Parkland has filed a response with the BCUC:
https://www.bcuc.com/Documents/Proceedings/2019/DOC_54405_C5-2-Parkland-Evidence.pdf
Skimming over it, it seems to make the following points:
1. Margins are not indicative of profit, and should never be confused, as the refining margin does not take into account various other costs, and the type of product mix being sold by a refinery, some of which is sold at a loss;
2. There's been increases of cost to comply with BC's various green fuel initiatives that the refineries have to absorb. Parkland's Burnaby refinery has seen a 35% increase in costs since 2015 to comply with these requirements;
3. Parkland has had issues with storage requirements to adapt to the green fuel requirements. Since there's very little room to expand storage facilities at the Burnaby refinery, the increasing requirement to mix in renewable fuel has meant storage for refined product gets sacrificed, exacerbating any potential supply uncertainty from Trans Mountain, and any sudden changes in local fuel demand;
4. There are also other pressures in which fuel suppliers have to absorb, such as credit card fees, land costs and property taxes, and salaries of employees, which have all gone up significantly in recent years;
5. Non-fuel revenues (convenience stores, car washes, and other ancillary sales) helps keep gas stations financially afloat. Seems to indicate that gas is either being sold with very thin margins, meaning that they are barely making money or not even breaking even on the sale of fuel;
5. Retail margins of fuel has been declining over the years;
6. Parkland has seen intense competition from Albertan refineries on pricing;
7. Parkland has also had to pay a premium for alternative deliveries and to other shippers to buy allocation on Trans Mountain because the Trans Mountain pipeline is so heavily over subscribed; often the costs to buy up someone else's allocation or to ship crude via rail can be anywhere from 7 to 34 times the base tariff price on Trans Mountain;
8. There is very low barriers for entry for those wanting to supply fuel in BC; witness the many very small players in the wholesale/bulk sales channel, some of which are just a guy with a tanker truck; Parkland is aware of a number of small players who are hauling fuel in from Alberta on trucks, taking advantage of the 75 ML/year threshold contained in the BC low carbon fuels regulations, meaning they don't have the same costs as Parkland does;
9. There is no incentive to arbitrarily drive up prices because of low barriers to entry, and because of constant oversight from Competition Bureau of Canada
Basically, reading over it again, Parkland is saying that what is happening isn’t price gouging at all, but in fact that profit margins are *lower* now than in 2015. It's all of the costs associated with government policies and taxes that are driving up the cost of fuel, especially once you strip away the taxes; the average price of fuel before taxes in BC is comparable to Washington State, California, Oregon, Hawaii, Alaska, and Nevada.