SANGRA MOLLER LLP

Barristers & Solicitors1000 Cathedral Place925 We~t Geol'l"ria StreetVancouver, British ColumbiaCanada V6C 3L2

Telephone: (604) 662·8808Facsimile: (604) 669-8803www.sangramoller.com

April 27, 2010

VIA EMAIL & COURIER

BRITISH COLUMBIA UTILITIES COMMISSION6th Floor, 900 Howe StreetVancouver, B.C. V6Z 2N3

Attention: Erica M. Hamilton, Commission Secretary

Dear Madam:

Reply Attention of:

K.c. Moller

Our File No.:

5000117

Direct Line:

(604) 692-3020

Email:

kmolh.;r@sangramoller.com

Per:

Re: British Colnmbia Utilities Commission, 2009 FortisBC Rate Design Applieation - Projeet No.3698564 (the "Application") and Zellstoff Celgar Limited Partnership ("Zellstoff Celgar") ­Notice of Witness Panel

In cOlU1ection with the Application, during the oral public hearing Zellstoff Celgar intends to call the followingpersons as members of its witness panel:

I. Brian Merwin - Mr. Merwin, 36, is Vice President Strategic Initiatives for Mercer InternationalInc. ("Mercer"), Zellstoff Celgar's parent company. Mercer is the largest NBSK, market pulpproducer in the world. Mr. Merwin has been with Mercer since 2005 and has extensive industryknowledge. Prior to joining Mercer, Mr. Merwin co-founded UCANU Manufacturing Corp.,which specialized in the technological development, advancement and production oflarge capitalequipment for industrial users in the oil and gas, mining and exploration and power generationsectors. Mr. Merwin holds a Bachelor of Commerce degree from the University of BritishColumbia and a Masters of Business Administration degree from the Richard Ivey School ofBusiness (University of Western Ontario);

2. Robert Hobbs - consultant for Zellstoff Celgar; and

3. Joe Linxwiler - Linxwiler Consulting Services Inc.

Please find enclosed the curriculum vitae of Robert Hobbs and Joe Linxwiler.

Yours truly,

SANGRA MOLLER LLP

/~--2K.C. Moller

KCM/fltEnclosure

cc. ZellstoffCelgar Limited Pmtnership

C13-12

Education

Robert Hobbs#30] - 2298 McBain Avenue

Vancouver, B.C.V6L 3B]

rhhobbs@shaw.ca

Western Executive Program (WEP), 1998M.B.A., University of Western Ontario, ]987LL.B., University of Manitoba, 1982B.Sc.(Mathematics), Brandon University, 1979

EmploymentBritish Columbia Utilities Commission, 2003 - 2008

Commissioner, March 2003Chair and CEO, August 2003- August 2008

Aquila Canada, 1989-2001, last position held:Vice President, Regulatory and Legislative Services

RESUME

OF

JOEN.LINXWILERJR.

LINXWILER CONSULTING SERVICES, INC.

Mr. Linxwiler is a utility business consultant and analyst with over 25 years ofexperience in electric utilityfinance, planning, rates, and economics. He formed Linxwiler Consulting Services, Inc., in March 2003,after nine years as a principal and officer ofthe firm ofFred Saffer & Associates, Inc., which he co-foundedin January, 1994.

Prior his tenure with Fred Saffer & Associates, Inc., Mr Linxwilerwas employed by the firm ofR. W. Beckand Associates for some 17 years. He joined R. W. Beck and Associates in June, 1976, as a Senior Engineerin the Rate Department of the firm's Orlando, Florida, Regional Office, and subsequently held a number ofpositions with this finn. From 1982-1986, he served on the staffofthe firm's Managing Partner and servedas Manager ofComputer Services in firm's Seattle, Washington, general office. In 1986, he returned to R.W. Beck's Orlando office to direct wholesale rate activities in the Southeast region. For the last three yearsof his employment there, he held the positions of Senior Client Services Director and manager of theLitigation Support and Regulatory Affairs Practice Group of that firm's Orlando, Florida, regional office.

The principal focus of Mr. Linxwiler's consulting practice has been in the areas of rates, contracts, inter­utility bulk-power arrangements, and strategic planning. He has participated in and directly supervisednumerous retail and wholesale cost-of-service studies, electric rate design studies, long-range power supplystudies, load forecasts, transmission system studies, financial feasibility stUdies, management systems studies,load management and energy conservation studies, and general business planning projects. His work inconnection with electric rates and cost-of-service studies has included work on behalfofboth purchasers andsellers of electric power. He also has served as a principal negotiator of power supply contracts betweenelectric utilities and between utilities and large industrial customers.

Mr. Linxwiler attended Southern Methodist University in Dallas, Texas, and Georgia Institute ofTechnologyin Atlanta, Georgia. He graduated from Georgia Tech in 1974, receiving a Bachelor ofElectrical Engineeringdegree with High Honors. He subsequently completed thirty-two hours of graduate stndy in mathematics,electrical engineering, operations research, and mathematical systems theory at Georgia Tech. During that time,Mr. Linxwiler also held gmduate research and teaching assistantships and participated in several researchprojects in and for the School ofElectrical Engineering at Georgia Tech. He also was employed as an instructorin electronics at DeVry Institute ofTechnology in Atlanta, an accredited vocational junior college.

AREAS OF EXPERTISE

Cost of Service and Rate Design

Mr. Linxwiler has extensive experience in preparing cost ofservice and rate design studies. He has supervisedand otherwise participated in the development ofcomplete cost ofservice studies, cost ofservice reviews, andrate design studies. These studies have included the development of test-year projections, the selection anddevelopment ofallocation factors, analyzing operating and fmaneial information, the complete design of rateschedules, including terms and conditions of service. This work has included engagements for both small andlarge utilities and their customers. Mr. Linxwiler's engagements also have spanned work involving both retailand wholesale rates. These engagements also have involved traditional embedded-costratemaking applicationsand marginal-cost ratemaking and rate-design applications.

Resume ofJoe N. Linxwiler, Jr.

Power Snpply Development

Pagel

. A significant amount ofMr. Linxwiler's professional experience has been in connection with existing and newregional power coordination arrangements between utilities. He has both participated in and led negotiationsand studies leading to the acquisition by seveml municipal joint action agencies of major ownership interestsin a number of nuclear and fossil-fueled genemting stations. His principal ar.eas of responsibility in thesematters have been (i) the terms and conditions for interconnected operations and wholesale power exchanges,(ii) the mtes for such exchanges and for wholesale "pllltial requirements" power, (iii) transmission wheelingarrangements, and (Iv) the development of computer-based models for analyzing all of these types ofarrangements. Much ofhis experience has involved detenninations of the cost and the value ofelectric powerand energy provided by utilities to their customers and one another. Mr. Linxwiler also has participated in thedevelopment offinancing arrangements to fund major new power supply projects. These types ofengagementsrequire a broad application of utility economics, operations, and ratemaking theory.

Litigation Support/Expert Testimony

Mr. Linxwiler has served as an expert witness in numerous regulatory and judicial proceedings. Briefdescriptions of the subjects of his testimony in these proceedings are provided in Exhibit A attached hereto.In addition, he has assisted in the preparation of testimony and exhibits of other witnesses in a number ofproceedings. He also has participated in negotiations leading to settlements in nwnerous other proceedings.Virtually all ofthe proceedings in which he has participated, as a witness or otherwise, have involved questionsrelating to the cost and value ofelectric service.

He also has appeared as a expert witness in several proceedings in arbitration involving contractual disputesbetween electric utilities. These proceedings have involved issues pertaining to cost-of-service matters, rates,power sales agreements, and interchange transactions. In addition, he has served as an arbitrator in one sucharbitration proceeding.

Furtber particulars concerning Mr. Linxwiler's educational and professional experience are provided in theaforementioned Attachment A.

Attachment AProfessional Experience of

Joe N. Linxwiler, Jr.

March 2003 to Present Linxwiler Consnlting Services, Inc.Orlando, Florida

Joe N. Linxwiler, Jr., is a prominent utility economics and regulatory consultant and owner of LinxwiJerConsulting Services, Inc. Through Linxwiler Consulting Services, Inc., Mr. Linxwiler provides consultingassistance and expertise to a broad range ofpublicly owned ntility systems and other clients in the areas ofratesand regulatory economics, power supply development, contract negotiations, and litigation support.

January 1994 to March 2003 Fred Saffer & Associates, Inc.Orlando, Florida

Prior to founding Linxwiler Consulting Services, Iuc., Mr. Linxwiler was a senior utility specialist andExecutive Consultant employed by the firm ofFred Saffer & Associates, Inc. Mr. Linxwiler was a co-foundingprincipal and Vice President of that firm, where he was responsIble for directing consulting engagement,involving retail and wholesale rates, intcrutility contrdcts, regulatory matters, litigation support services, andrelated matters for the firm's clients throughout the United States.

1976-1993 R. W. Beck and AssociatesOrlando, Florida

Seattle, Washington

Prior to joining Fred Safler & Associates, Mr. Linxwiler was employed hy the firm of R. W. Beck andAssociates for some 17 years. His experience with that firm included residencies in the firm's Orlando, Florida,and Seattle, Washington, offices. In 1976, he joined the finn's Orlando office where for several years he wasengaged in many aspects of the firm's electric utility consulting practice. L'l 1982, he moved to the firm'sGeneral Office in Seattle for three and a half years where he served on the staffofthe [mn's Managing Partnerand as the firm's Manager ofComputer Services. During this time, Mr. Linxwiler continued to be active inwork for the finn's clients. In 1986, Mr. Linxwiler returned to full-time consulting in the firm's OrlandoRegional Office. In 1988, he assumed the position of Manager ofLitigation Support and Regulatory Affairsin the Orlando office, in which capacity he was responsible for directing all regulated rate and litigation supportengagements for the firm's clients throughout the Southeastern United States.

1974-1976 Southern Engineering Company ofGeorgiaAtlanta, Georgia

Mr. Linxwiler served as a staffengineer and coordinator ofcomputer applications for the rate and power supplydepartments oflhis engineering firm. He participated in rate studies, power supply studies, and wholesale rateproceedings fnr rural cooperative electric system clients throughout the Southeastern United States.

Joe N. Linxwiler, Jr.Professional Experience

1974

Attachment APage 2

School ofElectrical EngineeringGeorgia Institute ofTechnology

Atlanta, Georgia

While in graduate school, Mr. Linxwiler held graduate teaching and research assistantships and concentratedin the areas of control systems, computer science, and the application of computer modeling to electricalellgineering problems. He also served as coordinator of computer use within thc School of ElectricalEngineering.

1974 DeVry Institute ofTec1mologyAtlanta, Georgia

Mr. Linxwiler was employed as a part-time instructor in electronics at this accredited junior college.

Highlights ofMr. Linxwiler's consultiug experience are provided below.

Alabama

In 1986 and 1987, Mr. Linxwiler directed the development of a participant billing system and budget­forecasting system for Alahama Municipal Electric Authority (AMEA), a municipal joint-action agency. Healso assisted this agency in designing and establishing its general financial accounting and reporting systems.He also continues to provide management cousulting services to this agency in a variety of suhject areas.

In 1991, Mr. Linxwiler provided expert testhnony in an Alahama state court proceeding regarding theconstitutionalityofstatc legislation establishing territorialboundaries for electric utilities in the Stateand relatedantitrust-related matters.

Periodically during 1994-1997, Mr. Linxwiler has assisted AMEA in investigating alternative rate designs.During 1997 and 1998, he servcd as AJ.\1EA's lead technical consultant in FERC proceedings involving thereasonableness ofthe open-access trausmission tariffofthe Southern Company and its operating suhsidiaries.He filed expert witness testimony on behalfofAMEA in Southern Company Services, Inc., FERC Docket Nos.ER98-1096-000, et 01.

During 2000 and 2001, Mr. Linxwiler assisted AMEA in its participation in several FERC proceedings,mediations, and stakeholder activities concerning the establishment of one or more regional transmissionorganizations (RTOs) in the Southeastern United States. He was heavily involved in the stakeholder processfor the proposed SeTmns RTO and, with AMENs legal counsel, in preparing protests and comments on behalfof AMEA regarding the organic documents proposed by the SeTnms sponsors. Mr. Linxwiler was alsoAMENs lead consultant in a major trausmission rate case involving tl,e Southern Company's open-accesstransmission tariff, Southern Company Services, Inc., FERC Docket No. ER02-85l-000, and was AMENs leadnegotiator in the negotiations resulting in a settlement of that proceeding.

In 2004, Mr. Linxwiler assisted AMEA in negotiating an agreement for the interconnection of AMENs newSylacauga Plant, a two-unit combustion turbine generating station. He continues to assist AMEA in severalmatrers pertaining to wholesale rates and transmission arrangements.

Joe N. Linxwiler, Jr.Professional Experience

Attachment APage 3

During 2001 and 2002, Mr. Linxwiler also supervised electric rate studies for a number ofAMEA's membermunicipalities. In 2004 and 2005, he undertook a comprehensive review ofAMEA's rates for wholesale salesto its Members.

In 2005, Mr. Linxwiler was engaged by the City of Opelika, Alabama, to undertake a complete review of itsretail electric rates:

California

In 1984 and 1985, Mr. Linxwiler participated in studies regarding the feasibility oHorming a new power poolamong various publicly owned utilities in Northern California. Tbese studies included analyses ofproductioncost savings and reliability issues. In 1985 and 1986, he participated in powersupply and wholesale rate mattersfor several municipal electric systems iu Southern Califorrtia. He also testified as an expert witness in SouthernCalifornia Edison Company, FERC Docket No. ER84-75-000. In 1987, he performed a review ofresource andstrategic planning methods for Los Angeles Department ofWater and Power.

Beginuing in early 1998, Mr. Linxwiler has been assisting the California Independent System Operator indetermining appropriate rates and charges for "must-run" generation necessary to support reliability of theCalifornia transmission grid. He filed expert witness testimony on behalf of the ISO in San Diego Gas &Electric Company, FERC Docket Nos. ER98-496-000 and ER98-2 I60-000. He participated in negotiationsleading to the settlements in these and anumber ofotherFERC proceedings relating to must-run generation fortransmission system support.

In late 2004 and early 2005, Mr. Linxwiler was retained by Tmckee Donner Public Utility District to assist itin a transmission rate proceeding, Sierra Pacific Power Resources Operating Companies, FERC Docket No.ER05-I4-Q00. Mr. Linxwiler analyzed the claimed transmission costs of Sierm Pacific Power Company,assisted the client's cOlUlSel in preparing a formal protest of the proposed transmission rate, and assisted innegotiations resulting in a settlement (with a rate significantly below the company's proposed rate).

From 1976 through 1982, Mr. Linxwiler participated in regulatory proceedings and negotiations concerningwholesale rates, interconnection agreements, wheeling llITdllgements, and othermatters for over 20 municipallyowned electric systems throughout Florida. He testified as an expert witness on behalfofwholesale customersin Florida Power & Light Company, FERC Docket No. ER77-175, and Florida Power & Light Company,FERC Docket No. ER78-19. He also led settlement negotiations in several other proceedings.

Mr. Linxwiler also has supervised load forecasting and load researcb projects for several ofthese clients. Twoofthese projects included comprehensive consumer surveys.

In 1982 through 1984, Mr. Linxwiler participated in power supply planning studies for the Florida MunicipalPower Agency, a joint-action agency comprised ofmost ofthe municipal electric systems in the state. He wasinvolved in analyses and negotiations leading to the settlement ofa large anti-trnst suit involving a number ofFlorida utilities.

During 1992-1996, Mr. Linxwiler directed consulting activities in several mqior Florida Power Corporation

Joe N. Linxwiler, Jr.Professional Experience

Attachment APage 4

wholesale rate proceedings on behalfofFlorida Municipal Power AgenL)' (FMPA) and was a lead negotiatorin negotiations that led to settlements in these proceedings. He has continued to serve as a consnltant and asan expert witness for FMPA in several wholesale rate proceedings involving Florida investor-owned utilities.These proceedings involve full- and partial.-requirements rates and tertns and conditions, interchangeagreements, and transmission wheeling services. He has filed expert affidavits and testimony in FloridaMunicipal Power Agency v. Fiorida Power & Light Company, FERC Docket No. TX94-3-oo0 (involving oneofthe TITst applications for transmission service pursuant to the Energy Policy Act of1992) and Florida Power& Light Company, FERC Docket Nos. ER93465-000, et al. In mid-1994, he testified before the FloridaPublicService Commission, in FPSC Docket No. 940345, regarding reserve planning and operating practices and theeffects ofnon-finn sales on such practices.

Since 1996, Mr. Linxwiler has been the lead technical consultant for FMPA in FERC proceedings involvingthe open-access transntission tariffs ofFloridaPowerCorporation, FloridaPower&Light Company, and TampaElecmc Company. He has also assisted FMPA is formula rate audits ofFlorida Power & Light Company andin a large, complex antitmst suit against Florida Power & Light (which was settled just prior to mal). He alsosubmitted expert witness testimony in Florida Power & Light Company, FERC Docket Nos. ER99-2770-000,et al. He subsequently assisted in negotiating settlements in PERC Docket Nos. ER93-465-000, et aI., andER99-2770-000, et at.

During 2000 and 2001, Mr. Linxwiler assisted FMPA in FERC proceedings involving the merger ofFloridaPower Corporation and Carolina Power & Light Company and in negotiating a settlement resolving FMPA'sconcerns over the anticompetitive effects of the merger. He also assisted FMPA in FERC proceedingsconcerning the proposed, but later withdrawn, merger ofFlorida Power & Light Company and Entergy. Heprovided expert affidavits on behalfofFMPA and Seminole Electric Cooperative, Inc., in FPL Group, Inc. andEntergy Corporation, FERC Docket No. ECOI-33-000.

Since late 1999, Mr. Linxwiler has been assisting FMPA in the fortnation of a regional transntissionorganization in Peninsular Florida pursuant for FERC Order No. 2000. In that regard, he has been an activeparticipant in stakeholder working gronps fortned for that purpose and has assisted FMPA's attorneys inpreparing protests, pleadings, other filings before the FERC. He submitted an affidavit regarding transmissionpricing in Florida Power & Light Company andTampa Electric Company, PERCDocket No. EROI -2205-000.In 2002, Mr. Linxwiler also assisted FMPA in project to assist several ofits transmission-owning members inpreparing to meet the likelyregnlatory requirements for obtaining compensation for their transmission facilitiesfrom the proposed Grid Florida RTO.

In 2003 and 2004, Mr. Llnxwiler assi~ted FMPA in analyzing and resolving pricing disputes under a majorwholesale power supply agreement. He also assists FMPA's staff in audits of costs under several joint­ownership agreements.

In 2004 and 2005, Mr. Linxwiler continued to assist FMPA in matters pertaining to transmission service fromFlorida Power & Light Company remaining at issue in Florida Power & Light Company, FERC Docket Nos.ER93-465-000, et al. He submitted several expert affidavits regarding FP&L's transmission facilities andFMPA's use of transmission service. In January 2006, Mr. Linxwiler submitted an expert affidavitaccompanying FMPA's reply comments in FERC's Notice ofInquiry regarding transmission service in DocketNo. RM05-26.

Joe N. Linxwiler, Jr,Professional Experience

Attachment APage 5

In 2008 and 2009, Mr. Linxwiler assisted FMPA in reviewing and protesting a major transmission rate changefiling by Florida Power Corporation (dba Progress Energy Florida) in which Florida Power Corpomtion wasseeking not only a significant rate increase but was also seeking to implement a formula rate for transmissionservice. Mr. Linxwiler assisted in negotiating changes to O,e proposed rate(s) and in reaching a settlement withFlorida Power Corporation and other parties. Mr. Linxwiler continues to assist FMPA in reviewing FloridaPower's annual fonnula rate updates.

Georgia

Since 1976, Mr. Linxwiler has participated in financing studies, strategic planning activities, power supplystudies, and wholesale rate and interconnection negotiations for the Municipal Electric Authority of Georgia,comprised of 47 municipal electric systems. He submitted expert witness testimony in Georgia PowerCompany, FPC Docket No. ER76-587, Georgia Power Company, FERC Docket No. ER78-166, GeorgiaPower Company, FERC Docket No. ER79-88, and participated in analyses and negotiations leading tosettlements in several other proceedings. In 1989, Mr. Linxwiler directed a study of a proposed new poolingand power coordination arrangement among Georgia Power Company, MEAG, and other utilities in Georgia.He also testified in Southern Company Services, Inc., FERC Docket No. ER89-48-000, regarding the SouthemCompany pool's Intercompany Interchange Contract. He has also supervised the development of severalcomputerized budgeting, financial planning, and management information systems for this agency. In recentyears, Mr. Linxwiler has assisted this agency in general strategic planning, in the development ofa new powercoordination and wholesale power arrangement, and in a variety ofother matters involving retail and wholesalerates and regnlation.

During 1996, Mr. Linxwiler served as an expert witness for the City of Calhoun, Georgia, in a stale courtproceeding involving disputes between Calhoun and the Municipal Electric Anthority ofGeorgia. During 1997and 1998, he was also engaged by the City ofLaGrange, Georgia, to assist it in a similarproceeding, which wassettled just prior to trial.

In 2008, Mr. Linxwiler assisted Altamaha Electric Membership Corporation in resolving a dispute with one ofits large industrial customers. Mr. Linxwiler testified as an expert witness in a proceeding before the GeorgiaPublic Service Commission in connection with this matter.

From 1979 through 1982, Mr. Linxwiler supervised a wide range of consulting services for Wabash ValleyPower Association (WVPA), an Indianapolis-based G&T cooperative comprised of 24 REMC distributionsystems. In addition to providing general consulting to WVPA's management, Mr. Linxwiler has supervisedthe development of management infonnation systems, provided general data processing consulting, andsupervised an extensive un-going load forecasting and load research project which included consumer surveys,and end-use and econometric forecasting. He served as project manager in the design and acquisition of acentral control system for load management and generation scheduling. In 1995, Mr. Linxwiler was engagedto develop new rates and pricing strategies for WVPA.

In 1999, Mr. Linxwiler was engaged by the Indiana Municipal Power Agency to assist in the resolntion ofdisputes nnder certain agreements between IMPA and PSI Energy. He provided expert witness testimony inan arbitration proceeding regard.ing appropriate cost allocation principles, and has continued to assist IMPA in

Joe N. Linxwiler, Jr,Professional Experience

Attachment APage 6

related matters, In 2000, Mr. Linxwiler testified as an expert witness on behalfofIMPA, WVPA, and certainother wholesale purchasers in a FERC rate proceeding involving PSI Energy; he also participated in settlementnegotiations leading to a settlement in this proceeding.

In 2007, Mr. Linxwiler assisted the Iowa Association of Municipal Utilities (IAl\fU) and others in reviewingand protesting the proposal by Interstate Power and Light Company ("IPL") to sell its transmission facilitiesto ITC Midwest LLC. Mr. Llnxwiler reviewed and analyzed tbe likely economic effect of the proposedtransaction on wholesale and retail customers oflPL, and he presented expert testimony on those matters beforethe Iowa Utilities Board and before the Minnesota Publie Service Commission. He also assisted in IAl\ilU'sreview the applications related filings before the FERC. He also assisted IAMU in negotiating a settlement ofthe various regulatory proeeedings related to the transaction,

Kentuekv

Since 2001, Mr. Llnxwiler has been providing technical assistance to legal counsel for municipal wholesalecustomers ofKentucky Utilities in a long-standing dispute over excessive fuel-adjustment clause charges, Apartial settlement has been achieved in tllat dispute, but some issues rentained in negotiations in early 2005.

Louisiana

In 1984 and 1985, Mr. Linxwiler assisted in studies and analyses for the City ofNew Orleans regarding thepossible acquisition by the City of the properties of New Orleans Public Service Company, Mr. Llnxwilerprovided special consulting regarding pool transactions between New Orleans Public Service Company andother subsidiaries of Middle South Utilities (now known as "Entergy").

Massachusetts

During I982 and I983, Mr. Linxwiler assisted in the preparation oftwo studies ofenergy conservation and loadmanagement programs for municipal electric systems in Massachusetts. In 1989, he testified as an expertwitness, on behalfof the Massachusetts Bay Transportation Authority, before the Massachusetts Departmentof Public Utilities regarding a retail rate increase requested by Boston Edison Company.

Missouri

During 2004, Mr. Linxwiler assisted Independence Power & Light, Independence, Missouri, in protesting andreaching a settlement involviug a proposed, significant increase in the rates for IPL's unit-power purchase fromthe Montrose Generating Station ofKansas City Power & Light Company. Mr. Linxwiler analyzed KCPL'sproffered cost support, identified a number offallacies and other issues, and assisted IPL in negotiating a veryfavorable settlement ofthe proceeding (Kansas City Power & Light Company, FERC Docket No. ER03-997­000).

Joe N. Linxwiler, Jr.Professional Experience

New Hampshire

Attachment APage 7

In 1991 and 1992, Mr. Linxwiler served as a member of a team of senior business and technical consultantsengaged to develop and implement a reorganization plan to resolve the bankruptcy ofNew Hampshire ElectricCooperative, Inc. Mr. Linxwiler, along with the cooperative's legal counsel, was responsible for negotiatingsettlemenls of several disputes between the cooperative and Public Service Company ofNew Hampshire andfor negotiating a new power supply program that served as the cornerstone for the cooperative's reorganizationplan, which was approved by the Bankruptcy Court in March 1992. Mr. Linxwiler was a lead negotiator inworking out a consensual reorganization plan for the cooperative with Public Service Company of NewHampshire, Northeast Utilities, New England Power Company, the State of New Hampshire, and the RuralElectrification Administration. He was also responsible for overseeing the studies necessary for demonstratingto the Court the financial feasibility of the reorganization plan.

New York

In 1986 and 1987, Mr. Linxwiler served as project manager for feasihility studies concenting public poweracquisition ofLong Island Lighting Company. The firm's clients in this work were the County ofSuffolk, NewYork, and the finn of Smith Bamey Harris Upham & Company. These studies were based on a proposedacquisition ofLILCO's common stock and involved a broad range offmancial rate making and accounting andlegislative and tax-related questions, as well as power supply and system reliability considerations.

North Carolina

Overseveral years, Mr. Linxwilerparticipated in wholesale rate proceedings and negotiations and power supplystudies for virtually all ofthe municipally owned electric systems in North Carolina. He testified as an expertwitness in Carolina Power & Light Company, FPC Docket No. ER76-495, Carolina Power & Light Company,FERC Docket No. ER77-485, and Virginia Electric and Power Company, FERC Docket No. ER78-522.

Mr. Linxwiler participated in negotiations and studies for two major joint action agencies, North CarolinaMunicipal Power Agency No. I and North Carolina Eastern Municipal Power Agency, resuIting in a billiondollar, joint-ownership arrangement with two major investor-owned utilities in the State. He played a key rolein the negotiation and development ofthe rate, interconnection, and interchange aspects ofthese arrangcments.

Mr. Linxwiler also purticipated in the development and implementation of management infonnation andreporting systems for these agencies. He also has supervised load forecasting, load research, and loadmanagen1ent projects for the North Carolina power agencies. Additionally, he snpervised the design andacquisition ofa large telemetry and control system for dynamic scheduling, electronically transferring loads ofa number ofcities from one control area to another.

In 1987 and 1988, Mr. Linxwiler served as an expert witness on hehalf of North Carolina Municipal PowerAgency No. I and Piedmont Municipal Power Agency in two arbitration proceedings with Duke PowerCompany. Also in 1988, Mr. Linxwiler submitted testimony before FERC on behalfofNorth Carolina EasternMunicipal Power Agency in North Carolina Eastern .Municipal Power Agency v. Carolina Power & LightCompany, FERC Docket No. EL88-27-000. In 1990, Mr. Linxwiler testified in an arbitration proceedinginvolving NC&\IlPA and CP&L.

Joe N. Linxwiler, Jr.Professional Experience

Attachment APage 8

From 1989 through 1993, Mr. Linxwiler also provided consulting services to these agencies in a variety ofmatters related to strategic planning, power supply economics, and wholesale rates.

In 2005, Mr. Linxwiler was retained by Green Mountain Energy Company to assist it in FERC proceedingsregarding "Seams Elimination Charge Assignments" ("SECA" charges) assessed to it by the MidwestIndependent System Operator in connection with the elimination oftransmission rate "pancaking" between theMISO and PJM. transmission systems.

South Carolina

For several years, Mr. Linxwiler supervised all wholesale and retail rate studies, negotiations, and relatedactivities for the South Carolina Public Service Authority, a state-established electric utility, generating anddistributing electric power at wholesale and retail throughout much ofSouth Carolina. In the early 1980's, hewas deeply involved on behalf of the Authority in negotiations leading to service to a major new industrialcustomer, a 300-MW aluminum reduction plant. He also was a lead negotiator in negotiations for a new powersupply arrangement between the Authority and a large G&T cooperative. He also designed a long-rangerevenue requirements and financial planning model for the Authority. In 1990, he assisted the Authority innegotiating a major extension and amendment to its contract with the aforementioned aluminum facility andserved as an expertwimess in litigation between the Authority and the U. S. Anny Corps ofEngineers regardingthe Authority's hydroelectric facilities. Mr. Linxwiler continnes to provide consulting services to this client onanumber ofareas, including general strategic planning, wholesale and retail rates, interutility coordination, andlitigation snpport.

In 1992, Mr. Linxwiler led a comprehensive strategic planning effort to review the goals and objectives of tlleAuthority's pricing and marketing efforts. In 1993, Mr. Linxwiler snpervised a comprehensive mte studywherein all the Authority's retail rates and rate schedules were restructured and updated, consistent with theresults of the planning effort the year before.

In 1994-1996, Mr, Linxwilerassisted the Authority in developing its open-access wholesale transmission tariffand in other matters relating to FERC Order Nos. 888 and 889. In 1999 and again in 2002, Mr. Linxwiler alsoassisted the Authority in negotiating of major new power supply arrangements for Saluda River ElectricCooperative, Inc., and Central Electric Power Cooperative, Ine. In recent years, Mr. Linxwiler has also assistedthe Authority in a number ofnegotiations related to wholesale power arrangements.

In 2002 and 2003, Mr. Linxwiler assisted the Anthority in suecessfully defending its retail rates in a class actionlawsuit brought by certain disgruntled customers. In 2005, Mr. Linxwiler assisted the Authority in developinga special economic "load retention rider" to provide certain incentive for large industrial customers in light ofrapidly rising fuel costs.

From 1979 through 1993, Mr. Linxwiler also participated in power supply, interconnection, and rate studies,litigation, and negotiations for Piedmont Municipal Power Agency.

In 2005, Mr. Linxwiler was retained my the City ofUnion, South Carolina, to assist it in matters involving theCity's wholesale power supply costs.

Joe N Linxwiler, Jr.Professional Experience

Attachment APage 9

In 2006, Mr. Linxwiler again assisted Santee Cooper in a matter involving Santee Cooper's hydroelectricfacilities. He preformed analyses relating to the effects offlow restrictions on the value ofcapacity and energyprovided by those facilities. He provided an expert affidavit regarding those result~ and in support of SanteeCooper's application to FERC for the relicensing of those facilities.

During 2008 and 2009, Mr. Linxwiler assisted Santee Cooper in a number of negotiations with wholesalecustomers and other suppliers and in a nwnber of matters related to Santee Cooper's retail rates, particularlyits rates for its large industrial customers. Mr. Llnxwiler continues to assist Santee Cooper in such matters.

In July 1992, Mr. Linxwiler served as the Senior Consultant on the consulting team engaged by the PublicService Board of the City of El Paso, Texas, to investigate (i) the feasibility of acquiring the properties ofEIPaso Electric Company, which is currently in Chapter II bankruptcy, and (ii) other measures or actions that theCity ofEl Paso could take to protect the interest ofits citizens iu matters involving El Paso Electric bankruptcy.

In 2005 and 2006, Mr. Linxwiler was engaged by Golden Spread Eleetric Cooperative to assist in two majorwholesale rate proceedings involving Southwestern Public Service Company on issues pertaining to costallocation.

Vennont

During 2000 and 2001, Mr. Linxwiler provided consulting services to a number of municipal electric utilitiesthatpurchase power from the Vennont Yankee Nuclear Power Corporation in FERC proceedings involving Ibeproposed sale of Ibe Vennont Yankee Nuclear Power Station to AmerGen.

Virginia

From 1976-1981, Mr. Linxwiler assisted in a nwnber ofwholesale rate proceedings and power supply coutractnegotiations for a number ofVirginia municipal electric systems. He testified as an expert witness in VirginiaElectric & Power Compmry, FERC Docket No. ER78-522-000.

During 1996-1997, he served as lead consultant for Virginia Municipal Electric Association No. I (VMEA) inFERC proceedings involving Ibe open-access transmission tariff of Virginia Electric & Power Company. Hecontinues to assist VMEA and its attorneys in wholesale rate and transmission matters. During 1999, Mr.Linxwiler also direct the design and development of a new computer software system for member billing forVMEA.

In 1984 and 1985, Mr. Linxwilcr assisted in the preparation ofpower supply plans for municipal wholesalecustomers of Utah Power & Light Company and was responsible for projections ofUP&L's power costs.

Joe N. Linxwiler, Jr.Professional Experience

British Columbia

Attachment APage 10

III 2007, Mr. LillXwiler assisted industrial customers of British Columbia Hydro and Power Authority ("BCHydro") in reviewing and responding to arate change application of BC Hydro. He testified as an expertwitness before the British Columbia Utilities Commission regarding the appropriate demand allocation factorsthat should he used in allocating BC Hydro's production and transmission costs.

The table beginning on the next page lists the proceedings in which Mr. Linxwiler has presented expert witnesstestimony and the subject matters of that testimony.

Joe N. Linxwiler, Jr,Professional Experience

Expert Witness Testimony byJoe N. Linxwiler, Jr.

Attachment APage 11

Proceedinll Subiect Matter

Carolina Power & Light Company Average Rate BaseFPC Docket No. ER76-495 Depreciation Expenses

Income TaxesAllocation FactorsDeferred Income Taxes

Georgia Power Company FunctionalizationsFPC Docket No, ER76~587 Allocation

Income Taxes

Florida Power & Light Company Transmission WheelingFERC Docket No. ER77-175 Transmission Losses

Levclized Fixed Charge RateFunctionalizationsAllocation Factors

Carolina Power & Light Company Depreciation ExpenseFERC Docket No. ER77-485 Interest Expense

Deferred Income TaxesInvestment Tax CreditPower Factor Adiustmenl$

Georgia Power Company Time Weighting Plant InvestmentFERC Docket No. ER78-166 Demand Allocation fiactors

Functionalization ofHydroelectric FacilitiesPreference Power AllocationCapacity and Energy LossesInterchange PowerTariffTerms and Conditions

Florida Power & Light Company FunctionalizationsFERC Docket No. ER78-19 Demand Allocations

LossesIncome TaxesRate DesignTerms and Conditions

Virginia Electric & Power Cnmpany TransrnissionLossesFERC Docket No. ER78-522 Hydroelectric Capacity

Functionaliz.ationsIncome Taxes

Georgia Power Company Rate DesignFERC Docket No. ER79~88 Tenns and Conditions

Partial Requirements ServiceIntercba01re Services Pricini!

Southern California Edison Company Fuel StocksFERC Docket No. ER84-75-000 Ener£\' Surety Reliability

North Carolina Eastern Municipal Power Agency v. Carolina Tenns and Conditions of InterconnectionPower & Light Company Bulk Power Market CompetitionFERC Docket No. EL88~27~OOO

Re: Boston h(ji~on Company Marginal CO~1: Pricing & RateMassachusetts Department ofPubIic Utilities Case No. 89-100 Demand Allocation Method

Joe N. Linxwiler, Jr.Professional Experience

Attachment APage 12

Proceedina: Subject Matter

Southern Sendee:>, inc, Pool CapacIty EqualizationFERC Docket No. BR8948-000 CaoacitY Cost AHocstions

Appeal ofSouth Carolina Public Service Authority, Power System OperationsContract No. DACW6o-77-C·Oa05 Power System EconomicsU. S. Army, Engineer Board ofContract Appeals Case No. ENG Value ofHydroclectric Facilities and Hydroelectric CapacityBCANo.5564

Dtxie Electric Cooperative, et aJ., v, The Citizens ofthe State of Territorial AssignmentsAlabama, et 01. Fair Value ofUtility PropertyState ofAJabaw.a, Circuit CQurt ofMontgomery County, Case Fair Compensation for CondemnationNo. CV-86-878-G General Utility Economic Matters

Florida Power & Light Company Tenus and Conditions for Interchange ServiceFERC Docket Nos. ER93..46S·000, f!'j af. Reserve Margin Criteria

Transmission Service PricingPricing ofPartial Requi.rements ServiceFuel Ad;ustment Clause

In Re: Generic investigation Into the Planning Practices and Reserve Margin and Reliability CriteriaOperating Reserves ofPeninsular Florida Generating Electric Provision of Interruptible ServiceUtilities Energy BrokerFlorida Public Service Commission Docket No. 940345-EO

City ofCalhoun v. Municipal Electric Authority afGeorgia, State Fair and Non·Discnmina1ory RatesofGeorgia, Superior Court of Gordon County, Civil Action File Interpretation of Contract TenusNo. 28934 DamaDc Estimate!>

San Diego Gas & Electric Company Cost-Based Rates for Must-Run Generation Service, FonnulaF"RC Docket Nos. ER98496-MO and ER98-2 160-000 Rates PixedlVariahle O&M Allocations

Southern company Services, inc. Cost-Based Rates for Ancillary Service.,: under Open Accessl F'PRC Docket Nos. ER98·l096-000 et a/. Transmission Tariff

Florida Power & Light Company FOlmula Rates, Generation Step-up Facilities, RatemakingFERC Docket Nos. ER99-2770-000. el al. Treatments ofAC("'fUals for future Liabilities, Various Cost

Accountimr Matters

PSI Energ;.~ Inc. Purchased Power Expenses. Off-System Sales Revenues. andFERC Docket No. BROO-188-000 Reserve Margins

Re: Review ofGridF10rida Regional Transmission Organization A variety ofmatters relating to transmission service and(RTO) Proposal, Florida Public Service Commission Docket No. transmission pricing.020233-E1

Golden Spread Electric Cooperative, Inc.. et ai. v. Southwestern Demand cost aUocation method for partial-requirementsPublic Service Company, PERC Docket Nos. EL05-l9-002 and whoJe~ale rate.BR05-168-001

Midwest independent Transmission System Operator, Inc., FERC Recovery of"Seams Elimination C'harge Assignments" related toDocket No. BR05-06-001 eta!. the elimination oftransmissioll rate "pancaking."

Southwestern Public Service Company. PERC Docket No. Demand cost allocation method for partial-requirements.ER06-274-000 wholesale rate,

In Re: Interstate Power andLight Company and In.? Midwest Various issues relating to the proposed sale oflPL's transmissionLLC, IowaUlilities Board Docket No. SPU-07·l1 sYStem to ITC Midwest.

In the Matter ofthe Joint Petition for Approval a/Transfer of Vario~ls issues relating to the proposed sale oflPL's transmissionTransmission Assets ofInterstate Power and Light Company and system to ITC Midwest.iTC Midwest LLC, Minnesota Public Utilities CommissionDocket No. B-0001IPA'()7-540

Joe N. Linxwiler, Jr.Professional Experience

Attachment APage 13

PrOCt,"edine: Subiect Matter

In the Matter o/BC Hydro ~~ 2007 Rate Design Application, The appropriate method ofdemand allocation for developingBritish Columbia Utilities Commission Proiect No. 3698455 cost-based retail rates.

SF New!'.print v. Alramaha Electric Membership Corporation, Appropriateness of marginal-cost-based rates for large retailGeorgia Public Service Commission Docket No. Docket No. industrial customer; !enns and conditions ofservice; whether rdtc22526-[] and tenns and conditions were discriminatorv,

In addition, Mr. Linxwiler has submitted expert-witness affidavits in anumberofother regulatory proceedings,and he has served as an expert witness in several arbitration proceedings involving contract disputes betweenutilities. He also has served as an arbitrator.