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From: DR Quinn [mailto:drquinn@rogers.com]
Sent: March 3, 2012 11:57 AM
To: 'Jay Shepherd'; 'Galick, Angela'; richard.king@nortonrose.com; john.beauchamp@nortonrose.com; david.butters@appro.org; jwolnik@era-inc.ca; cconway@bomatoronto.org; cstradling@bomatoronto.org; vderose@blgcanada.com; paul.clipsham@cme-mec.ca; pthompson@blg.com; rwarren@weirfoulds.com; jgirvan@ca.inter.net; EGDRegulatoryProceedings@enbridge.com; bonnie.adams@enbridge.com; fcass@airdberlis.com; DavidMacIntosh@nextcity.com; spainc@rogers.com; ian.mondrow@gowlings.com; mnewton@igua.ca; dpoch@eelaw.ca; kai@web.net; randy.aiken@sympatico.ca; jim.gruenbauer@kitchener.ca; vyoung@aegent.ca; barbara.reuber@opg.com; murray.klippenstein@klippensteins.ca; basil.alexander@klippensteins.ca; jgibbons@pollutionprobe.org; spracket@pwu.ca; jkwik@era-inc.ca; Richard.Stephenson@paliareroland.com; fhassan@era-inc.ca; paul.kerr@shell.com; elisabeth.demarco@macleoddixon.com; jharbell@stikeman.com; cramer@sitheglobal.com; clerks@timmins.ca; pete_serafini@transalta.com; laura-marie_berg@transalta.com; murray_ross@transcanada.com; jim_bartlett@transcanada.com; nadine_berge@transcanada.com; transcanada_mainline@transcanada.com; mbuonaguro@piac.ca; jwightman@econalysis.ca; admin@nrgas.on.ca; nick@sixnatgas.com; 'Ripley, Chris'; 'Kitchen, Mark'; 'Clark, Joanne'; 'Birmingham, Rick'; csmith@torys.com; asmith@torys.com; 'Wayne McNally'; 'Mark Rubenstein'
Cc: BoardSec; Khalil Viraney
Subject: RE: EB-2011-0210 2013 Rates Application



As requested by the Board in its letter of March 2nd on the above application, we provide the comments of the Federation of Rental-housing Providers of Ontario (FRPO).



Issues Conference



We understand and respect that scheduling difficulties can arise. We respect that the deferral of the Issues Conference to the week of March 19th would not necessarily create risks of prejudice to ratepayers expecting that the Issues process would not constrain the ability to modify the Issues List beyond only those items accepted by the Applicant.



Interrogatory Deadline



From our experience, we understand that the Applicant may have to answer a large volume of questions. However, we are concerned with why they would propose that the ratepayers’ window to generate those questions should be decreased so that the Applicant’s window could be increased. SEC and LPMA have expressed concerns about March time constraints, which we support. In addition, we submit that the Applicant’s justification for requesting a constraint on the ratepayers’ window is based on the premise that there has been ample time to process the application since it was delivered a few months ago. What the applicant is not recognizing is that in the last few months, amongst other priorities, ratepayers have been involved in the finalization of the Applicant’s 2010 deferral accounts, 2012 rates and the three year DSM plan. In addition, what has been learned in these applications, in our view, increases our need to ensure that there is sufficient scrutiny and discovery of the underlying assumptions and methodologies that ought not be constrained because the Applicant’s previous comparable application generated numerous questions. In our submission, the types of questions and understanding sought in the previous Application ought to have informed the Applicant on the information that should be contained in this Application to improve the discovery process in the public interest thus reducing questions.



Respectfully, we have not been privy to any discussions of the timing of the next steps including windows for an Oral Hearing and we are certainly respectful of available Board time. Therefore, we respect that the Board may be reluctant to push back the interrogatory response date. If that is the case, in respect of the Board’s desire to balance time, we would respectfully submit that if the Applicant needs more time, the earliest that ratepayers should be required to submit is April 9th (given the statutory holiday on April 6th). At that point, the Applicant has the discretion to apply for an additional extension of time based upon the number of interrogatories received.



Respectfully submitted on behalf of FRPO,



Dwayne R. Quinn

Principal

DR QUINN & ASSOCIATES LTD.

519-500-1022



From: Jay Shepherd [mailto:jay.shepherd@canadianenergylawyers.com]
Sent: March-02-12 7:59 PM
To: 'Galick, Angela'; richard.king@nortonrose.com; john.beauchamp@nortonrose.com; david.butters@appro.org; jwolnik@era-inc.ca; cconway@bomatoronto.org; cstradling@bomatoronto.org; vderose@blgcanada.com; paul.clipsham@cme-mec.ca; pthompson@blg.com; rwarren@weirfoulds.com; jgirvan@ca.inter.net; EGDRegulatoryProceedings@enbridge.com; bonnie.adams@enbridge.com; fcass@airdberlis.com; DavidMacIntosh@nextcity.com; spainc@rogers.com; drquinn@rogers.com; ian.mondrow@gowlings.com; mnewton@igua.ca; dpoch@eelaw.ca; kai@web.net; randy.aiken@sympatico.ca; jim.gruenbauer@kitchener.ca; vyoung@aegent.ca; barbara.reuber@opg.com; murray.klippenstein@klippensteins.ca; basil.alexander@klippensteins.ca; jgibbons@pollutionprobe.org; spracket@pwu.ca; jkwik@era-inc.ca; Richard.Stephenson@paliareroland.com; fhassan@era-inc.ca; paul.kerr@shell.com; elisabeth.demarco@macleoddixon.com; jharbell@stikeman.com; cramer@sitheglobal.com; clerks@timmins.ca; pete_serafini@transalta.com; laura-marie_berg@transalta.com; murray_ross@transcanada.com; jim_bartlett@transcanada.com; nadine_berge@transcanada.com; transcanada_mainline@transcanada.com; mbuonaguro@piac.ca; jwightman@econalysis.ca; admin@nrgas.on.ca; nick@sixnatgas.com; 'Ripley, Chris'; 'Kitchen, Mark'; 'Clark, Joanne'; 'Birmingham, Rick'; csmith@torys.com; asmith@torys.com; Wayne McNally; Mark Rubenstein
Cc: BoardSec; Khalil Viraney
Subject: RE: EB-2011-0210 2013 Rates Application



SEC notes that Union’s new proposed IR date of March 30th is only a week after the issues list is finalized. Interrogatories have to be organized and presented by issue, so cannot really be written until the issues list is available.



We note that, in addition, the date Union proposes is on the last day of a three-day RRFE stakeholder conference that will be the focus for many intervenors.



Under the circumstances, we believe this proposal provides an insufficient time frame for intervenor interrogatories to be prepared.



Jay



Jay Shepherd, Energy Law

2300 Yonge St., Suite 806

Toronto M4P 1E4



Tel: 416-483-3300

Cell: 416-804-2767 (best contact)

Fax: 416-483-3305







From: Galick, Angela [mailto:AGalick@uniongas.com]
Sent: March-02-12 2:57 PM
To: richard.king@nortonrose.com; john.beauchamp@nortonrose.com; david.butters@appro.org; jwolnik@era-inc.ca; cconway@bomatoronto.org; cstradling@bomatoronto.org; vderose@blgcanada.com; paul.clipsham@cme-mec.ca; pthompson@blg.com; rwarren@weirfoulds.com; jgirvan@ca.inter.net; EGDRegulatoryProceedings@enbridge.com; bonnie.adams@enbridge.com; fcass@airdberlis.com; DavidMacIntosh@nextcity.com; spainc@rogers.com; drquinn@rogers.com; ian.mondrow@gowlings.com; mnewton@igua.ca; dpoch@eelaw.ca; kai@web.net; randy.aiken@sympatico.ca; jim.gruenbauer@kitchener.ca; vyoung@aegent.ca; barbara.reuber@opg.com; murray.klippenstein@klippensteins.ca; basil.alexander@klippensteins.ca; jgibbons@pollutionprobe.org; spracket@pwu.ca; jkwik@era-inc.ca; Richard.Stephenson@paliareroland.com; fhassan@era-inc.ca; bwilliams@opsba.org; jay.shepherd@canadianenergylawyers.com; paul.kerr@shell.com; elisabeth.demarco@macleoddixon.com; jharbell@stikeman.com; cramer@sitheglobal.com; clerks@timmins.ca; pete_serafini@transalta.com; laura-marie_berg@transalta.com; murray_ross@transcanada.com; jim_bartlett@transcanada.com; nadine_berge@transcanada.com; transcanada_mainline@transcanada.com; mbuonaguro@piac.ca; jwightman@econalysis.ca; admin@nrgas.on.ca; nick@sixnatgas.com; Ripley, Chris; Kitchen, Mark; Clark, Joanne; Birmingham, Rick; csmith@torys.com; asmith@torys.com; Galick, Angela
Subject: EB-2011-0210 2013 Rates Application



Attached please find Union’s correspondence regarding the 2013 Rates Application.



This has been filed in the RESS and two paper copies have been sent by courier to the Board.



Angela Galick
Administrative Assistant, Regulatory Affairs
Union Gas Limited | A Spectra Energy Company
50 Keil Drive N | Chatham, ON N7M 5M1
519-436-4600 ext 2165





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