Roy Brady’s OEB submission

Ontario Energy Board
P.O. Box 2319
2300 Yonge Street, 27th Floor
Toronto ON    M4P 1E4

Attention:  Ms. Kirsten Walli
Board Secretary
Ontario Energy Board
Re:  EB-2018-0242

Dear Ms Walli:

I am writing as an observer from Peterborough at the full hearing on December 2-3 regarding the sale of Peterborough Distribution Inc to Hydro One.  I have been a member of Save PDI Peterborough Coalition throughout the controversy, but at the hearing did not make an oral submission or qualify to be part of the cross-examination proceedings there.

The focus during the hearing was on Year Eleven and beyond.  I remain so disappointed with the lack of specifics, beyond so many assumptions and projections.  Hydro One’s presentation throughout was ‘trust us’ and surprisingly lacked upfront positions on customer rates and prevailing costs beginning Year Eleven from the sale.  Very serious doubt remains for the ratepayers of Peterborough and two neighbouring municipalities.

“Adjustment factors” were discussed on a number of occasions, particularly during day one. It was never clear what these factors were to be, even though Hydro One would use these when assessing rates for Peterborough customers from Year Eleven on.  Hydro One has given itself so much flexibility that from Year Eleven on customers may receive much higher rate increases.  Hydro One apparently will determine these factors, with market decisions being foremost.

Would one “adjustment factor” used by Hydro One be “convergence costs” at Year Eleven. That would mean Peterborough’s rates would be influenced by rates already set in other communities.  We already know how elevated Hydro One rates have been set across the province.  Peterborough customers would hereby not be protected by these forces.

It was odd that when making assumptions about the cost and rate situation at Year Eleven, Hydro One did not refer to obvious customer increase.  Would such population increase be a factor to substantially raise customer rates?

I remain more than puzzled that the PDI and Hydro One projections for Year Eleven were so varied.  Why?  No clear explanation was provided, despite a challenge from Intervenor Jay Shepherd.

Hydro One could not respond when questioned by Ms Freeman for evidence that Hydro One has “competitive advantage” over other providers.  Although Hydro One had bragged about competitive advantage twice earlier in the hearing, the spokesperson simply stated ‘he would get that evidence’.

I must point out a serious error from John Stephenson, Chairperson of City of Peterborough Holdings Inc, hence PDI.  In a response to a question he claimed that the decision to sell PDI to Hydro One was based upon public consultation.  Consultation did occur, but opposition to the sale was clearly overriding.  This sale was ‘not’ considered to be acceptable to a large majority of ratepayers in Peterborough.  OEB must understand the fallacy.

Overall, there were too many projections and assumptions that were not well explained. Therefore, there is considerable uncertainty what rate increases Hydro One would present to the OEB and Peterborough ratepayers.  The sale can therefore not be approved.

Thank you for listening, and providing a process for challenge.

Roy Brady
304-136 Ware Street
Peterborough ON   K9J 2B8
705-745-2446,  rbrady1@cogeco.ca

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