Witness Palermo's new direct testimony on "impact factors" reveals that VEPCO has abused the discovery process egregiously by withholding requested information and data that it now uses in the Palermo testimony. Because of this abuse, if the Hearing Examiner elects not to strike the offending testimony, but instead allows Respondents to submit further rebuttal, then Respondents ask that the Hearing Examiner sanction VEPCO by denying it any opportunity to file further responsive testimony on this issue. VEPCO has already abused the process once; it should not be permitted to do so a second time.
Search SCC under case number PUE-2007-00031, then click documents and open the PDF dated 2.19.2008 "Respondents' Motion to Strike"
Jeffrey Palermo filed testimony as a witness for Dominion Power under the publicized KEMA report, which Dominion touts on their website, as proof for the need for the 500kv line, while discounting all other alternatives to meet capacity demand.
This 11th hour submission, producing a result that even Witness Palermo's (SCC) examiner concedes to be "somewhat surprising" (page 12, line 4), is not addressed in any of Respondents direct testimony because "impact factors" had never before been advanced as the justification for the line. Nor had "impact factors" ever been advanced before as a reason for rejecting alternatives to the proposed transmission line. Allowing testimony on "impact factors" to be sneaked into VEPCO's rebuttal would deny Respondents fundamental due process rights in this proceeding to know and answer the arguments that VEPCO is currently advancing.
The Meadow Brook to Loudoun 500kv line is intended to supply electricity to Northern Virginia, from the intermittently used 40 year-old coal-fired power station at Mount Storm, WV. Once the transmission line is constructed in 2011, Mount Storm's 1,581 MW generation capacity will operate full-time. By 2012 a second 500kv power line proposed by Maryland's PEPCO, will export the same amount of electricity from Northern Virginia, across the Potomac River the Chesapeake and Delaware Bays to southern New Jersey.
While Kaine's March 5th deferment expiration date looms closer, will Senate Democrats yield to the Republican-led House to appoint the next SCC commissioner? Will the appointee be someone who will challenge Dominion on matters such as the one raised yesterday at the SCC? Or will the new appointee shrug of this alledged "abuse of the process" as lawyer hogwash, just like Dominion would want us to believe?
Dominion may have bought off Governor Kaine and many state assemblymen and women; but Dominion has not bought off any of us. Let your voice be heard - contact your state legislative representatives NOW.