January 6, 2026

On January 6, 2026, BCSEA withdrew as an intervener in the BCUC’s proceeding on BC Hydro’s 2025 Integrated Resource Plan because the BCUC ordered BCSEA to file all submissions jointly with another intervener. BCSEA directors instructed its lawyer in the proceeding to file a letter to the BCUC stating the following:

“BCSEA withdraws as an intervener in this proceeding.

BCSEA asked to intervene on its own behalf. [Exhibit C8-1, pdf p.2.] However, the Panel purported to accept BCSEA as an intervener subject to a direction that “BCSEA and WE-CAN are … to participate as one intervener group, and to file all submissions jointly.” [Exhibit A-3, section 4.] BCSEA is unable and unwilling to intervene in this proceeding under limitations that would reduce, not improve, regulatory efficiency.

1. BCSEA would be unable to file a joint submission with WE-CAN in this proceeding primarily because BCSEA is unwilling to waste time trying to achieve consensus with WE-CAN as to what submissions do or do not fit within the narrow scope of the proceeding. [The scope of the proceeding was already narrow (in BCSEA’s view) when BCSEA listed the issues it intended to address. The scope of the proceeding was further narrowed by the Panel at Exhibit A-3, pdf p.8.]
2. BCSEA coordinated with WE-CAN before WE-CAN requested to intervene (including regarding whether a joint intervention would be workable) and BCSEA continues to coordinate with WE-CAN about this proceeding. This is consistent with Rule 10.03, which states: “The BCUC encourages and may require an intervener to coordinate with other interveners who represent substantially similar interests.” Unfortunately, the Panel has said nothing about why BCSEA’s coordination with WE-CAN would be insufficient.
3. BCSEA respectfully disagrees with the Panel’s apparent assumption that a mandatory joint submissions order against BCSEA [BCSEA speaks only for itself, not for other interveners.] would actually enhance regulatory efficiency. On the contrary, BCSEA’s experience of being subject to a mandatory joint submissions order in the BCUC’s RNG proceeding is that BCSEA’s expenditure of legal and consultant resources expanded substantially with no corresponding improvement in BCSEA’s submissions to the BCUC. BCSEA’s fundamental objection to a mandatory joint submissions order against it is that the order is wrong-headed. The order worsens regulatory efficiency.
4. BCSEA is very serious in supporting improved regulatory efficiency in BCUC proceedings. BCSEA routinely speaks in favour of shorter regulatory timeframes and more-focused identification of the issues. Moreover, while BCSEA believes it already maintains strict internal discipline on its time expenditures, BCSEA is not opposed to a reasonable cap on a cost award to it [Rule 37.02.] where the Commission wants to signal the level of work-effort it expects from BCSEA for a given proceeding.
5. Not only does the mandatory joint submissions order against BCSEA in this proceeding worsen regulatory efficiency, it would strip from BCSEA its sole responsibility to determine an acceptable level of work-effort and corresponding financial risk. In this way, the order directly undermines the concept of intervener responsibility that BCSEA submits is at the heart of the Commission’s ‘work now, maybe get paid later’ approach to cost awards.
6. BCSEA is very reluctant to accept the Panel’s denial of an opportunity for BCSEA to intervene on its own behalf in this important proceeding. BCSEA believes it could have made a significant contribution based on BCSEA’s experience as a long-time participant in BC Hydro’s Technical Advisory Committee and as an intervener in the Commission’s 2021-2024 proceeding on BC Hydro’s 2021 IRP.”