Revised Rebuttal Testimony of the Staff of the Illinois Commerce Commission
Exert from Exhibit 4.0R - Yassir Rashid (Redline)
Q. Why is it important that RICL have a solid experience managing and supervising the construction and operation of transmission lines?
A. The Commission needs to know that RICL has the demonstrated ability to construct, maintain, and operate a reliable, high voltage, direct current, electric transmission line, and that the Company can satisfy Section 8-159 406(b)(2) of the Act. RICL should demonstrate that it has experience performing similar tasks. Even if RICL has never performed tasks of similar Docket No. 12-0560 ICC Staff Exhibit 4.0R 8 magnitude, its experience performing similar tasks of lesser magnitude would provide some assurance that RICL has a reasonable chance to succeed. RICL has not demonstrated that it has all the experienced employees it needs for this project, but even if it had made that demonstration, it would also need to demonstrate that it has the organization to make use of those employees to succeed in this project. It has not made that second showing. According to the record evidence, RICL has never built a transmission line project of any kind or of any size. The proposed project is of a large scale and uses high voltage direct current technology that is not new, but is rather rare. In the entire United States, there are only a few high voltage direct current lines. I do not feel comfortable testifying that a startup company like RICL, which has many vacancies in its management structure will effectively and efficiently manage and supervise the construction of a $2.0 billion project