hydro aware of any commitment by the Province under the previous or current government to reimburse BC Hydro for water use planning costs? Provide a copy of all related correspondence and news releases. This information request falls outside the scope of the third round of information requests allowed by the Commission in Letter No. L and Order No. G Further, the burden of responding in writing to approximately 250 further information requests received at this late stage of the written phase of the hearing would jeopardize BC Hydro's ability to adequately prepare for the oral phase of the hearing. For these reasons BC Hydro declines to respond to this information request.

23 Information Request No (b) Dated: 5 April Reference: Internal Audit Report, Water Use Plans; Application, 5-49, 5-50 Explanation: BC Hydro is incurring significant costs for water use planning with costs estimated at $26 million. Where water use plans result in a reduction in generation, the additional energy costs are recovered against the water rental costs. There is a reference to future remissions for implementation costs (b) Provide a description of how Water Use Planning costs are tracked and reported to the Comptroller. This information request falls outside the scope of the third round of information requests allowed by the Commission in Letter No. L and Order No. G Further, the burden of responding in writing to approximately 250 further information requests received at this late stage of the written phase of the hearing would jeopardize BC Hydro's ability to adequately prepare for the oral phase of the hearing. For these reasons BC Hydro declines to respond to this information request.

24 Information Request No (c) Dated: 5 April Reference: Internal Audit Report, Water Use Plans; Application, 5-49, 5-50 Explanation: BC Hydro is incurring significant costs for water use planning with costs estimated at $26 million. Where water use plans result in a reduction in generation, the additional energy costs are recovered against the water rental costs. There is a reference to future remissions for implementation costs (c) If BC Hydro recovers water use planning consultation costs, describe the process, source and level of cost recovery. This information request falls outside the scope of the third round of information requests allowed by the Commission in Letter No. L and Order No. G Further, the burden of responding in writing to approximately 250 further information requests received at this late stage of the written phase of the hearing would jeopardize BC Hydro's ability to adequately prepare for the oral phase of the hearing. For these reasons BC Hydro declines to respond to this information request.

25 Information Request No (d) Dated: 5 April Reference: Internal Audit Report, Water Use Plans; Application, 5-49, 5-50 Explanation: BC Hydro is incurring significant costs for water use planning with costs estimated at $26 million. Where water use plans result in a reduction in generation, the additional energy costs are recovered against the water rental costs. There is a reference to future remissions for implementation costs (d) Provide the reference to where the Water Use Planning costs and related recoveries are identified the Application Water Use Planning costs for the test periods are referenced in Chapter 5, 5-45, table 5-28; Chapter, -, Table -4; and -5, Section The remissions program is described on 5-49 and A more detailed financial breakdown of estimated remissions is not available in the Application because not all Water Use Plan projects have been completed. In addition the completed projects have not been approved by the provincial Water Comptroller. Until these approvals are final, it is not practical to estimate remissions. Please also see BC Hydro s response to BCUC IR #.5.3.

26 Information Request No Dated: 5 April Reference: Application, 9-2, Table 9-3 Explanation: BC Hydro has reported an engineering head count of 650 in 2005 and 640 in 2006, including contractors. The number of engineering personnel appears to be high for an organization that is not expected to undertake generation projects Has BC Hydro undertaken a benchmarking study to evaluate the number of engineering personnel and productivity? Provide all benchmarks for engineering costs and personal by Line of Business available from the CEA, other industry associations or from a study commissioned by BC Hydro. This information request falls outside the scope of the third round of information requests allowed by the Commission in Letter No. L and Order No. G Further, the burden of responding in writing to approximately 250 further information requests received at this late stage of the written phase of the hearing would jeopardize BC Hydro's ability to adequately prepare for the oral phase of the hearing. For these reasons BC Hydro declines to respond to this information request. Please note, however, that much of the information requested in the questions above was provided in BC Hydro s responses to BCUC IR #2.54.0, BCUC IR #2.93. and BCOAPO IR #.4.0(b).

27 Information Request No (a) Dated: 5 April Reference: Application Update, 2A-5, 2A-6 Explanation: BC Hydro has filed an update to the Application with electricity sales revised for 2004, 2005 and (a) When were the sales forecast updates for Residential, Light Industrial /Commercial, Industrial and other domestic sales prepared? The Revised Evidentiary Update does not include an update to the load forecast. The most recent load forecast is the one prepared in October 2003, which was used in preparation of the Application. The Revised Evidentiary Update does, however, include an update to the forecast domestic sales revenue and volumes for F2004 based on more recent actual billing data. For the Revised Evidentiary Update, forecast F2004 revenues and volumes were derived by summing actual sales for April 2003 to December 2003 and forecast data for January 2004 to March 2004 from the load forecast. The comparisons of forecast domestic sales revenue and volumes for F2004 between the Application and the Revised Evidentiary Update are shown in Table 2A-3 and Table 2A-4 of Chapter 2A. As explained in Chapter 2A-6, Lines 2-20, the Domestic sales volume forecast remains unchanged in the Revised Evidentiary Update to that in the Application for F2005 and F2006. The changes to forecast revenues in F2005 and F2006 reflect the proposed rate increases and changes in foreign exchange rate assumptions. The comparisons of forecast domestic sales revenues for F2005 and F2006 between the Application and the Revised Evidentiary Update are shown in Table 2A-5 and Tables 2A-6 of Chapter 2A.

28 Information Request No (b) Dated: 5 April Reference: Application Update, 2A-5, 2A-6 Explanation: BC Hydro has filed an update to the Application with electricity sales revised for 2004, 2005 and (b) For 82 sales, for both the original Application and update, what level of input was solicited from customers? In the original Application, the 82 energy sales forecast for F2004, F2005, F2006 was prepared on a customer by customer basis. BC Hydro gathered information for each transmission customer on potential changes in plant operations that may impact sales. For the F2004 update, no input was sought from the transmission customers as the update reflects actuals. As stated in BC Hydro s response to JIESC IR #3.29.0(a), no update to the load forecast for F2005 and F2006 was made as part of the Evidentiary Update.

29 Information Request No (c) Dated: 5 April Reference: Application Update, 2A-5, 2A-6 Explanation: BC Hydro has filed an update to the Application with electricity sales revised for 2004, 2005 and (c) When preparing the Application Update, did BC Hydro review commodity prices and commodity demand and the affect on industrial electricity consumption? BC Hydro did not do a review of commodity prices and demand to prepare the F2004 Revised Evidentiary Update forecast for industrial customers. As stated in BC Hydro s response to JIESC IR #3.29.0(a), no update to the load forecast was made as part of the Revised Evidentiary Update. As such, there was no review of commodity prices and commodity demand.

30 Information Request No (d) Dated: 5 April Reference: Application Update, 2A-5, 2A-6 Explanation: BC Hydro has filed an update to the Application with electricity sales revised for 2004, 2005 and (d) Provide a step by step description of how the updated 82 customer forecast was prepared. There is no change to the 82 customer forecast for F2005 and F2006. Please see BC Hydro s response to JIESC IR #3.29.0(a) for further information.

31 Information Request No (e) Dated: 5 April Reference: Application Update, 2A-5, 2A-6 Explanation: BC Hydro has filed an update to the Application with electricity sales revised for 2004, 2005 and (e) For 82 sales provide the following information by customer for 2005 and SIC (Type of Customer) Forecast Demand Forecast Energy PowerSmart Conservation Stepped Rate Conservation Sales Forecast MWh Sales ($ 000 s) If BC Hydro is unable to provide the information by customer (as is done by other British Columbia utilities) provide the information by Standard Industrial Classification (SIC) or customer type. This information request falls outside the scope of the third round of information requests allowed by the Commission in Letter No. L and Order No. G Further, the burden of responding in writing to approximately 250 further information requests received at this late stage of the written phase of the hearing would jeopardize BC Hydro's ability to adequately prepare for the oral phase of the hearing. For these reasons BC Hydro declines to respond to this information request.