Mercer International, Inc. v. Canada (ICSID Case No. ARB(AF)/12/3), Respondent's CounterMemorial Witness Statement of J. Scouras (August 22, 2014)
I, Jim Scouras, declare:
A. BACKGROUND INFORMATION
1. I was born on ____________. I presently reside at ______________.
2. I am currently a Regional Relationship Manager within BC Hydro’s Aboriginal Relations department. I was appointed to this position in May 2013. From 2001 to 2013, I was involved in numerous positions related to power procurement at BC Hydro. In particular, I was involved in the 2002 Customer-Based Generation call for power, the 2008 Bioenergy Call for Power Phase I (“Bioenergy Phase I”), BC Hydro’s Integrated Power Offer, and several bilateral agreements for power. My involvement in these procurement activities culminated with my role as the Manager of Commercial Acquisitions in BC Hydro’s Energy Planning and Economic Development group from 2011 to May 2013. I attach my curriculum vitae to this witness statement as Appendix A.
3. As a result of my work in connection with power procurement at BC Hydro, I was involved in implementing BC Hydro’s policies with respect to its power acquisition activities. I also have a broad understanding of the provincial policy and regulatory framework applicable to electric utilities in British Columbia (“B.C.”) and the steps taken by BC Hydro to ensure compliance with this framework.
4. In Section B of this witness statement, I will describe BC Hydro’s general approach to power acquisition, including an explanation of the objectives of BC Hydro’s power acquisition activities and the reasons reason why BC Hydro procures electricity from industrial customers with self-generation capability.
5. In Section C, I will describe various government policies and corresponding procurement initiatives launched by BC Hydro in relation to self-generators in the Province. In particular, I will first discuss British Columbia’s 2002 Energy Plan and BC Hydro’s 2002 Customer-Based Generation Call for power, which was the first time that BC Hydro implemented the concept of the generator baseline (“GBL”) in a formal call. Second, I will explain the Province’s 2007 Energy Plan and BC Hydro’s corresponding 2008 Bioenergy Phase I call for power. Third, I will discuss briefly the federal government’s Pulp and Paper Green Transformation Program (“PPGTP”) and BC Hydro’s Integrated Power Offer (“IPO”). Finally, I will explain certain policies surrounding BC Hydro’s procurement of power through bilateral agreements.