DAVI S LEGAL ADVISORS since 1892

Transcription

1 DAVI S LEGAL ADVISORS since 1892 &companyllp C31-20 from the ofice oj P. John Landry direct tel: direct fax: pjl@davis.ca March 9,2006 file number: Mr. Robert J. Pellatt Commission Secretary British Columbia Utilities Commission Sixth Floor, 900 Howe Street Box 250 Vancouver, BC V6Z 2N3 Dear Mr. Pellatt: Re: Sea Breeze Victoria Converter Corporation ("Sea Breeze") CPCN Application for Vancouver Island Cable Project ("VIC") Please find enclosed the direct testimony for Sea Breeze Panel C, consisting of Mr. John Tompkins (Chair), Ms. Resja Campfens, Mr. Mike Wise, Mr. Harold Christian, Mr. Richard Harper, and Mr. Keith Robinson. Their CVs may be found in Exhibit B Yours truly, DAVIS & COMPANY LLP Per: P. John Landry DAVIS & COMPANY LLP w w w. da vis. c a 2800 Park Place, 666 Burrard Street, Vancouver, BC Canada V ~ 227 C VANCOUVER TORONTO MONTREAL CALGARY EDMONTON WHITEHORSE YELLOWKNIFE TOKYO

2 DIRECT TESTIMONY OF JOHN TOMPIUNS Q1. Piease state your name and present positions. My name is John Tompkins and I am a Director and the COO of Sea Breeze Pacific Regional Transportation System, Inc., Juan de Fuca Cable Management, Inc., and Sea Breeze Victoria Converter Corporation. I also a Director and the CFO of Boundless Energy NW, LLC. For our East Coast projects, I am the President of Tompkins Research and Management Consulting. I am also on the Board of Directors for Atlantic Energy Partners, the CFO of Boundless Energy, LLC, and a Partner and the President of CARITrans. Q2. How long have you held those positions? I have been with Sea Breeze since 2003 and the President of Tompkins Research and Management Consulting since I have been on the Board of Atlantic Energy Partners since 1999, the CFO of Boundless Energy since 2001, and with CARITrans since Prior to these positions, what other positions did you hold, and with whom? Prior to these positions I worked for Green Mountain Power Corporation from 1982 to 1986 and for Northeast Utilities Service Company from 1972 to While I was with Northeast Utilities & Green Mountain Power, I worked on transmission projects, including phase 1 & 2 of the HVDC interconnections from Hydro Quebec to Nepool (ISO-NE) projects which were designed to transmit 2,000 megawatts from Radison, Quebec to Sandy Pond substation in Massachusetts. Wile I was the Senior Officer of Green Mountain Power, and in charge of Planning and Generation, I was Green Mountain Power's Planner in charge of VELCO ownership, when we planned and developed the Highgate, Vermont HVDC back-to-back terminals which provided a 200mw interconnection between Quebec and Vermont. After leaving Green Mountain Power, I started my own consulting company, Tompkins Research & Management Consulting, which has been involved in the development of many generation projects. In 1994 Tompkins Research & Management Consulting came up with the idea for the multi-terminal NeptuneRTS HVDC project. The development of this project enabled the principals of Tompkins Research & Management Consulting to provide comments to FERC, which led to the opportunity for independent transmission alternatives in the United States. 44. What are your professional qualifications and other areas of special expertise? I obtained a B.Sc. (Electrical Engineering) from the University of Hartford in 1972 and an Associates Degree (Applied Science) from Waterbury State Technical College in 1969.

3 Q5. What role have you played in the development of the VIC Application, the Juan de Fuca Project, or the analysis of the VITR Application? I am responsible for the technical areas of all of the transmission projects that the Sea Breeze companies are involved in, including design, planning, memberships in utility groups such as WECC and the NWPP, contract negotiations, manufacturer negotiations, open season and transmission service marketing activities, all system impact studies, and related activities. Q6. Did you obtain any expert assistance in fulfilling this role? Yes, Sea Breeze has been assisted in its development activities by numerous executives, expert advisors, and support companies. With respect to technical areas, we have retained ABB's independent technical study group and ZE PowerGroup, which includes four BC Hydro retired technical experts, Gabor Furst, Bruce Prior, Jim Polvi, and Jiri Sochor. 47. Does this complete your direct testimony?

4 DIRECT TESTIMONY OF RESJA CAMPFENS Q1. Please state your name and present position. My name is Resja Campfens and I am the Vice President of Environmental Affairs at Sea Breeze Power Corp. Q2. How long have you held that position? I have been with Sea Breeze for four years and in my present position for two years. From 2002 to 2004 I worked as a Project Manager with Sea Breeze. Q3. Prior to this position, what other positions did you hold, and with whom? I was the Manager of Allen McCollum Studio, a large art production studio, from 1992 to 1999 and a Project Coordinator for Stadium Projects Ltd. from 1997 to Q4. What are your professional qualifications and other areas of special expertise? I am an MBA candidate at Simon Fraser University, anticipating successful completion of the program in July I also hold a B.F.A. from the N.S.C.A.D. University. Q5. What role have you played in the development of the VIC Application, the Juan de Fuca Project, or the analysis of the VITR Application? I oversaw First Nations and public consultation for both the VIC Application and for the environmental assessment process, advised on the consultation section of the terms of reference currently under review by the BC Environmental Assessment Office, and the draft environmental assessment application. With respect to JdF, I managed the development of the Canadian Environmental Assessment application (CEAA) that was submitted to the National Energy Board WB) in I continue to be involved in consultation and the NEB process. I have a coordinating role in the Environmental Impact Statement (EIS) process. I have been involved in analyzing the environmental aspects of the VITR. Q6. Did you obtain any expert assistance in fulfilling this role? Yes, I have worked with several specialized consultants in order to best fulfill specific aspects of my roles on JdF and VIC. On VIC, I worked with Tim Powers from Tim Powers Consulting and John Kaska from Cornerstone Consultations on First Nations issues. I received assistance from K&E Public Affairs Inc. and Alan Dolan with respect to public consultation. Terra Environmental provided environmental consultation.

5 The main consultants on JdE; have been Ecology and Environment in the US, who managed the EIS application and advised on the analysis of VITR, and Tera Environmental Services in Canada, who provided expert advice and review of on the NEB application and aided in the analysis of VITR, as well as Archipelago Marine Research Ltd., Millennia Research Limited, Manning, Cooper and Associates, and several others. Q7. Does this complete your direct testimony? Yes.

6 DIRECT TESTIMONY OF MICHAEL WISE Q1. Please state your name and present position. My name is Michael Wise. I am a Senior Project EngineerManager with GeoWise Engineering Ltd. I presently work as the Project EngineerManager for the Juan de Fuca Project. 42. How long have you held that position? I have been with GeoWise Engineering sine 1999, and started with Sea Breeze on a part-time basis since Q3. Prior to this position, what other positions did you hold, and with whom? I worked on small energy and transmission line projects as well as forestry and environmental projects. I worked as a Senior Geotechnical Engineer for International Forest Products from 1996 to 1999, and for the Ministry of Forests from 1994 to Prior to this time I was employed with Golder Associates Ltd. from 1989 to 1992 working as a Project Engineer on linear projects and large construction projects. 44. What are your professional qualifications and other areas of special expertise? I obtained a B.A.Sc. (Geological Engineering, Geotechnical Option) from the University of British Columbia in 1989, and an M.A.Sc. (Civil (Geotechnical) Engineering) from the University of British Columbia in My graduate courses focused on probabilistic modeling of landslides. I have co-authored two books and numerous technical papers dealing with landslides. Q5. What role have you played in the development of the VIC Application, the Juan de Fuca Project, or the analysis of the VITR Application? I worked with the other experts and specialists on the Project to address technical issues in the CPCN Application relating to routing, installation, and construction. I also coordinated many of the technical consultants associated with the VIC CPCN Application, Information Request responses, and Intervenor Evidence outside of the electrical and systems engineering work. I also participated in many meetings with municipal engineers and Councils, as well as the public information sessions in the Lower Mainland and Saanich area. 46. Did you obtain any expert assistance in fulfilling this role? Yes, during the project, I corresponded and consulted with ABB on a number of technical issues, along with other senior engineers of the Project Team with experience in HVDC Light installations. I worked very closely with John Tomkins and others at Sea Breeze regarding their previous technical experience in HVDC installations.

7 47. Does this complete your direct testimony? Yes.

8 DIRECT TESTIMONY OF HAROLD CHRISTIAN Q1. Please state your name and present position. My name is Harold Chnstian and I arn the Director of Christian Situ Geosciences Inc. Q2. How long have you held that position? I have held this position for six years, since the incorporation of the company. Q3. Prior to this position, what other positions did you hold, and with whom? Prior to being the Director of Chnstian Situ Geosciences Inc., I held the positions of Regional Manager, East Coast USA of ConeTec Investigations Ltd. and Marine Geotechnical Engineer with the Geological Survey of Canada. I worked briefly in 2000 in local geotechnical consulting firms on a part to full-time basis and acted as an expert external advisor to Jacques Whitford & Associates Ltd. during the GSX Pipeline Proposal Project. I was employed by the Geological Survey of Canada from 1985 to 1999 as a Marine Geotechnical Engineer, covering all of Canadian territorial waters. From 1992 to 2000 I was the lead researcher on the geotechnical component of the West Coast Seismic Hazards Project. In that capacity I worked closely with BC Hydro to evaluate geohazard risks to Northern and Southern Cable Corridors in the Strait of Georgia. Q4. What are your professional qualifications and other areas of special expertise? I graduated from Dalhousie University in 1981 with a B.Sc./Dipl.Eng. (MathematicslEngineering), from the Technical University of Nova Scotia in 1983 with a B.Eng. (Civil Engineering), and from the University of Alberta in 1985 with an M.A.Sc (Geotechnical Engineering). I am a Registered Professional Engineer in BC (APEGBC) and have an in-depth knowledge of seafloor geohazards and cable corridor stability issues. Q5. What role have you played in the development of the VIC Application, the Juan de Fuca Project, or the analysis of the VITR Application? I provided expert advice on marine geotechnical issues in the Strait of Georgia and on other geotechnical engineering issues.

9 Q6. Did you obtain any expert assistance in fulfilling this role? Yes, from Keith Robinson of EBA Engineering Ltd. and Professor Norbert Morgenstern of the University of Alberta. Q7. Does this complete your direct testimony? Yes.

10 DIRECT TESTIMONY OF RICHARD HARPER Q1. Please state your name and present position. My name is Richard Harper and I am a Senior Project EngineerIManager with Associated Engineering Ltd. Q2. How long have you held that position? I have held this position since January Q3. Prior to this position, what other positions did you hold, and with whom? Prior to joining Associated Engineering, I worked for Dayton & Knight Ltd., Consulting Engineers from 1993 to 2004, most recently as a Senior Project Engineer. Prior to working for Dayton & Knight, I worked for two land surveying companies. Q4. What are your professional qualifications and other areas of special expertise? I received a Diploma in Survey Technology from the British Columbia Institute of Technology in 1983, a Bachelor of Applied Science (Civil Engineering) from the University of British Columbia in 1992 and a Master of Engineering (Civil Engineering) from the University of British Columbia in In 2000, I received HDD Inspector Certification from Missouri Western State College. My expertise is related to the feasibility, design, permitting, and construction management of underground utilities and linear projects. I have specialized expertise in trenchless technologies such as horizontal directional drilling (HDD), pipe bursting, microtunneling, and pipe rehabilitation. Q5. What role have you played in the development of the VIC Application, the Juan de Fuca Project, or the analysis of the VITR Application? Associated Engineering worked on Sections 3.2.1, 3.2.2, to , to , Appendix A of Sea Breeze's VIC CPCN Application, and worked jointly with Geowise on Section Associated Engineering also provided assistance with scheduling and costing for the terrestrial portion of the work. In addition, Associated Engineering has provided assistance in preparing responses to Information Requests and has attended at public meetings, open houses, municipal council presentations, and meetings with municipal engineering staff and permitting agencies. For Juan de Fuca, Associate Engineering was responsible for Appendix 2-1 of the NEB Application, and also provided general terrestrial construction and routing advice.

11 I provided assistance to Sea Breeze in routing and terrestrial portions of the work, as well as with respect to HDD of the landfalls in White Rock and North Saanich. I have also assisted in the VITR analysis with respect to general alignment issues, construction procedures, and permitting. Q6. Did you obtain any expert assistance in fulfilling this role? No. 47. Does this complete your direct testimony?

12 DIRECT TESTIMONY OF KEITH ROBINSON Q1. Please state your name and present position. My name is Keith Robinson and I am a Principal Geotechnical Consultant with EBA Engineering Consultants Ltd. 42. How long have you held that position? I have held this position for three years. Q3. Prior to this position, what other positions did you hold, and with whom? Before joining EBA Engineering Consultants, I was the Vice President of Geotechnical Engineering for Jacques Whitford and Associates Ltd. from 1999 to 2003 and the President of SRK-Robinson Inc. from 1988 to Prior to my time with SRK-Robinson, I worked in a senior role with Robinson Dames & Moore from 1972 to Q4. What are your professional qualifications and other areas of special expertise? I obtained an M.A.Sc. (Civil Engineering) from the University of British Columbia in 1962 and an M.Eng. (Soil & Rock Mechanics) from the University of Illinois in I am also a registered Professional Engineer in British Columbia (APEGBC). Q5. What role have you played in the development of the VIC Application, the Juan de Fuca Project, or the analysis of the VITR Application? I have reviewed the information provided in the VITR Application and assessed issues related to offshore and onshore slope stability and safety issues during seismic shaking. Based on my experience on the GSX pipeline studies and on-going and recent work in the Fraser delta areas, I have been able to provide estimates of the VITR Project's reaction to seismic loading. 46. Did you obtain any expert assistance in fulfilling this role? No. Q7. Does this complete your direct testimony?