dear commission secretary mr wruck and dear …...1 1 vernon ruskin , phd,mcom,bsc,retired peng (bc)...
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VERNON RUSKIN , PhD,MCom,BSc,Retired PEng (BC) ,PE(WA) Numbered Author 1 … 2
CORRECTION F 26 Site C BCUC Ruskin Pt 1 .doc Revision 9‐ 8 30 2017 6 3 4
Dear Commission Secretary Mr Wruck and Dear Erica Hamilton 5
6 SITE C ‐ EXECUTIVE SUMMARY & CONCLUSIONS 7 BCUC requested submissions, relevant to the terms of reference which ask 8
a whether the project is on time and within budget; 9 b the cost to ratepayers of suspending the project; 10 c the cost to ratepayers of terminating the project & Mechanisms to recover c 11
d what portfolio of generating projects and 12 demand‐side management”initiatives could provide similar benefits; and 13
e what are expected peak capacity demand and energy demand. 14 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 15
i/SITE C is uneconomic and should be checked to be safe ,before 16 continuing or restarting ,so i focused on providing portfolios of cheaper 17 replacements complying with the Paris climate change accord 18 19
ii/ BCUC may safely conclude BC Hydro have enough plants and storage. 20 to supply domestic electricity growth for a minimum of 13 years, and probably 21 25 years, without building site C, or any high dam, or flooding any land ,or 22 more IPPs 23
iii,BC hydro have 5 years lead time( till the next election)to b/suspend 24 work on Site C and minimize cash and deferred costs involved 25
26 iv BC Hydro should thoroughly explore and report on all portfolios in d/. 27
and any material changes in load 28
v/Premier Horgan appointed former Powerex CEO Peterson chairman of 29 BC Hydro , who could potentially lower hydro cost and rates, by taking 30 advantage of a huge growing energy glut (6 times capacity of SiteC) in the US 31 northwest and replace, Site C energy at around ¼ cost 32
vi/ Former premier Clark had good intentions to create jobs ,but was 33 incompletely informed by BC Hydro managers' advice (.un‐reviewed by 34 BCUC)., that “building uneconomical "upgraded" Site C is urgent and the only 35 alternative 36
vii MLAs must fly blind if they don’t get unbiased, unvarnished, reliable 37 planning of all feasible alternatives completely independent of BC Hydro and 38 politically correct Victoria 39
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viii Huge Lake Williston could be operated like the world’s 41 largest” battery”and provide 4500 gwhrs( 90% of Ste C energy) at 42 no cost. 43
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ix/BC is also entitled to free 4000 gwhr( 90% of Site C) at no cost under 46 the terms of the Columbia River Treaty (CRT), subject to ten years notice 47
48 x/ Adding generators at Keenleyside and Duncan dams could provide 976 49 gwhr( 20% of Site C ) at much lower cost 50
51 xii/In 2008 BC Hydro tabled 15 hydro plants with BCUC which I listed 52
in “ DETAILS” They range from 17% to 250 % of Site C capacity, They. all 53 produce cheaper power around $58 to $73/mwhr, compared to $ 132 54 /mwhr for Site C 55
56 $xiii/ There are also 4 “ run of river” plants on the Columbia which flood 57
no land above natural high water. In total they can supply more energy than 58 Site C at lower cost... They are listed in DETAILS and explained in referenced 59 Amazon book “ Clean Energy Starvation in the Midst of Plenty”,about the 60 Columbia River Treaty ,which is not a issue today: 61
xiii/DSM is a type of energy conservation and so is engineering to conserve 62 the energy of water spilling over the dam 63 Conservation initiative Step 1 . In nov 2012 i was invited by the US State Dept 64 and May 2013 by BPA to explain options on the Columbia BPA published that 65 fish and irrigation water releases cost them 1000 MW ,( = 95% capacity of Site 66 C) and $750 million per year They wanted to to increase fish water plus save 67 millions. But BPA shelved the project because they didn’t think the then BC 68 government would approve it 69 , 70 Conservation Step 2 .BPA spills energy over their dams ( around 9000 mw= 8 71 times the capacity of Site c ).By cooperatively scheduling Lake Williston with 72 BPA in future BC Hydro can get lots of power at low cost. the new BC 73 Governmen could tell BPA they are interested in cooperative scheduling of 74 Lake Williston” It can be done anytime ,since the Columbia River treaty doesn’t 75 cover Peace river 76
77 Xiii/i believe it is unreasonable for ratepayers to pay to a/continue or b/ 78 suspend and restart Site C, unless it’s checked to be safe for people 79 downstream 80
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Xiv/I directed the team including Keith Kidd( ex Ontario Hydro),that 82 originally designed Peace River dams A B C D E.Though retired as a registered 83 BC professional engineer , I earlier wrote an Information Request (IR)to BCUC, 84 because I believe,not only is the new"upgraded "design weaker, but it requires 85 more material and cost to build, and reinforce from earthquakes,and it may be 86 weaker geotechnically because it is not tied into the midstream island. The 87 press reported failures that needed repairs ( eg July 2016, Feb 2017 etc ) See 88 3 pictures, 1. Original Dam (Gordon Campbell) 3.3 billion 89
2 Upgraded dam (Christie Clark) 9 billon; 3 Example of damage 90 91 Xv/ I taught "Engineering Economics" at UBC for 14 years and taught 92 students that Vancouver's Second Narrows Bridge falling down showed BC 93 professional engineers are #1 legally responsible during and after 94 construction,and for recommending the most Economical SAFEST alternative . I 95 believe BCUC should recommend that both dam designs be reviewed by 96 independent engineers outside of BC , to ensure the best value for 97 ratepayers’money, and above all, to ensure SAFETY of communities living 98 downstream of the dam. 99 100
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104 105 Original Dam (Gordon Campbell) 106 107
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108 Upgraded dam (Christie Clark) 109 110
111 112 Example picture of damage 113 114
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 115 ‐REFERENCES 116 1 Peace River In Peril, Chris Pollon book 2016 117 118 2.Clean Energy Starvation in the Midst of Plenty “,Vern Ruskin, amazon book 2013. 119 ISBN981492222552/Lake Williston , 88 total, 56.4 usable million acre‐feet, pages 112‐5 120 121 3 BPA stops wind power generation for the first time in four years | Wind ... 122 https://www.wind‐watch.org/.../bpa‐stops‐wind‐power‐generation‐for‐the‐first‐time‐in 123 124 4/BC Hydro > 2008 LTAP ‐ Appendix F8 125 https://www.bchydro.com/content/dam/hydro/.../info/.../2008_ltap_appendix_f8.pdf 126
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5/ BC HYDRO annual reports service plan 2005 to 2016 127 128 6/BCH application to BCUC July 2011for Dawson Creek/Chetwynd Area Transmission 129 Project, Appendix I Rate Impact Model” Sched 27 item 12 130 131 7/ Silent Spring") Rachel Carson (author 132 /“Never doubt that a small group of thoughtful, committed citizens can change the 133 world. Indeed, it is the only thing that ever has 134 + 135 DETAILS 136
‐‐‐pl forgive typos due to short time frame‐‐‐‐‐‐‐‐‐)‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 137
138 139 140 141 I agree with former CEO Eliesen load forecasts are over optimistic but sympathize 142 Hydro engineers were chained to follow orders and be “politically correct”, I believe 143 the new CEO engineer Chris O Reilly will free them 144
Dal Grauer, president BC Electric (the predecessor of BC Hydro), hired me in 145 1955, after Vancouver suffered a total blackout. I became Director, Planning 146 Division with a 45 person staff.,best in Canada. 147
it included Keith Kidd, ex Ontario Hydro engieer ,for PeaceRiver,and Bill 148 Weymark ,ex GenNaughton’s staff engineer for Columbia.We planned designed 149 budgeted contracted and made progress payments for more than ten dams in BC 150 including Site C. on Peace River and 4 dams on Columbia The system design 151 objectives were to supply dependable power at the lowest price world wide to 152 attract business to BC,ad avoid any more blackouts /the flexible system made sure 153 there would be no more blackouts to BC , its now called the heritage system and 154 to this day supplies 80% of BC Hydro's loads at low $7 per mwhr cost 155
I next formed my own company and ,built and ran the first computer model 156 of the Columbia River in Canada to check down stream benefits for Gen 157 McNaughton in Ottawa and BC Hydro. I then expanded into the US with offices in 158 Bellingham, San Francisco, Los Angeles, Chicago, Atlanta and Cincinnati We served 159 31 electric and gas utilities and pipelines in Canada and in the US and over 100 160 other customers (names upon request) 161
I retired to Vancouver in 1992 162 163
later I did independent unpaid nonpartisan volunteer research I gave to John Hogan, 164 when he was NDP energy critic and to engineer( Liberal )MLA Ralph Sultan ,.But both 165 got a deaf ear from the govt ministers 166
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around 2010 public protest stopped Premier Campbell from raising sales tax , so he 167 brought in the BC Clean Energy Act He muzzled BCUC and ordered 18 billion dollars of 168 IPP contract to replace Burrard Thermal Plant and wanted to build the original Site C 169 design by BC Electric estimated at 3.3 Billion dollars He deregulated BC hydro, so kept 170 BCUC just as a charade. Electric rates are now decided by the minister like the price at 171 the liquor control board store and set BY WHAT TRAFFIC WILL BEAR (and he directed 172 BCUC to add a hidden sales tax by adding non existing income tax with around 46% 173 bringing in around 2.5 billion dollars “pseudo sales tax” in 2016 ,all hitting ratepayers 174 which are only 1 in 3 people 175 176 177 178 179
a1 whether the project is on time and within budget; 180 181 182
The Site C project is not on time .According to multiple press reports and photographs ( 183 attached picture ref 1) Site C continues to develop serious defects which require time 184 and money to repair,. Hydro CEO O'Reily earlier stated these problems were 185 unforeseen. It logically follows site C cannot be on time and within budget.. 186 187 =========================================================== 188
A2.1; The implications to ratepayers of completing the project 189
a2.1 Building money‐losing Site C costs every BC Hydro customer $5300 190
a2.3 SITE C will raise rates by 40% .because adding $9 billion Site C raises BC 191 Hydro Property and Plant from around $22 to to $31 billion, which raises by 40% 192 the allowed return from electricity sold to ratepayers at raised rates ,But in turn 193 it also raises by 40% the" incentive pay "to BC Hydro top managers under 194 contract, who can cheer when Site C cost surges, 195
a2.4 In July 2011, BC Hydro tabled their “Rate Impact Model” with BCUC. Which assumed 196 that $9 billion Site C would be included plus also around $18 billion of IPP contracts, with 197 the latest windmills around $120 /mwhr according to Mr Coleman . 198 199 200 201 202
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A2.2 Any ordinary IPP business producing at $132 /mwhr and selling at 204 $82/mwhr .(let alone at $56/mwhr) will go bankrupt and its stockholders would 205 vote to change managers and directors. But BC Hydro tenured managers already 206 spent $2 billion dollars on Site C to date, and want to let it surge to $9 billion 207 dollars .So BC hydro must then surcharge its rates to collect $5300 208
Even if Minister Coleman cuts a 32% rate increase the difference is put into a 209 deferred “ rate rider” account and will be collected eventually plus interest from 210 each of 1.7 million captive ratepayers ,or their kids Worse it’s a never ending rate 211 spiral far beyond Canada's inflation index 212
It turns out that the govt is collecting hidden tax,around 46% on all hydro bills by “ 213 directing” BCUC to charge for non‐existing mythical income tax they never paid . 214 History shows Premier Campbell tried to raise sales taxes but was stopped by public 215 protest Thereupon , he passed the ”Clean Energy Act” , de‐regulated BC Hydro,muzzled 216 BCUC 217
I submitted a 100 page brief to BCUC which is in your files. It suggested among other 218 things that BCUC should seek clarification of its duty as the sole protector of captive 219 ratepayers from BC Supreme Court,or Canada Supreme court under the bill of rights, to 220 prevent rate gouging of captive ratepayers by utility monopolies like BC Hydro, and stop 221 them gold plating their facility rate base 222
BCUC was muzzled and ( wrongly?) prohibited to review site C for seven years since 223 2010,when Vancouver Sun reported that liberal MLA's said "BCUC has outlived its 224 usefulness “So do BC premiers or ministers ,unlike Harper,Trudeau and Obama,Trump 225 ,remain above the law? “ The King Can Do No Wrong.?” 226
the impact of any Site C cost jump is bad for ratepayers but good for the govt 227
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. BCUC was muzzled and ( wrongly?) prohibited to review site C for seven years since 229 2010,when Vancouver Sun reported that liberal MLA's said "BCUC has outlived its 230 usefulness “So do BC premiers or ministers ,unlike Harper,Trudeau and Obama,Trump 231 ,remain above the law? “ The King Can Do No Wrong.?” 232
In around 2011,after the” Clean Energy Act” was passed, and it de‐regulated BC Hydro, I 233 submitted a 100 page brief to BCUC which is in your files. It suggested among other 234 things that BCUC should seek clarification of its duty from BC Supreme Court,or Canada 235 Supreme court under the bill of rights, to prevent rate gouging of captive ratepayers by 236 utility monopolies like BC Hydro, and stop them gold plating their facility rate base 237
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4.3 The Rate Spiral will continue because the cost of Site C at $132 per mwhr. 244
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In 2011 Van Sun printed that three BC government deputy ministers reviewed BC 248 Hydro and minced no words reporting to then premier Clark: "The "gold‐plated" 249 corporate culture in BC Hydro is not for lowest Cost and greatest Value for 250 ratepayers money".".It's focused on justifying rate increases and associated costs” 251
a2.5 Impact from completing Site C on ratepayers permanent Jobs. 252
BC Hydro rate spiral which hurts ratepayers’ pockets, and will hit ratepayers kids 253 with “deferred” rate increase” time bombs” . BC Hydro website stated $9 billion 254 Site C added around 1700 construction jobs for 7 years ( at gross cost of $755,000 255 per employee per year) But Site C will increase power rates 40%, which will 256 REDUCE PERMANENT JOBS because industries eg lumber, pulp , paper, plywood, 257 mining, manufacturing need cheap power to remain competitive in world markets. 258
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Moreover, $9 billion could possibly create more construction and permanent jobs 259 building housing, hospitals and transit 260
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270 b/ the cost to ratepayers of suspending the project; 271 272 B1 273 B1.1 Apart from the payments to contractor Deloitte was asked to figure out 274 there is no point in paying extra to mothball the project unless it’s checked to be 275 safe for downstream people, if it is restarted 276 B1.2 The data attached are 4 pictures : 277 1. Original Dam (Gordon Campbell) 278 2 Upgraded dam (Christie Clark) 279 3 Example picture of damage 280 281
282 283 Original Dam (Gordon Campbell) 284 285
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286 Upgraded dam (Christie Clark) 287 288
289 290 Example picture of damage 291 292 293 294 B2 Analysis 295
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B2.1 “Upgrading” Site C Dam Design May have Compromised Safety. 297
Van Sun reported,in 2005 that site C cost had increased from $3.3 billion when BC 298 Hydro had earlier tabled BC Electrics standard design of Site C with the BC Utilities 299 Commission . I note that was the design and estimated cost when Premier Campbell 300 brought in the Clean Energy Act 301
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BC Electric designed ten (slightly curved) standard dams ,which everyday produce 302 most of BC's electricity at around $7 /mwhr .and have all stood a 50 year test of 303 time, (IPP's produce electricity around $86/mwhr) By 2011, BC Hydro documents 304 show their consulting engineers had” upgraded “the Site C dam, from using BC 305 Electric’s standard (slightly Curved) dam to a “right angle” dam –(see picture) raising 306 the cost to $7.9 billion .The “upgrade” has resulted in around $4 billion surge in 307 contractor cost, and about $200 million more for engineer’s supervision of 308 construction: I believe cost is only one item affecting ratepayers , but safety of people 309 downstream of the dam is paramount 310
311 312 B2.2 Engineering Questions 313 314 /though retired as a registered BC professional engineer ,I m legally obligated to raise 315 engineering safety questions : .(see pictures). 316 I believe,Not only is the new"upgraded "design weaker, but it requires much more 317 material and cost to build, and reinforce from earthquakes.( or nowadays from 318 terrorists )I also believe it may be weaker geotechnically because it is not tied into the 319 midstream etc land. The test of time showed eg In July 2016 and Feb 2017 etc the press 320 reported slope and other failures that needed repairs 321 I taught "Engineering Economics" at UBC for 14 years and 2 years for the Association of 322 BC Professional Engineers ,and taught students that Vancouver's Second Narrows 323 Bridge falling down showed BC professional engineers personally and firms( eg 324 Dominion Bridge Co) s are #1 legally responsible for their work during and after 325 construction,and #2getting a second expert opinion for anything they are not sure of #3 326 for recommending the most Economical SAFEST alternative 327 It also answers your question re one potential mechanisms for recovery by ratepayers 328 etc 329 330 B 2.3.2 For the public record 331 Before considering mothballing and restarting Site C , I believe BCUC should caution the 332 BC govt and BC hydro it is imperative t that both dam designs be reviewed by 333 independent engineers outside of BC , to ensure the best value for public money ‐if the 334 dam moves forward‐ .The BC Energy Board formed by WAC Bennett set a precedent in 335 1960, by engaging engineers outside BC (Sir Wm Hacrow and Partners) in Connection 336 with Peace ad Columbia dams ., and to ensure SAFETY of communities living 337 downstream of the dam. 338 If Site C is to be suspended for some time, there will be enough time to the outside of 339 BC independent engineers report ,and BCUC has the right to engage them under the 340 terms of reference 341
B 2.4 Potential Mechanisms to recover cost In accordance per terms of reference b (ii) 342 (e) and( f) 343
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BC ratepayers will be billed at least with $2 billion already paid on Site C and there are 344 several potential mechanisms to recover costs 345
B 2.4.1 BCUC was set up under the "BC Utilities Commission "Act as designated "public 346 watchdog" with fiduciary responsibility on behalf of captive ratepayers .BCUC could 347 legally stop BC Hydro gouging ratepayers with $billions unnecessarily spent or 348 “deferred” on site C by ordering a future credit or rate decrease (I recall BCUC ordered 349 future credits and rate decreases before , to offset overcharges, when I testified on rate 350 applications with BC Electric).But the BC government owns BC Hydro and might just get 351 it back in taxes? 352
B2.4.2 Errors and omissions Insurance? 353 In the event that 354 1/an independent outside engineers report concludes That the 'upgraded' design 355 (costing around 4 billion more) is just equally ,or is less safe. 356 Or 2/ ‘that BCUC finds per b (iv)” :there are other commercially feasible project or 357 DSM initiatives at LOWER unit energy costs to ratepayers than Site C which were 358 overlooked or unreasonably ignored by BC Hydro managers and directors , which in 359 2014 directed to proceed with Upgraded Site C .I am not a lawyer and but I believe 360 BCUC or ratepayers can file a class suit . BCUC has the right to hire consultants or 361 investigators under the terms of reference BCUC consultants or investigators might 362 decide that’s the starting of Site C by BC Hydro CEO or Directors was due unforeseen 363 errors and omissions and order 364 BC hydro to file an insurance claim to cover cost 365
In their annual reports BC Hydro chairman in writing states he personally and 366 directors are responsible ; they are covered by third party or errors and omission 367 insurance, and ratepayers are billed for the premiums of that insurance .Insurance and 368 Bonding also covers the CEO and officers and staff. And if the ship hits the dock,the 369 captain is responsible because he hired the helmsman. 370
B 2.4.3 Pushing Site C Beyond the Point of No Return? 371
If BCUC finds there is no insurance coverage, one suspicious part of “trying to push 372 Site C beyond the point of no return”,’by anyone, is that it was a feasible and fairly 373 economical project BEFORE its cost was tripled by “upgrading’ 374
I believe BCUC, acting on behalf of captive ratepayers to spend their money ,Should 375 insist on finding out i/ Who was responsible for directing to start site c ii. why did they 376 choose site c over alternatives iii/what alternatives were considered iv/after the 377 estimated cost jumped by billions , who authorized an “upgrade” in over $4 billion and 378 v/.did anyone personally benefit financially or get gifts or became an officer or director 379 of a contractor ? 380
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B 2.4.4 Bonding and insurance against theft, Potential Wrongdoing? 381 382 Another mechanism for recovery might be contractors or BC hydro’s Bonding 383
and insurance against theft, Potential Wrongdoing? 384 385 I Believe WAC Bennett would not have hesitated to get= Site C cost jump 386 investigated , and would have called in the RCMP ,even if one of his own MLA’s party’s 387 ministers and political donors and embarrassing scandal, might be involved 388 BC history shows Liberal Gordon Gibson didn’t hesitate to blow the whistle about 389 potential wrongdoing , and one of WAC Bennett's own ministers (Somers) went to jail 390 for accepting gift of a carpet ,(which was worth far less than 4 billion dollars ,but forest 391 license contracts were worth a lot) 392 393
B 2.4.5 Potential Recovery of Cost Boondoggle? 394
It is possible the BC hydro Chair ,directors and CEO were Misled by people wrongfully 395 performing a boondoggle, 396
When costs jump sky high, watchful newspaper reporters rightly investigate 397 potential wrongdoing and maybe kickbacks or bribes, eg “Georgia Straight" reporter 398 Smith wrote "The beneficiaries of this white elephant have been independent 399 contractors and businesses—including many BC. Liberal campaign contributors…..” Van 400 Sun report Hoekstra wrote that political donors got twice as many contracts as non‐ 401 donors ? that does not seem to be lawful with mandatory sealed competitive bidding 402 for contracts totaling over $2 billions 403
B 2.4.6 Site C mirrors regrettable “HIGH” Arrow (Keenleyside) dam, which benefited 404 contractors when its cost jumped over double original , ii/flooded out 2300 people iii/BC 405 Utilities Commission was muzzled to review whether it was necessary. ,iv/ and 406 protesting local MP, Bert Herridge (NDP),was legally stopped by BC Hydro lawyers from 407 testifying before a parliamentary committee 408
B 2.4.7 Recovery of Ratepayers costs might be impossible due to Statute of Limitations? 409 BC Hydro went ahead with Site C construction in 2014 410
B 2.4.8 Dam Boondoggles have happened before in BC. 411
Originally In 1957 , Gen. MacNaughton asked BC Electric to design all Columbia dams 412 ,and specifically to avoid flooding the Arrow Lakes, We designed’ LOW “ Arrow dam 413 which would not have flooded out 2300 people. But BC Hydro consulting engineers 414 “upgraded” BC Electric’s original “LOW” dam to a “HIGH” Arrow dam, which overran 415
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budget and cost more than double, benefiting Contractors, which built “HIGH” Arrow 416 dam . Thereupon “ BC Hydro’s Vice‐Chairman Keenleyside renamed it “Keenleyside” 417 dam, 418
But 17years later in 1974,, BC Assistant Deputy Minister McNabb, admitted at SFU (ref 419 36) .i/ ”Under the Treaty, BC Hydro could have built a “LOW” Arrow dam , avoided 420 flooding out 2300 people( or avoided building Arrow altogether) . 421
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C / The cost to ratepayers of terminating the project; and mechanism to recover 427 costs 428
An independent outside report by Deloitte can confirm this cost including any current 429 due and future payments to contractors and also deferred costs in BC hydro accounts 430 and any future remediation costs due to Site C 431
MECHANISM to recover Costs for Ratepayers 432
433 BC HYDRO BECOMES HIDDEN SALES TAX COLLECTOR 434
435 For example, the cost estimate for Site C has now jumped 4.6 billion from $3.3 436 billion in 2005 to $7.9 billion in 2011. 437 438
Q1: is that bad for the BC Finance Minister Department? 439 A: NO, It’s good, WHY? We see that $4.6billion cost increase actually costs 440
the BC government 3.88% around , or $179 million a year more 441
But per Column 2 we see the captive BC Hydro customers will be charged 442 11.0% per year or $ 506 million a year more So the BC Hydro or the BC government 443 pockets the difference of $ 327 million more as quietly disguised sales taxes on 444 electric power. 445
446 Q2 :Is it bad for BC Hydro top managers? 447 A: NO, it’s good, WHY? 448 The “ income” of BC Hydro increases by $506 million, so their “Performance 449
Bonus” Pay will also rise 450 451
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Q3 is it bad for captive BC Hydro Customers 452 A: YES, They have to pay 506 million a year more, which for 1.5 million BC 453
Hydro customers means around f $300 rate increase a year l, That’s equivalent to 454 around 46 % over 2011, BC hydro won’t charge it until Site C goes in service in 455 2024, so your kids may have to pay it, plus interest 456
457 Q4: So what discourages GOLD PLATING at BC Hydro, absent proper formal 458
regulation?Like NEB, FPC, PUC or what BCUC did (under public watchdog Dr. Angus) 459 in line with the lower rates aims by WAC Bennett, Dr. Shrum and NDP leader Bob 460 Strachan 40 years ago, 461
462 A: NOTHING DISCOURAGES BC HYDRO GOLDPLATING TODAY, 463 Sadly in 2011, the words of three BC government deputy ministers, 464
reporting to the Premier Clark and Energy Minister Coleman. nail it: 465 “..the “gold‐plated” corporate culture in BC Hydro“ is NOT for lowest cost or 466
greatest value for ratepayers money.’ It’s FOCUSSED on justifying… rate increases 467 and associated costs”. 468
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Hydro submitted to BCUC how they calculate WAAC (weighted annual 471 capital charges) as shown below, to be applied for 2012. The following notes explain 472 the details 473
474 475 476 477 478 479 480 481 COST OF MURPHY CREEK $/mwhr with DIFFERENT 482 FINANCING 483 484
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485 486 NOTES ON TABLES 487 Column 1 = true cost to BC Government treasury,Note actual rate for BC 488
4.7% bonds coupon matures 25 yrs. Price 112.73 yields 3.88 % on July 27/13 489 490 Column 2 Actual 21.53% rate of return to BC government who own equity 491
per BCUC in 2011, per info request stated in 2012. Note BC Finance Dept. simply tell 492 BC Hydro what return they want every year, and BC Hydro sets their rates to 493 customers and revenue requirements accordingly. 494
Column 3 Ditto 18.38% in 2010 495 Column 4 ‐shows how BC Hydro nominally sets their revenue requirements 496
and rates to their customers. These are the nominal figures of 12.75% BCUC 497 regulators officially states, when BCUC and BC Hydro quotes cost in $/mwhr .But 498 BCUC turns a blind eye that the actual return on equity was 21.53% in 2011vs 499 12.75%. Also actual rate of bonds interest is lower than BCUC allows 5.25% vs 4%. 500 But BCUC doesn’t order a refund. NEB or BCUC under Dr Angus in 1960 would 501 order an immediate refund 502
. But BCUC is handcuffed and gagged public appearance of proper honest 503 regulation. 504
Anyone familiar with formal regulation can see that public BCUC and BC 505 Hydro financial statements show that BC quietly jacks BC Hydro rates to be roughly 506 double their true costs, as a form of hidden taxation. 507
508 509 ‐‐TRUE FORMAL REGULATION 510 511 We all know that the essence of US and Canadian regulation is to set 512
monopoly utility return at no more and no less whatever yield it takes to get new 513 money for service extension.. 514
515 516
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Lest we forget both WAC Bennett, and NDP Leader Bob Strachan strongly 517 advocated cheap tax‐free power. 518
519 520 521 And BC Hydro managed to suspend all public rate hearings since 2010 522
claiming,” They take too long “ 523 524 i/The $/mwhr charged to BC Hydro customers are about double what it 525
actually costs the BC Finance Minister’s Department to finance new projects 526 Ii/BC HYDRO charge for nonexistent income tax 527 BUT .In 196O premier WAC Bennett, Dr. Shrum and NDP’s opposition leader 528
Bob Strachan all agreed that public (tax‐free) BC Hydro should take over private 529 (tax‐paying) BC Electric, in order to save federal income tax and thereby LOWER BC 530 Electric rates. Its a free country every people get the govt they deserve and vote in. 531
WAC Bennett's policy BC could have the lowest electric rates in the world 532 attracting permanent job in manufacturing where electricity cost robotics, pulp 533 paper, plywood, smelting mineral mining processing 534
535 .Clark policy have competitive 3rd lowest in Canada but spiral up 536
$9 billion Site C would raise Plant from around $22 billion to $31 billion, which 537 raises by around 40% the allowed return on rate base and continues the rate 538 spiral ALL BC parties know that $9 billion sinks BC AAA credit and squeezes money 539 desirable for health care,housing and transit 540 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 541 542 D 2 d demand‐side management initiatives folios could provide similar benefits as 543
Site C at reduced cost. 544
Demand side management initiatives are really a type of” conserving energy” 545
initiatives The latter. have been overlooked by BC hydro 546
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D2.2CONSERVATION Initiatives 548
3/Lake Williston behind“ WAC Bennett dam (Site A ) holds 20 years’ Peace river flow 549
and can be the wolds largest battery .in the US the Bath pumped storage in Virginia 550
is called the world largest battery in Wikipedia, But it is just around 1/100 on the 551
size of Lake Williston,BC hydro can achieve similar results by switching Vancouver 552
supply between Peace River generation or BPA By “ displacement” even without 553
pumped storage and gain free energy greater than Site C 554
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D2.2.1 DSM Conservation initiative (= Site C‐5,000 gwhrs) STEP 1 556
BPA’s top engineer John Hyde published fish water releases cost BPA 1000 ave MW 557
(approx the capacity of Site C) and $750 million per year in order to release 558
mandated 3.45 million acre feet of water for fish and irrigation 559
In Nov 14,2012 i was invited by the US State Dept, and on may 30 2013 by BPA to 560
explain future options on the Columbia ; I informed Liberal Ralph Sultan MLA who 561
advised the BC govt and NDP John Hogan, then energy critic, I wrote a book. One 562
related option BPA wanted to investigate was swapping more power (not 563
water)back and forth with BC Hydro ,using existing Peace River generation and Lake 564
Williston storage They wanted to i/ to increase fish water requested by first nation 565
tribes , ii./while saving BPA up to $ 750 million per year iii save 1000 mw capacity. 566
But BPA managers shelved the project because they believed (RIGHT OR WRONG) 567
the then BC government would not approve it, because they wanted to be anti 568
American to get more BC votes , 569
John Hogan seems more open minded. and I hope may approve the initiative 570
because i/ it could could conserve and save and provide as much energy as Site C 571
at low cost ii/.save BPA $750 million a year ii/ increase fish water for First Nation 572
Tribes and alleviate fish vs power controversy iii/ may potentially contribute millions 573
of US dollars towards improving,if needed, transmission and generation or pumped 574
storage for BC’s Lake Williston iv , create jobs 575
Details 576
For maximum power sales revenue BPA wants all water to run through turbo 577 generators, But fish 578
need most water releases in spring Then water flows produce too much power for 579
market needs,which causes problems i/BPA then has to spill water over the top of 580
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the dam , which wastes energy and loses potential revenue . ii/plus there's only so 581
much water that can lawfully be spilled over the top of the dam because too much 582
spill hurts fish 583
584 585 586 587 Growing US Northwest Power Glut Continues 588
The press and public are not all aware that there is a huge and growing US 589 Northwest Power Glut in hydro, wind power or solar energy . 590
For example under Oregon Senate Bills , wind, solar, and other renewable 591 power are legislated and must grow from 5% in 2011,to 25% by 2025 and 50% by 592 2040. 593
594 D what portfolio of 1. generating projects and 595 2.demand‐side management initiatives could provide similar benefits; and 596
597 D 1.1 The following generation projects could provide similar benefits similar to Site C 598 5100 gwhrs but at a small fraction of Site C cost. They are all carbon‐ free, complying 599 with the latest Paris Climate Change accord. 600 The Portfolios can be used singly or combined if load growth is higher than estimated 601 by BC hydro and need little lead time for changes 602 This provides flexibility and allow any final decision about Site C to be postponed beyond 603 5 years election time 604 605 606 607 D 1.1 CYCLIC Operation of Lake Williston (can replace 90% of Site C now at no cost) 608 609 If BC Hydro operated Lake Williston it the way, BC Electric originally planned it. Cyclic" 610 operation of its huge storage behind“ WAC Bennett dam (and GM Shrum power 611 generation could add around 4500 gwhr ‐(around 90% of Site C capacity),AT NO COST 612 This no extra cost energy could halt the rate spiral for ratepayers. 613 614
615
Table 3‐8 in the SITE C terms of reference has a material mistake which needs 616
correcting, or it will mislead BCUC, ratepayers and the public. 617
618
Earlier, politicians of both NDP and Liberal politicians got the correct information, but it 619
appears in the rush to get a quick review , BC Hydro overlooked to correct table 3‐8 , 620
which is mistakenly slanted to show we need site C now. 621
622
20
It is 4500 gwhrs (90% of Site C) too low for energy capacity because it is based on 623 minimum flow for Peace River generation whereas it should be average flow of Peace 624 River. 625 626 Earlier when he was NDP energy critic, John Hogan and I discussed the benefits of Lake 627 Williston having world record storage. 628 629 BC Electric specially designed Williston to operate "cyclically" so average flow 17000 630 gwhrs can always be generated. 631 And any deficit in a 12500 low year can be supplemented with water carried over from a 632 22,700 high flow year. 633 634 I got these numbers from BC Hydro Sept 28‐30 2012 (please see attached for 635 verification) thanks to a Liberal MLA Ralph Sultan, who years ago was a young engineer 636 doing surveys while I was BC Electric Director of Planning.? 637 638
Details 639
640
The mistake is due to wrongly assuming that the BC hydro system was designed, like all 641 other hydro systems in North America, where system firm capacity was limited by the 642 low flow year 643 644 BUT the BC hydro system is DELIBERATELY designed based on the AVERAGE flow year 645 which is much greater. Please see exhibit from Doug Robinson (Secretary of the 646 Canadian entity of the Columbia River Treaty. 647 648 That was requested by BC Electric CEO Dal Grauer and VP Tom Ingledow, who in 1956 649 asked me to write a paper to explained why BC Hydro (despite enough untapped hydro 650 for many future years) was installing the Buzzard Thermal plant ( ref 41 Ruskin, Vernon, 651 “Thermal plants for firming up hydro” recommended by the American Institute of 652 Electrical Engineers, Committee on Power generation, for presentation at the AIEE 653 Winter General meeting in New York, Jan 21 ,1957). 654 BC Electric successfully minimized electricity rates, using around average 750 gwhr 655 thermal, operated very little only in low years, firmed up and gained around 5,000 gwhrs 656 firm hydro capacity at lowered cost to ratepayers. 657 658 Lake Williston, is an underused heritage from WAC Bennett, planned by BC Electric. 659 It took 20 years to fill and now stores 340,000 gwhrs energy. 660 It holds 661 5 times as much water as the Grand Coulee Dam, Washington State, 662 .11 times more water than Lake Shasta Dam, California, 663 3 times more water than Hoover Dam, Lake Mead on Colorado River (bordering Arizona 664 and Nevada). 665 666
21
Lake Williston is like a world‐record …. “giant rechargeable battery” 667 668 We planned to operate to achieve the same benefit of lowered rates for electricity to 669 ratepayers, using the huge Lake Williston, by multi‐year (“cyclic” ) carryovers of water 670 stored over 20 years, thereby averaging low and high flows FOREVER . 671 Thus we don’t need Buzzard Thermal plant any longer, and the BC hydro grid is now 672 100% clean carbon‐free energy fully, complying with the Paris climate change accord. 673 I also checked there was diversity between Peace River and Columbia River. 674 The low flow at each of these watersheds is not synchronized, so there is plenty of time 675 for cyclic scheduling. 676 677
Technically the flows on the Columbia are now set by Bonneville Power 678
Administration. Lake Williston behind WAC Bennett Dam (Site A ) holds 20 years of 679
Peace River flows, so it smooths out any high and low flow years. The water from 680
Lake Williston is used “cyclically” so the combined Columbia River and Peace River 681
gwhr energy supply uses the same average 17,000 gwhrs Peace River flow level 682
every year. That is 4,500 gwhrs greater than the low flow level of Peace and 683
Columbia Rivers combined which BC Hydro now refers to as ‘firm dependable’.. The 684
average flow level is automatically updated by a moving average .(there is NO 685
EXTRA COST for this extra 4400 gwhr power, and Its assured regardless of any US 686
power glut or famine 687
688 The average flow level is automatically updated by a moving average. 689 690 There is NO EXTRA COST for this extra 4500 gwhr energy, which now counts as firm 691 dependable capacity. This no extra cost energy could halt the rate spiral for ratepayers. 692 693 694
Lake Williston behind“ WAC Bennett dam (Site A ) holds 20 years’ Peace river flows ,so it 695 evens out any high and low flow years .The water from Lake Williston is 696 used”cyclically” so the energy supply every year remains at the same 17000 gwhrs 697 average level every year ,I e any deficit in a 12500 minimum low flow year can be 698 supplemented with water carried over from a 22700 maximum high flow year. i got 699 these flows from Doug Robinson BC hydro on Sept 28, 2012 and also discussed them 700 with Chris Reilly please see attached exhibit X from i‐ phone 701
22
(in the SITE C terms of reference to BCUC was a table 3‐8 by BC hydro that needs 702 correcting ,it shows 4500 gwhrs too low for dependable energy capacity 703 because it is based on minimum flow for Peace generation) 704
Huge Lake Williston is a very valuable, but underused, heritage from WAC Bennett., 705 planned by BC Electric it stretches 150 miles like the distance from Vancouver to 706 Seattle.. It holds 5 times as much water as Grand Coulee dam IT , and 11 times as much 707 as Lake Shasta,the biggest reservoir in California, Lake Williston acts like a world‐record 708 giant ” battery” ..or “ energy recycle bin;’” 709
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 710 d 3 The following generation portfolios involve Powerex and could provide similar 711 benefits ,totaling around 7700 gwhrs which is 50% greater than the 5100 gwhrs from 712 site C but at a fraction of Site C cost and do not require building any dams. 713 The Port folios can be used singly or combined if load growth is higher than estimated 714 by BC hydro and need little lead time for changes 715 This provides flexibility and allows any final decision about Site C to be postponed 716 beyond 5 years election time 717 718
719
720
721
D 1.2 Powerex trading can replace All of Site C at 1/3 of the cost. 722
723
724 D 1.2.1 Growing US Northwest Power Glut 725
It is relevant for BCUC, for BC Hydro and the BC government to note that the 726 physical and economic power supply situation is changing completely, due to a 727 growing Northwest US power glut , and the load‐balancing needs of wind and solar 728 power and the inevitable northwest hydro springtime floods 729
730 The growing US Northwest Power Glut of hydro, wind power or solar energy 731
is due to US legislation funded by US taxpayers subsidizing carbon free electricity 732 generation ,directly or indirectly by very fast write‐offs, eg under Oregon Senate Bills , 733 wind, solar, and other renewable power are legislated to grow from 5% in 2011,to 734 25% by 2025 and 50% by 2040 735
23
Bonneville Power Administration (BPA)in the US Pacific Northwest, has growing 736 oversupply problems, since 6200 MW of US‐generated wind power ‐six times the 737 capacity of Site C – got curtailed and wasted because it is surplus to domestic US 738 needs during Spring and nights. Moreover BPA spills lots of water over the dam in spring 739 because of big floods and not enough load. Northwest US wind power is legislated to 740 increase ‐to ten times the capacity of Site C‐so wasted US power will further increase , 741 BC should explore “win‐win “ negotiations for this huge surplus capacity ( at $5 to 742 29/mwhr) as a much cheaper replacement for Site C (around $132/mwhr including 743 "deferred" expenses) . 744
The new BC Hydro Chair Keneth Peterson appointed by John Hogan has good 745 Powerex trading experience .He doubtless knows import‐export trade with US has 746 therefore grown from around 20,000 gwhrs to around 50000 gwhrs .and why this 747 presents a long term opportunity for BC to get cheap surplus power , that would 748 otherwise be wasted/ 749
Engineer Ben Kujala, with the Northwest Power and Conservation Council tells it like it 750 is.”, BPA started the wind‐power curtailments in mid‐March, earlier in the season than 751 ever before. When rivers are running too high from snow melt and precipitation there is 752 only so much water that legislation allows to be spilled over the top of dams, bypassing 753 turbine generators. Too much spill can harm threatened and endangered fish. Add to 754 that springtime winds and there could be too much power on the grid. . That could 755 cause a blackout ,& with more solar on the grid, California’s not buying as much of the 756 Northwest’s surplus. That leaves the extra US power with little place to go , Wind 757 operators are made to stop producing power. Wind power producers lose money with 758 each day they’re not generating power” 759 760 .”To explain how it physically works assume US wind farm X has surplus 200 mw it 761 cannot sell from 1 am to 6 am at night, on 100 days , because BPA's load isn’t big 762 enough when customers are asleep. But X will gladly sell that1000 gwhrs for say 763 $29million to Powerex . X will also get say $10,million 000000 US govt subsidy or fast 764 write off for wind power gwhrs generated .So far X ends up with $39million it would 765 otherwise lose . BC Hydro will reduce Peace River generation by 1000 gwhrs,thus 766 saving Y gallons of Lake Williston water .Then BC Hydro uses that Y gallons during peak 767 load hours to generate 1000 gwhrs and transmit it to US and/or BC users 768 Hen assume wind farms X nearby retail customers during days cook run hot water turn 769 on lights appliances and use 1000gwhrs at retail 100 per mwhr ad pay 100 million to 770 water heaters,so X buys back the 1000 gwhrs from Powerex at 40 million and pays BPA 771 1million transmission charges 772 bottom line ends up with #$100+29‐40‐1 = 98 million , Powerex with 40‐29= 11 million 773 BPA with 1 million of course that leaves out setils like overhead and line losses but it 774 gives you a ballpark idea 775 With out trading and Lake Williston X would have made zero 776
24
Without that trade nobody makes anything and 1000 gwhrs of energy I lost forever, 777 valued at a29 to 4o of course that leaves out overhead and transmission loss bot it 778 ballparks the advantages of trading by Powerex lo million 779 780 . Thus Lake Williston is an invaluable underrated legacy by WAC Bennett. planned by 781 BC Electric It stores 340,000 gwhrs ‐energy. It holds 5 times as much water as Grand 782 Coulee dam,, like a world‐record giant ” battery” or” energy recycle bin”. It can recycle 783 any surplus hydro ,wind power, IPP or solar energy .It can prevent much waste of water 784 spilling over BC or US dams 785 Lake Williston allows US to save and recycle energy worth far above $500 million per 786 year that would otherwise be wasted. Since US plans lots. more wind power that figure 787 will grow towards $ 1billion. .No US President would order to stop that 788
789 790 791 792 .There is a huge legislated and growing power glut in the Northwest Us S 793 Powerex imports and exports were in both the order of 20,000 gwhrs. IE that is 4 794 Times as much as Site C would ever generate, namely 5,100 gwhrs. The ‘trade totals is 795 around 40% of BC domestic load and lately went up to almost 50,000 ie 10 times as 796 much as Site C capacity 797 798 Its time some obsolete BC economists and statistician started to think about the 799 economics of buying energy on the open market like 39 million Californians vs investing 800 and financing new IPPs, wind farms and hydro , especially prohibitively costly Site C 801 802 BC Hydro could profitably supply its present domestic electricity sales growth up to 803 25 years‐ if they export 25% less power from BC dam (or import more) 804 BC Hydro/Powerex virtually uses only around 6% of Lake Williston storage ,buys at 805 around $ 23 per mwhr and sells it at around $42 per mwhr . This is a fraction of the site 806 C expected cost of $132 per mwhr including deferred charges. Imports are also far 807 cheaper than the average $86.per mwhr cost of BC IPPs 808
Bottom line. There is good reasons why BC Hydro could export 25% less (equal to Site C 809 capacity 5,100 gwhrs) which appears is enough to supply 25 years of BC’s growth. 810 New BC Hydro Chairman Peterson is expert in power trading and could get cheap 811 power for till for many years from Powerex trading 812 813 Powerex free trade: BC energy and lumber; California oranges 814 815 816 Nobody in BC need be afraid future back and forth trading by Powerex will ever stop. 817
25
Thus growing amounts of surplus US energy (which would otherwise be wasted) could 818 become available to BC at very low cost 819
Though the US NW has a power glut, BC Hydro pretend they need Site C to 820 make BC ‘self‐sufficient’ 821
I believe its unreasonable to continue the present Policies . 822 I believe only rich well paid political minded people would try to push site C 823
beyond the point of no return, trying to justify building uneconomic Site C. 824 825
NO president or premier would ever stop Powerex trading and restrict free 826 trade in energy (where NW US has a glut) but free trade in lumber(where BC 827 has a glut) and oranges (where California has glut) 828 829 Thus growing amounts of surplus US energy (which would otherwise be wasted) could 830 become available to BC at very low cost 831
Though the US NW has a power glut, BC Hydro pretends they need Site C to 832 make BC ‘self‐sufficient’ 833
I believe 50 years history shows its unreasonable to continue the past Policies 834 i/that BC must get all new power from more expensive Independent Power 835
Producers (IPP), or 836 ii /and restrict free trade in energy (where NW US has a glut) but free trade in 837 lumber(where BC has a glut) and oranges (where California has a glut) 838 839 840 841 D.1.3. Columbia River Treaty (CRT) (can supply 90% of Site C at no additional cost) 842 In 1960‐63 my company developed and ran Canada's FIRST Computer model of 843 the Columbia river for Gen. McNaughton in Ottawa and BC hydro to check BC’s 844 Downstream benefit calculated by the US Army Corps of Engineers 845
846 BC Hydro/Powerex is “entitled” to 4100 gwhrs generated in the US under the 847 Columbia River Treaty (CRT). 848 So that is enough for 13 more years with BC's present electricity growth. 849 850 851 Instead Powerex could sell it at around 1/3 the cost of Site C which is not cost 852 effective. 853 854 855 856 857 President Eisenhower signed the CRT to build BC flood control dams to prevent 858 recurrence of floods, killing 15 Americans and wiping out the second largest town 859 in Oregon . BC downstream benefit entitlement is calculated according to fixed 860 rules five years ahead and does not vary with actual flows. 861
26
862 The CRT treaty can only be canceled with ten years’ notice,By law any US 863 president (eg Trump) needs 2/3 votes in the Senate to change it,,,Thus BC’s 864 growing electricity needs are safe for 13 years No President will issue an 865 executive order to stop energy BC is lawfully entitled to and endanger Americans 866 and flood protection of their homes. 867 Because US Army Corps of Engineers are tasked with flood protection they will 868 intend to re‐negotiate only about lower costs and water releases for fish … never 869 for canceling the treaty. 870
871 872 873
874 875
D 1.4 xx Adding generators to existing dams produces around 1000 gwhrs 876 otherwise spilled and wasted which is 20% of Site C at reduced costs. 877 878 Note Revelstoke #6 with488 mw and only 26 gwhr is $1500 /mwhr=not cost effective 879 D 1.4.1 Every spring a tremendous amount of water spills over existing dams at 880 Keenleyside and Duncan ,which needlessly wastes around 1,000 gwhrs of energy, 881 (nearly 20% of Site C energy),because they have insufficient or no generator installed. I 882 researched conserving energy from needless spill in 2012 and Vancouver Sun published 883 my paper. 884 885 D 1.4.2 Keenleyside dam originally had no generators and BC hydro later installed only 886 185 mw, but installing additional 165Mw can produce an additional 700 gwhrs and 887 CONSERVE energy that would otherwise spill and be wasted., at a fraction of site C 888 unit cost, without building any new dam 889 This is shown on page 109 of my referenced book 890 891
2.2.3 Duncan dam has sat without generators for over 50 years . Installing around 892
100mw generators can add around 276 gwhrs and CONSERVE energy that would 893
otherwise spill and be wasted .BC Hydro has a report showing it needs a short 894
transmission line ,and it causes no environmental problems to add generators. The 895
report needs updating since it is based on old 5.5% interest and 28% contingency ,my 896
preliminary estimate subject to detailed study is far below Site C unit cost of $132/ 897
,mwhr 898
899
D2.2.2 DSM Conservation initiative 900
27
Step 1 ? 95% Capacity of site c) 901
902
IN 2010 BPA Top engineer John Hyde published that fish and irrigation water 903
releases cost BPA 1000 MW ,( equivalent to 95%t he capacity of Site C) and $750 904
million per year ,in order to release mandated 3.45 million acre feet of water for fish 905
and irrigation 906
907
908
For maximum power sales revenue BPA wants all water to run through turbo 909 generators ,But fish need most water releases in January and in spring Then water flows 910 produce too much power for market needs,which causes problems i/BPA then has to 911 spill water over the top of the dam , which loses potential revenue . ii/there's only so 912 much water that can lawfully be spilled over the top of the dam because too much spill 913 hurts fish 914
BPA is an agency of the US State Dept . In Nov 14,2012 i was invited by the US State 915 Dept and MAY30, 2013 BY BPA to explain future options on the Columbia. (The CRT is 916 option about which I wrote a book is not an issue now) but One option BPA wanted to 917 investigate was swapping more power (not water)back and forth with BC Hydro ,using 918 existing Peace River generation and Lake Williston storage They wanted to i/ to 919 increase fish water requested by first Nation tribes , ii./while saving BPA up to $ 750 920 million per year . But BPA shelved the project because they believed( right or wrong) 921 the then BC government would not approve it because they might get more votes 922 with an anti‐American stance , 923
John Horgan seems more open minded and I hope may approve it because i/ it 924 could increase fish water for First Nation Tribes and ii/ may contribute millions of US 925 dollars towards improving transmission and generation,( and possibly even 926 pumped storage) at the existing GM Shrum power plant on the Peace river,and 927 create jobs. 928
929 930 931
D2.2.2 DSM Conservation initiative Step 2‐ $40000 gwhrs ? (8 TIMES Capacity of 932
site c 933
STEP 2 “Upstream Benefits” 934
28
Thanks to WAC Bennett legacy of Lake Williston ,the BC govt can be the world 935
leader in Energy Conservation , BC could reverse the rate spiral, by getting free 936
energy from water that wold )otherwise be spilled and wasted (The WA and OR 937
state govt can potentially also achieve savings in energy cost 938
I regard that as”BC UPSTREAM BENEFITS”.(similar to Gen McNaughton ‘s BC 939
Downstream benefits”) 940
941
Columbia flow and spill ; records at various dams (available on internet ) I find that 942
despite all the energy saved by Powerex recycling US hydro spill, there is around ¼ of 943
US Columbia River flow gets spilled during 4 months That is roughly 9000 MW at 944
around 50% load factor . for 4 months per year or 40,000 gwhrs , or 8 times the 945
capacity is now spilled over US dams 946
That’s just 12% of Lake Williston 947
Pro rata I expect the water spilled and wasted over BC hydro dams is around 10000 948
gwhrs per year or twice the capacity of Site C. 949
950
951
Bottom line, by cooperatively scheduling Lake Williston with BPA in future I 952
estimate BC Hydro can get many times the capacity of Site C at very low or no cost 953
954
I hope the new BC Government will inform BPA they are willing to consider 955
cooperative scheduling of Lake Williston with BPA 956
If. Feasible, BC could horse trade the “Upstream Benefits” It can be done anytime 957
since the Columbia River treaty doesn’t cover the Peace river 958
959
I believe Lake Williston may turn out be the most valuable legacy of WAC Bennett 960
and his descendants might collect his posthumous Nobel prize for hydro energy 961
conservation preventing climate change per Paris accord 962
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 963
29
964
According to Wikipedia the US, there are 60 dams in the watershed, with 14 on the 965
Columbia, 20 on the Snake, seven on the Kootenay, seven on the Pend Oreille / Clark, 966
two on the Flathead, eight on the Yakima, and two on the Owyhee. Averaging a 967
major dam every 72 miles (116 km), the rivers in the Columbia watershed combine to 968
generate over 36,000 megawatts of power, with the majority coming on the main 969
stem. Grand Coulee Dam is the largest producer of hydroelectric power in the United 970
States,[1] generating 6,809 megawatts, over one‐sixth of all power in the basin. 971
972
973
974 975 976 977 978 979 D 3.1. Alternative Power Sources Portfolio 980 981 14/Sixty years ago BC Electric engineers diligently surveyed and designed four 982 HIGH DAMS on the Columbia plus five on the Peace river ( A B C D E ), when 983 buying flooded land was cheap and NOBODY cared about environment 984 985 15/Subsequently Rachel Carson wrote:” Silent Spring:" which inspired 986 environmentalism and caused creation of the EPA 987 988 16/ Today ,flooding land is no longer cheap and carefree. BC Hydro management 989 simply picking the same HIGH DAM sites as BC Electric fails reasonable due 990 diligence ,when they employ around 700 MODERN BRIGHT YOUNG engineers 991 who could diligently re‐survey and re engineer the same amount of Site C power 992 cheaper with multiple LOW DAM " run of river" plants that flood no land beyond 993 high water 994 995
D 3.2 CONVENTIONAL HYDRO PLANTS PORTFOLIO( 15 plants can replace Site C at 996 lower cost) 997
17/In 2008 BC Hydro tabled 15 plants with BCUC that could produce cheaper 998 power at $58 to $73/mwhr compared to $ 132 /mwhr for Site C including 999 deferred charges 1000
‐6.1 Peace and Columbia 1001 1002
30
1003
1004 1005 ‐6.2 Elaho, Homathko , McGregor Rivers‐ 1006
1007 1008
31
1009 1010 1011
32
D 3.3. 1012 1013 1014 1015 D3.4 Run of River Plants 1016 BC hydro has shelved BC Electrics designs for 4 "run of river" plants on the Columbia 1017 ,and could find more 1018
33
1019 1020
1021 D demand‐side management initiatives could provide similar benefits; and 1022
Conservation is the objective of DSM . judging by very slow growth of 1023 Domestic sales DSM works and there is a portfolio of i/prohibiting incandescent 1024 bulbs and ii /the new rate proposal of discounts for overnight water and house heat 1025 using smart meters but iii/ the spiralling rates must also work .Nobody can tell how 1026 much each contributes 1027
Conservation of energy by reducing spill over the dam 1028 But the biggest energy conservation could come from reducing unnecessary 1029
spill over the dam as shown by springtime pictures see pictures on BC Hydro report 1030 just by adding generators or replace them in the bigger ones to existing dams Duncan 1031 Revelstoke Keenleyside and GM Shrum 1032
1 Duncan dam has sat 50 years without generators and Keenleyside 1033 lacksenouh generators and together could total 976 gwhr at fraction of Site C cost . 1034 Previous Minister Bill Bennett criticized me on CBC for saying that, but CBC would not 1035
34
grant me any time to point out the report he sent me showed Duncan had no 1036 environment problem and cost a lot less than Site C Keenleyside spills a whole lot of 1037 water needlessly whih is like dollar bills spilling over dam] I estimated just thosetwo 1038 alone could add 976 gwhrs 20%of Site C , lots water spills at GM Shrum I got BPA 1039 spill and flows on internet records.Does BC Hydro publish theiers ? 1040
1041 1042 1043 1044
1045 D 3.1, ( ) .2.0 portfolios Without building Site C or any dam or more IPPs 1046 1047 2. unvikvinfg poerex 1048 1049 1050 1051 No one can accurately forecast loads a long ie ahead because to fch 1052 WITHOUT BUIING SITE C or any dam 1053 Alternative power sources 1054 2 BC has enough existing power for minimum 13 years 1055 If additional projects are needed see my book p 109 1056 1057 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 1058
1059 E w We welcome submissions of (1)data and/or (2) analysis until August 30, 2017 1060 1061
1062 E what are expected peak capacity demand and energy demand 1063
"I have but one lamp by which my feet are guided, 1064 and that is the lamp of experience. 1065
I know of no way of judging the future but by the past." 1066 by: Patrick Henry
I have carefully analyzed the data see below and based on my personal 1067 experience for 5 years in successfully planning and running the BC electric 1068 heritage system 1069 I conclude BC hydro has more than enough energy for guarantee 5 years 1070 plus 5yrs lead time till 2o27 to review actual growth every year ,well past 1071 the next elections .BC doesn’t need uneconomic and possibly unsafe site c 1072 now. 1073 I suspect the judgment and experience of anyone that tries to push site c 1074 forward beyond the point of no return. 1075
BC Hydro already has enough electricity for next 13 years and longer without Site C 1076 1077
35
2//BC Hydro annual reports show domestic power sales grew around 1078 2000 gwhrs over ten years, 1079 In 2015 Hydro/Powerex imported around 1400 gwhrs but was “entitled” to 1080 4100 gwhrs generated in the US under the Columbia River Treaty (CRT). 1081 So,BC Is entitled to another 2700 Gwhr,‐ enough for 13 more years with BC's present 1082 electricity growth 1083 .. 1084
1085 in the SITE C terms of reference issued by BCUC, directed by Energy Minister Michelle 1086 Mungall was a table 3‐8 by BC hydro that needs correcting 1087 1088 it is slanted to show we need site C now 1089 it is 4500 gwhrs (90% of Ste C) too low for energy capacity 1090 because it is based on minimum flow for Peace R generation 1091 1092 but should include average flow for Peace) 1093 John and I discussed that Lake Williston took 20 years to fill and has around 340,000 1094 world record storage 1095 1096 BC Electric specially designed Williston to operate "cyclically" 1097 so average flow 17000 gwhrs can always be generated 1098 1099 and any deficit in a 12500 low year can be supplemented with water carried over from 1100 a 20500 high flow year 1101 1102 I got these numbers from Doug Robinson BC Hydro around Sept 28‐30 2012 and also 1103 discussed it with Chris O' Reilly , see attached 1104 1105 Lake Williston is an underused heritage from WAC Bennett., planned by BC Electric It 1106 stores 340,000 gwhrs ‐energy. It holds 5 times as much water as Grand Coulee dam,, 1107 like a world‐record giant ” battery” 1108 Technically the flows on the Columbia are now set by BPA. Lake Williston behind“ WAC 1109 Bennett dam (Site A ) holds 20 years’ Peace river flows ,so it evens out any high and low 1110 flow years. The water from Lake Williston is used”cyclically” so the combined Columbia 1111 and Peace gwhr energy supply remains at the same average 17000 flow level every year 1112 ,That is 4500 gwhrs greater than the low flow level of Peace and Columbia combined 1113 which BC hydro now counts as firm dependable. The average flow level is automatically 1114 updated by a moving average .(there is NO EXTRA COST for this extra 4500 gwhr 1115 power, now counts as dependable. The average flow level is automatically updated by 1116 a moving average .(there is NO EXTRA COST for this extra 4500 gwhr power, and Its 1117 assured regardless of any US power 1118
1119 1120
36
BC Hydro installed capacity is 11400 mw 1121
1 data=BC Hydro’s own annual reports service plan show domestic power sales 1122 expected trend around 10500 Megawatts and around 56000 added 1123 2,000 gwhrs growth over ten years (2005&6 Average 52000 gwhrs and ‐2015&16 1124 average 54000 } 1125
That may be result of dsm but the demand is elastic and choked by doubling the price 1126 to rate to ratepayers from 2006 before all the IPP stuff to 2016 1127
1128 there used to be measurable effect than heating degree‐days a 1129 ) The sales dept can provide a list of signed future contracts and letters of intent with 1130
deposit from large customers 1131 . In BCUC files you can verify in 2012 I submitted a detailed brief to BCUC that BC 1132
Hydro boasting of cleverly(?) rolling dice at Monte Carlo ,.with millions of dollars 1133 of ratepayers money, to justify future electric transmission lines to provide 1134 power from Site C for “clean”Monterey gas compression( at projected inflating 1135 prices) was unreasonably risky for ratepayers 1136
1137 1138 I was hired by BC Electric in 1955 after Vancouver suffered a blackout ,to plan 1139 ,engineer ,budget and check progress and costs of generation and transmission 1140 1141 . 1142 I lerned the the successful planning method CEO Dal Grauer wanted for the heritage 1143 system 1144 it enabled him and directors to select the 10 “heritage” plants that over over 50 years 1145 to this day at $7 per mwhr (0.7 cents per kwhr) provide the lowest cost power world 1146 wide 1147 1148 First he wanted a yearly updated report to CEO and directors by me summarizing 1149 independent ,nonpolitical ,non ‐lobbied planning by engineers trained in detailed 1150 design and engineering economics and getting independent reports from surveys and 1151 geologists and cost estimates . 1152 1153 That report had a yearly updated 5year plan 1154 Budget with plants underway ,% completion,projected overruns 1155 1156 A table of Five year capacity and expected load 1157 1158 A yearly updated 25year list of all feasible alternatives we surveyed ,designed and 1159 engineer , ranked in order of lowest delivered cost to Vancouver customers 1160 1161 A a list of lead times and start dates needed for each project 1162 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 1163
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It was up to Grauer .,not up to planners ,to listen to the current government and 1164 lobbyists and customers and directors and decide what project to select, and ask 1165 permission for the project from BCUC, which was the watchdog with teeth on 1166 behalf of captive ratepayers 1167
1168 1169
But with all due respect,I submit the so called “ integrated planning’( like 1170 misleading Table 3‐2), with input by vote‐hungry politicians and subservient 1171 government and BC hydro staffers wanting promotion ,and by ratepayer groups and 1172 lobbyists trying to turn BCUC lawyers into mediators, has led to the Site C problem 1173 and cannot end the rate spiral hurting consumers. 1174 Truth will out :‐it’s planning by popupular vote‐counting, and “interim” yet 1175 irreversible, rate setting ,“directed” by the minister ,by the muzzled and powerless 1176 BCUC” regulators” with deferred “ rate rider “ accounting to whatever price the traffic 1177 will bearor hidden sales tax, like the liquor control board 1178 1179 you no longer plan and engineerm, you merely prit mounains of paper to justify 1180 decsions your political masters,who prefer to fly blind behind closed doors 1181 1182 1183 ictatedThe major hydro heritage system was sufficient for around 50 years. Today it 1184
still supplies most of BC Hydro’s power at around $7/WHR( 0.7 cents/kwhr 1185 which is less than any where in Canada 1186
Premier Campbell dictated all future power should come from IPP. The latest cost of 1187 power according to the annual BC Hydro report hows s price is $ 106/mwhr (10.6 1188 cents per kwhr) for residential;$91/mwhr (9.1cent/kwhr) or commercial an $56 1189 PER MWHR (5.6 cents/kwhr)for large industrial s report 1190
The The average price for site C power when completed quote in newspapers from 1191 Mr Coleman was around 132 per mwhr equivalent 13.2 cents per kwhr. 1192
1193 You asked e/what are expected peak capacity demand and energy demand 1194
Whether you believe that BC’s energy demand is almost flat due to BC Hydro big 1195 DSM budgets or just old fashioned price elasticity ,I analyzed the last ten years and 1196
quote :‐ 1197 "I have but one lamp by which my feet are guided, 1198
and that is the lamp of experience. 1199 I know of no way of judging the future but by the past." 1200
I can claim some prior experience 1201 CEO Dal Grauer Of BC Electric(the predecessor of BC Hydro) hired me as director of 1202 planning in 1955 after Vancouver had a total blackout and you can verify in the five 1203 years during which I planned and he trusted me to run the heritage system, there were 1204 no blackouts or shortages 1205
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To answer your question d/ I analyzed many feasible supply portfolios .To give you a 1206 perspective( like I yearly did for Mr Grauer and directors in a yearly updated power 1207 policy report I found That 1208 i/ BCUC could safely conclude that BC hydro already has sufficient plants and storage ( 1209 over twice the capacity of site C) to supply growing domestic electricity needs for a 1210 minimum of 13 years, and actually much longer, as explained under d/ , without 1211 building site C, or any high dam, or flooding any land ,or any new IPPs 1212 1213 e1 /will first give you a comparison like Table T 3‐8 and T3‐9 ,using the mid load forecast 1214 of BC Hydro though I consider it overoptimistic ,unless less you halt the rate spiral 1215 e2/I Will also give you analysis of what I consider needs correction 1216 I already wrote you about an error in Table 3‐ 8 and why it needs correcting 1217 e3\ i Will give you my revised forecast and recommend a way of using and revising it. I 1218 will be glad to explain the way to anyone interested 1219 1220 e1 With BC Hydro mid load forecast 1221 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐, 1222 ENERGY from tables 3‐8 1223
2oo5 year 2006 2010 2015 2016 2O22 2027 1224 ] 1225 51205 gwhr 52240 50223 51199 51023 63675 69267 1226 DSM ‐ 4672 ‐ 6356 1227 ‐ 7% ‐10% 1228 Load Proposed NET 59003 62911 1229 Capacity Corrected see my letter to Mr Wruck* 1230 Heritage * 47500 47500 1231 IPP 13874 12399 1232 Crt potential 4000 4000 1233 Potential Powerex imports 0 0 1234 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 1235 Total Avail 70699 68899 1236 Potential surplus Powerex export (incl CRT) 12699 10899 1237 1238 1239 ======================================================================= 1240 INSTALLED heritage 10480 10480 1241 1242 IPP 1472 1037 1243 CRT contract 1000 1000 1244
‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 1245 Total available 12952 12517 1246 1247 FROM TABLE 3‐9 1248
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P PEAK 11737 12708 1249 P DSM 818 1045 1250 PNET 10919 11663 1251 1252 Reserve 2033 1146 1253 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 1254 Table 3‐9 also has a serious and costly errors that need correction 1255 whoever prepared it did not understand the heritage system. the spinning reserve of 1256 10% has proved adequate for 50 years. 1257 1258 the biggest outage dangers are the long transmission lines subject to earthquakes 1259 mudslides ,vast storms. lightning terrorism, relay and breaker failure , which is how 1260 Vancouver had its total blackout . Increasing spinning reserves on Peace and Columbia 1261 dfrom 10 to 14% wastes money and doesn’t help long‐line outages. 1262 1263 We built two tie lines to BPA and joined the NW power pool which has enough spin 1264 reserve . we also installed Port Mann gas turbine and Burrard in case lines all fail due to 1265 big earthquake, war or terrorism with lines to power hospitals, police stations and 1266 street lights 1267 1268 On Table 3‐9 the statistician also forgets UNDER THE Columbia river treaty BC is 1269 guaranteed a firm 1000 mw any time 1270 1271
Revelstoke# 6 Is a scandalous waste of money with 448 mw and only 1272 26gwhr it costs $1500/mwhrs and has only 0.6 % load factor 1273
earlier I wrote BCUC which should be in your files about 1274 The generators added at Mica and Revelstoke (according to BC Hydro 1275
application to BCUC ) add 1000 MW peak but only 150 gwhrs energy(175 average 1276 MW), at a cost of $800 million and around $ 500/mwhr. Windmills cost around 1277 120/mwhr so if BC Hydro gets $60/mwhr revenue, so the BC Hydro CEO and CFO 1278 “defers “the $60 loss, (not counting the $500/mwhr heavy Mica peaking backup 1279 cost) 1280
I hope under the new minister BC Hydro might care about wasting 1281 ratepayers money . I suggest its more cost‐effective to get 276 gwhr by installing 1282 lacking generators at Duncan ,and 700 gwhrs at Keenleyside or others that spill 1283 water and waste money every spring 1284
1285 1286 1287 xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 1288 ‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐1289 ‐‐‐‐‐ 1290
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1291 xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 1292 1293 1294 DSM ‐ price elasticity? 1295 1296 2oo5 year 2006 2010 2015 2016 1297 1298 Price cents/’kwhr 1299 6.4 6.4 7.4 10.0 10.6 1300 Increase 16% 56% 66% 1301 xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 1302 Without building Site C or any plant BC Hydro BC Hydro already has enough electricity 1303 for next 10 years to 2027 and longer without Site C. 1304 I analyzed 1305 1306 2//BC Hydro annual reports show domestic power sales grew around 1307 2000 gwhrs over ten years(2005/6‐2015/16s eyeballed on graph paper and judgment 1308 and averaged), 1309 ENERGY 1310
2oo5 year 2006 2010 2015 2016 2O22 2027 1311 51205 gwhr 52240 50223 51199 51023 52000 53000 1312 CONTINGENCY 1000 1313 1314 Heritage 47500 47500 1315 IPP 13874 12399 1316 Crt potential 4000 4000 1317 Potential Powerex imports 0 0 1318 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 1319 Total Avail 70699 68899 1320 Potential Powerex export (incl CRT) 12699 10899 1321 ======================================================================= 1322 PEAK 1323 9437MW 9317 9847 9441 9612 9800 10000 1324 CONTINGENCY 200 1325 1326 INSTALLED heritage 10480 10480 1327 IPP 1472 1037 1328 CRT contract 1000 1000 1329
‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 1330 Total 12952 12517 1331 1332 Reserve 2952 2517 1333
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1334 1335 1336 1337 1338
Analysis = my experience as director of planning of BC electric was plotting 1339 several years gave a general trend, but breaking it into residential 1340
Commercial 1341 Large industrial 1342 With supposed loads way ahead statistically worked badly like predicting 1343
stock markets. \ 1344 Salesmen must be optimistic to be successful so they MUST be over estimate 1345 BC has unpredictable people influx ,economy , governments ,politics ,and 1346
weather. 1347 1348 CEO Dal Grauer agreed and wanted no subservient staff following top down 1349
marching orders ,but insisted on an open door, open mind .non political, 1350 non lobbied “ think tank” planning and said”if you agree with me every 1351 time, one of us is superfluous”. 1352
1353 e/ BC Hydro’s”Integrated Planning “is Politically Correct’ Myopia 1354 1355 9/Site C is not needed because there are several” greener” ways to supply BC;s domestic 1356 electricity growth for up to 25 years without building site C or any high dam or flooding 1357 any land “/ 1358 Any government decision to build a $9 billion plant, or purchase $18billion IPP contracts 1359 which last 25years is irreversible .In 25 years governments switch 5 to 6 times, but 1360 BC MLA’s must fly blind because “subservient BC Hydro managers and deputy ministers 1361 only produce ONE, “politically correct ”integrated plan”,myopically flip‐flopping 1362 between IPPs ,Wind power, Site C, and more gas fired plants, after shutting down 1363 Buzzard gas fired plant. 1364 1365 Unfortunately,BC Politicians must fly blind 1366 1367 B C Hydro planners don’t plan‐they just justify political vote‐getting decisions 1368 They fail to produce a yearly updated( unvarnished) 25 YEAR perspective ,showing 1369 future costs and rates with a long list of available alternatives ( like BC Electric 1370 produced every year for CEO Dal Grauer and Directors ) 1371 1372 It enabled them to choose cost effective projects. Grauer asked me to to direct 45 staff 1373 at BC Electrics to plan and design ,four of twelve feasible dams on Columbia, and two 1374 of BC's electricity at bargain $7 per mwhr, (at a fraction of Site C cost) otherwise BC 1375 might have the highest rates in Canada 1376 Conclusion 1377
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If mlas want reliable planning like Grauer had there’s too much bias in bc hydro or 1378 victoria 1379 1380 1381 1382 1383