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Sumas 2 Generation Facility - Application No. 99-1
Adjudication Archive 1999-2000

Motions

12/18/00 – Joint Motion to Reopen Record for Limited Purpose – Procedural Background, and Argument: PDF (5 pages)

  • Affidavit of Dr. Donald J. Easterbrook Regarding Motion to Reopen Record - PDF (3 pages)
  • Attachment 1 - Summary of the Geology of the Sumas and Vedder Mt. Faults - PDF (8 pages)
    • Figure 1 - PDF
    • Figure 2 - PDF
    • Figure 3 - PDF
    • Figure 4 - PDF
    • Figure 5 - PDF
    • Figure 6 - PDF
  • Attachment 2 – Resume of Dr. Don J. Easterbrook,  PDF (15 pages)

Responses to Joint Motion to Reopen Record for Limited Purpose

  2/18/01 - SE2's Motion to Stay Council Order No. 754:

3/5/01 - Sumas Energy 2's Motion for Reconsideration of Council's Order No. 754

3/7/01: EFSEC Requests responses from other parties to SE2's Motion for Reconsideration by Friday March 16, 2001, 5:00 PM. Letter to parties from EFSEC.... (pdf version)

3/8/01: City of Abbotsford/Abbotsford Chamber of Commerce requests extension to time for response to SE2's Motion for Reconsideration. Request for extension in Adobe Acrobat pdf format....

3/14/01: Posthearing Order No. 4, Council Order No. 756, Order On Abbotsford And Abbotsford Chamber Of Commerce’s Motion For Additional Time To Respond To NESCO’s Motion For Reconsideration (PDF Version - 2 pages) - Extends responses from parties to SE2's motion for reconsideration through March 30, 2001

3/30/01: Responses to SE2's Motion for Reconsideration

4/20/01: Council Order No. 757 - Order on Applicant's Motion for Reconsideration

4/30/01: Motion for Reconsideration of Council Order no. 757

5/7/01: Reponses to Motion for Reconsideration of Council Order No. 757

Prefiled Testimony:

Sumas Energy 2 Direct -  Sumas Energy 2 Rebuttal
  Counsel for the Environment - Ecology - Fish & Wildlife
Community, Trade & Economic Development
BPA - City of Sumas  - Whatcom County - Constance Hoag
NW Energy Coalition/WA Environmental Council
City of Abbotsford/Abbotsford Chamber of Commerce

Applicant's Prefiled Direct Testimony:

Prefiled Testimony Witness #1 Darrell Jones
Exhibit DJ-1: Annual Energy Outlook 2000 - pages 64, 65, 70, 71
Exhibit DJ-2: SE2 Correspondence to Ross Lea, BC Hydro and Power Authority, March 24, 2000

REVISED 6/21/00 Prefiled Testimony Witness #2 David Eaden 
Exhibit DE-1: Sumas Energy 2 Color Rendition of Facility
Exhibit DE-2: Site Plan
Exhibit DE-3: Preferred Transmission Route
Exhibit DE-4: FERC Order Issuing Section 3 Authorization and Presidential Permit - December 22, 1999 NOTE: Format may be different from original filed with EFSEC, but content same

REVISED 6/21/00 Prefiled Testimony Witness #3 Katy Chaney 
Exhibit KC-1:  Curriculum Vitae of Katy Chaney 
Exhibit KC-2: Curriculum Vitae of Roy. W. Elliott, P.G., A. David Every, Ph. D., Mark P. Molinari, Robert Mott, Robert Nielson 
Exhibit KC-3: Wetland Fill & Mitigation Area
Exhibit KC-4: Facility location plan

Prefiled Testimony Witness #4 James Litchfield 
Exhibit JL-1: Resume - James W. Litchfield 
Exhibit JL-2: Regional Need for Power
Exhibit JL-3: 1999 Biennial Energy Report - Challenges and Opportunities for Washington's Energy Future - excerpts
Exhibit JL-4: Washington State Electricity System Study, December 31, 1998 - Excerpts

REVISED 6/21/00 Prefiled Testimony Witness #5 Eric Hansen
Exhibit EH-3: A numerical simulation of impacts on ambient ground level ozone concentrations from the proposed Sumas Energy 2, Inc. power generation facility.
Exhibit EH-4: Figure: Lb CO2 per MW produced
(Exhibits EH- I, and -2, Curricula Vitae of Eric Hansen et al., not available in electronic format at this time).

REVISED 6/21/00 Prefiled Testimony Witness #6 Burt Clothier 
Exhibit BC-1: Curriculum Vitae of Burt G. Clothier
Exhibit BC-2: Curriculum Vitae of F. Michael Krautkramer
Exhibit BC-3: City of Sumas - Certificate of Water and Sewer Availability

Prefiled Testimony Witness #7 Ted Potter 
Exhibit TP-3: Property ownership along gas pipeline
(Exhibits TP- I to TP-2 - Resumes of Ted E. Potter, P.E. and Roderick I. Phipps, P.Eng., not available in electronic format at this time).

Prefiled Testimony Witness #8 Michael Woltersdorf 
Exhibit MW-1: Curriculum vitae of Mike Woltersdorf 

Prefiled Testimony Witness #9 John Wong
Exhibit JW-1: John E. Wong Curriculum Vitae
Exhibit JW-2: Wetland Delineation on the Boundary Paper Site, Sumas, WA, draft, 11/17/95
Exhibit JW-3: Aerial photo of site
Exhibit JW-4: Preliminary site grading and drainage plan.

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Counsel for the Environment

Counsel for the Environment's Prefiled Direct Testimony - Bradley Smith
Exhibit BS-1: Resume of Bradley Smith

Counsel for the Environment's Prefiled Direct Testimony - Richard Gammon
Exhibit RHG-1: Resume of Richard Gammon
Exhibit RHG-2: IPCC Second Assessment Synthesis of Scientific-Technical Information relevant to interpreting Article 2 of the UN Framework Convention on Climate Change
Exhibit RHG-3: Sustainability 0 Holistic Perspectives for the Next Century - EPA Region 10 - CD-ROM - http://www.epa.gov/r10earth/sustainability/gccframe.shtm
Exhibit RHG-4: Letter from Ewins and Baker, December 22, 1999

Counsel for the Environment's Prefiled Direct Testimony - Richard Watson
Exhibit RW-1: Resume of Richard Watson
Exhibit RW-2 - Report body - appendices: Northwest Power Supply Adequacy/Reliability Study - Phase 1 Report, NWPPC, March 2000

Sumas Energy 2 Draft Environmental Impact Statement, March 2000

DEIS and General Comments received by Counsel for the Environment and EFSEC

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WA State Department of Ecology

Dept. Of Ecology's Prefiled Direct Testimony - Steven L. Hood
Exhibit SLH-1: Curriculum Vitae of Steven Hood
Exhibit SLH-2: Figure - Full Control Structure
Exhibit SLH-2: Figure - Partial Control Structure
Exhibit SLH-4: Figure - Comparison of Stormwater Controls A
Exhibit SLH-5: Figure - Comparison of Stormwater Controls B

Dept. of Ecology's Prefiled Testimony of Eric Stockdale
Exhibit ECS-1: Curriculum Vitae of Eric Stockdale
Exhibit ECS-2: Sumas Energy 2 Photo Log, May 10, 2000 Site visit
Exhibit ECS-3: October 1995 David Evans & Associates wetland delineation map
Exhibit ECS-4: Wetland and Stream Buffer Size Requirements - A Review, Castelle, Johnson, Conolly, Sept-Oct 1994

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WA State Department of Fish and Wildlife

Prefiled testimony of Curt Leigh (WDFW)
Exhibit CSL-1: Curt Leigh - Curriculum Vitae
Exhibit CSL-2: Sumas 2 Field Reconnaissance Photos
Exhibit CSL-3: Figure 9 - Wetland Fill and Mitigation Area (with mark-ups by Leigh)

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WA State Department of Community, Trade and Economic Development

WA State CTED Prefiled Direct Testimony - Dave Warren
Exhibit DPW-1: Curriculum Vitae of David P. Warren, P.E.
Exhibit DPW-2: Northwest Power Supply Adequacy/Reliability Study - Phase 1 Report, NWPPC, March 6, 2000, p.3
Exhibit DPW-3: High Temperatures and Electricity Demand - An Assessment of Supply and Adequacy in California - Trends & Outlook, July 1999, Excerpts
Exhibit DPW-4: Vanalco press release, June 5, 2000
Exhibit DPW-5: Kaiser Aluminum and Chemical Press Release, June 14, 2000
Exhibit DPW-6: Wall Street Journal - March 22, 2000 - Bonneville Power Proposal Sparks Battle Among States
Exhibit DPW-7: Federal Energy Policy Act of 1992 - Public Law 102-486, Section 16 USC 2602 (8)(d)(19)
Exhibit DPW-8: Wind Energy Weekly, May 18, 1998 - National Poll Again finds Renewables Support Strong
Exhibit DPW-9: Renewable Energy Focus Groups and Deliberated Poll - June 18, 1998, Executive Summary
Exhibit DPW-10: 1999 Report to the 76th Texas legislature - Statewide Integrated Resource Plan, Executive Summary
Exhibit DPW-11: Delivering Added Supply from the Rockies - Average Gas Prices
Exhibit DPW-12: Options to secure site Restoration at WNP 4, Lazar & Eschels, November 1999

WA State CTED Prefiled Direct Testimony - Tony Usibelli
Exhibit AJU-1: Resume of Anthony J. Usibelli
Exhibit AJU-2: Annual Energy Look 2000, EIA, December 1999, table of contents & p. 70
Exhibit AJU-3: Washington's Energy Strategy - An invitation to action, January 1993
Exhibit AJU-4: Governor's Executive Order 94-01, Implementing Washington's Energy Strategy
Exhibit AJU-5: RCW 80-52-080 - Energy Financing Voter Approval Act
Exhibit AJU-6: Title 480 WAC - Utilities and Transportation Commission - Chapter 480-100-251
Exhibit AJU-7: 1991 Northwest Conservation and Electric Power Plan, volume 2, chapter 3
Exhibit AJU-8: Draft Fourth Northwest Conservation and Electric Power Plan, NWPPC, March 13, 1996, executive summary
Exhibit AJU-9: Satsop Power Plant Site Certification Agreement, Amendment No. 2, May 21, 1996 - Excerpts
Exhibit AJU-10: Chehalis Generation facility Site certification Agreement, March 4, 1997
Exhibit AJU-11: Prehearing conference, Application No. 94-2 of Chehalis Power, Inc. Before EFSEC, September 18, 1995, excerpts

Direct testimony of Jim Lazar on behalf of Washington Department of Community, trade and Economic Development
Exhibit JL-1: Curriculum Vitae of Jim Lazar
Exhibit JL-2: Sumas Energy II - Increase in Washington Natural Gas Electric Generation
Exhibit JL-3: Sumas Energy 2 - Share of State Primary Energy Consumption
Exhibit JL-4: Estimated Gas Usage of CCCT Projects
Exhibit JL-5: Cost of Natural Gas at Sumas

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Bonneville Power Administration:

REVISED 6/27/00 Prefiled Direct Testimony of Anthony G. White (note: pagination and line numbering of web version different from original)
Exhibit AGW-1: Applicant's request to the BPA for Transmission for Sale of SE2 Power into the United States

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City of Sumas:

Prefiled Direct Testimony of Margaret Curtis
Exhibit MC-1: Professional Resume of Margaret Curtis

Prefiled Direct Testimony of David Davidson
Exhibit DD-1:  Excerpts from City of Sumas Water System Comprehensive Plan

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Whatcom County

Whatcom County's Prefiled Testimony - John Sproul
Exhibit JTS-1: WRIA 1 Watershed Management Plan (Organization chart)

Whatcom County's Prefiled Testimony - Paula J. Cooper
Exhibit PJC-1: Curriculum vitae of Paula Cooper
Exhibit PJC-2: Excerpts - Lower Nooksack River Comprehensive Flood Hazard Management Plan, October 1999
Exhibit PJC-3: The Sumas Rover Flood Routing Study, Interim Report, July 28, 1998

Whatcom County's Prefiled Testimony - Ioana Park
Exhibit IP-1: Resume of Ioana Park

Whatcom County's Prefiled Testimony - Petur Sim
Exhibit PS-1 (page 2 of 2 only): Noise Measurements at Jager Residence, 6/12/00 
Exhibit PS-2 (page 2 of 2 only): Noise Measurements at Jager Farm, 6/13/00
Exhibit PS-3 (page 2 of 2 only): Noise Measurements at Jager Farm, 6/14/00
Exhibit PS-4 (page 2 of 2 only): Noise Measurements at Jager Pasture, 6/15/00
Exhibit PS-5 (page 2 of 2 only): Noise Measurements at Jager Pasture, 6/16/00
Exhibit PS-6 (page 2 of 2 only): Noise Measurements at Jager Farm, 6/18/00
Exhibit PS-7 (page 2 of 2 only): Noise Measurements at Jager Residence, 6/19/00
Exhibit PS-8 (page 2 of 2 only): Noise Measurements at Jager Residence, 6/20/00
Exhibit PS-9 (page 2 of 2 only): Noise Measurements at Jager Farmhouse, 6/21/00
Exhibit PS-10 (page 2 of 2 only): Noise Measurements at Jager Farmhouse, 6/21/00
Exhibit PS-11 (page 2 of 2 only): Noise Measurements at Jager Residence, 6/21/00
Exhibit PS-12 (page 2 of 2 only): Noise Measurements at Jager Residence, 6/21/00
Exhibit PS-13: Map of Locations of Noise Measurements

Whatcom County's Prefiled Testimony - Karen Grenzow

Whatcom County's Prefiled Testimony - Calvin Jager

Whatcom County's Prefiled Testimony - David Lipscomb Ph.D.
Exhibit DML-1: Curriculum Vita of David Lipscomb Ph.D.
Exhibit DML-2: Noise Reduction, Beranek, 1960, p.523

Whatcom County's Prefiled Testimony - Axel Franzmann

Whatcom County's Prefiled Testimony - Dr. Jane Q. Koenig, Ph.D.
Exhibit JQK-1: Curriculum Vitae of Jane Q. Koenig
Exhibit JQK-2: Bibliography - Jane Q. Koenig
Exhibit JQK-3: Pulmonary Function changes in children Associated with Fine Particulate Matter, Environmental Research volume 63, pp. 26-38, 1993
Exhibit JQK-4: Particulate Air Pollution and Hospital Emergency Room Visits for Asthma in Seattle, Am Rev Respir Dis, Vol 147, pp. 826-831, 1993
Exhibit JQK-5: Effects of Ambient Air Pollution on Nonelderly Asthma Hospital Admissions in Seattle, Washington, 1987-1994, Epidemiology, January 1999, volume 10 Number 1, pp. 23-
Exhibit JQK-6: An Association between Fine Particles and Asthma Emergency Department visits for children in Seattle, Environmental health perspectives, vol. 107,
Number 6, June 1999

Whatcom County's Prefiled Testimony - Daniel A. Jaffe
Exhibit DAJ-1: Resume of Daniel Jaffe

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NW Energy Coalition/Washington Environmental Council

Prefiled Direct Testimony of Nancy Ellen Hirsh
Exhibit NEH-1: Bonneville Power Administration's Sumas Energy 2 System Impact Study

Prefiled Direct Testimony of Peter G. West
Exhibit PGW-1:Applicant's Response to NWEC/WEC Data Request #4

Prefiled Direct Testimony of K.C. Golden
Exhibit KCG-1: City of Seattle's Resolution #30144

Prefiled Direct Testimony of NW Energy Coalition & WA Environmental Council - Philip W. Mote
Exhibit PWM-1: Executive Summary, Impacts of Climate Change on the Pacific Northwest

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City of Abbotsford / Abbotsford Chamber of Commerce

Prefiled Testimony of Jerry G. Lilly

Prefiled Testimony of Peter G. Sagert
Exhibit PGS-1: Curriculum Vitae of Peter Sagert P.E.

Prefiled Testimony of Constance Hoag
Exhibit CH-1: Resume of Constance Hoag
Exhibit CH-2: Lynden Tribune, Oct. 10, 1999 - Plant Plan Sparks Opposition
Exhibit CH-3: "Sumas Energy Inc. - Good for Sumas"
Exhibit CH-4: Natural Resources Committee Minutes, 3/7/2000, pages 10-12
Exhibit CH-5: Abbotsford & Mission News, June 3, 2000 - Special Report - A Power Struggle
Exhibit CH-6: News clipping - Georgia Straight, June 22-29, 2000
Exhibit Ch-7: Public Hearing - facts about the proposed power plant
Exhibit CH-8: Sumas Energy 2 - Question & Answer Fact Sheet
Exhibit CH-9: Letter from Sen. Georgia Gardner to Constance Hoag, May 2, 2000
Exhibit CH-10: Sworn Affidavits from Van Dyken and Rossi, June 2000
Exhibit CH-11: Letter from Sumas Energy 2, Inc. Re Public Open House, December 1999, and fact sheet
Exhibit CH-12: Comments from David Davidson re noise impacts of facility
Exhibit CH-13: Cal Jager Affidavit authorizing C. Hoag to represent interests
Exhibit CH-14: Affidavit of J. De Vries
Exhibit CH-15: Letter to Whatcom County Council from Washington Toxics Coalition, March 7, 2000
Exhibit CH-16: May 2000 valley Air News - reclassification to Affect Major Sources
Exhibit CH-17: Display advertisement from Bellingham Herald June 25, 2000

Prefiled Direct Testimony Sponsored by C. Hoag and Abbotsford - Don Gustafson
Exhibit DG-1: Qualifications of Appraiser - Gustafson & Ospvig
Exhibit DG-2: Appraisal of Hoag Residence, June 1, 2000

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Constance Hoag

Constance Hoag's Prefiled Testimony - John McKay
Exhibit JCM-1: Biography of John C. McKay

Constance Hoag's Prefiled Direct Testimony - Dr. Nathan Kronenberg
Exhibit NK-1: Resume of Nathan Kronenberg M.D.
Exhibit NK-2: Noise Exposure and Public Health, Environmental health Perspectives, Vol 108, Supplement 1, March 2000
Exhibit NK-3: Noise-Induced Extra-Aural Pathology: A Review and Commentary; Aviation, Space and Environmental Medicine, Vol 70, No. 3, Section II, March 1999

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Sumas Energy 2 Rebuttal Testimony

Applicant's Prefiled Rebuttal Testimony - Witness: David Carlton
Exhibit DC-1: Resume of David K. Carlton P.E.
Exhibit DC-2: Resume of Gregory L. Gaasland P.E.
Exhibit DC-3: Resume of A.M. Melone Ph. D, P.E.

Applicant's Prefiled Rebuttal Testimony - Witness: Katy Chaney

Applicant's Prefiled Rebuttal Testimony - Witness: Burt Clothier

Applicant's Prefiled Rebuttal Testimony - Witness: Margaret Curtis

Eric Hansens's Prefiled Rebuttal Testimony was revised at the Adjudicative Hearing on 7/28/00 - Revised Page 6
Applicant's Prefiled Rebuttal Testimony - Witness: Eric Hansen
Exhibit EH-5 (rebuttal): Letter from Sumas Energy 2 to Hu Wallis, MELP, 4/18/00
Exhibit EH-6 (rebuttal): Letter from Sumas Energy 2 to Hu Wallis, MELP, 5/24/00

Applicant's Prefiled Rebuttal Testimony - Witness: Darrell Jones
Exhibit DJ-3 (rebuttal): Seattle Times Article (web), 7/2/00
Exhibit DJ-4 (rebuttal): Bellingham Herald Articles, 6/28/00
Exhibit DJ-5 (rebuttal): Clearing Up, July 3, 2000, pages 8-10
Exhibit DJ-6 (rebuttal): BC Hydro Preliminary Feasibility Study to Integrate Sumas 710 MW Generation into the BC Hydro System at Clayburn Station, 2/23/99, pages 1-7

Applicant's Prefiled Rebuttal Testimony - Witness: James Litchfield

Applicant's Prefiled Rebuttal Testimony - Witness: Charles Martin

Applicant's Prefiled Rebuttal Testimony - Witness: Jeremy Pratt
Exhibit JP-1 (rebuttal): Resume of Jeremy Pratt
Exhibit JP-2 (rebuttal): Greenhouse Gas Emission Offsets and Natural Gas-Fired Combined cycle combustion Turbines
Exhibit JP-3 (rebuttal): carbon Dioxide Emissions from the Generation of Electric Power in the United States, Oct. 15, 1999, DOE

Applicant's Prefiled Rebuttal Testimony - Witness: Sharon J. Quiring
Exhibit SQ-1 (rebuttal): Resume of Sharon J. Quiring
Exhibit SQ-2 (rebuttal): Resume of Betty J. Locey, Ph. D, DABT

Applicant's Prefiled Rebuttal testimony - Witness: Mark Schrimp
Exhibit MS-1 (rebuttal): Resume of Mark E. Schrimp
Exhibit MS-2 (rebuttal): www.transmission.bpa.gov… Q and A web page

Applicant's Prefiled Rebuttal Testimony - Witness: John Wong
Exhibit JW-3 (rebuttal): city of Sumas, Certificate of Land Use Consistency, 3/2/99
Exhibit JW-4 (rebuttal): Wetland Delineation & Mitigation Report for the Sumas Energy 2, Inc. Generating Plant Facility, June 26, 2000

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