Open letter to Premier Darrell Pasloski and Mike Nixon, minister of Justice,
During the recent Yukon Utility Board proceedings for the Yukon Electrical 2013-15 General Rate Application, the parties involved were formally informed that YECL plans on spending some $10.6 million on their Fish Lake facility for which they now want to place onto the rate base. In other words, have the Yukon electrical ratepayers pay for all of these expenses.
They are creating this brand new hydro infrastructure due to a “catastrophic failure” of their very old facility which has earned their shareholders millions upon millions of dollars over the years.
On August 15, 2013 the Utilities Consumers’ Group wrote you requesting the Yukon Energy-proposed Diesel Liquified Natural Gas Conversion project be brought forward for a Part 3 assessment under the Public Utilities Act. This has been done and we thank you and all concerned very much.
Now we have a private enterprise trying to ram through a major project without undergoing the same scrutiny. The YECL conveniently split this project into several business cases numbers 1,2,7,9 and 28 – separating the costs in an attempt to ease this through a far less in-depth regulatory process.
The Public Utilities Act Chapter 186 section 36 states: Interpretation “energy operation certificate” means a certificate issued under this Part authorizing the holder of the certificate to operate a regulated project. Further “energy project” means a facility for the generation of electricity from the motion of wind or water, or the combustion of natural gas, oil, petroleum project, coal or plant products or geothermal energy.
The Act goes on in Section 37: No person shall construct a regulated project except in accordance with an energy project certificate. Section 39 continues: An application for an energy project certificate or energy operation certificate shall be made to the minister and shall contain the prescribed information. Section 40 On receipt of an application, the minister shall refer the application to the board for a review.
Under these sections, once this project is applied to be regulated onto the rate base, the privately owned Yukon Electrical company must be treated under the same conditions as our publicly-owned corporation.
UCG also recommends the costs for the rebuild of the Old Crow facilities also go through a Part 3 review as business plans numbers 8, 10 and 15 for this project demonstrates a cost of $3 million. The new development of an ice road to the community now needs to be considered as this should lower these costs greatly, so this plan should be re-evaluated.
Secondly, Yukon Electric has not even considered any other alternative energy source to this plan to get the community of Old Crow off-base fossil fuel generation. The various government’s concerned (First Nation, federal and YTG) have the fiduciary and environmental responsibility to make this happen before Yukon Electric spends these millions on a revamp of old technology.
There is great urgency in making this request, as the Yukon Utilities Board is now deliberating on these applications and they need advance notice that a Part 3 process application for an energy project certificate advance before these plans can become a regulated project to go into rate base.
Utilities Consumers’ Group