DECISION - IN THE MATTER OF BRITISH COLUMBIA TRANSMISSION CORPORATION - British ...

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DECISION - IN THE MATTER OF BRITISH COLUMBIA TRANSMISSION CORPORATION - British ...
IN THE MATTER OF

BRITISH COLUMBIA TRANSMISSION CORPORATION

   CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
FOR THE VANCOUVER CITY CENTRAL TRANSMISSION PROJECT

                   DECISION

                      June 2, 2010

                          Before:

           A.A. Rhodes, Panel Chair/Commissioner
                 L.A. O’Hara, Commissioner
                 A.J. Pullman, Commissioner
DECISION - IN THE MATTER OF BRITISH COLUMBIA TRANSMISSION CORPORATION - British ...
TABLE OF CONTENTS
                                                                 Page No.

INTRODUCTION                                                        1
1.0   BACKGROUND AND REGULATORY PROCESS                             1
      1.1   The Applicant                                           1
      1.2   Orders Sought                                           2
      1.3   Project Overview                                        2
      1.4   Regulatory Process and Jurisdiction                     3
2.0   NEED AND PROJECT JUSTIFICATION                                5
      2.1   Background                                              5
      2.2   Potential Solutions                                    11
3.0   PROJECT DESCRIPTION, COSTS AND RISKS                         16
      3.1   Description of the Project                             16
            3.1.1 Route                                            18
                   3.1.1.1 Circuit 2L44                            18
                   3.1.1.2 Circuit 2L20                            19
                   3.1.1.3 Construction                            19
            3.1.2 Open Trench Construction                         19
                   3.1.2.1 Tunnel                                  21
                   3.1.2.2 Project Costs                           22
      3.2   Project Timetable                                      23
      3.3   Other Permits and Approvals                            23
      3.4   Project Risks/Mitigation                               23
4.0   ENVIRONMENTAL, HEALTH AND RATE IMPACTS                       26
      4.1   Environmental Impacts                                  26
            4.1.1 Environmental Overview Assessment Process        26
      4.2   Electric and Magnetic Fields                           27
            4.2.1 Current EMF Exposure Guidelines                  27
            4.2.2 Expected EMF Levels from the VCCT Project        28
            4.2.3 Mitigation Measures                              29
            4.2.4 The Potential Impact of EMF on Human Health      32
      4.3   Ground Potential Rise and Neutral to Earth Voltage     36
      4.5   Rate Impact                                            39
DECISION - IN THE MATTER OF BRITISH COLUMBIA TRANSMISSION CORPORATION - British ...
TABLE OF CONTENTS
                                                   Page No.

5.0    FIRST NATIONS AND PUBLIC CONSULTATION         39
       5.1     First Nations Consultation            39
       5.2     Public Consultation                   42
6.0    PROJECT REPORTING                             42
7.0    COMMISSION DETERMINATION                      43

COMMISSION ORDER C‐3‐10

LIST OF APPENDICES

APPENDIX A     List of Acronyms
APPENDIX B     List of Appearances
APPENDIX C     Utilities Commission Act Extracts
APPENDIX D     List of Exhibits
INTRODUCTION

This is an application by the British Columbia Transmission Corporation for a Certificate of Public
Convenience and Necessity for its Vancouver City Central Transmission Project. It also seeks a
further Certificate of Public Convenience and Necessity on behalf of the British Columbia Hydro and
Power Authority to construct the substation distribution assets which form part of the project.

British Columbia Transmission Corporation proposes the Vancouver City Central Transmission
Project as a means of addressing:

      i) what it expects to be a future substation capacity shortfall in the Mount Pleasant/South
         False Creek area of Vancouver,

      ii) the need to replace certain distribution duct banks in the area that are approaching end of
          life condition, and

      iii) the fact that circuit 2L53 which connects Mainwaring (at Waverly Street and Inverness
           Avenue) and Murrin (at Georgia Street and Main Street) substations is to be zero‐rated for
           planning purposes as of November, 2011.

1.0      BACKGROUND AND REGULATORY PROCESS

         1.1     The Applicant

The British Columbia Transmission Corporation (BCTC) is a Crown corporation which was formed in
2003 to operate and manage the transmission assets owned by another Crown corporation, the
British Columbia Hydro and Power Authority (BC Hydro). BCTC is also responsible for planning,
constructing, and obtaining necessary regulatory approval for investments in the transmission
system. BC Hydro, as owner of the transmission assets, is responsible for making the necessary
capital expenditures. (Exhibit B‐1, p. 12)
2

       1.2     Orders Sought

BCTC is seeking an order approving a Certificate of Public Convenience and Necessity (CPCN) for its
Vancouver City Central Transmission (VCCT) Project (the Project) as well as an order approving a
CPCN for construction of the substation distribution assets which form part of the Project, on
behalf of BC Hydro (the Application).

       1.3     Project Overview

The VCCT Project involves the construction of an indoor substation and two new underground 230
kV transmission circuits to serve anticipated increased load in the Mount Pleasant/South False
Creek area. The Mount Pleasant/South False Creek area is the area bounded by False Creek and
Terminal Avenue to the north, King Edward (25th) Avenue to the south, Clark Drive to the east and
Oak Street to the west. (Exhibit B‐1, p. 20)

The proposed new Mount Pleasant substation is a three storey building (two storeys above and one
storey below ground level) to be constructed on land, most of which has already been acquired by
BC Hydro, at the corner of Alberta Street and West 6th Avenue. The new substation will house both
transmission and system distribution assets. BCTC contemplates a staged approach to
development of the substation capacity, which will allow additional equipment to be installed over
time as the electrical loads served by the substation increase.

The two new transmission circuits will be installed underground and connect the new Mount
Pleasant substation with the existing Sperling substation, which is located at approximately 25th
Avenue and Arbutus Street, (new circuit 2L44) and with the existing Cathedral Square substation,
which is located at Richards Street and Dunsmuir Street in (new circuit 2L20).
3

       1.4     Regulatory Process and Jurisdiction

BCTC initially applied for a CPCN for the Vancouver City Central Transmission Project on
September 21, 2009. It amended its application on October 21, 2009 to also seek a CPCN for the
substation distribution assets, which form an integral part of the Project, on behalf of BC Hydro.

The matter was heard by way of a Written Hearing process, which was completed on April 15, 2010
with the filing of BCTC’s Reply.

Five parties registered as Interveners: The British Columbia Old Age Pensioners’ Organization et al.
(BCOAPO), BC Hydro, Protest New Powerlines (PNP) represented by Dr. Anne McMurtry, the
Commercial Energy Consumers Association of BC (CEC) and the Joint Industry Electricity Steering
Committee (JIESC). As noted above, the Application is brought on behalf of BC Hydro as well as
BCTC such that BC Hydro is effectively an applicant as opposed to an Intervener.

The only Intervener to file evidence was PNP. BCTC filed rebuttal evidence in response.

Two rounds of Information Requests (IRs) were conducted as between Commission Staff and BCTC
and/or BC Hydro. One round of IRs was conducted as between Interveners and BCTC and/or BC
Hydro. One round of IRs was also conducted as between Commission Staff and PNP, however, due
to unforeseen circumstances involving the health of Dr. McMurtry, the requirement for a response
to the Commission IR was withdrawn.

Two letters of comment were also received.

Jurisdiction

The Application is brought pursuant to sections 45 and 46 of the Utilities Commission Act (the Act).
These sections are set out in full in Appendix C. Subsection 46 (3.1) of the Act requires the
Commission to consider the “government’s energy objectives” in making a decision on whether to
4

issue a CPCN. The “government’s energy objectives” is a defined term. The government’s energy
objectives are:

     “ (a) to encourage public utilities to reduce greenhouse gas emissions;

       (b) to encourage public utilities to take demand side measures;

       (c) to encourage public utilities to produce, generate and acquire electricity from
           clean or renewable sources;

       (d) to encourage public utilities to develop adequate transmission infrastructure
           and capacity in the time required to serve persons who receive or may receive
           service from the public utility;

       (e) to encourage public utilities to use innovative energy technologies

                  (i)    that facilitate electricity self‐sufficiency or the fulfillment of their
                         long‐term transmission requirements, or

                  (ii)   that support energy conservation or efficiency or the use of clean or
                         renewable sources of energy;

       (f) to encourage public utilities to take prescribed actions in support of any other
           goals prescribed by regulation.”

BCTC states that the Project is consistent with government energy objective (d): “to encourage
public utilities to develop adequate energy transmission infrastructure and capacity in the time
required to serve persons who receive or may receive service from the public utility” as it would
provide the infrastructure and capacity necessary to supply the current load more securely and to
meet anticipated load growth in the South False Creek and Mount Pleasant areas of Vancouver.
Specifically, BCTC submits that “[s]erving the forecast load growth through the VCCT Project, rather
than serving the load growth through new distribution feeders from existing substations, is
consistent with the Provincial government’s energy objectives.” (Exhibit B‐1, p. 5)

BCTC also submits that the Project is consistent with the government energy objective “to use
innovative energy technologies that support energy conservation or efficiency” and that the
construction of a new substation at Mount Pleasant would result in the use of longer high voltage
5

transmission cables and shorter distribution feeder lengths, resulting in lower line losses.
(Exhibit B‐1, pp. 5‐6)

Commission Panel Discussion

The Commission Panel agrees that the Project, as applied for, is consistent with the government’s
energy objective in respect of the development of adequate energy transmission infrastructure and
capacity in the time required to serve persons who receive or may receive services from the public
utility. BCTC forecasts a significant growth in load in the area to be served and the Project has the
added benefit of improving system reliability.

The Commission Panel does not agree that the lower line losses, which will result from the increase
in high voltage cables as compared with distribution feeder lengths, while certainly a positive
result, is relevant to the energy objective concerning the use of “innovative energy
technologies…that support efficiency.” In the Panel’s view, the technology described is not
“innovative”.

Commission Determination

The Commission Panel accepts that the Project, as applied for, is consistent with the
government’s energy objectives.

2.0    NEED AND PROJECT JUSTIFICATION

       2.1      Background

BCTC files the Vancouver City Central Transmission Project Planning Report as Appendix F and the
Metro Vancouver Strategic Supply Plan as Appendix E to the Application, and states that these
studies demonstrate that new facilities are needed to:
6

   •   provide new capacity required to meet load growth in the Mount Pleasant/South False
       Creek area and vicinity as early as 2013;

   •   provide approximately 70 MVA out of the 110 MVA of distribution load in the Mount
       Pleasant/South False Creek area which is at risk because of the deteriorating condition of,
       and seismic risk to, duct banks originating at Murrin substation; and

   •   resolve the breach of the N‐1 planning criterion that would arise upon the zero‐rating of
       transmission circuit 2L53 as of November 2011.

   (Exhibit B‐1, p. 1)

Metro Vancouver Strategic Supply Plan

BCTC identified two major options available to upgrade the Metro Vancouver system to resolve the
forecast south Metro Vancouver system constraints and comply with the N‐1 planning criterion.
These options are east‐west system development and north‐south system development.

Under the east‐west system development option, the north‐south tie presently provided by 2L53
would not be replaced. As a result, the Metro Vancouver 230 kV transmission system would be
sectionalized into two separate sub‐systems, a north Metro sub‐system, and a south Metro sub‐
system.

Under the north‐south system development option, the north‐south tie function presently
provided by circuit 2L53 would be replaced in response to the zero‐rating of circuit 2L53. This
option would result in retaining interconnection between the north Metro sub‐system and the
south Metro sub‐system.

BCTC concluded that the north‐south system development option was the preferred means for
future Metro Vancouver transmission system development, as it would:

       i) improve overall system reliability, in particular during major events that could force out
          of service one of the major substations supplying the Metro area (i.e., Meridian or
7

              Ingledow) or the circuits supplied by one of these stations and

          ii) result in fewer facilities upgrades and have a lower implied system cost.

          (Exhibit B‐1, p. 31)

BCTC’s proposed method of establishing a north‐south tie circuit is a new circuit connecting
Cathedral Square and Sperling substations. BCTC prefers this method for three reasons:

      •   a termination at Cathedral Square substation would maximize the reliability benefits of the
          north‐south tie for north Metro area supply purposes in general and downtown supply
          purposes in particular because Cathedral Square substation will be connected to four
          circuits (instead of three circuits presently connected from the north Metro system);

      •   the reliability of supply to the stations in the south Metro Ingledow‐ Mainwaring‐Camosun‐
          Sperling‐ Kidd 2‐Ingledow 230 kV loop will be improved by terminating the tie at Sperling
          substation; and

      •   terminations at Cathedral Square and Sperling substations will improve 230 kV system
          circuit loading conditions in the Metro system under normal and all single contingency
          outage conditions which will defer system upgrades in the south Metro system between the
          Mainwaring and Camosun substations because more power flow would come from the
          Sperling substation to the Camosun substation.

      (Exhibit B‐1, pp. 31‐32)

The CEC agrees with BCTC in its preference for the North‐South options and the need for the tie
between the Cathedral Square and Sperling substations. (CEC Argument, p. 6)

Load Growth

BCTC estimates that the current total load for the Mount Pleasant/South False Creek area is
approximately 110 MVA, and that its growth rate will be faster than other areas of Vancouver, due
to:

      •   rezoning of portions of the area from commercial to residential;
8

   •   the development of the South False Creek waterfront area; and

   •   commercial development along the Canada Line.

BCTC forecasts the demand in the area to reach 152 MVA by F2019 and 200 MVA by F2039 with an
average load growth rate of 2.02 percent per year over the next 30 years. (Exhibit B‐1, pp. 21‐22)

BCTC states that the Mount Pleasant/South False Creek area is presently supplied from three
substations, Mainwaring, Murrin, and Sperling. However, based on the number and size of
transformers, the total number of feeder sections, and the feeder egress configuration, both
Murrin and Mainwaring substations are loaded to their maximum firm supply capability and will
start to suffer supply deficiencies in 2018. BCTC concludes that, in the combined service areas of all
three substations, new capacity will be needed to meet load growth in 2013.

BCTC’s load growth forecast was based on the 50th percentile forecast (P50) without incremental
Demand Side Management (DSM) and without taking into account the conservation impact of BC
Hydro’s future rate increases. BCTC’s rationale for this practice is that DSM is forecast at a system
level and is then, due to customer load diversity, allocated down to individual regions. BCTC
submits that, at a given point in time, DSM impacts have a higher likelihood of materializing at the
macro level than at a micro level. That is, having allocated DSM savings forecast at the system level
down to individual regions; it is uncertain whether savings forecast to occur in a particular region at
a specific point in time will actually materialize. Instead, savings in that region may be lower than
forecast and higher than forecast in another region. (BCTC Argument, para. 16)

BCOAPO submits that the appropriate treatment of DSM in load forecasts used for planning
purposes requires more consideration. As the Province’s reliance on DSM increases, load forecasts
should reflect this reality. This is an issue that should be addressed in either a Capital Plan review
or the Commission’s Section 5 Transmission Inquiry. (BCOAPO Argument, para. 12)
9

In Reply, BCTC notes that it did consider the potential impact of DSM on the identification of the
preferred supply alternative by conducting a sensitivity analysis of the present values of the two
lowest cost supply alternatives (Alternatives 2 and 3) using a P50 forecast with DSM. The analysis
demonstrated that because of the near‐term capital costs that will be required under either
alternative, with DSM there would be no material difference in the present value cost between
Alternative 2 and 3. This left construction of the Mount Pleasant substation in F2012 (Alternative
3) as the preferred alternative because of superior reliability. (BCTC Reply, para. 6)

The CEC recommends that the Commission direct BCTC to “examine how it can better integrate its
regional strategic supply planning with the DSM planning and execution to obtain the optimum
benefits from avoided supply investment.” The CEC also recommends that the Commission direct
BCTC to work proactively with BC Hydro to incorporate potential DSM savings into its planning
wherever possible rather than waiting for BC Hydro’s DSM information to become more certain.
(CEC Argument, p. 2)

Duct Banks Originating At Murrin substation

BCTC states that approximately 70 MVA out of the 110 MVA distribution load in the Mount
Pleasant/South False Creek area is presently served by distribution duct banks originating from
Murrin substation which have deteriorated due to:

   a) rebar corrosion and concrete spalling and pose a risk to the cables enclosed within them;

   b) swelling fibre ducts in which the cable distribution circuits are installed to the point that is it
      now difficult or impossible in some cases to pull the cables through the duct banks to
      facilitate repair or replacement; and

   c) several manholes experiencing severe structural degradation, putting the cables at risk of
      damage.
10

In addition, the duct banks traverse through seismically unstable soil and are approaching end‐of‐
life, causing BC Hydro to believe that they should be retired in the near future. (Exhibit B‐1, pp. 26‐
27)

The Zero‐Rating Of Transmission Circuit 2L53

Transmission Circuit 2L53 was installed in 1959, and has served as an integral part of the Metro
Vancouver transmission system, connecting downtown Vancouver and Vancouver south. Its
condition has been deteriorating over the past 10 years, such that it has received a “Very Poor”
asset health index score. BCTC cites the following:

      •   persistent fluid leaks averaging 3 to 4 leaks per year;

      •   two explosive stop joint failures due to electrical faults within the joints, which should not
          occur in a normal service life and indicate that the circuit is near the end of its useful life;

      •   a weakness in the design of its lead alloy sheath, making it more prone to cracking and
          leaking, which has occurred in some locations; and

      •   three sections of the underground self‐contained fluid filled (SCFF) cables on circuit 2L53
          are in “very poor” condition.

BCTC proposes to assign 2L53 a zero‐rating for system planning purposes, effective November
2011, based on a number of factors including asset health, performance compared to equipment in
the same category, and circuit criticality. This will mean that the transmission system in the south
Metro area will not meet the N‐1 planning criterion, and that if 2L53 is unavailable, several
different circuits in the south Metro Vancouver sub‐system would overload during outages on
major circuits supplying the south Metro Vancouver area. (Exhibit B‐1, pp.27‐28)
11

       2.2      Potential Solutions

Supply System

BCTC identified three potential solutions to meet the need for supply to the Mount Pleasant/South
False Creek area:

   1) reconstruction of the distribution system from Murrin substation;

   2) expansion of the distribution system from Sperling substation to provide 70 MVA supply
      and to meet load growth; and

   3) construction of a new substation in the Mount Pleasant/South False Creek area at its
      earliest in‐service date (F2012).

BCTC estimates that all three potential solutions will not only meet the forecast load growth, but
will also effectively secure supply of 70 MVA to the Mount Pleasant/South False Creek area that is
currently at risk because of the approaching end‐of‐life condition of the duct banks originating at
Murrin substation. Exhibit B‐1, pp. 33‐37)

BCTC performed an evaluation and comparison of the three potential solutions. The evaluation
ignores transmission because under all three alternatives, transmission circuits will be required to
address the zero‐rating of circuit 2L53 as of November 2011, by establishing a transmission link
between Sperling and Cathedral Square, and to provide supply to a new Mount Pleasant substation
before F2039.

Based on capital cost estimates which include a 20 percent contingency factor and have an
accuracy level of +100%/‐50%, distribution losses, operating and maintenance costs and taxes,
BCTC calculates the following present values for the three supply alternatives:
12

                             Table 1: Present Value of Supply Alternatives

                           Source: Exhibit B‐1, Table 4.2, p. 39

BCTC concludes that constructing a new substation in the Mount Pleasant/South False Creek area
in F2012, would mitigate seismic risk, result in the lowest distribution energy losses, and have the
lowest present value cost, and accordingly determines that it is the preferred supply alternative.
(Exhibit B‐1, pp. 37‐39)

BCTC addresses its failure to include DSM in its load forecast and states that although the
consideration of DSM deferred the need to build the new Mount Pleasant substation in Alternative
2 until 2047, there is still a need to construct distribution duct banks from Sperling in the relatively
near term. As result, the present value analysis indicated that there was not a material difference
in present value cost between the two alternatives.

BCOAPO submits that Alternative 3 has been demonstrated to be the preferred alternative from a
number of perspectives, and that “overall, BCTC’s choice as the preferred alternative is
reasonable.”

The CEC recommends that the Commission impose certain conditions on any CPCN and that the
Commission direct “that BCTC review and strengthen its alternative assessment and evaluation
methodology to provide a more rigorous treatment of the ‘terminal conditions’” for future project
13

alternatives. Notwithstanding, the CEC agrees with BCTC that Alternative 3 is the appropriate
option for the project at this time. (CEC Argument, pp. 3, 8)

BCTC submits that the CEC’s proposed condition is too vague and appears directed not to the VCCT
Project but toward future action, and urges that proposed conditions directed to future projects
ought not to be imposed by the Commission at this time. (BCTC Reply, para. 18)

Transmission System

BCTC states that it initially identified six options as a means by which to replace circuit 2L53 and to
connect the new Mount Pleasant substation to the existing 230 kV Metro Vancouver transmission
system.

The preferred route was identified after an initial assessment of six potential transmission routing
options followed by detailed analyses of two remaining alternatives based on the following criteria:

   •   supply need for the Mount Pleasant/South False Creek Area;

   •   capital costs;

   •   probabilistic reliability (quantified as expected energy not served(EENS));

   •   potential environmental impact;

   •   geotechnical considerations;

   •   public and First Nations input; and

   •   system planning.

After elimination of transmission routes that either i) assumed a new substation to be built later
than F2012, ii) had the highest estimated capital cost, or iii) had heightened risk of encountering
either public or First Nations concern, or archaeological resources, BCTC identified two potentially
viable route options:
14

   •   Revised Option A – consisting of a route around the original False Creek basin via Woodland
       Drive, necessary to avoid areas of unstable soil that would consist of 10.6 km of new
       underground 230 kV circuit construction from Murrin to Sperling passing by the future
       location of a new substation in the Mount Pleasant/South False Creek area. Circuit 2L31
       would be cut and tied to this transmission circuit in order to establish a connection with
       Cathedral Square substation; and

   •   Option B – consisting of a route through the downtown Vancouver area via David Lam Park
       on the north side of False Creek, through a 640 m tunnel beneath the bed of False Creek
       and Charleson Park on the south side of False Creek consisting of 8.1 km of new
       underground 230 kV circuit construction from Cathedral Square substation to Sperling
       substation and connecting to a new substation in the Mount Pleasant/South False Creek
       area.

   (Exhibit B‐1, pp. 42‐48)

Having eliminated the four options, BCTC evaluated the two remaining transmission route options,
Revised Option A and Option B, by:

   a) comparing their cost and reliability performance;

   b) consulting the public and First Nations on the two options; and

   c) conducting an Environmental Overview Assessment and Geotechnical Overview Assessment
      of the two options.

Having compared these two options, BCTC notes:

   a) Option B is the lower cost alternative, with a present value cost of $66.5 million compared
      to $72.9 million for Revised Option A. It also provides the opportunity for further cost
      reduction if construction of the False Creek tunnel by Horizontal Directional Drilling (HDD) is
      feasible;

   b) Option B is routed directly to Cathedral Square substation in a new corridor separate from
      that used by other circuits supplying the downtown area, thereby enhancing the security of
      supply to that area;

   c) Option B avoids the vicinity of Murrin substation, an area which is seismically unstable; and
15

   d) its probabilistic reliability analysis demonstrates that, over a 30‐year planning period ending
      in 2039, Option B results in lower EENS than Revised Option A which suggests that the
      reliability of Option B is superior to that of Revised Option A.

BCTC then observes that capital cost, potential environmental impact, public input and First
Nations input are not determinative of a preferred option. From a geotechnical perspective,
Option B may be preferable if HDD technology can be used for crossing beneath the bed of False
Creek. BCTC concludes that, from an overall reliability perspective of the transmission system in
Metro Vancouver and to ensure consistency with the long term strategic vision for the system,
Option B is preferred over Revised Option A.

As a result, BCTC selected Route Option B as the preferred transmission route for the Project.
(Exhibit B‐1, pp. 48‐54)

BCOAPO agrees with BCTC that Option B is preferable for the increased reliability, lower capital
cost and increased seismic safety. (BCOAPO Argument, para. 25)

Commission Determination

The Commission Panel accepts BCTC’s forecast of load growth in the Mount Pleasant/South False
Creek area, and accepts BCTC’s submission that there would be no material difference in the
present value cost between Alternative 2 and 3.

However, the Commission Panel shares the concerns of BCOAPO and of the CEC with respect to
BCTC’s practice of not analyzing DSM by region. Given the government’s energy objectives which
promote the use of DSM, and the 2007 BC Energy Plan which “sets an ambitious conservation
target, to acquire 50 per cent of BC Hydro’s incremental resource needs through conservation by
2020” the Panel directs BCTC to address this practice more fully in its next filed Capital Plan.
16

The Commission Panel accepts BCTC’s assessment of the other two drivers: namely the duct
banks originating at Murrin substation, and the decision to zero‐rate transmission circuit 2L53.

The Commission Panel accepts BCTC’s analysis of both the supply options and the transmission
options and determines that BCTC’s preferred options, namely construction of a new Mount
Pleasant substation and transmission Option B, are the most cost‐effective.

3.0    PROJECT DESCRIPTION, COSTS AND RISKS

       3.1     Description of the Project

As noted earlier, the Project entails the construction of a new three storey building at the corner of
West 6th Avenue and Alberta Street to house the proposed Mount Pleasant substation together
with two new underground 230 kV transmission circuits connecting the new Mount Pleasant
substation with existing Sperling and Cathedral Square substations.

New circuit 2L44 connecting Sperling substation and the new Mount Pleasant substation consists of
4.8 kilometres of 230 kV underground transmission circuits, duct banks and associated manhole
covers. New circuit 2L20 connecting Cathedral Square substation and the new Mount Pleasant
substation consists of 3.4 kilometres of 230 kV underground transmission circuits, duct banks and
associated manhole covers. Transmission terminations and associated 230 kV Gas Insulated
Switchgear (GIS) will be installed in each of the existing substations.

The new substation will house transmission terminations and associated 230 kV GIS as well as
“facilities in common between the transmission facilities and [system distribution asset] facilities
within the substation.” The equipment to be installed as part of this Project will provide
distribution feeder capacity of 134 MVA. BCTC proposes to follow a “staged approach,” allowing
room for possible future expansion of the transmission facilities and system distribution assets in
the substation to meet increased load, to a capacity of 400 MVA.
17

The equipment included in this Application (which will provide for 134 MVA of distribution feeder
capacity) is made up of:

       2x230/12kV, 168 MVA step‐down transformers (LV winding reconnectable to 25 kV)
       4x230 kV GIS positions (2 transformers, 2 transmission cables)
       2x12kV, 67 MVA GIS feeder sections

The substation transmission facilities, which include the building itself, consist of:

   a) a below‐grade tunnel through which the 230 kV transmission cables would enter the
      building;

   b) a ground floor hall to house the 230 kV GIS at which the 230 kV transmission cables would
      terminate. The 230 kV GIS would include four positions: one each for termination of the
      230 kV circuits, and one each for two transformers, which are considered to be system
      distribution assets (with room to add three additional positions in the future which would
      accommodate termination of two additional 230 kV circuits and one additional
      transformer);

   c) a lay down area, battery room and station service room, also on the ground floor; and

   d) a second floor mechanical room and control room.

BCTC states that it is necessary to use gas insulated switchgear as opposed to air insulated
switchgear in an indoor situation with its associated space constraints.

The system distribution equipment which would also be housed in the substation includes low
voltage switchgear and current‐limiting feeder reactors on the main and basement levels as well as
230 kV step‐down transformers housed within enclosed transformer bays on the ground level. The
second floor includes a room for future installation of capacitor banks.
18

              3.1.1 Route

The proposed routing for the new circuits 2L44 and 2L20 is shown in the map below.

                                  FIGURE 1 – VCCT PROPOSED ROUTE

    Source: Figure 5‐1, Exhibit B‐1, p. 59

                      3.1.1.1   Circuit 2L44

Circuit 2L44 will connect Sperling substation with the new Mount Pleasant substation. From
Sperling substation the route travels north on Maple Crescent, across King Edward, continuing in a
northeast direction to Cypress Street where it continues north to 13th Avenue. The route proceeds
19

east on West 13th Avenue to Ash Street where it heads north for one block. It then heads east
along 12th Avenue to Alberta Street, where it proceeds north to 6th Avenue and Alberta Street the
location of the new Mount Pleasant substation. There are duct banks already in place at the
intersection of 12th Avenue and Cambie Street which can be used. (Exhibit B‐1, pp. 59‐60)

                      3.1.1.2    Circuit 2L20

From the new Mount Pleasant substation Circuit 2L20 will travel in a westerly direction for one
block at which point it turns south for one block and then heads west on West 7th Avenue until
Laurel Street, where it will enter a tunnel and proceed in a northerly direction beneath False Creek
to David Lam Park. It will re‐emerge from the tunnel at the north edge of David Lam Park, cross
Pacific Avenue, and then proceed in a northwesterly direction along Drake Street to Richards
Street, where it will travel northeast to its terminus at the existing Cathedral Square substation at
Dunsmuir Street. (Exhibit B‐1, p. 60)

                      3.1.1.3    Construction

The duct bank system which will house the underground transmission cables will be constructed
using “open trench” methodology, where possible. The remaining roughly 10 percent portion of
the route which runs beneath False Creek will involve the construction of a tunnel.

               3.1.2 Open Trench Construction

BCTC describes open trench construction as involving:

   a) Cutting and removing the asphalt on the road surface;

   b) Removing the underlying earth to a depth which would allow the duct bank to sit in
      seismically secure soils or bedrock, with a minimum depth of one meter between the
      highest point of the duct bank system and the ground surface, and an average depth of 2 ‐
      2.5 meters below grade;
20

   c) Installing the PVC duct system;

   d) Filling the trench, compacting the fill and covering the trench with an asphalt cap.

   (Exhibit B‐1, pp. 63‐64)

The duct bank system to be installed in the trench involves:

   a) PVC pipe (duct) to accommodate the circuit cables

   b) PVC pipe (duct) located in the centre of the system to accommodate monitoring and
      telemetry systems

   c) High‐impact PVC spacers to hold the ducts in place during concrete placement to ensure
      adequate cable spacing is maintained

   d) Concrete to support and protect the ducts

   e) Thermal backfill to dissipate the heat generated by the transmission cables into the
      surrounding ground

   f) Warning tape above the backfill to flag the buried high voltage cable

   g) Specified backfill materials to minimize settlement

   (Exhibit B‐1, p. 62)

BCTC notes that installation times may vary depending on the subsurface conditions encountered
and that typical installation times range from ten to forty‐five days per city block. The time per city
block is longer where a manhole needs to be constructed. BCTC anticipates that between 12 to 18
manholes will be required. The exact number will not be known prior to the detailed design phase.
BCTC will use the pre‐cast method of construction (as opposed to cast in place) wherever possible
as the pre‐cast method is much less time‐consuming (7‐10 days per manhole vs. six to eight weeks
for cast in place) and involves a smaller footprint. (Exhibit B‐1, pp. 64‐67)
21

                       3.1.2.1   Tunnel

The portion of Circuit 2L20 which travels beneath False Creek (approximately 850 meters) will
require the construction of a tunnel. BCTC describes two methods of tunnel construction which
could be appropriate for the geological conditions: Horizontal Directional Drilling (HDD) and
tunneling using a Tunnel Boring Machine (TBM). (Exhibit B‐1, p. 69; Appendix D – Golder
Geotechnical Overview Assessment Report, p. 18)

HDD involves the use of a steerable, fluid‐jet assisted, mechanical cutting tool to bore a small pilot
hole from the ground surface, generally along a curved arc. Reamers are then pulled through the
pilot hole to enlarge it to a diameter sufficient to pull the conduit bundle through. The hole is
stabilized by circulating a large volume of viscous fluid such as bentonite slurry, which also removes
the drill cuttings. The tunnel would be about 15 to 30 meters below the bed of False Creek.
Installation time would be in the order of four to five months. This method is generally cheaper
than tunnelling where conditions are favourable. (Exhibit B‐1, pp. 69‐71; Appendix D – Golder
Geotechnical Overview Assessment Report, p. 14)

The TBM method requires the excavation of vertical entry and exit shafts, the walls of which are
supported by temporary shoring. Large work areas are required at shaft locations. The tunnel
would be about 12‐18 meters beneath the bed of False Creek. Construction time is estimated to
take a minimum of eight months. (Exhibit B‐1, pp. 69‐71; Appendix D – Golder Geotechnical
Overview Assessment Report, p. 12)

BCTC notes that the use of HDD, if feasible, would result in a lower cost for the False Creek crossing
and is investigating the subsurface conditions with a view to determining feasibility. The cost
estimates provided assume the more expensive Tunnel Boring Machine methodology. Therefore, if
HDD can actually be used, the project cost will be lower. (Exhibit B‐1, p. 71) Without the additional
information provided by an exploratory HDD program, Golder opines that the chance of successful
completion of an 813 mm diameter HDD bore is about 60 percent, as compared to the chance of
successful completion of a 3 m diameter tunnel using an Earth Pressure Balanced (EPB) Tunnel
22

Boring Machine of 100 percent. Golder notes that if HDD can be used, cost savings in the order of
$8 to 16.5 million may be achieved. (Exhibit B‐1, Appendix D, p. 17)

                       3.1.2.2   Project Costs

Based on a ‐15%/+30% accuracy level, BCTC estimates the Project will cost a total of $200.9 million,
which includes $173.7 million for transmission assets and $27.2 million for system distribution
assets. (Exhibit B‐1, p. 73 Revised)

The following table shows a breakdown of the Project Costs:

                Table 2 Vancouver City Central Transmission Project Cost Schedule

                         Source: Table 5‐3, Exhibit B‐1, p. 74
23

       3.2     Project Timetable

The Project is expected to take approximately two and a quarter years and be in service in F2012.
(Exhibit B‐1, pp. 76‐77)

       3.3     Other Permits and Approvals

Most of the proposed routing for the new circuits is beneath municipal streets. BCTC advises that
municipal streets are considered by the City of Vancouver to be utility corridors; therefore, no
statutory Right of Way (ROW) is required.

New ROW will be required from the City for the portions of the route, (approximately 0.43 km)
running beneath David Lam and Charleston Parks. Right of Way will also need to be acquired from
a private owner for a 0.16 km portion which impacts a water lot south of David Lam Park and a
further new ROW from the Integrated Land Management Bureau for the 0.26 km portion of the
route which crosses False Creek and falls under provincial jurisdiction.

A railway crossing permit is required from CP Rail to cross under the Arbutus corridor to Maple
Crescent (at the location of the Sperling substation). (Exhibit B‐1, pp. 60‐61)

       3.4     Project Risks/Mitigation

BCTC performed a risk assessment to identify and prioritize risks. Risk priority was determined by
analyzing the risk likelihood and potential impact for each risk. The primary risks relate to estimate
accuracy and uncertainty of geotechnical conditions, which would impact construction costs and
timeline. (Exhibit B‐1, pp. 135‐136)

The cost estimate risk relates to conditions being different in fact than those assumed, and/or poor
estimation. BCTC/BC Hydro used their experience from recent contracts and projects where
24

applicable, or obtained multiple quotes. BCTC also retained a consultant for the construction
estimate for the new Mount Pleasant substation as building construction is not within the core
expertise of BCTC or BC Hydro Engineering.

BCTC proposes to procure all equipment, materials and construction services through fixed price or
fixed unit price contracts, in accordance with its standard practice. BCTC estimates that
approximately 81 percent of the direct costs of the Project either are or will be subject to fixed
price or fixed unit price contracts. (Exhibit B‐9, BCOAPO 1.2d) Other risks considered to be
uncontrollable such as commodity and currency fluctuations, market conditions, inflation etc. may
be transferred to others if such treatment can be done on a cost effective basis.

BCTC also proposes to engage in competitive sourcing of project components and to use “prudent
project management best practices” to monitor and control costs where possible. Prudent project
management best practices include: the development of contingencies for areas of uncertainty,
the clear documentation of cost estimate assumptions and the continual monitoring of the most
sensitive assumptions, with validation through external sources, if needed. (Exhibit B‐1, pp. 138‐
139)

Construction risks involve potential unforeseen changes to the scope of work which could impact
both the project cost and schedule. Two areas of concern relate to the geotechnical subsurface
conditions in the area of False Creek and the general staging and ultimate configuration of the new
substation.

As noted above, BCTC has based its cost and timing estimates for the False Creek crossing on a
conservative basis using the more expensive and time‐consuming TBM tunnel construction
methodology. Significant savings may be possible if HDD can be used. BCTC is also looking to
perform additional field work and a drill program to further assess the feasibility of using HDD. The
risk associated with delay was addressed in part through proceeding with test drill holes and
ordering long lead time equipment (subject to cancellation) in advance of the decision related to
this Application.
25

The risk associated with the scope of the new substation was mitigated by using assumptions which
involved the largest equipment size available and the use of a staged approach to allow room at
the new substation for future expansion to meet potential load growth. BCTC proposes to continue
to monitor risks and mitigation activities throughout the definition and implementation phases of
the Project. (Exhibit B‐1, pp. 139‐142)

The CEC supports the approval of a CPCN using the cost estimate provided by BCTC. The CEC does,
however, suggest that the Commission make any approval of the Project conditional on BCTC
“making every effort to capture cost reductions from the use of HDD” and that such cost savings be
used to reduce the cost estimate rather than to increase the contingency reserve. (CEC Argument,
p. 9) The CEC also recommends that the Commission make any approval of the Project conditional
on BCTC keeping the Commission informed on the potential for additional costs, such as First
Nations or contaminated soil treatment costs. The CEC agrees with BCTC’s approach to seeking
cost certainty through fixed price contracts and agrees with BCTC’s contingency estimate. (CEC
Argument, p. 10)

BCOAPO agrees that the high percentage of project costs which will be subject to fixed price or
fixed unit price contracts will serve to contain overall costs. However, BCOAPO also believes the
geotechnical uncertainty associated with the HDD drilling beneath False Creek is a potentially
significant risk and suggests that BCTC be required to “report any potential cost overruns to the
Commission as soon as they are projected, and that the Commission establish a cost control
mechanism.” (BCOAPO Argument, p. 6)

Commission Determination

The Commission Panel accepts BCTC’s description of the Project and its attendant risks and cost
estimates. The Commission Panel notes the comments of the CEC and BCOAPO with respect to
potential cost overruns but expects that these can be adequately managed within the context of
BCTC’s regular reporting requirements.
26

4.0      ENVIRONMENTAL, HEALTH AND RATE IMPACTS

         4.1     Environmental Impacts

BCTC states that although the VCCT Project did not trigger an environmental assessment under
section 5 of British Columbia’s Environmental Assessment Act or the Canadian Environmental
Assessment Act, it nevertheless commissioned Golder Associates Ltd. (Golder) to undertake the
Environmental Overview Assessment in compliance with the Commission’s CPCN Guidelines. By
way of a summary, the assessment indicates that “with the implementation of an environmental
management plan and best management practices, the VCCT Project is unlikely to result in
significant adverse environmental effects” (Exhibit B‐1, pp. 79‐80, Appendix C).

                 4.1.1 Environmental Overview Assessment Process

The objectives of the Environmental Overview Assessment were to:

      a) identify key environmental resource attributes at the substation site and within each of the
         230 kV transmission corridor options;

      b) provide recommendations for avoiding, minimizing or otherwise mitigating potential
         adverse project‐related effects associated with each; and

      c) recommend general environmental mitigation measures for design and implementation of
         the VCCT Project.

BCTC indicates that resources considered included existing city parks, aquatic habitats, rare plant
species and plant communities, wild life resources and habitats, socio‐economic conditions,
potential for encountering contaminated materials, and potential for encountering archaeological
resources. (Exhibit B‐1, pp. 80‐81)
27

       4.2     Electric and Magnetic Fields

Electric and magnetic fields surround any electrical device, including power lines. The term “EMF”
typically refers to electric and magnetic fields at extremely low frequencies such as those
associated with the use of electric power. Health concerns raised during the VCCT proceeding
focused on the magnetic fields associated with transmission cables and the proposed Mount
Pleasant substation. Therefore, in this Decision the term EMF will refer to magnetic fields with a
frequency of 60 Hz, measured in milligauss (mG), unless otherwise stated.

               4.2.1 Current EMF Exposure Guidelines

BCTC cites Commission Order C‐4‐06 and Decision dated July 7, 2006 in which the Commission,
while granting a CPCN to the Vancouver Island Transmission Reinforcement Project (VITR), set forth
the standard for its review of matters related to EMF (VITR Decision). The Commission concluded
that the EMF exposure guidelines developed by the International Commission on Non‐Ionizing
Radiation Protection (ICNIRP), and endorsed by the World Health Organization (WHO) and Health
Canada, are the appropriate guidelines for considering the safety of EMF levels. The Commission
also determined “in the absence of convincing new evidence that indicates that change is
warranted and/or imminent, the Commission Panel concludes that it should not impose lower EMF
exposure standards for VITR.” BCTC further submits that the Commission’s other decisions have
followed this approach. (BCTC Argument, para. 113)

The ICNIRP is an international non‐profit organization, which is made up of independent scientific
experts who are responsible for providing guidance and advice on non‐ionizing radiation protection
for people and the environment. In 1998, the ICNIRP developed voluntary exposure guidelines,
recommending a residential exposure limit of 833 mG and an occupational exposure limit of 4,200
mG.
28

              4.2.2 Expected EMF Levels from the VCCT Project

BCTC engaged BC Hydro Engineering to estimate the magnetic field levels that would be expected
from the VCCT Project and includes the BC Hydro Magnetic Field Level Assessment Report as a part
of the Application. (Exhibit B‐1, Appendix Q) The following table provides a summary of the peak
magnetic fields computed for various averages and peak currents anticipated to flow in the two
cable corridors, measured at one metre above ground level. These readings are based on the
measurements for the Sperling to Mount Pleasant and Mount Pleasant to 2L32 circuits.

 Table 3: Summary of the peak magnetic field computed for various average and peak currents
             (used in Figures 3‐6) anticipated to flow in the two cable corridors

           Source: Exhibit B‐1, Table 4, Appendix Q, p. 10

In addition, the Figure below, reproduced from the BC Hydro report contained in Appendix Q
illustrates the symmetrical magnetic field profiles across the ductbank in the Sperling to Mount
Pleasant Corridor and shows how within 2.5 meters off the ductbank the magnetic field levels are
reduced by almost 50 percent. The peak readings of this sample are included on the third line in
the above Table.
29

            FIGURE 2 – MAGNETIC FIELD PROFILES ACROSS THE DUCTBANK BETWEEN SPG AND MPT
                             AT PEAK CURRENTS IN 2012, 2022 AND 2032

              Source: Exhibit B‐1, p. 93; Exhibit B‐1, Appendix Q, Figure 5, p. 13

BCTC submits modelling demonstrates that EMF levels expected from the transmission cables for
the VCCT Project range up to 95 mG, significantly below the exposure guideline of 833 mG
established by the ICNIRP. BCTC also notes that the actual magnetic field levels from the VCCT
Project are expected to be lower than the levels shown in the Table above as a result of the
conservative approach taken to estimate magnetic field levels. (Exhibit B‐1, p. 92; BCTC Argument,
p. 30)

               4.2.3 Mitigation Measures

BCTC states that the duct bank system housing the cables would be a minimum 1 metre below
street level and, on average, 2 to 2.5 meters below grade. (Exhibit B‐1, p. 63) BCTC further states
that transmission cables will be shielded with aluminum or copper sheath, which will reduce the
electric field outside a transmission cable to zero. (Exhibit B‐3, BCUC 1.60.1) Additionally, BCTC
explains, transmission cable geometry has been selected to space the cables as close together as
possible within thermal limits in order to reduce electromagnetic field through cancellation effects.
(Exhibit B‐3, BCUC 1.60.10)
30

The Intervener, Protest New Powerlines, asks that the Commission compel BCTC to bury the power
lines at least an additional meter. (PNP Argument, p. 1) In Reply, BCTC submits that there is no
convincing new evidence that doing so and incurring the extra cost would result in any benefit to
human health. (BCTC Reply, para. 28)

As part of its public consultation program, BCTC introduced a new section on its website for the
purpose of providing up to date information on the VCCT Project. (Exhibit B‐1, pp. 101‐102) The
bar graph shows the typical magnet field levels that would occur, depending on distance (measured
in meters) from the centre line of the duct bank.

              Source: Exhibit B‐3, BCUC IR 1.60.11, Attachment 1 (following p. 212)

PNP also measured magnetic fields over a comparable installation during January 2010, obtaining
measurements consistent with those obtained by Powertech Labs, Inc. on behalf of BCTC.
(Exhibit C3‐16, p. 3)
31

Mr. Anderson, the witness retained by PNP suggests two alternative transmission cable
technologies that could reduce the level of EMF; namely, oil‐filled steel pipe‐type cable and “HVDC
[High Voltage Direct Current] Light.” (Exhibit C3‐8, pp. 5, 8; Exhibit C3‐15, pp. 2‐3)

BCTC takes the position that neither option is appropriate for the Project for a number of reasons.
With respect to pipe‐type cables, BCTC notes that high‐pressure fluid filled (HPFF) pipe‐type circuits
have relatively lower ampacity, which would necessitate the use of an additional cable in each
circuit, and result in the need for a corresponding additional set of GIS terminations. As well, HPFF
cables suffer higher heat losses and also require the use of pumping plants to maintain the high
fluid pressure within the pipe. Construction of pumping plants is not considered to be feasible
given the limited space available at the existing Cathedral Square substation and the proposed new
Mount Pleasant substation. Further, there is increased potential for the escape of electrical
insulating fluid in the event of a fault or equipment malfunction, increasing the environmental risk.
These factors all tend to increase capital and maintenance costs and reduce reliability while also
increasing the environmental risk. (Exhibit B‐10; BCTC Argument, para. 118)

With respect to HVDC Light technology, BCTC takes the position that direct current technologies
are neither cost effective nor practical for the VCCT Project. BCTC notes that “a direct current
solution would require large, expensive and complex AC‐DC converter stations at each end of the
circuits” – three in total for the VCCT Project, each housed in its own multi‐storey building. Neither
the existing Cathedral Square nor proposed Mount Pleasant substation has sufficient space to
accommodate the addition of a converter station. Further, HVDC Light is a relatively new and
largely unproven technology. (Exhibit B‐10; BCTC Argument, p. 31)

In summary, BCTC submits that it has adopted an approach of implementing no cost/low cost
mitigation measures, consistent with the recommendations of the WHO. (BCTC Argument, p. 31;
Exhibit B‐3, BCUC 60.12) Specifically, BCTC notes that, although no specific measures have been
undertaken to reduce EMF beyond applying BCTC’s standard design practices, the layout of
equipment in the substation reduces the magnitude of EMF at the substation property line.
(Exhibit B‐9, BCUC 2.8.1, 2.8.2)
32

               4.2.4 The Potential Impact of EMF on Human Health

In the VITR Decision, the Commission Panel directed BCTC to file a public report with the
Commission every two years, or sooner if there are major developments in the field, summarizing
the latest results of EMF risk assessments and any changes in the guidelines developed by the
World Health Organization, ICNIRP, Health Canada and others, where relevant.

BCTC filed its first report, “EMF and Health Review and Update of Scientific Research,” with the
Commission in November 2007 (Exponent 2007). That report evaluated the scientific research
published from the end of 2005 through August 2007. The second report (Exponent 2009), filed in
conjunction with the Application, is based on “a comprehensive literature search and includes
experimental and epidemiologic studies available from September 2007 through to January 2009.”
The Exponent 2009 report also summarizes the conclusions of the weight‐of‐evidence consensus
reviews by scientific organizations that have been completed since September 2007. (Exhibit B‐1,
Appendix R)

By way of summary, BCTC states the general conclusion of the Exponent 2009 report is that peer
reviewed studies published and scientific reviews conducted since the period covered by the first
report in 2007 provide no new evidence to change the conclusion of Exponent’s 2007 report that
exposure to EMF from power lines has no known adverse effects on human health, or on plants or
animals. (Exhibit B‐1, p. 95)

Intervener Evidence and BCTC Rebuttal Evidence

Protest New Powerlines is a group of local residents and other individuals who oppose the VCCT
Project in particular and new transmission lines in general. PNP submitted several lists of
signatures which began with the following statement:
33

       “We the undersigned do strongly object to the Vancouver City Central Transmission
       Project which intends to lay high voltage power lines in the south Granville and
       Kitsilano areas endangering our health and lowering our property values.”
       (Exhibit C3‐1‐1)

The PNP also filed a number of documents regarding the potential impact on human health.
(Exhibits C3‐3, C3‐5, C3‐8, C3‐10, C3‐12, C3‐14, C3‐16) Some of these documents indicate that
keeping public exposure levels to power line EMF under 2 mG is necessary to avoid adverse health
effects. (Exhibit C3‐8, p. 6; Exhibit C3‐14, p. 112).

BCTC retained Dr. Linda Erdreich of Exponent Inc. to review the documents filed by the PNP and to
respond to scientific documents that have not been addressed specifically in previous Exponent
reports. Dr. Erdreich found that the analysis in various reports “is seriously flawed and does not
provide a basis for rejecting the reviews of numerous scientific organizations that have carefully
considered the entire body of research on EMF and public health.” Dr. Erdreich noted that many of
the reports submitted by PNP lacked the appropriate “weight‐of‐evidence consensus review”
necessary to a balanced assessment. Dr. Erdreich further concluded that “the materials submitted
by the PNP have not provided evidence of adverse effects at levels of a few milligauss. Given the
consensus of national and international health and scientific agencies that EMF is not a public
health hazard, further lowering of the magnetic field levels of the VCCT Project is unlikely to
provide any public health benefit of increase safety.” (Exhibit B‐10, pp. 1, 8)

BCTC and Intervener Arguments

In its Argument, BCTC provides a further extensive review of the documents filed by PNP. (BCTC
Argument, paras. 121‐137) BCTC submits that in recent years, the Commission has issued eight
decisions, all of which have consistently rejected the claim that EMFs pose health hazards. BCTC
further submits that the evidence in the VCCT proceeding does not provide any convincing new
evidence regarding EMF related health hazards and that there is no basis upon which the
Commission can or should require the VCCT Project to be designed to ensure that EMF levels are
limited to a few milligauss. (BCTC Argument, paras. 138‐139)
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