No fur flying at the VITR Pre-Hearing Conference

On Friday, October 21, the BC Utilities Commission held a Pre-Hearing Conference with applicants and intervenors in both the BCTC - VITR proceeding and the Sea Breeze - VIC proceeding.

The transcript is here.

The big point of debate was expected to be whether the Sea Breeze VIC application should be consolidated with VITR. In my notes, only one intervenor firmly opposed the Sea Breeze motion to consolidate, and despite lots of cautions about the Sea Breeze proposal and whether it would pass the "threshold" or "credibility test" of the BCUC, even the heavy hitters - BCTC, BCH, JIESC - did not oppose.

"What credibility test?" was asked, to which no answer was forthcoming.

The lawyer for Sea Breeze came all set up to defend a motion that he expected to have roundly trashed in the debate, and when he had his chance at the microphone, he was at sixes and sevens in his reply which was cobbled on the spot out of his prepared notes and his need to recognize that most likely (the decision is now in the hands of Chairman Hobbs, who may seek advice from Heaven, but sure isn't taking any from anyone else) Sea Breeze was going to get what it wanted.

On a number of occasions Hobbs was reminded about the risk of appeal if he were to make any decision that was not watertight in terms of its legal integrity. One great line from Mr. Carpenter, counsel for BCTC: "I'm not going to suggest that some of my friends in this room are actually wearing their court robes under their suits but I can assure you that they have them close by." (The GSX Concerned Citizens Coalition is pleased to take significant credit, with thanks to its lawyer, Bill Andrews, for the sensitivity of appeal at the BCUC.)

The fur didn't fly, so it wasn't as rich a day as some hearing days - the mention of energy and Vancouver Island is akin to a lit cigarette tossed out a car window.

Perhaps the next most interesting event in these two proceedings will be the Sea Breeze replies to BCUC Information Request #1 with respect to the VIC application. I expect a lot of people will devour that document. It's due November 7. Some excerpts from the lengthy IR are appended, below.

BCTC-VITR: BC Transmission Corp. - Vancouver Island Transmission Reinforcement, 230 kV AC cable from Delta to Duncan
http://www.bcuc.com/ApplicationView.aspx?ApplicationId=78

Sea Breeze-VIC: Sea Breeze Pacific Regional Transmission System Inc. - Vancouver Island Cable, 300 kV HVDC Light cable from Surrey to Victoria
http://www.bcuc.com/ApplicationView.aspx?ApplicationId=90

--
BCUC Information Request #1

[The BC Utilties Commission has fired its first Information Request to Sea Breeze for the Vancouver Island Cable (VIC) project. Here are just a few of the questions from the 3 MB, 27 page document. The selection is pretty random. These are questions that I could understand, and which I found interesting after a quick read of the 27 page IR.]

Sea Breeze does not agree with BCTC's assessment of HVDC Light® technology in its CPCN application for the VITR Project.

56.1 From Sea Breeze's perspective, what are the errors or misconceptions in BCTC's review of HVDC Light®? Please support the list of errors with relevant statistics, system studies, or technical papers, and include BCTC's Appendices P, Q, and R in the review.

2.1 The VIC Application states that Sea Breeze management is confident that, if a CPCN is granted for VIC, there will be no major difficulty in obtaining funding. Please explain whether Sea Breeze believes that a CPCN under Section 45 of the Utilities Commission Act ("UCA") is the unique significant condition precedent for arranging funding for VIC, and if so why it holds this view. If a CPCN is not the unique significant condition precedent, what others are there?

3.6 Where the VIC proposed route would be in lanes, streets or other municipal property, does Sea Breeze anticipate that it will be expected to pay fees under franchise or operating agreements with the municipalities through which it will pass? Why or why not? Please outline the discussions regarding franchise or operating fees that Sea Breeze has had to date with municipalities.

[there are more in this vein on ROW from BCTC, expropriating from unwilling private owners, etc.]

6.1 On page 178, Sea Breeze states it agrees with the position of BCTC, that there is a clear need for new transmission facilities providing additional reliable transmission capacity from the Mainland to Southern Vancouver Island. Please confirm that in Sea Breeze's view, the power supply deficiency lies on Vancouver Island and the primary requirement of the new transmission facilities is to carry power to the Island,

6.2 The VIC Application states that the Juan de Fuca Cable Project is well advanced and is scheduled to be operational as much as one year prior to VITR. On page 180, Sea Breeze states that either VIC or the Juan de Fuca Project will avoid the need for the VITR project until 2016. On page 178 of the VIC Application, Sea Breeze submits that the Vancouver Island transmission need is best served "by one or both of (Sea Breeze's) proposed projects. If the Juan de Fuca Cable Project is "well advanced" and is sufficient to meet the transmission need, why is Sea Breeze proposing VIC?

6.3 Please expand on how "well advanced" the Juan de Fuca Cable Project is, and when all necessary project approvals are expected.

6.4 The discussion on page 160 indicates that the VIC and Juan de Fuca projects are redundant until 2016, when they would become complementary. Please explain how Sea Breeze believes the Commission should deal with the VIC Application at this time, when Sea Breeze appears to be also actively pursuing the more-advanced Juan de Fuca Project.

6.9 Please clarify the statement on page 204 that ".. .when energized this project (Juan de Fuca) would come under the jurisdiction of the BCUC pursuant to the Province's legal definition of a 'utility'." Does Sea Breeze expect that the Commission will approve rates for the Juan de Fuca cable?

6.10 Please discuss whether Sea Breeze intends to hold an Open Season for VIC transmission rights. Why or why not?

6.11 Please discuss whether Sea Breeze is requesting Commission approval of a CPCN for the VIC Project on the basis that it will be a merchant transmission facility. Why or why not?

8.2 The VIC Application at page 199 estimates the EPC cost of VIC at $302 million, based on a turnkey project estimate from ABB. Please provide a copy of the information with regard to cost and schedule that Sea Breeze received from ABB.

[and many more questions that nose around Sea Breeze costs for VIC]

9.12 Sea Breeze notes on page 44 of the VIC Application that the VIC will bypass the Gulf Islands. What (if any) are the differences between the VITR and the VIC with respect to providing transmission service to the Gulf Islands?

11.3 If the Commission were to conclude that HVDC Light technology as set out in the VIC Application and/or the VIC route is the preferred option, is there any reason why it should not direct BCTC to adopt this option?

12.1 The VIC Application at page 44 states that the VIC project line will be operated exclusively by BCTC. Does this mean that BCTC will be the only customer of Sea Breeze? What other customers would Sea Breeze intend to serve using the VIC line?

14.5 With reference to Exhibit B-6, BCUC DR 56.4 in the VITR proceeding, please provide a comparison of the seismic risk of VIC to VITR Options i and 2, in terms of the ability to withstand seismic events that have a return period of once every X years.

15.1 Further to the statement that HVDC Light® systems are in commercial operation around the world, please provide a summary of all comparable HVDC Light® systems that are in service, stating the length of the cables, the transmission capacity and commercial in-service date of each.

15.2 For each of the foregoing HVDC Light® systems, please provide the year by year availability performance statistics, including Forced Energy Unavailability and Scheduled Energy Unavailability.

17.0 Reference: VIC Application, Exhibit HI, page 8

"The VIC Project eliminates or defers for many years the need to upgrade the Island's AC grid to relieve constraints on Cut-Plane D (between Dunsmuir and Pike substations) because it will serve the major load on Vancouver Island below the existing bottleneck. BCTC has estimated that it would cost $49 million to alleviate such north to south transmission constraint."

Reference: VIC Application, Exhibit Bl, p. 188

"Our studies indicate that the transmission capability problem can be related to any of the transmission sections between Dunsmuir and Pike Lake, hence the additional infeed at VIT alone does not provide an adequate solution."

17.1 Please supply the studies referenced on page 188.

[this may be a key part of Sea Breeze's costing comparison. I believe Sea Breeze says BCTC is not including costs of necessary upgrades on the line between Duncan (VIT) and Victoria (Pike) if VITR goes ahead.]

"Export of energy off island via VITR by an DPP, BC Hydro, or Powerex, to a customer in the Lower Mainland or U.S. would be problematic."

26.1 What level of on-island generation would be required before a power flow in the VI to Lower Mainland direction could be reasonably expected on either the VIC or VITR projects?

26.2 Is Sea Breeze aware of any VI to Lower Mainland scheduling path constraints?

Sea Breeze notes that the VIC would become part of the BC electricity grid and would be operated exclusively by BCTC.

29.1 Does Sea Breeze expect to continue to own the VIC?

Sea Breeze suggests that one or both of the VIC and the Juan de Fuca Cable Project could meet the need for new transmission facilities to Vancouver Island.

55.2 The construction of transmission facilities alone is not sufficient to ensure an adequate supply of energy to Vancouver Island customers. Please provide Sea Breeze's proposals with respect to the acquisition of energy. In the response, please address potential energy sources, the responsibilities of the various parties (including BCTC and BC Hydro), the mechanism(s) for accessing transmission capacity on the Juan de Fuca link, the implications for BC Hydro's EEP and REAP, and the consequence of BC Hydro not acquiring capacity on that link.

Sea Breeze submits that it is not necessary, nor would it be appropriate, for the Commission to carry out a detailed review of the potential environmental effects of the VIC Project.

85.1 Given that the relative environmental impact of the VIC and VITR projects has been cited by Sea Breeze as a factor in favour of the VIC project, why is it not appropriate that the Commission consider the environmental effects in its deliberations?

Read the entire IR:
BCUC Information Request #1 at