Motions

Motions for Reconsideration:

Motion for Reconsideration of Order No. 768 by Parties NW Energy Coalition and Washington Environmental Council, Whatcom County; and Counsel for the Environment. PDF (9 pages)

Constance Hoag's Motion for Reconsideration of Council Order No. 768  PDF (6 pages)

Joint Motion for Reconsideration of Air Offset Recommendation (CFE, Abbotsford, Whatcom County) PDF (5 pages)

SE2's Response to Motions for Reconsideration PDF  (11 pages)

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
Province of British Columbia

Applicant's Prefiled Direct Testimony:

Prefiled Testimony Witness: Charles Martin
Exhibit CM-1: February 2, 2001, Vancouver Sun Article
Exhibit CM-2: BC Hydro Report for the Nine Months ended Dec. 31, 2000
Exhibit CM-3: July 20, 2001 BC Hydro 2001 Annual Report News Release
Exhibit CM-4: March 7, 2001, Seattle Times Article
Exhibit CM-5: Northwest Power Planning Council Briefing Book, Jan. 2001
Exhibit CM-6: December 17, 2000, Seattle Times Article
Exhibit CM-7: December 18, 2000, Seattle Times article
Exhibit CM-8: December 8, 2000, Seattle PI Article
Exhibit CM-9: December 28, 2000, Seattle PI Article
Exhibit CM-10:December 13, 2000, Seattle Times Article
Exhibit CM-11:NW Council Power Supply Outlook Update June 8, 2001
Exhibit CM-12:August 11, 2000, Seattle Times Article
Exhibit CM-13:August 10, 2000, Governor Locke Press Release
Exhibit CM-14:August 17, 2001, Bellingham Herald Article
Exhibit CM-15:December 23, 2000, Seattle Times Article
Exhibit CM-16:January 5, 2001, Vancouver Sun Article
Exhibit CM-17:January 8, 2001, Vancouver Sun Article

Prefiled Testimony Witness: Katy Chaney
Exhibit KC-1: SE2 Plant Site Wetland Mitigation
Exhibit KC-2: Wetlands Compensatory Mitigation Site Plan Revised 8/31/01
Exhibit KC-3: SE2 Second Revised Application for Site Certification

Prefiled Testimony Witness: Eric Hansen

Prefiled Testimony Witness: Sanya Petrovic
Exhibit SP-1: Curriculum vitae of Sanya Petrovic, M.Sc.
Exhibit SP-2: Curriculum vitae of Ross Wilson, M.Sc., DABT

Prefiled Testimony Witness: A. David Every, Ph. D.
Exhibit ADE-1:Curriculum vitae of David Every, Ph. D.
Exhibit ADE-2:Curriculum vitae of Greg Mazer
Exhibit ADE-3:Curriculum vitae of Jeff Walker
Exhibit ADE-4:SE2 Plant Site Wetland Mitigation
Exhibit ADE-5:Wetlands Compensatory Mitigatin Site Plan Revised 8/31/01

Prefiled Direct Testimony Witness: Margaret Curtis

Prefiled Testimony Witness: Hsueh-Ju Chang
Exhibit HC-1: Resume of Hsueh-Ju Sherrie Chang

Prefiled Direct Testimony Witness: Douglas Sovern
Exhibit DS-1: Resume of Douglas T. Sovern

Prefiled Direct Testimony Witness: Burt Clothier

Prefiled Testimony Witness: Mark Molinari
Exhibit MM-1: Resume of Mark P. Molinari, R.G., C.E.G.
Exhibit MM-2: List of References
Exhibit MM-3: Geologic Map of a Portion of the Kendall 7.5-Minute Quadrangle Showing Inferred Trace of Vedder Mountain Fault Concealed Beneath Sumas Stade Glacial Deposits
Exhibit MM-4: Surface Traces of Vedder Mountain and Sumas Faults and Location of Geologic Cross Sections on Exhibits MM-6 and MM-7
Exhibit MM-5: Thickness of Unconsolidated Deposits/Depth to Bedrock
Exhibit MM-6: East-West Cross Sections Showing the Subsurface Projection of the Vedder Mountain and Sumas Faults
Exhibit MM-7: North-South Cross Sections Showing the Subsurface Projection of the Vedder Mountain and Sumas Faults
Exhibit MM-8: Preliminary Observations of Ground Deformation Nisqually Earthquake

Prefiled Testimony Witness: Allan Porush 
Exhibit AP-1: Curriculum vitae of Allan R. Porush
Exhibit AP-2: Liquifiable Soil Layer Figure (ASCE-1987)

Prefiled Direct Testimony Witness: Frank Brittain, Ph.D.
Exhibit FB-1: Resume of Frank H. Brittain

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Counsel for the Environment

Prefiled Testimony Witness:  Ronald Eachus
Exhibit RE-1:  Resume of Ronald Eachus
Exhibit RE-2:  Puget Sound Energy asks for extension of Personal Energy Management.
Exhibit RE-3:  Puget Sound Energy Schedule 93
Exhibit RE-4:  California Energy Outlook: Draft Report, 09/07/01
Exhibit RE-5:  Oregon Office of Energy - Power Plants in Oregon
Exhibit RE-6:  EFSEC Summary of Proposed or Licensed Facilities
Exhibit RE-7:  Dec. 14, 2000, Order Pursuant to Section 202 of the Federal Power Act.

Prefiled Testimony Witness:  Jim Lazar
Exhibit JL-6:  Office of Trade and Economic Development's May 2001 Report - Convergence: Natural Gas and Electricity in Washington
Exhibit JL-7:  Reuters - Graphs 9/19/01
Exhibit JL-8:  Database of Proposed Generation within the Western Systems Coordinating Council, Updated 6/19/01
Exhibit JL-9:  California Power Authority - Summaries
Exhibit JL-10:  New Gas Fired Projects served by Westcoast Pipeline

Prefiled Testimony Witness: Richard Harris Gammon
Exhibit RHG-1:  Resume of Richard Gammon
Exhibit RHG-5:  Summary for Policymakers: A report of Working Group 1 of the Intergovernmental Panel on Climate Change
Exhibit RHG-6:  Climate Change Science - An Analysis of Some Key Issues
Exhibit RHG-7:  Climate Talk in Bonn: News and Information, July 24, 2001

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WA State Department of Ecology

Settlement Agreement Between Washington Department of Ecology and Sumas Energy 2 Regarding the Second Revised Application.
      - Declaration of Restrictive Covenants

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WA State Department of Fish and Wildlife

Settlement Agreement Between Washington Department of Fish & Wildlife and Sumas Energy 2 Regarding the Second Revised Application.
Figure 3.4-5 Wetlands Compensatory Mitigation Site Plan, Revised 9/20/01
Summary of Wetlands, Wetlands Impacts, and Compensatory Mitigation Planned for Sumas Energy 2 Generation Facility (9/20/01)

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WA State Department of Community, Trade and Economic Development

No prefiled testimony submitted.

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Bonneville Power Administration:

No prefiled testimony submitted.

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City of Sumas:

Prefiled Testimony Witness: David Davidson
Exhibit DD-1:  City of Sumas 1996 PERF Application
Exhibit DD-2:  Memo dated 6/12/01 regarding interviews for Sumas Flood Plain Project.
Exhibit DD-3:  City of Sumas Flood Plain Planning Project, Minutes of TAC Meeting 2/3/97

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Whatcom County

Prefiled Testimony Witness: Dr. David Engebretson, PhD
Exhibit DCE-1:  Resume of Dr. David Engebretson, PhD

Prefiled Testimony Witness: Dr. Don J. Easterbrook PhD
Exhibit DJE-1:  Resume of Dr. Don J. Easterbrook, PhD
Exhibit DJE-2:  Potential Seismic Hazards of the Sumas and Veder Mtn. Faults

Prefiled Testimony Witness: Paula J. Cooper

Prefiled Testimony Witness: Dr. Jane Q. Koening, PhD

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NW Energy Coalition/Washington Environmental Council

Prefiled Testimony Witness: Nancy Ellen Hirsh

Prefiled Testimony Witness:  Peter G. West
Exhibit PGW-1:  May 2001 Request from White House to National Academy of Sciences
Exhibit PGW-2:  Executive Summary of National Academy of Sciences Report
Exhibit PGW-3:  Center for Clean Air Policy's Highlights of State Initiatives on Global Climate Change
Exhibit PGW-4:  Testimony of the Climate Trust before the Energy Facility Siting Council Rulemaking Hearing, 8/27/01
Exhibit PGW-5:  Oregon Office of Energy Testimony on the Proposed Rulemaking for the Monetary Offset Rate of the Carbon Dioxide Standard, 8/27/01

Prefiled Testimony Witness:  KC Golden
Exhibit KCG-1:  City of Seattle's Resolution #30256
Exhibit KCG-2:  City of Seattle's Resolution #30359

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City of Abbotsford / Abbotsford Chamber of Commerce

Statement from the City of Abbotsford

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Province of British Columbia

Prefiled Testimony Witness: David V. Bates
Exhibit DVB-1:  Resume of David V. Bates

Prefiled Testimony Witness: Jerry G. Lilly
Exhibit JGL-1:  Resume of Jerry G. Lilly

Prefiled Testimony Witness: David V. Bates
Exhibit DVB-1:  Resume of David V. Bates

Prefiled Testimony Witness: Michael F. LePage
Exhibit MFL-1:  Resume of Michael F. LePage

Prefiled Testimony Witness: R. Allan Dakin
Exhibit RAD-1:  Resume of R. Allan Dakin
Exhibit RAD-2:  Well field Radius of Influence Map (Figure 1)
Exhibit RAD-3:  Profile Through the Abbotsford-Sumas Aquifer

Prefiled Testimony Witness: Robert B. Caton
Exhibit RBC-1:  Resume of Robert B. Caton

Prefiled Testimony Witness: Yaroslav Shumuk
Exhibit YS-1:  Resume of Yaroslav Shumuk

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Constance Hoag

No prefiled testimony submitted.

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Sumas Energy 2 Rebuttal Testimony

Prefiled Rebuttal Testimony Witness: Charles Martin

Prefiled Rebuttal Testimony Witness: James Litchfield

Prefiled Rebuttal Testimony Witness: David Montgomery
Exhibit DM-R1:  $/MWH vs. MW Capability (graph)
Exhibit DM-R2:  NWPP Control Area Hourly Load History
Exhibit DM-R3:  California - Peter West cites establishment of a registry in CA to record early action efforts to reduce CO2 emissions.

Prefiled Rebuttal Testimony Witness: Richard Keefe

Prefiled Rebuttal Testimony Witness: Eric Hansen
Exhibit EH-R1:  SE2 Estimated Startup and Shutdown Emissions
Exhibit EH-R2:  Summary of total emissions during startup and shutdown
Exhibit EH-R3:  Letter to Allen Fiksdal, 10/4/00: Draft PSD Permit for Sumas Energy 2 Generation Facility

Prefiled Rebuttal Testimony Witness: Sanya Petrovic

Prefiled Rebuttal Testimony Witness: Dr. Frank Brittain, PhD

Prefiled Rebuttal Testimony Witness: Douglas Sovern

Prefiled Rebuttal Testimony Witness: Hsueh-Ju Chang

Prefiled Rebuttal Testimony Witness: Burt Clothier

Prefiled Rebuttal Testimony Witness: Allan Porush

Prefiled Rebuttal Testimony Witness: Mark Molinari
Exhibit MM-R1:  List of References
Exhibit MM-R2:  Stratigraphic Cross Section from Burrard Inlet in Vancouver to Bellingham, Washington
Exhibit MM-R3:  Earthquakes Shallower than 30 km 1980 - September 1983

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