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PC Landing Corp

319 Diablo Road, Suite 213, Danville CA 94526 USA


Tel: +1 415 200 0300 Fax: +1 415 402 0772

August1,2012

ViaElectronicFiling,FERCOnline

Mr.VinceYearick
DivisionofHydropowerLicensing
OfficeofEnergyProjects
FederalEnergyRegulatoryCommission
888FirstStreet,NE
Washington,D.C.20426

Re: AdmiraltyInletPilotTidalProject,FERCProjectNo.12690005

DearMr.Yearick:

ThankyouforyourinterestinandattentiontoPCLandingCorp.ssubmissionsinthe
AdmiraltyInletPilotTidalProjectreferencedabove.Wewritetoprovideresponsestoyour
requestforadditionalinformationdatedJuly16,2012inadvanceoftheAugust6,2012meeting
ontheissueswehaveraised.

Attachedheretoaredetailedresponsestoyourquestionsontheareasofinquiry
directedtoPCLandingCorp.Inaddition,toassistinthetechnicalevaluationoftheseissues,we
areincludingsupportingandsupplementalinformationfromsubjectmatterexpertsworking
withPCLandingCorp.Thissupplementalmaterialalsoclarifiesvariousmattersraisedbythe
applicant,PublicUtilityDistrictNo.1ofSnohomishCounty,initsJune22,2012responsestoour
Protest,andaddressesanumberofissuesraisedinyourrequesttotheDistrictforadditional
information,datedJuly16,2016.

Thankyouagainforyourattentiontoourconcerns.Welookforwardtodiscussing
theseissuesfurtherattheAugust6meeting.

Verytrulyyours,

/s/KurtJohnson

KurtJohnson
ChiefFinancialOfficer

Attachments



UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION



Public Utility District No. 1
of Snohomish County, Washington
)
)
)
)
)


Project No. 12690-005




PC LANDING CORP. RESPONSE TO
ADDITIONAL INFORMATION REQUEST FOR AUGUST 6, 2012 MEETING




Craig S. Trueblood
Ash S. Miller
Kari Vander Stoep
K&L Gates LLP
925 Fourth Avenue, Suite 2900
Seattle, WA 98104-1158
Phone: (206) 623-7580
Fax: (206) 623-7022
Email: craig.trueblood@klgates.com
ash.miller@klgates.com
kari.vanderstoep@klgates.com
Martin L. Stern
William M. Keyser
K&L Gates LLP
1601 K Street, NW
Washington, D.C. 20006
Phone: (202) 778-9000
Fax: (202) 778-9100
Email: marty.stern@klgates.com
william.keyser@klgates.com





Attorneys for PC Landing Corp.



Dated: August 1, 2012
i
TABLE OF CONTENTS

Page

TABLE OF CONTENTS................................................................................................................. i
I. INTRODUCTION.............................................................................................................. 1
II. RESPONSE TO FERC INFORMATION REQUEST....................................................... 2
A. Determination of the Appropriate Separation Distance Under ICPC
Recommendations....................................................................................................2
1. ICPC 13 As Applied Here Counsels Separation of 750-1000 Meters.........3
2. ICPC 2, Relating to Parallel Cables in Deep Water, With Minimal
Vessel Traffic Is Not Applicable to the Project ...........................................6
3. The ROV Repair Operation Proposed by the PUD is Not Feasible in
Admiralty Inlet, and Does Not Support Limiting Separation To Twice
the Water Depth. ..........................................................................................7
B. PC-1 Physical Characteristics................................................................................12
C. Increased Separation is Required Because Subsurface Conditions at the
Proposed Site are Currently Unknown, and May Cause Significant Risk to
PC-1 .......................................................................................................................12
D. Increased Separation is Required Due to the Complications and Difficulties
of Operations in an Extreme Marine Environment................................................16
E. Increased Separation is Required Because Damage to PC-1 Would
Substantially Interfere with Communications on PC-1 .........................................25
F. To Allow for Increased Separation, Feasible Alternatives Exist, and Should
be Explored............................................................................................................27
III. CONCLUSION................................................................................................................. 30


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Appendices

Appendix A Statement of Thomas F. Brenneman

Appendix B Alcatel-Lucent Submarine Networks Letter dated July 16, 2012

Appendix C Evidence of Admiralty Inlet Marine Conditions and Adverse and
Unanticipated Impacts On Project Marine Operations As Reported In
Contractor Pre-Installation Study Reports

Appendix D Gordon Fader, P. Geo., Atlantic Marine Geological Consulting Ltd.,
Supplement to Admiralty Inlet Pilot Tidal Project Siting Assessment and
Observations from OpenHydro Bay of Fundy TISEC Deployment

Appendix E Report of Capt. Richard P. Fiske, USN (Ret.)

Appendix F Complaint and Consent Judgment, GCI v. US, 2:10-cv-00856-RAJ (W.D.
Wash.)

Appendix G Statement of Kurt E. Johnson

Appendix H Ship Accidents Sever Data Cables Off East Africa, Wall Street Journal
Online (February 28, 2012)

Appendix I Ship's anchor accidentally slices internet cable cutting off access in six
African countries, Mail Online (Mar. 1, 2012)

Appendix J AECOM, Supplement to Assessment of Tidal Energy Sites Near
Admiralty Head



UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION



Public Utility District No. 1
of Snohomish County, Washington
)
)
)
)
)


Project No. 12690-005

PC LANDING CORP. RESPONSE TO
ADDITIONAL INFORMATION REQUEST FOR AUGUST 6, 2012 MEETING

I. INTRODUCTION
On July 16, 2012, the Federal Energy Regulatory Commission (FERC or the
Commission) requested that PC Landing Corp. (PCLC) provide certain additional
information in connection with PCLCs Motion to Intervene and Protest, dated May 23, 2012
(the Intervention and Protest) with respect to the proposal by Public Utility District No. 1 of
Snohomish County, Washington (the PUD) to site two hydrokinetic turbines in Admiralty Inlet
(the Project), approximately 100 and 150 meters, respectively from the north segment of
PCLCs trans-Pacific fiber optic submarine telecommunications cable, PC-1. This Response
provides PCLCs reply to the inquiries in FERCs request to PCLC. In addition, in order to help
clarify technical issues raised by the proposed separation distance of the turbines from PC-1
North, we also provide certain supplemental information relevant to the appropriate separation
distance between PC-1 and the Project, as well as addressing a number of issues raised in the
Commissions request to the PUD for additional information, dated July 16, 2012. Finally,
PCLC clarifies certain misstatements and mischaracterizations made in the PUD Response, dated
June 22, 2012, relevant to the questions posed by the Commission.
1
PCLC hopes that the factual

1
See Response of Public Utility District No. 1 of Snohomish County, Washington, To Recommendations,
Terms and Conditions, Protest, and Comments (June 22, 2012) at 24 (PUD Response). This filing is
intended to respond to the Commissions additional information request. However, to the extent the

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material and analysis in this Response will aid the Commission in its evaluation of PCLCs
concerns prior to the August 6, 2012, technical meeting.
II. RESPONSE TO FERC INFORMATION REQUEST
A. Determination of the Appropriate Separation Distance Under ICPC
Recommendations
FERCs July 16, 2012 request to PCLC (FERC Request to PCLC) seeks additional
information from PCLC with respect to how PCLC calculated its proposed separation distance
pursuant to International Cable Protection Committee (ICPC) Recommendation Number 13
(ICPC 13), and why it is appropriate to have more than a 120 meter separation distance
pursuant to the PUDs interpretation of ICPC Recommendation Number 2 (ICPC 2):
P.C. Landing states that based on International Cable Protection Committee
(ICPC) recommendations, a separation of 750 to 1,000 meters between the turbine
and PC-1 is needed. However, it is unclear how the estimated separation distance
was calculated. In response to the FCCs and P.C. Landings comments, the
District states that ICPC Recommendation 13 is not applicable because the
recommendations were developed in the context of wind energy projects where
the maneuverability of repair ships could be compromised by pilings supporting
the wind turbines and the whirling blades. The District asserts that the submerged
tidal turbines pose zero risk to the cable ship which can freely navigate over it.
The District adds that ICPC Recommendation 2 is more applicable and that with
modern navigational equipment and repair practices, a separation of twice the
water depth (about 58 meters) is sufficient to allow for a safe repair. The District
also provides evidence of alternative methods of repair that would allow the
project and PC-1 to coexist. Please explain why a separation of more than 120
meters, given the current water depth, would be necessary.

Commission considers aspects of this filing to be beyond the questions raised in the request, PCLC
requests that the Commission accept this filing as responding to the PUD Response. The Commission has
granted leave to respond to answers in accordance with Rule 213 when the response submitted provides
additional information that will aid the Commission in issuing a reasoned decision. This response is
limited to correcting and clarifying misstatements and mischaracterizations and does not reargue issues
already raised by the PCLC in its Intervention and Protest. In prior proceedings, the Commission has
permitted otherwise impermissible answers that help ensure a complete and accurate record or aid in the
Commissions decision-making process. See, e.g., Duke Energy Oakland, LLC, 102 FERC 61,093, at P
10 (2003) (finding good cause to accept an otherwise impermissible answer because the answer assisted
the Commission in understanding and resolving the issues involved in the proceeding); Carolina Power
& Light Co., et al., 97 FERC 61,048, at p. 61,278 (2001) (finding good cause to waive Rule 213 when
the pleading helped to ensure a complete and accurate record).


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Each question is addressed in turn below.

1. ICPC 13 As Applied Here Counsels Separation of 750-1000 Meters
ICPC 13 provides useful and applicable insight into the question posed here of the
adequate separation distance between the Project and PC-1, an active submarine
telecommunications cable. In order to clarify the application of ICPC recommendations, PCLC
submits herewith a statement from Thomas F. Brenneman, an independent consultant with over
30 years of experience in offshore construction representing owners, purchasers, and the U.S.
government in numerous subsea projects, with particular expertise involving fiber optic
submarine cables, power cables, pipelines and wind farms.
2

As Mr. Brenneman explains, ICPC 13 is the most appropriate guideline that currently
exists to determine the appropriate distance between the Project and PC-1. Despite being written
for wind farm projects, ICPC 13 is in fact quite nuanced, and breaks down its recommendation
separation distance into several components, one of which is a 500-meter safety zone.
3
This
500-meter figure is intended to prevent above-water collisions between wind turbines and ships.
This is the only aspect of ICPC 13 that is operationally specific to the fact that the wind turbines
protrude above waterthe remainder of the recommendation is therefore entirely relevant.
Accordingly, notwithstanding the PUDs and its consultants assertions,
4
PCLC in fact omitted

2
Statement of Thomas F. Brenneman (July 12, 20120) (Brenneman Statement), attached hereto as
Appendix A. Mr. Brenneman has extensive experience onboard vessels overseeing cable lay and repair
projects, post-lay burial, pre-lay and burial assessment surveys, cable landing inspections, cable repairs,
dredging and ROV operations.
3
The PUD claims that ICPC has never recommended a 500 meter safety zone. PUD Response at 24.
This statement is apparently incorrectICPC Recommendation No. 13 expressly recommends a 500m
safety zone around wind turbines. ICPC Recommendation No. 13, PCLC Intervention and Protest,
Appendix A, Exhibit 1, at 6. That being said, as noted here and despite the PUDs and its experts
assertions to the contrary, PCLC does not propose that a 500 meter safety zone be imposed around the
tidal turbines.
4
PUD Response, Attachment B, Statement of Keith Ford-Ramsden, at 5 (Ford-Ramsden Statement).

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this 500-meter safety zone from its application of ICPC 13 set forth in the Intervention and
Protest.
As described by Mr. Brenneman:
The 500 meter safety zone in the [ICPC] recommendation [No. 13] is not relevant
to the separation between PC-1 and the turbines. But in referring to ICPC No. 13
as the best guidance for appropriate separation with the turbines, PCLC explicitly
did not use the 500 meter safety zone for wind turbines in Recommendation No.
13 (If it had used the 500 meter safety zone, the recommended separation would
have been closer to 1200 meters).
5


The remaining separation distances set forth in ICPC 13 are appropriate and applicable to
subsurface turbines. As Mr. Brenneman explains:
Other aspects of ICPC No. 13 are, however, completely relevant, including
allowance for run on (200m), grappling rig (300m at 60 meter water depth), and
ship length (here, approximately 140m for ASN or TE SubCom vessels which
would likely be doing the work under a teaming agreement with ASN).
6


Thus, ICPC 13 counsels a separation distance of approximately 640 meters as calculated
by Mr. Brenneman.
7
This number does not provide any safety zone around the turbine, but
Mr. Brenneman notes that some safety zone would nonetheless be appropriate given that ropes,
umbilicals, or other items that may trail a vessel have the potential to catch on the turbines or the
associated transmission cables:
An additional issue is that while vessel draft is not an issue given water depth and
the height of the turbines, cable vessels have ropes, umbilicals, etc. that trail
behind the vessel, which could easily snag the turbines or the transmission cables,
requiring the need for separation to allow for safe operation.
8


In addition, as Mr. Brenneman notes, in the event the repair to PC-1 were necessitated by a
vessel anchor snagging the PC-1 cable, it would not be uncommon for the vessel to drag the

5
Brenneman Statement at 16.
6
Id. at 17.
7
Id. at 15.
8
Id. at 17.

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snagged cable, in this case bringing the cable potentially even closer to the turbines, counseling
an additional cushion to account for that possibility over and above the 640 meters calculated
above.
9
Taking into account this need for a minimal safety zone less than the 500 meters for a
wind farm, PCLC in its Intervention and Protest therefore requested a 750-1000 meter separation
distance between PC-1 and the proposed Project turbines.
10

Thus, PCLC has put forth an appropriately tailored version of ICPC 13. PCLC notes that
the PUD argues ICPC 13 should be disregarded altogether because wind turbines protrude above
the water. PCLC has already taken that difference into account in its application of ICPC 13.
Due to the nuance built into ICPC 13, it is appropriate to consider this recommendation when
assessing a subsurface hydrokinetic turbine, but consideration must also be given to underwater
operations, grapnel rigs, run on, and ship length.
PCLC also notes that one component of the ICPC 13 is the length of the ship itself
servicing the cable. Here, such a ship will be 140 meters long. It is particularly notable that the
PUD would separate the Project from PC-1 by less than the length of the ship required to service
the cable. Thus, in order to repair or maintain PC-1, a 140 meter vessel would likely be
positioned directly over turbines located 100 150 meters from the cable for an extended period

9
Id. at 17 ([H]here, the damage to the cable requiring the repair could be caused by a vessel dragging
an anchor, which could drag the cable even closer to the turbine unit.). PCLCs marine contractor,
Alcatel-Lucent Submarine Networks (ASN), likewise notes this concern in its supplemental letter to
PCLC addressing the expected repair operation and cost in the event of a cable break near the proposed
turbine locations. See Letter from ASN to PCLC at 3 (July 16, 2012), Appendix B, hereto (ASN
Supplement):
[W]e note that when a cable is snagged, before it breaks, it is not uncommon for it to be
dragged hundreds of meters along the seabed. Here, given the already minimal
separation between PC-1 N and the turbines, there is a real possibility that in the event of
a snag, the cable could be dragged even closer to the turbine if not over it. However,
with adequate separation, the risk of this possibility would be greatly reduced.
10
Intervention and Protest, Appendix A, at 11, 3.

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of time during the cable repair operation, raising direct safety issues for both the cable lay vessel
as well as for the turbines given the potential for cable repair equipment to snag the turbines.
2. ICPC 2, Relating to Parallel Cables in Deep Water, With Minimal
Vessel Traffic Is Not Applicable to the Project
FERC requests that PCLC explain why a separation distance of more than 120 meters is
necessary. This request would appear to be in part due to the PUDs claimed reliance on ICPC 2,
in asserting that a separation distance of only twice the water depth is appropriate, and
suggesting that ICPC 2 recommends separations in the range of twice the water depth or 100
metres to allow for a safe repair distance.
11
Recognizing that here twice water depth would be
approximately 120 meters FERC has asked PCLC why a separation of more than 120 meters,
given the current water depth, would be necessary
12
in light of the water depth here of
approximately 60 meters.
A separation distance of more than 120 meters is required for many reasons, as set forth
throughout this Response and PCLCs previous Intervention and Protest.
13
Looking solely at
ICPC 2, however, it is clear that ICPC 2 does not take into account the factual scenario of this
Project involving a proposed subsea structure in relatively shallow waters.
ICPC 2 is intended to address situations of parallel cables in deeper water. Here, there
has been no showing that the Project involves a parallel cable situation in the first instance. The
PUD makes no assertion in its response that parallel cables would exist here after Project
construction.
14
In addition, ICPC 2 is more generally focused on the siting of cables in much

11
See Ford-Ramsden Statement at 6.
12
FERC Request to PCLC at 2. Of course, the PUDs proposed separation distance of 104 meters does
not even meet a separation of two times water depth, which as FERC notes is 120 meters.
13
See infra Sec. II.C-F (explaining why increased separation distance is necessary here).
14
PUD Response, Statement of Keith Ford-Ramsden at 6, f; PUD Response at 26.

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deeper water, specifically makes reference to separation distances of 9 kilometers and 6
kilometers based on water depth as examplesorders of magnitude different from the current
situation. As summarized by Mr. Brenneman:
I also disagree with Mr. Ford-Ramsdens suggestion that ICPC No. 2 would be
the most appropriate recommendation to apply to the situation here and
particularly its recommendation as to Cable Parallels. As the name implies, that
recommendation involves separation between parallel cables particularly in deep
water (as opposed to shallow water here), and is not relevant to separation
between a cable and a structure such as a turbine because the installation and
repair operations to a turbine use different operational procedures. But again,
as indicated by the 9 km and 6 km references, this recommendation was written
for deeper water.
15


For these reasons, and the additional reasons provided below and throughout PCLCs
Protest materials, a separation distance of much more than 120 meters is necessary and
appropriate. As described above, PCLC believes a separation of 750-1000 meters is appropriate.
3. The ROV Repair Operation Proposed by the PUD is Not Feasible in
Admiralty Inlet, and Does Not Support Limiting Separation To Twice
the Water Depth.
The PUD urges that a remotely operated underwater vehicle, or ROV, can be used for
any repairs to PC-1 adjacent to the turbines, which it believes would obviate the need for a
reasonable separation between the cable and the turbines. The PUD argues that an ROV can
operate in closer quarters than a grapnel operation that ASN believes would be required for a
repair adjacent to the turbines.
16
However, the use of an ROV to complete a cable repair

15
Brenneman Statement at 18. PCLC notes that the PUD has mischaracterized ICPC 2 as
recommending a separation of twice the water depth, in any event. In fact ICPC 2 states that separation
should be three times water depth, and only upon consultation and express agreement of the parties
involved is two times depth considered. Id. See also ICPC Recommendation No. 2 at 11-12. (Where
cables parallel one another, the distance between them shall be maintained at 3 times depth of water
where possible or 9 km, whichever is the lesser. However, with the use of modern navigational
equipment and lay/repair practices, these distances could be reduced to 2 times depth of water and 6 km
spacing, whichever is the lesser, after consultation and agreement by all affected parties.)(emphasis
added).
16
Ford-Ramsden Statement at 8-9. Intervention and Protest, Appendix B (ASN Initial Letter) at 2.

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operation in Admiralty Inlet is simply not feasible, as demonstrated by the reports of the PUDs
contractors and their failed pre-installation ROV operations in Admiralty Inlet.
Admiralty Inlet is a particularly turbulent area with extremely strong currentsthe same
reason it is targeted for tidal power development also makes marine operations there particularly
challenging. This is due to the unique geographic characteristics of the inlet:
Though only 6 kilometers (3.7 mi) wide at the narrowest point (between the Point
Wilson and Admiralty Head lighthouses), it is through this passage that nearly all
the seawater flows into and from Puget Sound during daily tidal variations. Tidal
currents can reach six knots in the area northeast of Point Wilson.
17


As both ASN and Mr. Brenneman explain in detail, an ROV operation to complete a
cable repair in Admiralty Inlet is simply not feasible. According to ASN, there are a number of
concerns regarding this alternative repair procedure given the presence of strong currents in
Admiralty Inlet. Even if an ROV could be used for a limited aspect of the operation, in our
opinion, a grapnel operation would still be required for this operation.
18
As ASN explains:
ROVs for this type of activity are fairly large vehicles (see Exhibit 4 to Mr. Ford-
Ramsdens statement which shows a picture of an ASN ROV) and are extremely
hard to hold to position in strong currents. Essentially, in strong currents, the
current pushes the ROV, with the operator struggling to hold it in place. In our
experience, in currents over 2 knots, which is typical of Admiralty Inlet, the kind
of ROVs that are used on cable repair vessels would struggle to maintain position
in this type of bottom operation.
19


A further issue is visibility:
ROVs use cameras for the operator to see the work area, as well as mechanical
arms to cut and grip. However, to cut and grip the cable using an ROV the
operator needs to be able to see it. However, in strong currents visibility is
limited, further limiting the use of an ROV for repair of a cable fault in an area
such as Admiralty Inlet. In addition, where cable is buried, as is the case in

17
Brenneman Statement at 2.
18
ASN Supplement at 1.
19
Id. at 2. See also Brenneman at 4-5. ([T]he work location here is in a very confined area, with very
high currents (NOAA predictions for the area of > 4 knots), and high vessel traffic. Due to the high
currents, this area is not favorable for an ROV repair as described by Mr. Ford-Ramsden.)

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shallow water such as in Admiralty Inlet, the inability for the operator to see the
cable would further complicate its use in recovery operations.
20


These concerns are not merely hypothetical. In fact, ROV repairs were recently
unsuccessful in an attempt to repair another cable that traverses Admiralty Inletthe Alaska
United Fiber Optic System (AUFS) owned by GCI. An attempt to repair AUFS in 2009 via
ROV failed, due to extreme currents, and a grapnel had to be used to complete the procedure.
21

Mr. Brenneman explains this operation in more detail:
ROV operations can be particular[ly] challenging in strong currents, such as
Admiralty Inlet. For example, during repair operations of Alaska United Fiber
Optic Cable System (AUFS), which parallels PC-1, the Tyco Cable Ship, CS
Global Sentinel, attempted to utilize an ROV for the repair of AUFS-E and had
only partial success. Operation of the ROV in the current was done with great toil,
and conditions were at some points beyond the vehicles capabilities. It could
only operate in a very limited window at slack water. In this very limited window,
the ROV was successful in cutting the cable, eliminating the cutting grapnel drag,
but due to the current it was not used for the holding/recovery drag. Grapnel drags
where used to recover the cable.
22


That the PUD and their consultant would suggest that an ROV operation in Admiralty
Inlet could replace a grapneling operation and obviates the need for greater separation is rather
surprising given the experience of the PUDs own contractors in their attempts to use ROVs to
conduct pre-installation surveys in the vicinity of the proposed turbine locations, as reflected in a
series of pre-installation study reports collected in Appendix L to the Application. The
contractors pre-installation reports, relevant excerpts of which are included in Appendix C
hereto, candidly document the extreme, unrelenting tidal conditions in Admiralty Inlet and their

20
ASN Supplement at 2.
21
Use of grapnels, and associated run on are the factual reasoning underlying the separation distances
recommended in ICPC 13, discussed in detail above.
22
Brenneman Statement at 2.

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adverse, and unanticipated impacts on marine operations generally, and ROV operations, in
particular.
For example, the PUDs contractors prepared preliminary and final reports on seafloor
substrate and benthic habitat characterization based on ROV surveys conducted in August 2010
and September 2011.
23
These substantially similar reports on the ROV operations reported
significant issues with the overall marine operations (discussed in more detail in Section II.D,
below), and, in particular, with the ROV surveys. As the Final ROV Survey Report noted,
[t]his is a site of high tidal water exchanges and almost continuous strong currents, an ideal site
for tidal energy conversion but a hindrance to seafloor examination.
24
Recognizing the
difficulty that the currents presented to ROV operations, the ROV surveys were undertaken at
two separate times, the first in mid-August 2010 and the second in late September 2010, in order
to take advantage of tidal conditions with the least amount of exchange and velocity.
25

However, the initial ROV survey in August was a complete failure due to tidal conditions and
the inability of the support vessel to hold position.
26
In the September survey, the contractors
attempted to perform the surveys during slack currents, but still experienced significant issues
with the ROV operations:
The investigation area, the tidal turbine site, is by necessity a highly dynamic and
energetic environment subjected to strong tidal flows. Even though timing of the
ROV surveys was selected to occur when tidal flow was comparatively low, the
water mass at the site was always restless and very seldom was true slack

23
See Application, Appendix L-8, Seafloor Substrate and Benthic Habitat Characterization of the
SnoPUD Admiralty Inlet Pilot Tidal Project Turbine Site Through ROV Video Observations A
Preliminary Report (Preliminary ROV Survey Report); Appendix L-10, Habitat Characterization of
the SnoPUD Turbine Site Admiralty Head, Washington State Final Report, June 1, 2011 (Final
ROV Survey Report).
24
Final ROV Survey Report at 1.
25
Preliminary ROV Survey Report at 1.
26
See Id. at 2-3.

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experienced. Quite the contrary, strong currents often over a knot in speed were
encountered and affected the smooth, trouble-free operation of the ROV.

Much time was spent untangling the tether when wrapped around boulders.
Although moderate to large size boulders were rare they did occur in sufficient
numbers to tangle the tether.

Visibility varied throughout the survey and the presence of marine snow often
prevented good observation of the seafloor from much more than a meter above
the bottom.
27


Thus, as reflected in the expert opinions of Mr. Brenneman and ASN, and reinforced by
the experience of the PUDs own contractors, ROV operations are simply not a reliable option
for effectuating repairs to PC-1 in Admiralty Inlet in the event of damage to the cable. At most,
ROVs could be used during slack currents for only one aspect of the repair operation, which
would still entail significant waiting time and delay, but still, grapneling operations that require
increased separation from the turbines would be required for the balance of a repair operation.
28

Moreover, as reflected in the reports of the PUDs own contractors, the water mass at the site
was always restless and very seldom was true slack experienced. Quite the contrary, strong
currents often over a knot in speed were encountered and affected the smooth, trouble-free
operation of the ROV.
29
Under these circumstances, the use of an ROV operation is not
feasible, and does not support limiting separation to two times water depth.

27
See Preliminary ROV Survey Report at 5; Final ROV Survey Report at 5 (emphasis added). See also
Preliminary ROV Survey Report at 2; Final ROV Survey Report at 2 (caption to a graphic included in
both reports showing the ROV in Admiralty Inlet advised the reader to Note strong current even though
this operation is occurring at slack tide.).
28
See, e.g., ASN Supplement at 2 (were an ROV to be used, the repair operation would need to wait for a
slack tide, typically a wait time of 5 or 6 hours, and then could only proceed during the slack tide, maybe
a two hour window, which adds cost and delay; even if the extent conditions were suitable (i.e., in slack
tide) and the cable was on the surface, the ROV could be used, at most, for a cutting operation, but then
grapnels would be used to clamp and recover the cable).
29
Preliminary ROV Survey Report at 5; Final ROV Survey Report at 5.

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B. PC-1 Physical Characteristics
FERCs Request to PCLC also asks: (1) is PC-1 buried near the proposed turbines, and if
so, at what depth; and (2) what is the size of the cable and is it shielded in any fashion near the
project site?
PCLC believes, based on the best information available to it, that PC-1 is buried in the
vicinity of the proposed turbines. While precise data is not available for this particular location,
PCLC believes that the depth of burial in this area likely ranges between 0.5 and 1 meter.
PC-1 in the vicinity of the turbines is 31.3 millimeters in total diameter, and is single-
armored, meaning the cable contains a layer of wires that are 4.57 millimeters in diameter,
wrapped in an outermost layer of tar-soaked nylon yarn.
C. Increased Separation is Required Because Subsurface Conditions at the
Proposed Site are Currently Unknown, and May Cause Significant Risk to
PC-1
Increased separation between the Project and PC-1 is required for the additional reason
that the PUD simply does not know what underlies the seabed where it proposed to site its 386-
ton turbines. This issue was raised by PCLC in its Intervention and Protest, and has been almost
entirely ignored by the PUD.
30
This issue is critical because if, as the PUD believes, the seabed
is underlain by soft material this would likely result in the turbines settling unevenly on the sea
bottom, causing the need for additional turbine maintenance and repair. In addition, exposure of
underlying soft sediments to currents can cause significant scouring hundreds of meters away,
cross current.
These issues are clarified and described in detail in the supplemental report attached
hereto by Gordon Fader, of Atlantic Marine Geological Consulting, who was an expert geologist

30
PCLC Intervention and Protest at 27, and material cited there; PUD Response at 29, Attachment A, at
2.

- 13 -
for the Fundy Ocean Research Centre for Energy (FORCE) in Nova Scotia, Canada in
connection with the test of OpenHydro and other tidal instream energy conversion (TISEC)
technologies in the Bay of Fundy, and compared geologic characteristics from the Bay of Fundy
site to the Project site here.
31

As described by Mr. Fader, the PUD does not know the geologic physical characteristics
of the proposed site:
The various studies that have been conducted to evaluate the seabed and
subsurface geology give the impression that the foundation is well-known. The
evidence presented in the geophysical reports in the Application, however,
demonstrate that actual foundation conditions are not known as no samples have
been collected and analyzed. . . . Descriptors such as likely, suspected,
extrapolated, estimated, interpreted, suggested, and unknown are terms
used throughout SnoPUDs supporting documents to describe the state of
knowledge about the seabed and immediate subsurface at the sites where the
turbines are planned to be placed. This is not a quantitative understanding of the
conditions on which the gravity structures will be placed, only a qualitative
estimate at best.
32


The PUDs own materials admit, candidly, that this information is unknown:
In addition, SnoPUDs survey contractor reports its failure, despite multiple
attempts, to grab sediment samples due to rocky bottom type and intense current
activity, and consequently as a result of this and other limitations, we do not and
cannot have a complete understanding of the subsurface conditions underlying the
site.
33


Marine operations expert, Capt. Richard P. Fiske, USN (ret.), who PCLC retained to
assist in assessing the risks to its cable, put it this way, citing to and quoting from various PUD
pre-installation reports:
[C]urrent and visibility conditions made visual characterization of the bottom
difficult. . . . [A]fter several failures the seabed sampling was unsuccessful and

31
Supplement to Admiralty Inlet Pilot Tidal Project Siting Assessment and Observations from
OpenHydro Bay of Fundy TISEC Deployment, attached hereto as Appendix D (Fader Supplement).
32
Id. at 2 (emphasis added).
33
Id.

- 14 -
ultimately abandoned despite multiple attempts at multiple locations near the
proposed turbine sites due to intense current activity. The sub-bottom profile
data showed little or no subsea penetration. Further, Fugro states in its
Executive Summary: The thickness of the glacial deposits is unknown as no
geotechnical explorations have been performed and the gravel, cobbles, and
boulders on the seafloor precluded a sub-seafloor penetration and seismic
imaging. There are no indications that samples have been taken to characterize
the bottom and its substrate. Yet, the District asserts that it performed
bathymetric, geophysical, and geological hazard site surveys. While the surveys
may have been performed, their contributions to understanding site geology
appear to be limited.
34


The implications of this data gap are quite significant. While questions surround the
PUDs inferences about the underlying conditions at the proposed location, there is evidence of a
relatively thin rocky layer underneath the turbines, which overlies softer sediment material. Mr.
Fader concludes that if this is correct, two things are likely to occur: differential settlement of
the turbines into the softer materials below, and substantial scouring of sediments. Both of these
events will adversely impact PC-1 and require increased separation between the Project and PC-
1.
Differential settlement will result in more vessel trips to the turbines, increasing risks to
PC-1 with unknown, and currently unplanned, marine operations:
[S]ettlement of the device will likely occur and it may be uneven or differential,
resulting in tilting of the entire gravity structure and attached turbine. This may
occur during deployment. It may also occur later during operation as turbine
vibrational forces are transmitted to the feet from tidal action, resulting in bearing
capacity failure. This lack of understanding of the sub gravel properties of the
sediments on which the device will rest will likely necessitate repeated visits and
repositioning of the devices on the seabed, require premature intervention for
removal or other means of leveling through unknown and untested marine
operations in an intense marine environment. This additional maintenance will

34
See Report of Capt. Richard P. Fiske, USN (ret.), Appendix E, hereto, at 6-7 (citations omitted)
(emphasis added) (Fiske Report). Capt. Fiske has 47 years experience in marine operations, including
ship operations, ship repair, diving and salvage, deep ocean search and recovery operations, casualty
analysis, and research and development. See id., Attachment 1.

- 15 -
result in increased intervention and vessel traffic much greater than is described in
the application and supporting documents over the 5-year pilot licensing period.
35


Scouring of soft sediments can also pose a threat to PC-1. Mr. Fader has observed scours
at the Bay of Fundy, which propagate thousands of meters, and hundreds of meters cross current.
The potential adverse impacts on PC-1 are twofold. First, scouring could directly expose PC-1
in an area that is likely to see significant vessel traffic, and second, it would exacerbate the
differential settlement of the turbines.
It is common in strong current regions for the seabed to be covered with thin
protective lag gravel surfaces over soft sediments, but once broken through, major
erosion often ensues, and through local scour and slumping processes, the seabed
can be eroded into deep troughs resulting in removal of sediments that are over
100 meters in thickness. These scoured depressions also grow normal to the
current directions and propagate for large distances down current and across
current. SnoPUDs report suggests that if scoured trenches formed around the
turbines they would not propagate across current. In the Bay of Fundy, Canada,
where tidal power test sites have been selected, similar scours from large currents
and seabed obstacles such as large boulders have propagated thousands of meters
downstream and hundreds of meters across currents.
36


In Mr. Faders initial report filed with PCLCs Intervention and Protest, Mr. Fader noted
in connection with the Bay of Fundy project that when eventually deployed, OpenHydro moved
the location of the turbine from its original location on a gravel lag surface overlying unknown
materials, likely soft sediments similar to the PUDs proposed site here, and instead placed the
device on the nearby volcanic platform of exposed basalt rather than the substrate of bedrock
ridges and gravel with boulders.
37
As Mr. Fader observes in his Supplement, the move gave the
OpenHydro device the most stable seabed possible as a foundation and:

35
Fader Supplement at 3.
36
Id. at 3-4.
37
Report of Atlantic Marine Geological Consulting Ltd., Appendix C to PCLC Intervention and Protest,
at 5-6.

- 16 -
suggests a concern by the project sponsor regarding substrate suitability but a
report on the lessons learned from the Bay of Fundy experience, including the site
relocation, has never been made available publicly. Nonetheless, it appears that
OpenHydro still proposes to locate the device for the project here in a thin gravel
bottom setting overlying soft unsampled materials, similar to the conditions which
they moved away from in the Bay of Fundy.
38


The PUD, however, did not address this change in location at the Bay of Fundy in its response,
or potential concerns with the suitability of the substrate, which would be particularly relevant to
consideration of the present location and risks to PC-1. In light of these data gaps and the
concomitant risks to PC-1, increased separation distance from the turbines is the only available
and appropriate mechanism to avoid or mitigate the threat to PC-1.
D. Increased Separation is Required Due to the Complications and Difficulties
of Operations in an Extreme Marine Environment
As noted above in the context of the PUDs efforts to conduct pre-installation surveys at
the turbine locations, Admiralty Inlet is a particularly turbulent area with extremely strong
currents. Thus, the same reason it is targeted for tidal power development also makes marine
operations there particularly challenging. As Capt. Fiske explains:
The proposed turbine location is environmentally challenging. The Projects own
site surveys report the difficulty in working in the currents at the survey sites.
While strong currents are appropriate for generating electricity, the attendant
difficulties and hazards for marine operations mandate increased caution.
39


According to the PUDs Application, these pre-installation survey reports augmented
the already extensive collection of data available for the Admiralty Inlet region to support a
thorough and complete environmental analysis for the Project.
40
However, what these pre-
installation reports actually document are (1) the extreme tidal conditions in Admiralty Inlet and
their adverse and unanticipated impacts on marine operations at the proposed Project locations;

38
Fader Supplement at 4.
39
See Fiske Report at 1.
40
Application, Executive Summary at 4.

- 17 -
(2) the inexperience of the PUD and its contractors in adequately preparing for and addressing
these conditions in the context of particular marine operations; and (3) a failure to appreciate and
plan for risk in the context of marine operations, particularly through a series of survey
operations around the cable that have already served to hazard PC-1 North. All of these
complications and difficulties further demonstrate why increased separation is required to ensure
the protection of PC-1 from harm by the Project.
First, as noted above, as part of a bathymetric and geophysical survey to understand the
sea bottom that will underlie the turbines, the PUDs contractor attempted to obtain seabed
samples using a device known as Van Veen Grab Sampler. However, according to the survey
report submitted with the application, the seabed sampling survey was unsuccessful and
ultimately abandoned despite multiple attempts at multiple locations near the proposed turbine
sites due to intense current activity and rocky bottom type.
41
The Survey Report at Table 2-1,
reflects that although four sample locations were planned near the turbine locations, no
recovery was made at three of the locations after multiple attempts, and that, as a result, the
fourth site was abandoned.
42
Clearly, the PUD and its contractors believed that sediment
samples were important to a full understanding of the sea bottom underlying the turbines. The
failure to obtain these samples as discussed above and in Mr. Faders Supplement reflects a
significant data gap in the PUDs understanding of the sea bottom. It also reflects a lack of
experience with marine operations, including the inability to accurately plan and consider
unanticipated contingencies necessary to the successful completion of a critical marine operation.

41
Application, Appendix L-3, Bathymetric and Geophysical Survey Site Characterization Admiralty Inlet
Pilot Tidal Project at 2-6.
42
A relevant excerpt from the survey report is included in Appendix C, hereto.

- 18 -
Second, as discussed above, the PUDs contractors attempted to conduct ROV survey
operations in the proposed locations of the turbines to understand the seafloor substrate and
benthic habitat. As noted, due to the marine environment, the contractors faced significant issues
with those ROV operations. At the same time, the Application and the installation methodology
concept shows an ROV monitoring the cable installation, as well as periodic post-installation
ROV monitoring. Despite known issues with ROV operations in Admiralty Inlet, the PUD
indicates in its Application materials that it will use ROVs to monitor installation of the turbines
as well in connection with post-installation surveys without caveat or explanation (and staunchly
advocates their use for PC-1 repairs). This discrepancy creates a significant credibility gap in the
Application.
43

Third, and more significantly, from a risk standpoint vi--vis PC-1, vessels engaged in
these activities used anchors to maintain position and in fact had anchor-related issues at the
Project location. As reflected in the ROV survey report, during the initial ROV attempt in
August 2010, [u]nfortunately the support vessel Prudhoe Bay was too small for the tidal
conditions and the anchors too light to keep the vessel in position . . . .
44
This implies an
anchored vessel in the vicinity of PC-1 that could not keep its position, i.e., the anchor was being
dragged along the sea bottom creating a potential cable snag scenario. The second ROV attempt
was conducted in late September and involved repeated anchoring in the vicinity of PC-1 North
over a four-day period, involving a large barge supporting the ROV that was properly
anchored.
45
The survey report reflects that at various points during the four-day period, that the

43
See Fiske Report at 9-10. (Given the visibility and handling problems experienced by District
contractors when conducting simple visual bottom surveys, noted above, the assertion that ROVs will be
used to monitor the cable during and post-installation is not understood.).
44
ROV Summary Preliminary Report, at 2.
45
Id.

- 19 -
barge was repositioned implying repeated anchoring in the vicinity of PC-1 North. As noted
by Capt. Fiske, the barge was anchored using a four-point anchoring system and one of the
barge anchors dragged to the surface in its flukes a small boulder and cobble from the turbine
site.
46

According to Capt. Fiske, this indicates that, in fact, Hazarding of PC-1 North has
already occurred:
Perhaps most alarming is that the District has already hazarded PC-1 North by the
anchoring of contractor vessels in close proximity to the cable while performing
surveys. . . I find no indication that the District or its contractors had any
appreciation of the presence of an active international communications cable in
the immediate vicinity of its work zone (despite the presence of PC-1 North on
navigational charts and in a recorded aquatic lands easement), or that the District
or its contractors notified PCLC that these surveys were being conducted in the
vicinity of PC-1 North and that anchoring was undertaken in the vicinity of PC-1
North as a deliberate part of the survey process.
47


Unfortunately, this also is emblematic of the PUDs attitude towards risk to PC-1: quite
simply, its actions belie its words. On one hand, the District asserts, [c]onsideration for the
avoidance of risk to PC-1 North has been a fundamental design premise for the planning [sic].
48

On the other hand, the Districts Assessment of Potential Puget Sound Marine Safety Risk
Resulting from Installation of the Admiralty Inlet Tidal Energy Project
49
and its Project
Safeguard Plans
50
make no mention of PCLC, PC-1 North, any risk that the Project presents to
submarine cables or any practices with respect to the cable, including, the PUDs no-anchoring
and other assurances contained in the Marine Operations Report submitted with its response. As

46
Fiske Report at 8, citing Application, Appendix L-8, Figure 2 and Figure 23 (emphasis added).
47
Id. at 7.
48
Response, Attachment 1, Marine Operations Installation Considerations Relating to
Telecommunications Cable PC-1 at 1 (Marine Operations Report).
49
Application, Appendix L, Pre-Installation Study Reports, L-13.
50
Id., Appendix E.

- 20 -
Capt. Fiske observes, to reconcile these statements is a challenge and demonstrates a weakness
in the Projects approach to risk.
51

Of note, the Districts risk analysis, while superficially thorough in process
52
appears to
focus on interactions between the turbines and vessel traffic, while completely ignoring potential
impacts on PC-1, from such activities as vessel anchoring, that as noted, already hazarded the
cable:
There are broader risk issues that have yet to be addressed by the District. They
include the risk posed by OpenHydros lack of experience and unexplained
problems with previous installations, hazarding of PC-1 North without notice
by the Districts contractors while conducting surveys, incomplete bottom
information, and incomplete launch and recovery information and casualty plans,
at a distance of 100m from PC-1 North, all of which cumulatively contribute to
the risk of severing PC-1 North.
53


While the PUDs Response argues that Project installation cannot pose a risk to PC-1
because installation, operation, maintenance, and removal of the turbines will not involve
anchors,
54
this statement does not hold up under scrutiny. Capt. Fiske points out that the PUD,
despite assurances to the contrary, actually does plan to use anchors as part of the Project, as
follows:
However, and despite its assurances, the District elsewhere indicates that it does
expect to anchor, using vessel anchors, in the vicinity of PC-1 North while
performing work on the Project turbines. This is not only contemplated, but
planned. In its Response to the PCLC Protest the District asserts, If the District
observes derelict fishing gear snagged on the Project works, the District will
remove the gear as soon as possible. Successful removal of deep-water fishing
gear using ROVs has been demonstrated in Puget Sound (NRC 2008). The gear
removal deployment will generally involve vessel anchoring, ROV anchoring,

51
Fiske Report at 12.
52
Id.
53
Id. at 11 (emphasis added).
54
Id. at 4.

- 21 -
(emphasis added). This clearly obviates assurances that there will be no
anchoring on behalf of the District for work on the Project.
55


The PUD is simply not in a position to guarantee that no anchors will be utilized, and
cannot credibly state that no anchors will ever be used at any stage of the Project. This claim is
further belied by the PUDs own Navigation Safety Plan, which expressly contemplates use of
anchors in contingencies:
if the vessel is adrift and no assistance is immediately available, the vessel
master may make both anchors ready for letting go and prepare to anchor at
closest anchorage or moor at nearest harbor of safe refuge upon direction of the
Captain of the Port.
56


As Capt. Fiske observes in response to the PUDs assurance that it will not use anchors:

To look at risk is as simple as recognizing that the master of an installation tug,
having experienced a casualty and been cut loose from the Project may, despite
plans and District commitments to the contrary, feel it necessary to drop an
anchor to slow or stop himself from being driven by the current and into danger,
whether or not he is near a submarine cable. This is the reality of life on the
water, despite assertions that no anchors will be used.
57


A 2009 anchor snag incident in Admiralty Inlet involving a U.S. Coast Guard cutter, is
instructive. The Polar Sea, a Coast Guard vessel based in Seattle, dropped an anchor in
Admiralty Inlet after an incident with a small passenger launch, dragged the anchor across the
sea bottom, and snagged a segment of the Alaska United Fiber System submarine cable
(AUSF), causing a cable fault. The owner of AUSF, General Communications, Inc., filed a

55
Fiske Report at 4 (citation omitted, emphasis added).
56
PUD FERC Application, Vol. II, Appendix E, at 9 (emphasis added). Precisely how a vessel that is
adrift without power and without assistance could navigate to any anchorage or mooring location
other than its current location is not explained. In essence, this language must be given a practical
interpretation: when it has to, the vessel will simply drop an anchor where it is currently situated. This is
precisely the type of event which could result in anchor incursion to PC-1.

57
Fiske Report at 11.

- 22 -
complaint in U.S. District Court against the United States claiming $1.5 million in damages, and
a consent judgment was entered against the United States for $805,320.
58

The PUD further claims that there will be no maintenance of the turbines insofar as
all maintenance will occur onshore after removal of the turbine and its gravity base.
59
What
exactly the PUD intends by this statement is unclear, but if the turbines have to be removed from
the seafloor to conduct maintenance, such a removal operation will only compound the potential
for interference with PC-1. To be clear, turbine repair and/or maintenance activities are
referred to numerous times throughout the most recent PUD report on the topic, as well as in the
PUDs Response.
60
Moreover, as noted, the need for maintenance and more frequent vessel

58
See Consent Judgment, General Communications, Inc. v. United States, Case No. C10-856 RAJ (W.D.
Wash., May 20, 2011). The Complaint (GCI Complaint) and Consent Judgment are attached as
Appendix F. AUSF is a fiber optic submarine cable that connects points in Alaska with points in
Washington State. According to the GCI complaint, the Polar Sea, a vessel designed to perform science,
icebreaking, and all Coast Guard missions, after dropping anchor in Admiralty Inlet, snagged a segment
of AUSF, causing a cable fault. The Polar Sea was conducting a small boat launch for passenger
embarkation from Port Townsend, and the crew of the Polar Sea was unable to release the rigging
attached to the launch vessel, causing it to swamp and capsize. Shortly after the launch capsized, the
Polar Sea let go of its anchor, west of an area in Admiralty Inlet where several submarine cables are
located, including segments of AUSF and PC-1. The Polar Sea, with the permission of the Coast Guard
Vessel Traffic Center, was permitted to drag anchor through the cable area, and snagged a segment of the
AUSF cable. After the Polar Sea attempted to break away from the cable, the combination of the vessel
propulsion and the ebb tide, stressed the cable, damaging its fibers.
The cable repair operation took 10 days, 18 hours, and 45 minutes. GCI claimed damages in the amount
of $1.5 million. As noted, a consent judgment was ultimately entered ordering the United States to pay
$805,320.
59
PUD Response at 4-5.
60
See, e.g., PUD Response, Attachment A, Marine Operations Installation Considerations Relating to
Proximity to Telecommunications Cable PC-1, at 1, 6 (June 20, 2012) (referring to potential impacts of
installation, operation, and maintenance of the Admiralty Inlet Project turbines, the installation,
operation, and maintenance of the Admiralty Inlet Project in its current proposed location presents no
material risk to the PC-1, and installation and maintenance activities do not require nor permit the use
of anchors, [f]ailure modes and effects analysis has been performed on the installation and maintenance
activities); PUD Response at 4 (referring to The Installation and Maintenance of the Project and the
installation, operation, maintenance, and removal of the turbines and all maintenance of the turbines)
and 6 (referring to the processes used to install, repair, and remove the Project. (All emphases
supplied.)


- 23 -
traffic will likely be exacerbated by potential settling or uneven placement of the turbines due to
unknown characteristics of the substrate. The Commission must fully understand precisely what
the PUD intends in this regard, because the prospect of multiple installation and removal
operations of the turbines for onshore maintenance would further increase the risks to PC-1.
Finally, the proposed use of tugs as a backup to maintain the lay barge during turbine
installation does not alleviate these concerns. According to Mr. Brenneman, in his experience,
in an area of strong currents, even the use of backup tugs has risks.
61
For example, Mr.
Brenneman relates that during the lay of the fiber-optic cable Maya, the same procedure as the
PUD proposes here was used off the coast of Florida while working in the Gulf Stream.
However, one of the 2 tugboats lost power during lay operations and the lay vessel ended
running over 1000 meters offline with the cable.
62
Capt. Fiske similarly notes the complexities
and the dangers inherent in the backup proposal that the PUDs contractors lay out here:
The District plans to use a standby tug in the event that one of the three planned
tugs becomes inoperative. As noted throughout the documentation, the
installation location is subject to strong currents. To disengage a disabled tug,
move it clear of the barge (or in the case of the trailing barge in the OpenHydro
Deployment Concept keep the disabled tug from being driven by the current into
the tug/barge assembly), transfer wires or rig new wires to the standby tug, and
the standby tug to take a strain, all while current are driving the entire flotilla,
tethered to the bottom by power cables or by turbine lift wires, timely and without
need to repeat steps, presents a not-insignificant challenge. To accomplish this
while avoiding being carried by currents a short 104m to the West, where lies PC-
1 North, seems to be overly optimistic. The District has not provided sufficient
operational detail to demonstrate that such a contingency could be managed
without adverse incident. Loss of control of the flotilla in such a scenario while
the turbines are suspended (mid-installation) in the water column, or near the
seabed, would pose substantial risks to PC-1 North.
63



61
Brenneman Statement at 2.
62
Id.
63
Fiske Report at 5 (emphasis added).

- 24 -
Overall, as Mr. Brenneman observes, most installations he has participated in are
carefully planned, with professional mariners and advanced marine technologies. Still,
unanticipated events frequently occur, resulting in injury and significant damage to infrastructure
and property.
64
Despite the most careful planning, the very definition of an unforeseen event is
that it was not anticipated. Here, even use of anchors is actually anticipated in certain known
circumstances. These risks are only heightened in an extreme current environment such as
Admiralty Inlet, hence the need for a greater separation to minimize the risks of interference
between the turbines and cable. Plainly, the Project as currently proposed creates a substantial
conflict with PC-1s preexisting use, and the extreme currents and environment, combined with
the close proximity as proposed to PC-1, render this a sensitive area to locate the Project, which
would create substantial adverse impacts on PC-1:
65

The planned Project location, in close proximity to PC-1 North, is a sensitive
location from an operational perspective due to the presence of the cable. In
maritime operations, 100 meters is very close proximity. To install a large, heavy
experimental project in close proximity to PC-1 North is to invite problems
needlessly.
66


As Capt. Fiske concludes, in offshore operations the easiest problems to solve are those
that are avoided altogether through careful planninghere, through greater separation:

64
Id.
65
PUD in its Response cites Verdant Power, LLC, 138 FERC 62,049 at P 3 (2012) in arguing that the
Commission there suggested that the sensitive location prohibition [in the Commissions white paper
on Licensing Hydrokinetic Pilot Projects] refers to environmentally sensitive areas, not areas with
potential user conflicts. PUD Response at 13. This argument fails for two reasons. First, Verdant
Power did not hold that user conflicts cannot render an area sensitive it merely made passing reference
to environmentally sensitive areas. The question of user conflicts was not contested or addressed in the
decision. Second, environmentally sensitive areas can include areas of user conflict, because the
preexisting uses constitute a part of the built human environment, consistent with the expansive definition
of environment under the National Environmental Policy Act. 40 CFR 1508.14 (Human
environment shall be interpreted comprehensively to include the natural and physical environment and the
relationship of people with that environment.). See also PCLC Intervention and Protest, IV.A.
66
Fiske Report at 2.

- 25 -
Marine operations are dynamic and cannot, as in terrestrial operations, simply be
stopped until a problem is resolved. This planning is best done by persons
experienced in marine operations. Even with the best planning, unanticipated
situations arise and the best way to deal with both anticipated and unanticipated
problems offshore is to use the planning process to minimize risk. The values in
planning maritime operations are foresight, simplicity and common sense. The
easiest problems to solve are those that are avoided.
67


E. Increased Separation is Required Because Damage to PC-1 Would
Substantially Interfere with Communications on PC-1
The PUD, through Mr. Ford-Ramsden, asserts that a break in PC-1 would not interfere
with data traffic over the cables, adversely impact customers, or result in significant costs or lost
revenue, because, among other things, the traffic could be rerouted over other segments of the
cables ring system. This characterization is incorrect. The consequences to PC-1 would be
severe and thus increased separation is necessary to ensure that such damage does not occur.
As explained by PCLC in the statement of its Chief Financial Officer Kurt Johnson
attached herewith,
68
the network of which PC-1 is a part has at any given time a fixed and
limited capacity to transmit data, known as a systems lit capacity. As a result, only a limited
amount of data can be rerouted in the event of a break in the cable. A small portion of PCLCs
customers take advantage of this capability and, for a premium charge, purchase the protection to
have their data reroutedbut the balance of its customer traffic cannot typically be rerouted:
[I]n the event of a fault on an unprotected PC-1 North circuit, PC-1 is not
contractually required to reroute the interrupted circuit on other PC-1 segments,
but more importantly would not physically have the ability to do so. Simply put,
PC-1 only has the capability to manually reroute capacity from PC-1 North to
adjacent segments to the extent there is available lit capacity on those segments.
Given the cost and time to light additional capacity, excess lit capacity is typically
(and currently) very limited.
69



67
Id. at 1.
68
Statement of Kurt Johnson Before the Federal Energy Regulatory Commission Snohomish County
Public Utility District No. 1, dated July 31, 2012, attached hereto as Appendix G.
69
Id. at 11.

- 26 -
In fact, contrary to its (erroneous) extrapolation from press clippings, the cable fault on
two segments of PC-1 resulting from the Japan Tohoku earthquake caused significant disruption
to PCLCs data traffic:
In fact, all customers on PC-1 North and West suffered service interruptions from
the Tohoku earthquake on March 11, 2011. Some customers were not restored
until May 26, 2011 and most customers were without service for four to seventy-
six days while they were manually restored.
70


PCLCs ability to manually restore this traffic was the result of a completely fortuitous
event:
This manual restoration was possible because coincidentally, Pacific Crossing had
just completed a system upgrade adding additional lit capacity of 170 gigabits per
second of transpacific capacity on PC-1 South (Shima, Japan to Grover Beach,
California) only days before the earthquake and therefore had this additional lit
capacity, that had not yet been sold to customers, available for restoration. This is
highly unusual and, in this case, completely fortuitous.
71


As recent headlines demonstrate, severing an international submarine cable is a major,
adverse event with significant consequences.
72
As Capt. Fiske notes, this case is all about risk,
and here the risk to PC-1 can and should be addressed in the planning stage:
Unless they are urgent in nature, most marine operations are carefully planned
and deliberately executed. Alternatives are investigated with the goal of
simplifying the operation, minimizing risk, and developing as completely as
possible a list of possible failures and problems and other variables, such as the

70
Id. at 13.
71
Id. at 14-15.
72
See Ship Accidents Sever Data Cables Off East Africa, Wall Street Journal Online (February 28,
2012)(Undersea data cables linking East Africa to the Middle East and Europe were severed in two
separate shipping accidents this month, causing telecommunications outages in at least nine countries and
affecting millions of Internet and phone users, telecom executives and government officials said.);
Ships anchor accidentally slices internet cable cutting off access in six African countries, Mail Online
(Mar. 1, 2012), attached as Appendices H and I, respectively. As noted above, to resolve the alleged
negligent snag of the Washington-Alaska AUSF resulting in a fault in one of its segments, a consent
judgment was entered against the United States in the amount of approximately $802,000. This is a far
cry from the non-event posited by Mr. Ford-Ramsden, suggesting incremental repair costs in the $10,000
to $20,000 range.

- 27 -
operational environment, that might arise and plans to deal with those problems
and failures and variables.

Some risks are necessary and some risks are elective. An elective risk need not be
taken and can often be reduced through planning, organization and design. To
take an elective risk without justification is to invite problems.
73


The cost of repairs to the cable in event of a break would be substantial, also contrary to
the PUDs assertions. Mr. Ford-Ramsden opines on an incremental cost estimateignoring that
if the PUDs Project caused a fault, the PUD would bear responsibility for the entire cost of
repairs, not just an incremental analysis.
74
Further, ASN has reviewed his cost estimate and
determined that it significantly underestimates the actual costs of repairs and does not account
for significant unknowns which would increase costs further, and cannot be readily
quantified.
75
A detailed statement underlying this conclusion is included in Appendix B.
In short, a break or disruption in cable operations would result in an immediate disruption
of PC-1s role in worldwide telecommunications, and cause substantial expense and
complication for repairs. The PUD's apparently casual attitude toward these risks is inexplicable
and unsupported, and is further support for increased separation between PC-1 North and the
turbines.
F. To Allow for Increased Separation, Feasible Alternatives Exist, and Should
be Explored
Greater separation between PC-1 and the turbines should be explored because the
available data indicate that tidal forces are likely sufficient to sustain the Project in other
locations. The PUD in its Response takes issue with the technical aspects of the AECOM tidal

73
Fiske Report at 1, 11.
74
Id. at 10.
75
Altcatel-Lucent Supplement at 2-3.

- 28 -
model submitted by PCLC, however, nowhere does the PUD deny that other sites lack sufficient
tidal energy for a successful pilot Project with further separation.
To the contrary, the modeling results now produced by the PUD confirm that other sites
can workAECOM has reviewed and analyzed the PUDs latest submittal, and concludes based
on the PUDs data and modeling output:
There are now three modeling exercises one conducted by AECOM and two by
SnoPUD, that show multiple locations to the west of PC-1 may produce
acceptable power potential compared to the proposed locations 100 and 150
meters east of PC-1. In addition, these sites appear to be consistent with
SnoPUDs other siting criteria such that a detailed analysis is warranted. We also
agree with Dr. Polagye that the appropriate siting methodology is modeling to
measurement. We conclude that, based on the results of both AECOMs
simplified and SnoPUDs sophisticated modeling exercises, at this point it would
be appropriate to conduct stationary ADCP measurements at multiple alternative
locations west of the PC-1 cable where the models have indicated potential
alternative sites.
76


Significantly, as noted by AECOM, the PUDs Dr. Polagye, in his critique of the
AECOM model can only say that results from the new PUD model (Thyng 2012) indicate no
regions of higher power density to the west of the PC-1 cable.
77
Areas to the west of PC-1 are
not dismissed as having insufficient power potential under the sophisticated modeling (Thyng,
2012), or being significantly below the power potential at the proposed turbine location.
78

Thus, the PUDs modeling exercises, while perhaps more sophisticated, expensive and
time-consuming than AECOMs modeling exercise, confirm AECOMs fundamental conclusion
here: other sites at greater distance from PC-1 are feasible and should be explored further in
order to avoid or mitigate adverse impacts on PC-1.
79
The Commission now has the benefit of

76
Supplemental Report of AECOM at 2, Appendix J hereto.
77
Id. at 3 (citing Polagye Supplemental Report at 5, PUD Response, Attachment D.)
78
Id.
79
In addition, as reflected in the Polagye Supplemental Report, sites father away from PC-1 North to the
west of the current proposed location also meet the PUDs other siting criteria.

- 29 -
more than one model which support PCLCs request for a detailed analysis of reasonable
alternative sites. A full and proper analysis of alternatives should follow.
80


80
PCLC expressly preserves its arguments with respect to environmental review under the applicable
state and federal statutes, as set forth in full in its Intervention and Protest.

- 30 -
III. CONCLUSION
PCLC remains hopeful that productive dialogue will occur on August 6 with the PUD
and FERC staff, and PCLC welcomes a reasonable and open discussion to resolve the issues
through a detailed analysis of reasonable alternative Project locations. PCLC appreciates that the
Commission has scheduled the upcoming technical meeting, and hopes it will further such a
dialogue.
Respectfully submitted,
Martin L. Stern
William M. Keyser
K&L Gates LLP
1601 K Street, NW
Washington, D.C. 20006
Phone: (202) 778-900
Fax: (202) 778-9100
Email: marty.stern@klgates.com
william.keyser@klgates.com

kari.vanderstoep@klgates.com

By /s/ Martin L. Stern
Attorneys for PC Landing Corp.

Dated: August 1, 2012

Craig S. Trueblood
Ash S. Miller
Kari Vander Stoep
K & L Gates LLP
925 Fourth Avenue, Suite 2900
Seattle, WA 98104
Phone: (206) 623-7580
Fax: (206) 623-7022
Email: craig.trueblood@klgates.com
ash.miller@klgates.com



















Appendix A

STATEMENT OF THOMAS F. BRENNEMAN

Before the Federal Energy Regulatory Commission
Snohomish County Public Utility District No. 1
Project No. 12690-005

1. My name is Thomas F. Brenneman. I am a United States citizen and live at 3523
Canterbury Road, Trent Woods, North Carolina.

2. I have been asked by PC Landing Corp. (PCLC) to provide this statement as an expert
in the field of submarine cable installation, maintenance and repair in connection with the
application of Snohomish County PUD No. 1 (SnoPUD) to license a pilot tidal energy project
in Admiralty Inlet (the Project) and the written statement of Keith Ford-Ramsden filed by
SnoPUD with its Response, dated June 22, 2012, to, inter alia, PC Landing Corp.s protest to the
Project, filed May 23, 2012.

3. Specifically, I have been asked to address certain issues relative to the proposed location
of the Project turbines one approximately 100 m and the other approximately 150 m from the
northern segment of the Pacific Crossing submarine cable system, PC-1, based on my experience
in the industry.

Experience and Qualifications

4. I am an independent consultant with over 30 years experience in the offshore
construction industry, with particular expertise involving fiber optic submarine cables, power
cables, pipelines, and windfarms. I have served as the representative for owners, purchasers,
and the U.S. government in connection with numerous subsea projects, including projects
involving cable lay operations, post-lay burial, pre-lay and burial assessment surveys, cable
landing inspections, cable repairs, dredging and ROV operations. I have also served as the
Project Surveyor on wind farm and power cable projects.

5. In my capacity as a party representative, it is my responsibility to oversee the day-to-day
operations onboard the vessel, liaison between the owners and the sub-contractor(s), insure a safe
working environment is maintained, report discrepancies in operations with the owners, and
provide guidance to the sub-contractor(s) as required using my knowledge and experience. As
lead surveyor, my role is to maintain the highest caliber of survey data capable, direct the survey
crew on a day to day basis, resolve problems onboard if and when they occur, and to liaison with
the client representative. A representative list of my clients is provided in the attachment.

6. I am very familiar with PC-1 and have worked as the owner representative for the former
parent of PCLC in connection with several projects involving PC-1, including involving PC-1
North and East off the waters of Washington State and an environmental survey off of California
State.



- 2 -
The Need for Adequate Separation

Unanticipated Events Occur in Difficult Marine Environments

7. Most installations I have participated in are carefully planned, with professional mariners
and advanced marine technologies. Still, unanticipated events frequently occur, resulting in
injury and significant damage to infrastructure and property.

8. For example, while working on the Walney II wind farm in the Irish Sea, a vessel lost
dynamic positioning control (which is a technology for vessels to maintain position without
anchoring), and the ROV it was operating was dragged into the platform, taking over 72 hours to
recover and repair.

9. The PUDs experts have indicated that installation of the Project turbines will be
supported by the use of tugboats as a backup to maintain the lay barge during turbine installation.
Yet in my experience, in an area of strong currents, even the use of backup tugs has risks. For
example, during the lay of the fiber-optic cable "Maya", the same procedure was used off the
coast of Florida while working in the Gulf Stream. One of the 2 tugboats lost power during lay
operations and the lay vessel ended running over 1000 meters offline with the cable.

10. And as I discuss in more detail below, ROV operations can be particular challenging in
strong currents, such as Admiralty Inlet. For example, during repair operations of Alaska United
Fiber Optic Cable System (AUFS), which parallels PC-1, the Tyco Cable Ship, CS Global
Sentinel, attempted to utilize an ROV for the repair of AUFS-E and had only partial success.
Operation of the ROV in the current was done with great toil, and conditions were at some points
beyond the vehicles capabilities. It could only operate in a very limited window at slack water.
In this very limited window, the ROV was successful in cutting the cable, eliminating the cutting
grapnel drag, but due to the current it was not used for the holding/recovery drag. Grapnel drags
where used to recover the cable. Thanks to pinpoint accuracy by the CS Global Sentinel, this was
a success, but involved significant risk due to the proximate distance of the PC-1 cable to the
AUFS cable, which was greater than the 100m being proposed for one of the Project turbines.

11. These type of risks are particularly heightened given the nature of currents, marine
traffic, and weather in Admiralty Inlet. Though only 6 kilometers (3.7 mi) wide at the narrowest
point (between the Point Wilson and Admiralty Head lighthouses), it is through this passage that
nearly all the seawater flows into and from Puget Sound during daily tidal variations. Tidal
currents can reach six knots in the area northeast of Point Wilson. All sea vessels must pass
through Admiralty Inlet to enter or leave Puget Sound, except those small enough to use
Deception Pass. Today a great deal of maritime freight traffic passes through Admiralty Inlet to
the major shipping ports at Seattle and Tacoma, as well as significant United States Navy traffic
to the Naval facilities in Puget Sound. The Keystone-Port Townsend run of the Washington State
Ferries crosses the inlet and serves as a link for State Route 20. Any work in this area is
potentially unpredictable and dangerous to personnel, equipment, and vessels due to tidal
conditions, rapidly changing currents, ship traffic, and variable weather conditions.


- 3 -
The Need to Separate Infrastructure Involving Significant Vessel Activity From Submarine
Cables In Difficult Marine Environments

12. Submarine cables, by their very nature, are susceptible to damage and breaks as a result
of outside aggression, particularly from vessel anchoring, dredging works, subsea obstacles and
debris, as well as other cables in the same vicinity. (During the installation of West Africa
Connect, off the coast of Gabon, the cable vessels plow cut two power cables belonging to Total
Oil, resulting in over 10 million GBP loss). A typical submarine cable is comprised of a variable
number of fiber pairs, surrounded by shielding and protection, i.e., single or double armor. My
understanding is that the PC-1 cables used in Admiralty Inlet are single armored and buried.
Still even armored cable can be snapped or damaged as a result of a snag, and, as noted, I am
aware of this occurring even in connection with well-planned and established installations.
Because the cable is of the armored type in this area it would likely be dragged far off position
before breaking because of the added strength of the cable that the armor provides.

13. For these reasons, in planning an infrastructure that involves significant vessel activity, I
believe it is important to allow an adequate separation distance in the planning stage between the
planned infrastructure and an existing undersea cable. This is particularly critical here, in a
marine environment characterized by extreme weather, currents and turbulence, such as
Admiralty Inlet, where marine operations will by necessity include a higher degree of risk and
uncertainty. Consequently, adequate precautions should be taken at the onset, where possible,
through physical separation of infrastructure, to avoid unanticipated conflicts that can occur even
in the most carefully planned installations.

The ICPC Recommendations

14. This is the wisdom behind the ICPC recommendations allowing for adequate separation
at the planning stage between new infrastructure and existing submarine cables, both to avoid
injury to the cable infrastructure and to allow for ease of repair.

15. While I agree with Mr. Ford-Ramsden that the ICPC recommendations are just that --
recommendations and not mandates, I also believe that they provide the best guidance available
as to safe distances between cables and other infrastructure for planning purposes. Here, Mr.
Ford-Ramsden dismisses reference to ICPC No. 13 (which was developed for wind farms) and
suggests that if an ICPC recommendation is to be used, he would use Recommendation No. 2,
which addresses coordination between cable systems, including recommended distances between
cables that are parallel to each other. I do not believe that is appropriate in this circumstance.

16. As to ICPC No. 13, I agree with Mr. Ford-Ramsden that the 500 meter safety zone in the
recommendation is not relevant to the separation between PC-1 and the turbines. But in
referring to ICPC No. 13 as the best guidance for appropriate separation with the turbines,
PCLC explicitly did not use the 500 meter safety zone for wind turbines in Recommendation No.
13 (If it had used the 500 meter safety zone, the recommended separation would have been
closer to 1200 meters).

- 4 -
17. Other aspects of ICPC No. 13 are, however, completely relevant, including allowance for
run on (200m), grappling rig (300m at 60 meter water depth), and ship length (here,
approximately 140m for ASN or TE SubCom vessels which would likely be doing the work
under a teaming agreement with ASN). Thus, without any safety zone around the turbines at all,
the recommended separation distance would still be 640 m. The run on is defined as the distance
needed between the cable and the start of the grapnel touchdown on the ocean floor to begin
recovery. The recommended scope of rope equals 5 times the water depth. An additional issue is
that while vessel draft is not an issue given water depth and the height of the turbines, cable
vessels have ropes, umbilicals, etc. that trail behind the vessel, which could easily snag the
turbines or the transmission cables, requiring the need for separation to allow for safe operation.
Moreover here, the damage to the cable requiring the repair could be caused by a vessel dragging
an anchor, which could drag the cable even closer to the turbine unit.

18. I also disagree with Mr. Ford-Ramsdens suggestion that ICPC No. 2 would be the most
appropriate recommendation to apply to the situation here and particularly its recommendation as
to Cable Parallels. As the name implies, that recommendation involves separation between
parallel cables particularly in deep water (as opposed to shallow water here), and is not relevant
to separation between a cable and a structure such as a turbine because the installation and repair
operations to a turbine use different operational procedures. In addition, Mr. Ford-Ramsden
inaccurately quotes ICPC No. 2 in any event for the proposition that the recommended
separation would be 100 meters. That recommendation provides for separation of the lesser of 3
times the water depth or 9 km, but could be reduced to the lesser of 2 times the water depth or 6
km, but only after consultation and agreement by all affected parties. But again, as indicated
by the 9 km and 6 km references, this recommendation was written for deeper water.

19. Based on ICPC recommendations and my experience with the installation of
telecommunications and energy infrastructure, the potential for external aggression and the need
for safe operating distances to make repairs, ideally I recommend a separation here of 1000
meters between PC-1 north and the project turbines. In my opinion, separations of 100 and 150
meters between the turbines and PC-1 north present an unmanageable risk that would be
tempting fate. If a separation of 1000 meters cannot be achieved, under no circumstances should
a separation of less than 500 meters be authorized.

ROV Repair

20. Mr. Ford-Ramsden also recommends the use of an ROV for the cable recovery and repair
operation, which, in his view, would eliminate the need for greater than 100 meter separation
since ROVs can work in confined spaces. As noted, the work location here is in a very confined
area, with very high currents (NOAA predictions for the area of > 4 knots), and high vessel
traffic. Due to the high currents, this area is not favorable for an ROV repair as described by Mr.
Ford-Ramsden.

21. I described above the issue with an ROV operation in Admiralty Inlet involving the
AUSF. As a further example, while working on the Walney II wind farm, a 600hp ROV was
limited to 3 to 4 hours of working time per day in 3 knot currents. This same situation occurred
on the "Eirgrid" power cable lay last year in the Irish Sea. Operation of the ROVs in the current
- 5 -
was done with great difficulty, and as in the AUSF situation, sea conditions were, at times,
beyond the capabilities of the ROV. My understanding is that the ROVs on the ASN and TE
SubCom vessels are of lower power.

22. The point is that ROVs cannot work in fast currents, and the only way they can be used is
to wait for slack currents, use them in a brief window of several hours, and then wait for the next
slack current. This is obviously an unacceptable approach from a time standpoint, where waiting
time could add multiple days to such an operation, as well as from a cost standpoint, since cable
owners are charged days rates for the repair, as well as will incur additional costs associated with
cable down time.


Thomas F. Brenneman

Dated: July 12, 2012
- 6 -
THOMAS F. BRENNEMAN
REPRESENTATIVE CLIENTS

Telecommunications Sector
Cable Owners:
x TATA
x Unity Cable
x Tyco
x Melita Cable
x Verizon
x Global Crossing Limited
x Pacific Crossing Ltd. (former parent of PCLC)

Contractors:
x Global Marine
x Fugro
x Alcatel Submarine Networks

Energy Sector
x Trans Bay Cable
x TranElec
x Eirgrid
x Tran Ocean
x National Petroleum Construction Company, UAE (NPCC)

Government
x US Government [Agency classified]



























Appendix B
Centre de Vitlarceaux
Route de Villejust
91620 Nozay
France
Alcatel Lucent @
PC Landing Corp.
319 Diablo Road, Suite 213
Danville, CA 94525
USA
Attn: Mr. Kurt Johnson, (FO
16 July 2012
Re: Admiralty Inlet Pilot Tidal Project - FERC No.12690
Dear Mr. Johnson.
We are writing in reference to the application of Snohomish County PUO No.1 ("SnoPUD")
to License a pilot tidal energy project in Admiralty Inlet (the "Project") and the written
statement of Keith Ford-Ramsden filed by SnoPUD with its Response, dated June 22, 2012,
to, inter alia, PC landing Corp. ' s protest to the Project, filed May 23, 2012.
As we explained in our letter to you dated May 10, 2012, as the maintenance contractor
for the Pacific Crossing cable system (PC-1), we have a number of concerns with the
proposed location of the Project turbines - one approximately 100 m and the other
approximately 150 m from PC-1 N, the northern segment of PC-1.
In our letter, we contrasted a typical cable fault repair operation with the type of repair
operation that would be required in the event of a cable fault adjacent to the turbines,
See Exhibit 1 to our 10 May 2012 letter, and also concluded that the proposed proximity of
the turbines to PC-1 N would increase the cost, complexity, and timing of such a repair.
In the SnoPUO Response, Mr. Ford-Ramsden states that rather than the typical grapnel
operation that ASN recommends (which would require, among other things, two cable cuts
each at a distance away from the fault to allow for safe operations), a potential
alternative repair method, sometimes used when working near other seabed
infrastructure, could be considered. This alternative would require the use of an ROV for
the repair operation, which would allow the cable to be accessed directly at the fault
location adjacent to the turbine. The import of the SnoPUD Response appears to be that
to the extent an ROV can be used for the repair in place of grapnels, the proposed
proximity of the turbines woutd have no impact on normal repair activiti es in the case of a
fault adjacent to the turbines.
ASN can envisage a number of concerns regarding this alternative repair procedure given
the presence of strong currents in Admiralty Inlet. Even if an ROV could be used for a
limited aspect of the operation, in our opinion, a grapnel operation would still be required
for this operation.
ALCATEllUCENT SUBMARINE NETWORKS
5AS au capilal de EUR 112 013 478 . social; 3, avenue Octave Greard, 75007 Paris - 389 534 256 R.C.S. Paris
Basically, ROVs for this type of activity are fairly large vehicles (see Exhibit 4 to Mr. Ford-
Ramsden's statement which shows a picture of an ASN ROV) and are extremely hard to
hold to position in strong currents. Essentially, in strong currents, the current pushes the
ROV, with the operator struggling to hold it in place. In our experience, in currents over 2
knots, which is typical of Admiralty Inlet, the kind of ROVs that are used on cable repair
vessels would struggle to maintain position in this type of bottom operation. In this
context it is essential to note that there is no guarantee that an ASN repair vessel,
equipped with the more powerful ASN ROV, would be used. It is quite possible that an
alternative vessel could be used, which would be equipped with a different kind of ROV
which, although meeting the industry standard, is lower powered when compared with the
ASN ROV and thus even less able to cope with the strong currents experienced in the Inlet.
Thus here, were an ROV to be used, the repair operation would need to wait for a slack (or
slow) tide, to proceed with the operation - typicaUy a wait time of 5 or 6 hours. Even then,
the operation could only proceed during the period of the slack tide, maybe a two hour
window in which to work, followed by additional waiting time, which adds cost and delay
to the operation.
A further issue is visibility. ROVs use cameras for the operator to see the work area, as
well as mechanical arms to cut and grip. However, to cut and grip the cable using an ROV
the operator needs to be able to see it. However, in strong currents visibility is timited,
further limiting the use of an ROV for repair of a cable fault in an area such as Admiralty
Inlet. In addition, where cable is buried, as is the case in shallow water such as in
Admiralty Inlet, the inability for the operator to see the cable would further complicate its
use in recovery operations. With buried cable, the operator will not be able to get a hold
of or cut the cable wi th an ROV. Should the cable be exposed and visible due to, for
example an anchor drag, it is possible that the distance to the turbines would be reduced
by the external aggression event, further reducing any safety margins for the repair
operation.
Depending on conditions, an ROV could be deployed at the start of the operation but
whether and how it would be used, depends on the specific conditions. To the extent that
the conditions are suitable (i.e., in slack tide) and the cable was on the surface, the ROV
could be used to for a cutting operation, but then grapnels would be used to clamp and
recover the cable, requiring the grapnel operation that we explained in our May 10 letter.
Basi cally. utilizing ROV cameras and mechanical arms to clamp the cable and then recover
it is a slow operation compared to a grapneling run. Thus, even if an ROV could be used
for the cutting operation, the ROV would not be used to clamp and recover the cable in
any event. In addition, even using an ROV to cut the cable presumes suitable tides and
that the cable was unburied in the work area.
In short, an ROV would have at most a limited role in a repair operation in Admiralty Inlet,
and even if it could be used to cut the cable, given the current in the area it would still be
likely to be less time consuming to use a grapnel to recover the cable, requiring the more
complex and costly operation described in our May 10 letter.
In terms of cost, Mr. Ford-Ramsden takes exception to our characterization of the cost and
complexity of a repair operation using cutting and holding drives with grapnels as
described in our May 10 letter. Basically, the SnoPUD Response estimates the i ncremental
vessel time and spare cable cost at $11 , 100 to $21 ,840. In our vi ew, this signi ficantly
2
underestimates the likely incremental cost of such an operation, particularly since it fails
to account for the additional cost of relaying the cable further to the west of the existing
route, to allow for additional separation from the turbines. In particular, even under a
best case scenario, the incremental work would take at least an extra day for the
recovery, repair and burial operation alone without accounting for the cable reroute,
adding approximately $25,000 per day for fuel, lube, and the vessel day rate, plus the
incremental cable cost. This does not take into account potential additional time for the
complexity of the operation, allowances for complications, or waiting time for currents.
Thus, for planning purposes, we would expect this to be a multiple day operation, and
think that Mr. Ramsden's estimate of an additional 4 to 8 hours to complete this repair is
overly optimistic.
In addition, the SnoPUD Response does not account for relaying the cable to the west of
the current location. ! For example, if the cable were moved approximately 400 m to the
west of its current location to allow for 500 m in separation to the turbine location, this
would require not only additional cable, but we would be particularly concerned with the
permitting costs and issues associated with changing the current alignment of the cable,
which, in our view, could be significant. These are significant unknowns that cannot be
immediately quantified.
Finally, as an additional point supporting an increased separation between PC-1 N and the
turbines than is currently planned, we note that when a cable is snagged, before it breaks,
it is not uncommon for it to be dragged hundreds of meters along the seabed. Here, given
the already minimal separation between PC-1 N and the turbines, there is a real possibility
that in the event of a snag, the cable could be dragged even closer to the turbine if not
over it. However, with adequate separation, the risk of this possibility would be greatly
reduced.
Yours Sincerely,

Claire Boggis
Alcatel-Lucent Submarine Networks
Vice President Marine
Attachment
1 SnoPUD states i n its Envi ronmental Report (at 102) that "The project wilt constrain Pacific
Crossing to re-Lay the repair section to the west of the existing cabLe route_ They will want to re-
Lay as paralleL to the existing cabLe as possible to minimize cross current forces on the able as much
as possible."
3



















Appendix
Appendix C

EVIDENCE OF ADMIRALTY INLET MARINE CONDITIONS AND ADVERSE
AND UNANTICIPATED IMPACTS ON PROJECT MARINE OPERATIONS AS
REPORTED IN CONTRACTOR PRE-INSTALLATION STUDY REPORTS

As reflected in its Application, the PUD, through outside contractors, conducted a suite of pre-
installation studies, that according to the PUD augmented the already extensive collection of
data available for the Admiralty Inlet region to support a thorough and complete environmental
analysis for the Project. PUD Application, Executive Summary at 4. These are collected in
Appendix L to the Application.

In fact, the reports of the PUDs own contractors at the turbine sites candidly document the
extreme, unrelenting tidal conditions in Admiralty Inlet and their adverse, and unanticipated
impacts on marine operations at the proposed project locations. Significantly, vessels used in
these activities used anchors to maintain position and in fact had anchor-related issues. Relevant
excerpts from the actual reports are included below.

Appendix L-3:
Bathymetric and Geophysical Survey Site Characterization
Admiralty Inlet Pilot Tidal Project (Fugro Seafloor Surveys, Inc., June 25-30, 2009)

Purpose: Perform bathymetric and geophysical site surveys for the project to determine seafloor
characteristics, including through seabed sampling with a Van Veen grab sample. The seabed
sampling, however, was unsuccessful and ultimately abandoned despite multiple attempts at
multiple locations near the proposed turbine sites due to intense current activity (see Appendix
L-3 at 2-6):



2

Appendix L-8:
Seafloor Substrate and Benthic Habitat Characterization of the SnoPUD Admiralty
Inlet Pilot Tidal Project Turbine Site Through ROV Video Observations A
Preliminary Report

Appendix L-10
Habitat Characterization of the SnoPUD Turbine Site Admiralty Head, Washington
State Final Report, June 1, 2011 (CapRock Geology)

These reports were prepared and based on two ROV video surveys undertaken to characterize the
benthic substrate and habitats of the project site. The ROV surveys were undertaken at two
separate times, one in mid-August 2010 and the second in late September 2010, in order to take
advantage of tidal conditions with the least amount of exchange and velocity. Preliminary
Report at 1. Reflecting on the surveys, the final report noted that This is a site of high tidal
water exchanges and almost continuous strong currents, an ideal site for tidal energy conversion
but a hindrance to seafloor examination. Final Report at 1 (Emphasis added.)

The Reports contain substantially identical discussions of survey method and difficulties
encountered. See Preliminary Report at 2-3, 5; Final Report at 2-3, 5. (referenced figures omitted
in excerpt below). Note specifically issues with ROV use and operation, and observation that
very seldom was true slack experienced. Quite the contrary, strong currents often over a knot in
speed were encountered and affected the smooth, trouble-free operation of the ROV. The
reports comment extensively on need for and difficulty with anchoring. This demonstrates issues
with marine operations in Admiralty Inlet currents, and difficulties with use of an ROV even for
simple video operations. However, of particular concern, it also indicates significant vessel
operations and anchoring in the vicinity of PC-1 N without notification to or coordination with
PCLC. Fortunately, there were no external aggressions during these operations.

Method



3






















Appendix D
1
Supplement t) Admiralty Inlet Pil)t Tidal Pr)ject
Siting Assessment and Observati)ns fr)m OpenHydr)
Bay )f Fundy TISEC Depl)yment
FERC Pr)ject P-12690
Submitted By:
Atlantic Marine Ge)l)gical C)nsulting Ltd.
G)rd)n Fader, P. Ge).
2901 Parkdale Ave.
Halifax, NS
Canada
B3L3Z2
July 2012
2
This rep*rt supplements my May 2012 Admiralty Inlet Pil.t Tidal Pr.ject Siting
Assessment and Observati.ns fr.m OpenHydr. Bay .f Fundy TISEC Depl.yment (Fader
Rep*rt). On June 22, 2012, the Public Utility District N*. 1 *f Sn*h*mish C*unty (Sn*PUD)
filed with FERC a set *f resp*nses t* many *f my c*mments in a d*cument entitled Marine
Operati.ns Installati.n C.nsiderati.ns Relating t. Pr.ximity t. Telec.mmunicati.ns Cable PC-1
(June 20, 2012) (Sn*PUD Marine Operati*ns Rep*rt) *n the installati*n and maintenance *f the
OpenHydr* device in Admiralty Inlet that suggests that the device p*ses n* risk t* the adjacent
PC-1 submarine cable. Many *f the c*mments in my May 2012 Assessment were n*t addressed
by Sn*PUD in its resp*nse and I reiterate th*se here al*ng with further clarificati*n and
emphasis. In additi*n, *n July 16, 2012, FERC issued a Request f.r Additi.nal Inf.rmati.n t* PC
Landing C*rp. and this supplement als* addresses, in part, FERCs requests.
It has been stated that the OpenHydr* system will be placed *n the seabed with a planned
maintenance schedule f*r rem*ving the turbines five years after depl*yment (Draft Bi.l.gical
Assessment, Sn*PUD, Applicati*n F*r A New Pil*t Pr*ject License, Admiralty Inlet Pil*t Tidal
Pr*ject (the Applicati*n), Appendix (App.) G, at 31) s*, acc*rding t* Sn*PUD, peri*dic
maintenance is anticipated t* be minimal. The vari*us studies that have been c*nducted t*
evaluate the seabed and subsurface ge*l*gy give the impressi*n that the f*undati*n is well-
kn*wn. The evidence presented in the ge*physical rep*rts in the Applicati*n, h*wever,
dem*nstrate that actual f*undati*n c*nditi*ns are n*t kn*wn as n* samples have been c*llected
and analyzed. It is appreciated that sampling the seabed and immediate subsurface in str*ng
current regi*ns where the seabed is b*ulder-c*vered is a very difficult undertaking, but it is
n*netheless essential that samples be c*llected and their ge*technical pr*perties be well-
underst**d f*r pr*per system design. Descript*rs such as likely, suspected, extrap*lated,
estimated, interpreted, suggested, and unkn*wn are terms used thr*ugh*ut Sn*PUDs
supp*rting d*cuments t* describe the state *f kn*wledge ab*ut the seabed and immediate
subsurface at the sites where the turbines are planned t* be placed. This is n*t a quantitative
understanding *f the c*nditi*ns *n which the gravity structures will be placed, *nly a qualitative
estimate at best.
The immediate seabed (*r pavement as it is referred t* in the Sn*PUD Marine
Operati*ns Rep*rt) is suggested t* be 0.5 t* 1m thick, c*nsisting *f gravel with c*bbles and very
r*unded b*ulders. The rep*rts states that the r*unded b*ulders *n the seabed can and d* m*ve
ab*ut in the str*ng currents *f Admiralty Inlet. It is described as being in a l**se and
unc*ns*lidated c*nditi*n. Seafl..r Substrate and Benthic Habitat Characterizati.n .f the
Sn.PUD Admiralty Inlet Pil.t Tidal Pr.ject Turbine Site Thr.ugh ROV Vide. Observati.ns A
Preliminary Rep.rt, Applicati*n, Appendix L-8, at 25. This gravel lag is suspected t* *verlie a
glacial clay layer, which is a relatively s*ft material. Habitat Characterizati.n .f the Sn.PUD
Turbine Site Admiralty Head, Washingt.n State Final Rep.rt, June 1, 2011 (CapR*ck
Ge*l*gy), Applicati*n, Appendix L-10 at 28. In additi*n, Sn*PUDs survey c*ntract*r rep*rts
its failure, despite multiple attempts, t* grab sediment samples due t* r*cky b*tt*m type and
intense current activity, and c*nsequently as a result *f this and *ther limitati*ns, we d* n*t and
cann*t have a c*mplete understanding *f the subsurface c*nditi*ns underlying the site.
Bathymetric and Ge.physical Survey Site Characterizati.n Admiralty Inlet Pil.t Tidal Pr.ject
(Fugr* Seafl**r Surveys, Inc., June 25-30, 2009), Applicati*n, Appendix L-3 at 2-6, 6-1.
3
The design *f the feet f*r the gravity structures is pr*p*sed t* be tapered steel p*ints
(Applicati*n, Exhibit F, Sheet 3, Gravity Base and Turbine Assembly) *ver 1 meter in length,
which w*uld penetrate the thin l**se gravels and rest up*n the sub gravel sediments. Other
secti*ns *f the rep*rts state that the base f**t print will distribute the l*ad s* that the s*il shear
strength will n*t be exceeded the subsea base f**t print will be c*nservatively designed t*
distribute the l*ad s* that the s*il shear strength is n*t exceeded. Sn.PUD Marine Operati.ns
Rep.rt, at 2. These tw* f**ting descripti*ns c*ntradict *ne an*ther. M*st imp*rtantly, this
c*nclusi*n simply cann*t be supp*rted with*ut actual measurements *f the shear strength *f the
sea b*tt*m and immediate subsurface material and certainly n*t with tapered and p*inted feet that
rest up*n s*ft s*ils. This is a critical sh*rtc*ming in the siting *f the devices.
Given what is kn*wn, tw* events will likely *ccur. One is that the full weight *f the
gravity structure will n*t be *n the gravel lag, as the tapered steel p*ints will penetrate the thin
l**se gravel lag, and will lie *n the unkn*wn sub b*tt*m sediments underlying the gravel lag.
Depending *n the pr*perties *f these sediments, and their distributi*n, settlement *f the device
will likely *ccur and it may be uneven *r differential, resulting in tilting *f the entire gravity
structure and attached turbine. This may *ccur during depl*yment. It may als* *ccur later during
*perati*n as turbine vibrati*nal f*rces are transmitted t* the feet fr*m tidal acti*n, resulting in
bearing capacity failure. This lack *f understanding *f the sub gravel pr*perties *f the sediments
*n which the device will rest will likely necessitate repeated visits and rep*siti*ning *f the
devices *n the seabed, require premature interventi*n f*r rem*val *r *ther means *f leveling
thr*ugh unkn*wn and untested marine *perati*ns in an intense marine envir*nment. This
additi*nal maintenance will result in increased interventi*n and vessel traffic much greater than is
described in the applicati*n and supp*rting d*cuments *ver the 5-year pil*t licensing peri*d.
Given the pr*ximity t* PC-1, it is essential t* *btain samples *f the material directly
beneath the gravel lag at the actual site where the turbines are ultimately placed, in *rder t* assess
the ge*technical pr*perties *f the sediments and their behavi*r under l*ading. Extrap*lati*n fr*m
nearby land *r anecd*tal evidence fr*m the dragging *f seabed anch*rs in the vicinity is simply
n*t sufficient f*r predicting the nature and pr*perties *f the sediment *n which the devices will be
f*unded. The c*llecti*n and ge*technical assessment *f seabed and sub b*tt*m samples is
standard *ffsh*re energy industry practice f*r determining the l*cati*n *f large *ffsh*re
structures that are b*tt*m f*unded, and the lack *f such inf*rmati*n is a significant and surprising
*missi*n at this site.
The presence *f s*ft clay materials interpreted by Sn*PUDs c*ntract*rs t* exist beneath
the gravel lags will als* likely result in sc*ur ar*und the feet *f the gravity base. Sc*ur will result
fr*m the thinness and m*bility *f the gravel lag, the presence *f s*ft materials beneath the gravel
lag, and increased fl*w ar*und the tubular legs and feet. This c*uld als* enhance differential
settlement *f the feet *f the gravity base structure and induce an unstable p*siti*n f*r the entire
device. It is c*mm*n in str*ng current regi*ns f*r the seabed t* be c*vered with thin pr*tective
lag gravel surfaces *ver s*ft sediments, but *nce br*ken thr*ugh, maj*r er*si*n *ften ensues, and
thr*ugh l*cal sc*ur and slumping pr*cesses, the seabed can be er*ded int* deep tr*ughs resulting
in rem*val *f sediments that are *ver 100 meters in thickness. These sc*ured depressi*ns als*
gr*w n*rmal t* the current directi*ns and pr*pagate f*r large distances d*wn current and acr*ss
current. Sn*PUDs rep*rt suggests that if sc*ured trenches f*rmed ar*und the turbines they w*uld
4
n*t pr*pagate acr*ss current. In the Bay *f Fundy, Canada, where tidal p*wer test sites have been
selected, similar sc*urs fr*m large currents and seabed *bstacles such as large b*ulders have
pr*pagated th*usands *f meters d*wnstream and hundreds *f meters acr*ss currents (AECOM
Canada Ltd., 2009, V*lume 2, Fundy Tidal Energy Dem*nstrati*n Facility, Appendix 3, Ge*l*gy,
Bathymetry, Ice and Seismic C*nditi*ns, AMGC) (Exhibit A heret*). Such cr*ss-current er*si*n
is enhanced by l*cal slumping and turbulence and is c*mm*n. Evidence already exists f*r such a
pr*cess presently underway t* the n*rtheast *f the pr*p*sed turbine l*cati*ns in a large sc*ured
tr*ugh interpreted t* *ccur in Admiralty Inlet. Fader Rep*rt, Fig. 3.
As I n*ted in my initial rep*rt (Fader Rep*rt at 5-6), at the Bay *f Fundy test site,
OpenHydr* initially ch*se t* place the turbine *n a similar gravel lag surface *verlying unkn*wn
materials (likely s*ft sediments) as is the case with Sn*PUDs pr*p*sed site here. Late in the
pr*ject depl*yment pr*cess, OpenHydr* m*ved t* a nearby site *f exp*sed basalt bedr*ck giving
their device the m*st stable seabed p*ssible as a f*undati*n. The m*ve suggests a c*ncern by the
pr*ject sp*ns*r regarding substrate suitability but a rep*rt *n the less*ns learned fr*m the Bay *f
Fundy experience, including the site rel*cati*n, has never been made available publicly.
N*netheless, it appears that OpenHydr* still pr*p*ses t* l*cate the device f*r the pr*ject here in a
thin gravel b*tt*m setting *verlying s*ft unsampled materials, similar t* the c*nditi*ns which
they m*ved away fr*m in the Bay *f Fundy.
5
EaHIBIT A
AECOM Canada Ltd., 2009, V*lume 2, Fundy Tidal Energy Dem*nstrati*n Facility, Appendix 3,
Ge*l*gy, Bathymetry, Ice and Seismic C*nditi*ns, AMGC

Minas Basin Pulp and Power
Volume II: Appendices
Fundy Tidal Energy Demonstration Facility
draft for discussion
Prepared by:
AECOM Canada Ltd.
1701 Hollis Street, SH400 (PO Box 576 CRO), Halifax, NS, Canada B3J 3M8
T 902.428.2021 F 902.428.2031 www.aecom.com



Project Number:
107405


Date:
April 21, 2009






Minas Basin Pulp and Power
Vol . I I Appendi ces
Fundy Ti dal Ener gy Demonst r at i on Faci l i t y

List of Appendices

Appendix 1: Joint Federal/Provincial Harmonization Agreement (Pending)
Appendix 2: Device Plans and Scaled Drawings
Appendix 3: Geology, Bathymetry, Ice and Seismic Conditions (Fader 2009) Final Report Pending
Appendix 4: Benthic Communities (Envirosphere 2009a) Final Report Pending
Appendix 5: Currents in Minas Basin (Oceans Ltd. 2009) Final Report Pending
Appendix 6: Physical Oceanography (Envirosphere 2009b) Final Report Pending
Appendix 7: Marine Seabirds and Marine Mammals (Envirosphere 2009c) Final Report Pending
Appendix 8: Terrestrial and Intertidal Environments (Envirosphere 2009d)
Appendix 9 Commercial Fisheries Studies-Phase I and Phase II (CEF Consultants Ltd., 2008, 2009)
Appendix 10: Archaeological Assessment (Davis Archaeological Consultants Ltd., 2008)
Appendix 11: Invitations to Public Participation
Appendix 12: Marine Transportation Study (Gartner Lee Ltd. 2008)






draft for discussion
(vol_ii_appendix_final_draft_ea_minas_2009apr21-1)
Minas Basin Pulp and Power
Vol . I I Appendi ces
Fundy Ti dal Ener gy Demonst r at i on Faci l i t y




Appendix 3:
Geology, Bathymetry, Ice and Seismic Conditions
(Fader 2009) Final Report
draft for discussion
(vol_ii_appendix_final_draft_ea_minas_2009apr21)
1



Geological Report for the Proposed In
Stream Tidal Power Demonstration Project
in Minas Passage, Bay of Fundy, Nova Scotia





Prepared By:

Atlantic Marine Geological Consulting Ltd.
2901 Parkdale Ave.
Halifax, Nova Scotia
B3L 3Z2

For:

Minas Basin Pulp and Power Co. Ltd.
53 Prince St., P.O. Box 401,
Hantsport, N.S.
B0P 1P0













April 27, 2009


2



Contents:


Chapters

1) Regional Physiography, Geography and Bathymetry of Minas
Passage, Inner Bay of Fundy

2) Bedrock and Surficial Geology of Minas Passage

3) Sediment Transport and Suspended Sediments

4) Glacial, Post Glacial, Present and Projected Sea Levels: Bay of
Fundy

5) Seismic Hazard, Faults and Earthquakes: Inner Bay of Fundy













3

Regional Physiography, Geography and Bathymetry of Minas
Passage, Inner Bay of Fundy

Physiography

The location of the proposed tidal power demonstration facility falls within one
major physiographic province of eastern Canada known as the Appalachian Region
(Figure 1). Within the Appalachian Region there are two divisions: the Atlantic Uplands
and the Carboniferous-Triassic Lowlands. The proposed tidal power demonstration site
(Minas Passage) falls within the Carboniferous- Triassic Lowlands that is named because
it is underlain largely by rocks of Carboniferous and Triassic age. A further subdivision
of the Carboniferous Triassic Lowlands is known as the Fundian Lowlands (Williams
et al., 1972).

The development of the Appalachian Region began during the late Jurrassic to
early Cretaceous time with the modification of the landscape by fluvial drainage systems
and today is considered a mature surface. The Fundian Lowlands cover most of the Bay
of Fundy continuing into the deeper parts of the Gulf of Maine. They extend inland in
Nova Scotia to include the Annapolis and Minas Lowlands. Both the uplands and
lowlands of the Appalachian Region are thought to have developed together in response
to a long and continuous cycle of erosion. Subsequent glacial erosion of these surfaces
has been minor in nature. It only altered local regions of the former landscape previously
developed by subaerial erosion.

Geography

Minas Passage occurs in the inner part of the Bay of Fundy connecting Minas
Channel with Minas Basin, (Figure 2). Minas Channel connects with the inner Bay of
Fundy to the west. The Bay of Fundy is part of a much larger regional marine system that
includes the Gulf of Maine and Georges Bank and is referred to as the FMG for research
purposes. The Bay of the Fundy is a linear embayment, 155 km in length that tapers to 48
km wide at its northeastern end where it bifurcates into Chignecto Bay and Minas
Channel. The Bay also shallows in a northwest direction from 233 m water depth in
Grand Manan Basin at the entrance, to 45 m at the bifurcation. The Bay of Fundy
connects to the northeastern corner of the Gulf of Maine between the islands of Grand
Manan, New Brunswick; and Brier Island, Nova Scotia.

Divisions of the Bay of Fundy

The Bay of Fundy has been divided into a variety of geographic regions for
research and fisheries purposes. One system divides the Bay into what is referred to as
the Upper Bay and the Lower Bay with the dividing line running from Cape Spencer
east of Saint John, NB, to Parkers Cove northeast of Digby, NS. A further subdivision is
sometimes used to divide the Bay into four quadrants separating the north and south
4
portions. Other divisional systems define the boundary between the inner and outer Bay
of Fundy as a line that runs in a more southerly direction from Cape Spencer in NB to the
Digby Gut area (Figure 3). Dadswell et al, (1984), in a review of fisheries in the Bay of
Fundy, divided it into three geographic regions: lower, mid and upper. Fisheries divisions
of the Bay of Fundy term the Inner Bay as area 55 and the Outer Bay as area 54. The
dividing line in this case is between Digby and Musquash Head in NB, slightly to the
west of the other divisions. The Minas Passage project area occurs within the inner or
upper Bay of Fundy.

Minas Passage

Minas Passage is a rectangular shaped body of water that connects Minas
Channel to Minas Basin (Figure 2). Minas Channel is the area of the inner Bay of Fundy
east of a line that extends from Cape Chignecto in the north, to Harbourville in the south.
The entrance to Minas Channel lies east of Ile Haute, a prominent Island of the inner Bay
of Fundy.
Minas Passage is approximately 14 km long. At its narrowest constriction, it is 5
km wide between Cape Sharp and the southern shore of North Mountain and is 10 km
wide at its widest point between Parrsboro and Cape Blomidon. The Passage is oriented
northwest southeast. The four corner points and boundary lines of Minas Passage are
Ramshead Point west of the mouth of the Diligent River in the northwest, south to the
western tip of Cape Split, southeast to Cape Blomidon and northeast across the passage to
Second Beach, at the eastern headland of the entrance to Parrsboro Harbour. Black Rock
is a small basalt island that lies in the northern part of Minas Channel to the east of Cape
Sharp, located approximately 0.5 km offshore. Some maps present Minas Passage as a
minor geographic component of Minas Channel that occurs to the west.

Coastline of Minas Passage

The southern shoreline of Minas Passage is a straight coastline with steep basalt
cliffs of North Mountain basalt extending from Cape Split to Blomidon, where the
coastline turns to the south as part of the western shoreline of Minas Basin. There are few
bays, indentations and headlands along the southern shore of Minas Passage and this is
the result of the bedrock geology of this coastal segment that consists of uniform North
Mountain basalt.
In contrast, the coastline of the northern part of Minas Channel is much different,
largely the result of varying bedrock lithologies at or near the shoreline. Partridge Island
and Cape Sharp are prominent steep sided, high-relief basalt promontories that resisted
erosion in comparison to the adjacent siltstone and shale softer rocks of the
Carboniferous Parrsboro Formation and the Triassic to Jurassic Blomidon Formation that
have been more heavily eroded. Additionally, the overlying glacial and post glacial
sediments of the region were formed in a complex environment resulting from caving ice
fronts and raised sea levels that have produced terraced regions of glacial outwash, gravel
barriers, till cliffs and bedrock exposed coastal segments. These processes and materials
have resulted in a coastline that is highly irregular with some straight coastal segments
5
and a large embayment called West Bay controlled by the resistant headlands of Cape
Sharp and Partridge Island.
Welsted, 1974 undertook a study of the shorelines of the Bay of Fundy to produce
a series of maps showing a coastal classification based on the interpretation of air photos.
Shaw et al., 1998 undertook a regional sensitivity study of the coastlines of Atlantic
Canada to rising sea levels (Figure 4). The shoreline region of Minas Passage is classified
as moderate in this assessment.

Bathymetry

The Canadian Hydrographic Chart for Minas Passage is Chart # 4010 (Figure 2).
The sparse bathymetry presented on this chart is in fathoms and it depicts Minas Passage
as a narrow body of water constricted to the north of Cape Split as defined by the 20
fathom contour that broadens toward the east to the north of Cape Blomidon. The deepest
depths in the Passage are 61 fathoms in the central area to the south of Cape Sharp.

Chart #4010 also shows a number of current velocity vectors with the highest
values of 7 - 8 knots off Cape Split and Cape Sharp (Figure 2). A current velocity of 5
6 knots is plotted on the north side off Ram Head. Minas Passage is the region of highest
currents in the Bay of Fundy.

Minas Passage had previously been studied as part of early tidal power proposals
in the 1960s and 70s and geological/geophysical surveys were conducted to investigate
seafloor conditions and sediment distributions. Two tidal barrages were proposed for
construction in the passage at both ends termed the B4 and B5 crossings.

Multibeam Bathymetry

Modern bathymetric mapping technologies have significantly evolved over the
past several decades and present methods utilize multibeam sonar systems that provide
for 100% seabed coverage, precise measurements of depth and location, and an ability to
present the information in a variety of interpretation friendly images and fly-throughs. At
the start of this project, multibeam bathymetry had just been collected from the Minas
Channel and Minas Passage region of the Bay of Fundy by the Geological Survey of
Canada and the Canadian Hydrographic Service. That information was obtained at the
start of this project and subsequent multibeam surveys were conducted in the region of
Minas Passage by the proponents to obtain very high-resolution information for project
needs and infrastructure micro-siting. Multibeam bathymetry not only provides water
depth information, but through processing of the data, images of backscatter (proxy for
seabed hardness) and seabed slope can be generated.
The bathymetric imagery can be presented as shaded-relief maps that depict the
seabed as a digital terrain model with an artificial sun shining across the imagery to
enhance relief. They are similar to aerial photographs of land surfaces. The data can also
be displayed using conventional, but very precise bathymetric contours. These maps and
images can be interpreted in conjunction with seabed samples and photographs, and
seismic reflection and sidescan sonar data to understand seabed materials and processes
6
active on the seabed. The following is a description of the regional bathymetry of Minas
Passage based on multibeam bathymetry.

Minas Passage

The regional multibeam bathymetric shaded relief image in Figure 5 shows the
water depths of Minas Passage in a colour depth-coded presentation. The image extends
from the western tip of Cape Split in the south to Black Rock in the northeast key
geographic components of the Minas Passage area. The bathymetry was collected by the
Geological Survey of Canada and provided to the project. A major feature of Minas
Passage is a deep narrow linear depression that runs throughout Minas Passage oriented
parallel to the southern shoreline of North Mountain and has been termed the Minas
Scour Trench by researchers during the first round of tidal power development. This
deep channel begins in an area to the north west of Cape Split where it is oriented
southwest and turns to the south east to the north of Cape Split. Here the Channel is 0.6
km wide. The channel broadens to 1.5 km wide toward the east and largely occurs in the
southern part of Minas Passage. As the channel approaches Minas Basin, it shallows,
bifurcates into three deep regions, and gradually merges with the seabed. The north and
south flanks of this channel are steep and bedrock controlled. The southern area of Minas
Passage near North Mountain consists of a narrow platform that continues to the southern
shoreline.

To the north of the deep channel lies a broad bedrock controlled platform 3 km
wide with a very rough surface of exposed bedrock ridges and some fields of ripples in
gravel. A prominent series of three, 30 40 m shallow flat topped platforms extend to the
west from Black Rock and collectively form a ridge that is over 4 km in length. These
represent areas of volcanic outcrop of North Mountain Basalt on the seabed confirmed by
magnetic maps of the region and bottom photographs. Directly to the south of the
volcanic platform is a prominent linear fault that runs east-west parallel to the trend of the
platform extending from the southern area of Cape Sharp to the west. The region to the
north of the volcanic ridge consists of rough morphology similar to the area to the south
of the platform and is a region of outcropping bedrock. The seabed shallows abruptly
toward the north shore of Minas Passage with a shore platform at about 10 m water depth
that is approximately 0.5 km wide from the low water shoreline. Sand and gravel
bedforms occur on this surface. In the north west region of Minas Passage the seabed is
smoother (Figure 5) in comparison to the rough bedrock ridged region in the central part.
This suggests a cover of surficial sediments overlying the bedrock as the Passage
gradually shallows to the northwest. To the east of Cape Sharp, a similar shallow region
extends further offshore and its edge presents a steep slope to the deep channel.

Minas Channel Bathymetry

Minas Passage connects to Minas Channel in the west and the bathymetry of this
region is more complex (Figure 6). To the northwest of Cape Split lie a series of shallow
offset faulted volcanic ridges that are likely a seaward continuation of North Mountain
basalt projecting from Cape Split across the adjacent seabed. This series of shallow
7
platforms that together make up a northwest trending ridge, are similar in shape,
composition and morphology to the volcanic platforms that lie to the west of Black Rock
in Minas Passage. Minas Channel consists of both broad flat shallow regions mainly in
the southeast and deeper scoured depressions in the central region with a high degree of
roughness. The bottom of the broad scoured regions display only a few small areas of
exposed bedrock directly to the south of the volcanic ridge suggesting that the remaining
scoured areas are cut into glaciomarine sediments and till. The scouring process has not
been as severe as that in Minas Passage where vast regions of exposed bedrock have been
exhumed.

Two prominent linear northeast trending ridges cut across the seabed of the
northern area of Minas Channel and may represent boulder covered moraines that were
originally deposited by receding glaciers and have survived the subsequent scouring
process. Other isolated scour depressions occur in Minas Channel and contain large
symmetrically-shaped sandy bedforms or dunes. A very large deposit of sand, termed a
banner bank, lies to the southwest off Cape Split and is referred to as the Cape Split
Dunefield (Miller and Fader, 1990). It has been studied in considerable detail and
contains large sand waves or dunes on its surface that shift orientation, shape and height
with every tidal cycle, all while maintaining the general location of the dune field.

Most Recent Multibeam

An interpretation of the Minas Channel and Minas Passage region was first
undertaken utilizing previous published material and reconnaissance seismic reflection,
sidescan sonar and sample data collected by the Geological Survey of Canada. This
analysis determined that the most appropriate location for a demonstration tidal power
project was located in Minas Passage and that such a location occurred to the west of
Black Rock in the northern area of Minas Passage. The siting analysis was based on
criteria such as avoidance of seabed hazards, preference for hard and stable seabed, water
depth limits for devices, length reductions for marine cables, avoidance of shipping lanes
and fishing zones, proximity to the electrical grid and distance from adjacent parkland.
Once the area was selected, it was necessary to conduct very high-resolution seabed
surveys in order to characterize the seabed in considerable detail and to determine
appropriate sites for device micro-siting.

The prime system utilized for survey was a Reson multibeam bathymetric sonar
system that had an ability to represent the morphologic information at approximately 0.5
m resolution, considerably higher than the previous multibeam data collected by the
Geological Survey of Canada that was girded at 2 m. The multibeam information from
the high resolution survey was collected over a smaller region that contained potential
candidate sites to characterize details of seabed relief and to provide detailed contoured
imagery of bottom topography and seabed slope information. The following is a general
description of the bathymetry based on the detailed multibeam information (Figure 7).

The high resolution multibeam bathymetric survey was conducted in an area in
and around Black Rock extending to the west across the volcanic platform and to the
8
north to an area south of Ram Head (Figure 7). It also continued to the low water
shoreline to the north of Black Rock and was conducted at high water to provide near
shore coverage. The survey covers a region of approximately 4 km by 1.6 km.

The high resolution multibeam bathymetric shaded-relief map, Figure 7 shows the
east west trending volcanic ridge as the dominant morphologic feature of the southern
part of this study region. Water depths across the ridge show that it is defined by the 30 m
contour in the eastern portion near Black Rock, and increases in depth to 35 m at the
western tip of the feature. It is a broad flat platform with very minor relief of a few m
across its surface and is 500 m wide at its widest location tapering to a triangular-shaped
western end. Several broad deep channels occur across the surface of the platform near
the western part of the feature and reach over 50 m water depth. A few localized linear
depressions occur along the northern flank of the volcanic ridge and appear as erosional
moats. The volcanic ridge protrudes above the surrounding areas by as much as 15 m but
averages 5 m in height and has very steep slopes. The slopes are steeper and higher in the
western portion of the platform area. Some local scouring appears to occur around the
volcanic ridge flank in the west.

A broad region of northwest trending bedrock ridges lies to the north, south and
west of the volcanic platform in deeper water. The ridged region to the north has water
depths that range between 35 and 40 m in the east and is slightly deeper in the west,
ranging between 40 and 45 m. A few intervening deeper regions between ridges approach
50 m water depth. The ridges are rough and undulating with flat regions occurring
between ridges.

In the northern region of the study area at approximately 45 m water depth, the
seabed becomes smoother and the bedrock ridges appear to be buried beneath sediments
as the region approaches the shoreline. Continuing to the north and northeast, the seabed
presents a gradual shallowing slope with increasing steepness, and at 10 m water depth a
scarp occurs where the seabed flattens to the north. This flat region is a broad platform
that continues to the shoreline across the intertidal zone. The edge of the scarp is
convoluted in places and only a few areas are straight and well-defined. These regions of
convoluted scarp are interpreted to represent possible slump scars.

To the northwest and south east of Black Rock are a series of prominent ridges on
the seabed that are interpreted as gravel bedforms. On the nearshore platform in water
depths around 5 m are a variety of sand and gravel bedforms as defined by crests and
troughs that are oriented normal to the adjacent shoreline.

A detailed interpretation and discussion of the bathymetry and how it relates to
the bedrock and surfical geology and seabed processes will be presented in other sections
of this report.



9

Figures



Figure 1. Major Physiographic divisions of Atlantic Canada from Williams et al., (1972).















10







Figure 2. A section of Canadian Hydrographic Chart 4010 that shows the relationship of
Minas Passage to Minas Channel in the west and Minas Basin in the east. See text for
detailed description.












11






Figure 3. Divisions of the Bay of Fundy into inner and outer, and other geographic
regions of the inner Bay.

















12






Figure 4. Sensitivity index for coasts of Atlantic Canada vulnerable to the effects of
global sea level rise, from Shaw et al., 1998. The shorelines of Minas Channel, Passage
and Basin are shown in yellow indicating moderate sensitivity.





13








Figure 5. Multibeam bathymetric shaded-relief image of Minas Passage from data
collected by the Geological Survey of Canada and the Canadian Hydrographic Service.

14


Figure 6. Multibeam bathymetric shaded-relief image of Minas Channel from data
collected by the Geological Survey of Canada and the Canadian Hydrographic Service.



Figure 7. High resolution multibeam bathymetric map of the area to the west of Black
Rock produced by Seaforth Engineering where the in-stream tidal power demonstration
test sites are proposed to be located.



15
References

Dadswell, M. J., Bradford, R., Leim, A. H. and Scarratt, D. J., 1984. A review of the
research on fishes and fisheries in the Bay of Fundy between 1976 and 1983 with
particular reference to its upper reaches. In, Update on the marine environmental
consequences of tidal power development in the upper reaches of the Bay of Fundy by
Gordon, D. C. and Dadswell, M. J., Canadian Technical Report of Fisheries and Aquatic
Sciences No. 1256, Fisheries and Oceans Canada.

King, L. H., and MacLean, B., 1976. Geology of the Scotian Shelf, Geological Survey of
Canada, Paper 74-31, 31 p.

Miller, R. O. and Fader, G.B. J., 1990. Cruise Report C.S.S. Navicula 89-009, Phase C,
The sand wave field-Scots Bay, Geological Survey of Canada Open File Report #2298,
28 p.

Shaw, J; Taylor, R B; Forbes, D L; Ruz, M H; Solomon, 1998.
Sensitivity of the coasts of Canada to sea-level rise. Geological Survey of Canada,
Bulletin 505, 1998; 79 pages (1 sheet)

Welsted, J. W., 1974. Morphological Maps of the Fundy Coast, Maritime Sediments,
Vol. 10, No. 2, pp.46-51.

Williams, H., Kennedy, M. J. and Neale, E. R.W., 1972, The Appalachian Stuctural
Province, p. 181-261. In R. A. Price and R. J. W. Douglas (ed.). Variations in Tectonic
Styles in Canada. Geol. Assoc. Can. Spec. Pap. 11: 181-261.
16

Bedrock and Surficial Geology of Minas Passage

Bedrock Geology

Prior to studies associated with this tidal power demonstration project, a limited
amount of research had been conducted in the Minas Passage region of the Bay of Fundy.
Most was undertaken to evaluate environmental and engineering aspects of the previous
round of tidal power development in the 1980s that envisioned the construction of tidal
power barrages or dams across regions of the inner Bay of Fundy. Surveys were
conducted using low-resolution acoustic systems and details of the seabed morphology,
bedrock, sediments, seabed features and bathymetry were lacking.

The most recent study (2008) for this project has had the advantage of the
development and application of many new and improved seabed mapping systems and
technologies over the past two decades. These included high-resolution seismic reflection
systems, sidescan sonars, multibeam bathymetric sonars, cameras, and navigation
systems. As part of the proposed tidal power demonstration project, surveys have been
conducted in Minas Passage using these systems and the data has provided a
characterization of the seabed with resolutions of decameters.

The following is a description of the bedrock geology and surficial sediments of
Minas Passage as well as the proposed sites for tidal power device and associated cable
placement. The present study has been integrated with results of previous research.


Data Base

Seismic reflection surveys have previously been undertaken in Minas Passage to
support bedrock mapping by the Geological Survey of Canada and by the Atlantic
Development Board for the 1980s tidal power assessment (Huntec Ltd., 1966). The
marine bedrock geology of the region has been mapped by King and MacLean, (1976)
and in a subsequent digital revised map released by King and Webb (in press) (Figure 8).
The geology was interpreted on the basis of structural and stratigraphic relationships and
acoustical reflectivity from a grid of high-resolution seismic reflection profiles collected
in the 1960s and 70s. Bedrock information from adjacent land areas, well data, dredged
samples, and gravity and magnetic and seismic refraction data were also used. The
bedrock geology of the adjacent land in Nova Scotia has been studied by the Nova Scotia
Department of Natural Resources over many years and the land geology assessment in
this report was extracted from map ME 2000-1 (Keppie, 2000) and map 82-7 by
Donohoe and Wallace, 1982.

The most recent geophysical survey in the Bay of Fundy was conducted by Fader,
1998, from the CCGS Hudson that collected sidescan, airgun and Huntec high-resolution
17
seismic reflection data from a survey that extended from Minas Basin through Minas
Passage and Minas Channel.

Previous Research

Earliest research on the bedrock of the Bay of Fundy and adjacent Gulf of Maine
suggested that the Bay was a graben (Upham, 1894 and Johnson, 1925). Koons (1941,
1942), proposed that the Bay formed by fluvial erosion followed by submergence and
that glacial erosion played a minor role. Shepard (1930, 1931) interpreted that the deep
basins in the Bay were glaciated and that glaciation was responsible for its overall shape.
Swift and Lyall (1968) investigated Triassic sediments in the Bay of Fundy using sparker
seismic reflection techniques and defined a broad open syncline as well as the Fundian
Fault along the northern flank of the Bay. The sparker seismic reflection profiles from
that survey have been published and preserved in Geological Survey of Canada Open File
Report #898 (Fader, 1983) and were assessed for this study.

Based on a study of industry wells and seismic reflection profiles, Wade et al.,
1996 assessed the subsurface geology of the Fundy Basin and determined that the Basin
has been influenced by major pre-existing transverse faults. Deep penetrating seismic
reflection profiles were interpreted and show that it is a half-graben that lies south of the
Cobequid-Chedabucto Fault System (Glooscap Fault, King and MacLean, 1976) in Nova
Scotia, at the boundary between the major Avalon and Meguma lithotectonic zones of the
northern Appalachians. The Basin formed at the eastern margin of North America during
the Triassic/Jurassic rifting of Pangaea. Continental derived red clastic rocks and Triassic
and Early Jurassic basalt flows crop out along the Bay of Fundy and Minas Basin coast of
Nova Scotia and are comprised of four formations: Wolfville, Blomidon, North Mountain
Basalt and Scots Bay.

The most recent geological map of Nova Scotia, Map ME 2000-1 (Keppie, 2000)
describes the North Mountain Basalt that borders the southern part of the Bay of Fundy
as tholeiitic plateau basalt. Based on a U-Pb concordant zircon age of 202+- 1 Ma, the
basalt is considered to be Jurassic in age. This therefore controls the age of the overlying
Scots Bay Formation as Jurassic as well. The entire suite of sedimentary rocks extending
from North Mountain across the Bay of Fundy is now accepted to be Jurassic in age in
contrast to the earlier Triassic assumption (King and MacLean, 1976) and others. The
recent geological map of Nova Scotia (Keppie, 2000) indicates they the rocks of the
Scots Bay Formation are lacustrine limestone, siltstone, chart, fluvial sandstone and
contained vertebrate fossils. The dominant structure of the Acadian Basin is a syncline
defined by the hook of Cape Split to the northeast that plunges to the southwest along the
entire Bay. The thickness of the Triassic sediments are up to 900 m as measured from
seismic reflection profiles and regionally there may be as much as 2000 m of section
present.




18
Minas Passage

The bedrock geology of most of the floor of Minas Passage is mapped as
Triassic/Jurassic sedimentary bedrock (King and Webb, in press), (Figure 8). This
compilation is regional in nature and presents the geology at a scale of 1:1,000,000 and
does not show details at any given location. The passage is depicted as being underlain
mostly by Triassic sedimentary rocks but a long linear volcanic deposit occurs parallel to
the passage just south of the north shore and is mapped as the Triassic McKay Head
Basalt. Along the northern coast the bedrock is complex and consists of the McCoy
Brook Formation of fluvial, deltaic, lacustrine, playa and aeolian clastic rocks. Lacustrine
limestone and basalt agglomerate are common.

1980 Surveys

As part of the studies for the first round of tidal power development in the Bay of
Fundy, Huntec Ltd. prepared a report in 1966 on the marine geology and geophysics of
Minas Channel, Minas Passage and Minas Basin for the Atlantic Development Board. It
was intended as an overview engineering evaluation of Minas Passage. The systematic
grid survey resulted in bathymetric, sediment, and bedrock maps that were prepared to
assess the feasibility of constructing a dam across Minas Passage as it was considered the
most probable location for a tidal dam. Bedrock structural and stratigraphic assessments
were undertaken as part of this study and although of low resolution, some of this
information provides a regional framework in which to place the present study and is
summarized here.

The bedrock surface was found to be highly irregular and rough and interpreted to
occur at the seabed in places and to have been modified by glacial erosion. Much of
Minas Channel was found to have been swept clean of sediments attributed to strong tidal
currents. Sediments up to 330 feet in thickness, however, occur in adjacent Minas Basin
outside of the scoured region.

A map of the distribution of bedrock was prepared for the Minas Passage region
(Huntec Ltd., 1966) (Figure 9). This showed that three different bedrock types occurred:
Carboniferous and Triassic sedimentary rocks as well as Triassic basalt. Carboniferous
rocks were interpreted to occupy the northern two thirds of Minas Passage and Triassic
rocks occur in the southern third. Volcanic ridges extended to the west from both Cape
Sharp and Cape Split. They interpreted that Minas Passage is part of the north limb of the
Fundy Syncline with the centre of the syncline occurring in the curving ridge of North
Mountain south of Cape Split.

The contact between the Triassic Blomidon Formation in the south and
Carboniferous rocks in the north was interpreted to partially coincide with a regional fault
in the deepest part of Minas Passage and was thought to be responsible for the origin of
the deep channel. The contact was suggested to contain fractured and crushed rock that
was prone to severe differential erosion by fluvial and glacial processes.

19
The sedimentary rocks were found to consist of gently to steeply dipping
sandstones and shales that are weathered on the seabed exhibiting highly variable
properties. They are described as being wellcompacted and sound. The southern
Blomidon formation was found to have better engineering properties for the foundation
of a tidal barrage in the offshore then on adjacent land.

Based on the Huntec 1966 studies, bedrock mapping on the adjacent land, and the
new results obtained on bedrock by the 2008 round of surveys, it appears that the
stratified bedrock at the seabed of the proposed facility represents the Parrsboro
Formation (Mossman and Grantham, 2000). It consists of a lower red facies and a thicker
coarser overlying grey facies (Belt, 1962, 1965). The upper part is a predominantly
lacustrine unit composed of grey and red mudrock, dark coloured shale, with intervals of
red and grey sandstone. Vertebrate tracks have been found in the upper section along
with rooted horizons, raindrop impressions, dessication cracks and dewatering structures.
Tree stems and roots are common in some sections.

Faults

The Huntec Ltd. 1966 report identified several faults in Minas Passage
that trend eastwest. The North Mountain Basalt to the west of Black Rock is portrayed
as being in fault contact with the surrounding Carboniferous rocks. A number of smaller
northeast trending shear faults also occur in this area.

The main fault zone within the inner Bay of Fundy is part of a major system that
occurs along the north flank of the Bay and connects with the Chedabucto-Cobequid
system in Nova Scotia. These faults are all part of the Glooscap Fault System (King and
MacLean, 1976) that continues further to the west in the Bay of Fundy and east across the
Scotian Shelf. Within Minas Passage a large fault is clearly seen on the multibeam
bathymetry (Figures 5,10). It occurs to the south of the volcanic ridge that projects to the
west from Black Rock and extends from an area off Cape Sharp in the east, to an area to
the northwest of Cape Split, for a distance of over 13 km. It is manifest on the multibeam
bathymetry (Figure 5) as a linear depression that varies in width up to 50 m. Along some
parts of the fault, both northern and southern flanks consist of prominent ridges. The
depression associated with the fault is interpreted to arise from preferential erosion of
weaker and fractured rocks. It is difficult to determine the horizontal offset along this
fault as the strike of the exposed bedrock on both sides is the same. Wade et al., (1996)
have mapped a prominent fault on land to the east that may be the same one as identified
from the multibeam bathymetry. It is the Portapique Fault that begins in the west near
Cape DOr and extends to the east past Truro, sub parallel to the Cobequid Fault further
to the north. The Portapique Fault on land sets the Carboniferous rocks against the
Triassic deposits which surround Cobequid Bay. In the offshore the strata exposed on
both sides of the fault have the same strike so it is difficult to determine the amount of
strike slip offset. The character of the bedrock exposure on either side of the fault is quite
similar suggesting that the rocks may be of the same age. This is in agreement with the
bedrock geology interpretation from the 1966 Huntec Ltd. survey but not in agreement
with the interpretation by King and MacLean, 1976 that suggested that all the rocks in
20
Minas Passage are Triassic (Jurassic).The Huntec Ltd. 1966 survey suggests that the
contact between the Carboniferous rocks and Triassic rocks is interpreted to be further to
the south in the deepest part of Minas Passage in what has been termed the Minas
Passage Scour Trench. Therefore the age of the bedrock in the central and southern area
of Minas Passage is not yet resolved.

Several sets of prominent joints occur within the exposed bedrock that trend
almost north-south and southwest northeast. These features occur as linear deeper
regions and may represent suitable locations for routing of project cables as protection in
regions of lower hydrodynamic conditions, low relief and flat gravel surfaces.

Surficial Sediments

With the exception of the nearshore regions of Minas Passage, much of the seabed
consists of exposed bedrock. In the northwest region thick surficial sediments overlie the
bedrock and have large linear furrows, ridges and isolated scour depressions on their
surface (Figure 5). An area of bedforms in gravel termed gravel waves occurs in the
deepest part of Minas Passage. Other areas of gravel waves occur in the eastern part of
Minas Channel and to the northwest and southeast of Black Rock (Figure 10). These
gravel waves overlie a thicker deposit of surficial sediments that are thought to represent
coarse deposits in the lee of the island associated with strong currents. They may also
represent a remnant of a deposit of till or glaciomarine sediment that once covered much
of the seabed of Minas Passage but has survived erosion in this area.

On the north side of Minas Passage is a narrow flat shelf that extends from the
shoreline dipping gently seaward to a depth of approximately 10 m. Gravels and sands
occur on this shelf and are formed into a variety of bedforms with an orientation normal
to the shoreline. The shelf dips steeply from its seaward edge to 40 m water depth where
bedrock begins to crop out on the seabed and continues to the south. This slope is
covered in gravel consisting of granules, pebbles, cobbles and boulders. Samples are
difficult to collect across this surface because of a dominance of large boulders at the
seabed. Seismic reflection profiles across this area (Figure 11) show that the thickest
material below the slope is largely stratified glaciomarine sediment and till is thin or
absent. Overlying the glaciomarine sediment is a more recent deposit of sand and gravel
that continues to the shoreline. The western part of the inner shelf and adjacent slope as
well as the region to the north of Black Rock has features interpreted as bedforms and
slumped sediments. Circular depressions are common and suggest current scouring. The
inner shelf outer edge appears to be incised with circular features that are the headwall
scarps of slumped sediments. Cable routes from the offshore devices have been chosen to
avoid these features.

The volcanic flat ridge that extends to the west from Black Rock is mostly
exposed bedrock but pebbles, cobbles and boulders are common. No fine-grained clays,
silts and sands appear to be present. In the region of exposed bedrock sedimentary ridges
to the north and south of the volcanic platform, sediments occur in the flat areas between
the exposed ridges. They have a gravel cover of granules, pebbles, cobbles and boulders.
21
Several seismic reflection systems were used to determine the nature and thickness of the
surficial sediments between the exposed bedrock ridges. Little acoustic penetration was
achieved and side echoes were common acoustic artifacts on the profiles that result from
the hardness and steepness of the nearby bedrock ridges. A covering of boulders also
scattered the acoustic energy from the systems degrading penetration and resolution of
subsurface events. Regional interpretations of the seismic reflection data from the Minas
Channel region and indeed the inner Bay of Fundy show that glaciomarine stratified
sediments are widespread and very thick, in contrast to thin or absent glacial till. This
suggests that Minas Passage once contained thick glaciomarine sediments in early post
glacial time and today it is a large scoured depression formed by beach erosion during
times of lowered sea level and strong currents. The surficial material that occurs between
the bedrock ridges and underlies the gravel is more likely to represent glaciomarine
muddy sediments than till. Wider areas of seabed between bedrock ridges would be
expected to contain thicker glaciomarine sediments.


Crown Lease Area and Device Site Bedrock and Surficial Geology

The proposed Crown Lease Area and three device sites occur to the west of Black
Rock and south east of Ram Head, Minas Passage. They all occur in the northern part of
Minas Passage. Device areas B and C occur over stratified outcropping bedrock and site
A lies over North Mountain basalt. The new survey information on the nature of the
bedrock geology comes from a study and interpretation of multibeam bathymetry,
sidescan sonograms and mosaics, a few samples, and bottom photography and video.
Samples of the bedrock are difficult to collect as the bedrock is very hard and covered
with boulders in many places. The following is a more detailed description of the bedrock
and overlying surficial sediments at each of the proposed device locations each of which
covers an area defined by a 200 m diameter circle (Figure 12).

Site A

Site A occurs over a volcanic shallow flat ridge that extends to the west from the
Black Rock region. It is located approximately 1400 m from the centre of Black Rock on
the northern part of the volcanic ridge. The northern part of A also covers the northern
flank of the volcanic platform and extends to water depths of 45 m over a steep bedrock
surface. The water depths at site A average 30 m and the surface is largely exposed
bedrock with gravel (boulders, cobbles and a few pebbles). Many boulders larger than 1
m in diameter can be seen on the high resolution multibeam bathymetric imagery. The
bedrock surface is rounded and hummocky with a roughness of less than 1 m and differs
from sites B and C that display sharp eroded edges of upturned bedrock strata. The
multibeam bathymetry and the sidescan sonograms show a slight linearity to the surface
that may represent variations in the volcanic flows, glacial erosional grooves, or patterns
of subaerial erosion that were developed when the area was exposed at lower sea levels in
post glacial time. The slope map of site A shows that it is a very flat surface and the
backscatter imagery indicates that it is an area of very uniform high reflectance hard.

22
Bottom photographs from nearby area A on the volcanic platform show that the
bedrock surface is gently rounded and hummocky much like exposures of North
Mountain Basalt in the shoreface of the region. Crevasses are filled with pebbles, cobbles
and some granules and biogenic growth is quite extensive.

Site B

Site B occurs 2 km to the west of Black Rock north of the volcanic ridge over a
region of largely exposed sedimentary bedrock as the furthermost offshore test site.
Water depths over this region are the deepest of the three device locations and average 45
m. This area has a slightly greater exposure of bedrock than site C. Nearby bottom
photographs show the bedrock to consist of Carboniferous Parrsboro Formation grey and
red beds. The bedrock beds are upturned strata with a rough and undulating surface and
the strike of the beds is northwest, close to the direction of the prevailing current. This is
considered to be coincident rather than controlled. The beds appear to dip to the northeast
based on the geometry of exposed bedrock ridges on the seabed. This is contrary to the
dip of the beds presented in the early Huntec Ltd. 1966 study. The relief on the bedrock
surface is less than in other areas of the region and was one of the criteria for site
selection. Both the northern and southern regions of area B have zones of flat seabed.
These regions are gravel covered with boulders. The flatness arises from the presence of
surficial sediments that fill the deeper regions between bedrock ridges. The composition
of the material underlying the gravel is not well known because of sampling problems
associated with bouldery seabeds and a lack of penetration and resolution of the high-
resolution seismic reflection systems. Based on a regional distribution of sediments
throughout Minas Passage interpreted from seismic reflection profiles and a few samples
collected by bottom dredge, it appears that the subsurface sediments are either till or
glaciomarine muds. The regional relative distribution of till and glaciomarine sediment
indicates that glaciomarine sediment is more prevalent. Although in both cases the
surface of these materials is heavily armoured with gravel including boulders. Dredge
samples collected in the region penetrated the gravel lag in a few places and sampled
stiff, dry, and red muddy sediment that is similar to glaciomarine sediments cored in the
inner Bay of Fundy.

Site C

Site C lies 1 km to the west of Black Rock just north of the volcanic ridge with
the southern boundary of the area encroaching on the northern flank of the volcanic ridge.
Average depths across this area are 40 m and it consists of exposed bedrock ridges and
several flatter regions of gravel with boulders and is similar to site B. The northern part
of the area has the largest region of flat seabed. Bottom photographs from Area C show
both exposed bedrock at the seabed as well as gravel regions with granules, pebbles,
cobbles and boulders. Broken shell debris occurs in some areas. The bedrock is similar to
that of Site B and the overlying surficial sediments that lie beneath the flat areas of
seabed are interpreted as erosional remnants of both till and glaciomarine sediment.
Gravel occurs over the flat regions of the seabed and boulders are common within the
gravel and on the bedrock.
23


Cable Corridor Geology

The selection of the cable corridor is largely controlled by seabed characteristics
and engineering design criteria. One of the criteria for route selection requires that the
cable must be able to be removed if required. This results in a route that avoids regions of
moving seabed gravel bedforms that could bury it and make recovery difficult. It is
important to lay the cable on seabeds that would not abrade the cable and as a result, the
crossing of exposed bedrock ridges is not a preferred route. The chosen cable route also
takes advantage of bedrock structure to minimize hazards. A main route through the
sedimentary bedrock region has been chosen in a wide gravel covered flat region of
seabed that represents an eroded joint in the bedrock. The individual cables to each of the
devices have been chosen to run parallel to bedrock strike in the slightly deeper and
protected depressions between bedrock ridges that are flat and gravel covered. Steep
slopes were avoided and routes were chosen to traverse the terrain with the lowest slopes
to place the cable on the seabed and avoid suspensions.

At the northern end of the sedimentary bedrock region, the cable route crosses the
slope and adjacent inner shelf edge in a region with no bedforms, slumps or headwall
scarps and crosses the shelf edge at right angles. The cable route then turns to run
southeast on the shallow inner shelf approximately parallel to the shoreline. Areas of
bedforms, and rock outcrop are avoided along this part of the route and the cable route
takes a final turn to the shoreline in an area north of Black Rock.


24

Figures







Figure 8. A map of the inner Bay of Fundy portion of a new digital bedrock compilation
by King and Webb, (in press). Minas Passage is mapped as being underlain by Triassic to
Jurassic sedimentary bedrock. Some areas of volcanic Jurassic North Mountain basalt
have been mapped in this regional compilation. 8B is the index for the bedrock of this
region.














25











Figure 9. Huntec Ltd., (1966) interpreted bedrock map of the Minas Passage region. The
site of the tidal power test project overlies Carboniferous sediments and the contact
between the Triassic Blomidon Formation and the Carboniferous sedimentary bedrock is
presented as occurring in the southern part of Minas Passage in the area of the Minas
Scour Trench. Contours are drawn on the bedrock surface as interpreted from seismic
reflection data.











26












Figure 10. An interpretation of multibeam bathymetry for the Minas Passage region
showing both bedrock and surfical geological characteristics. The major regional fault,
likely the Portapique Fault, lies just to the south of the volcanic platform that extends to
the west from Black Rock. The fault runs east west.















27










Figure 11. A Seistec Line in Cone seismic reflection profile from the inner shelf of the
north shore of Minas Passage extending down the slope to the deeper water in the south.
The stratified material beneath the seabed is interpreted as glaciomarine sediment
deposited at the time of glacier recession from the region. It has been eroded during times
of lower sea level and marine transgression as the sea level rose. Strong currents also
played a major role in removing the glaciomarine sediments from Minas Passage. Much
of the Passage was likely filled with these sediments at the end of the last glaciation, the
Wisconsinan.






28














Figure 12. A multibeam bathymetric map of the northern part of Minas Passage showing
the Crown Lease area as a rectangle and the proposed device sites as circles. The dashed
line represents a potential cable corridor to shore.

29
References


Donohoe, H. V. and Wallace, P. I., 1982. Geological Map of the Cobequid Highlands,
Colchester, Cumberland and Pictou Counties, Nova Scotia, Map 82-7.

Fader, G. B. J. 1983, Sparker seismic reflection profiles; Bay of Fundy, from Grand
Manan island to Chignecto Bay, Geological Survey of Canada, Open File Report #898.

Fader, G.B. J. 1998, Cruise Report CCGS Hudson, Bay of Fundy when

Huntec Ltd, 1966. Report of geological-geophysical study Minas Basin, Bat of Fundy,
Nova Scotia for Atlantic Development Board.
Johnson, D. W., 1925. The New England Acadian shoreline. John Wiley and Sons, Inc.
New York, NY, 608 p.
Keppie, J. D., 2000. Geological map of the Province of Nova Scotia, Map No. ME 2000 -
1.
King, E.L. and Webb, K. J., In press. Geology of the Scotian Shelf and adjacent areas
offshore Nova Scotia; 2nd edition of the 1976 map by King and MacLean; Geological
Survey of Canada A-Series, scale 1: 100 000.

King, L. H. and MacLean, B., 1976. Geology of the Scotian Shelf, Geological Survey of
Canada paper 74-31. 31 p., enclosure Map 812H.

Klein, G. deV., 1962. Triassic sedimentation, Maritime Provinces, Canada. Geological
Society of America Bulletin 73, pp. 1127 1146.

Koons, E. D., 1941. The origin of the Bay of Fundy and associated submarine scarps.
Journal of Geomorphology, 4. pp. 135 149.

Koons, E. D., 1942. The origin of the Bay of Fundy: a discussion. Journal of
Geomorphology, 5. pp. 143 150.

Mossman, D. J. and Grantham, R.G., 2000. Vertebrate trackways in the Parrsboro
Formation at Rams Head, Cumberland County, Nova Scotia. Atlantic Geology.
Shepard, F. P., 1930. Fundian faults or Fundian glaciers. Geological Society of America
Bulletin 41, pp. 659 674.

Shepard, F. P. 1931. Glacial troughs of the continental shelves. Journal of Geology, 39,
pp. 345 360.

Shepard, F. P., 1942. Origin of the Bay of Fundy: a reply. Journal of Geomorphology, 5.
pp. 137 142.
30

Swift, D. J. P. and Lyall, A. K., 1968. Reconnaissance of bedrock geology by sub-bottom
profiler, Bay of Fundy, Geological Society of America Bulletin 79, pp. 639 646.
Upham, W. 1894. The fishing banks between Cape Cod and Newfoundland. American
Journal of Science, 3
rd
. series, 16: p. 123 129.
Wade, J.A., Brown, D.E., Traverse, A. and Fensome, R. A., 1996. The Triassic-Jurassic
Fundy Basin, eastern Canada: regional setting, stratigraphy and hydrocarbon potential.
Atlantic Geology, pg. 189-231.










31
Sediment Transport and Suspended Sediments

Introduction

Sediments in Minas Passage can be transported in the water column as suspended
sediments; ice rafted at the sea surface and released through melting to the water column
and seabed, and transported directly on the seabed as bedload. Sediment transport, seabed
stability, sediment deposition and erosion, and suspended sediments are considered
important components of the in-stream tidal power demonstration project that must be
understood in order to determine the effects of the infrastructure on the environment and
the effects of the environment on the infrastructure. Sources of fine-grained material (silt
and clay) are provided to the Bay of Fundy from both natural and anthropogenic sources
that include ocean dumping activities, rivers, seabed bottom fishing activities, natural
erosion of the seabed, shorelines, the adjacent land, and by ice rafting. In order to
understand issues associated with sediment transport in Minas Passage, particularly at the
site of the proposed in stream tidal power demonstration project, an understanding of the
seabed, its characteristics and the processes that are active there are essential components.

Previous Research

Within the Bay of Fundy most of the research on seabed sediments, sediment
transport and suspended sediment has been confined to the inner Bay with a historical
emphasis on Minas Basin and Chignecto Bay. An early phase of the research was largely
controlled by a need to understand the potential effects of erosion, sedimentation and
suspended sediments associated with the construction of tidal barrages for proposed tidal
power generation (Gordon and Dadswell, 1984; Amos, 1984)). Increased sedimentation
seaward of the Windsor Causeway, near the gypsum dock in Hantsport, and associated
with the Petitcodiac River has further focused research on sediments in the inner Bay of
Fundy.

In the outer Bay, a large project has been underway for over many years to
investigate the fate of sandy and muddy dredge spoils disposed to the seabed off Black
Point derived from dredging activity in Saint John Harbour (Parrott et al., 2006). This
study used a modern multibeam bathymetric and modeling approach to the assessment of
sediment transport associated with large scale dredge disposal and its effects on seabed
habitat and in particular the lobster fishery. It also provided detailed information on the
seabed and natural processes of the region.

Multibeam bathymetric systems are a new tool for seabed understanding that
provides considerable insight into seabed processes of erosion, deposition and sediment
transport (Courtney and Fader, 1994). Multibeam data were collected during three phases
of the early study in the Bay of Fundy during the 1990s. The first collected information
off Margaretsville, in Minas Channel, and in Scots Bay of the inner Bay of Fundy by the
University of New Brunswick and the Canadian Hydrographic Service and these studies
were intended to characterize dynamic bedforms that were discovered through earlier
32
mapping of the surficial sediments (Fader et al., 1977) and to test and calibrate multibeam
mapping systems. A second phase by the Geological Survey of Canada collected
multibeam bathymetry in Chignecto Bay in 1998 and was undertaken to investigate
reported changes to sediment distributions and over-deepening of the seabed reported by
the fishing community. A large scoured region off Cape Enrage is similar
morphologically to Minas Passage. A third phase conducted multibeam mapping over a
number of issue related seabed features and processes in the outer Bay of Fundy: horse
mussel bioherms, iceberg furrowed terrain, for sea level studies, archaeological
discoveries and glacial ice dynamics. From all of these surveys, new insights have been
gained into present conditions of erosion, sediment transport and deposition at the seabed
and complex relationships associated with large sand waves that were not previously
known.

The Petitcodiac River, New Brunswick, is the largest river discharging into the
upper Bay of Fundy. The hydrological and geological characteristics of the river have
been altered dramatically by the construction of a causeway between the City of Moncton
and the Town of Riverview in 1968. This has changed the hydrodynamics and
accelerated the deposition of fine-grained sediment in the upper reaches of the estuary.
In 2002 and 2003, the Science Branch of Fisheries and Oceans Canada, Maritimes
Region, conducted field surveys on the Petitcodiac River Estuary (Curran et al., 2004).
Preliminary analysis indicates extremely high suspended sediment concentrations
including the presence of fluid mud on the seabed and sediment deposition near the
causeway that extends 34 km out into the Bay of Fundy (Chignecto Bay).

As part of a project to determine underwater marine park boundaries, an ADCP
(acoustic doppler current profiler) study was conducted in 2001 by the Ocean Mapping
Group of the University of New Brunswick. They studied the M2 tidal circulation
patterns at the mouth of the Musquash Estuary where it exchanges water, nutrients and
sediments with the open Bay of Fundy (Byrne et al., 2002). The experiment was designed
to better define the seaward boundary of the proposed Musquash Marine Protected Area
(MPA). Observations from this study show a large quantity of suspended sediment
transferred from the estuary into the Bay of Fundy.

Recent observations of environmental characteristics of the Bay of Fundy indicate
significant modern change (Daborn and Dadswell, 1988). These include changing
sediment grain size distributions on the mudflats, anecdotal observations from the fishing
community of increasing water depths in some areas, and changing benthic communities.
These concerns have led to a need to better understand the dynamics of the Bay of Fundy
and a more detailed knowledge of seabed, sediment, suspended sediment, oceanographic
and biological conditions.

An important sediment transport study using a 2-dimensional tidally-forced model
was undertaken by Greenberg and Amos, 1983, for Minas Passage and Minas Basin that
combined a numerical model and a sediment budget analysis. It involved an assessment
of the tides and currents, suspended sediments, bottom sediments, sediment sources and
the postglacial evolution of the system. The study was mainly concerned with cohesive
33
clay and silt sized sediments and was intended to assess sedimentation associated with
the construction of a tidal barrage in inner Minas Basin. They suggest that the only
significant source of suspended sediment was from the open boundary to Minas Basin
(through Minas Channel and Minas Passage). This study was undertaken before the
development of multibeam sonars that can provide digital terrain models of seabed relief
and can be assessed for an understanding of processes of erosion and deposition. From
the study of the multibeam bathymetry it is clear that fine-grained sub-surface sediments
are eroding from the seabed of the inner Bay of Fundy, from Minas Channel and the
entrance to Minas Basin. Minas Passage is not a major contributor of fine-grained
sediment as it has largely been removed from this mature scoured region. It is merely a
conduit for the transfer of suspended sediment.


Sediment Transport

Minas Channel and Minas Passage

From a morphological perspective, most of the area of the Bay of Fundy is a
gently sloping surface from west to east with several anomalous deep scoured regions.
The largest of these occurs between Grand Manan Island and southwestern Nova Scotia
at the entrance to the Bay of Fundy where it is narrow and restricted. Such deep
depressions are attributed to fluvial followed by glacial erosional processes of over
deepening. For the inner Bay of Fundy, deep regions occur in central Chignecto Bay, two
off Cape DOr in Minas Channel and in Minas Passage. These deep regions are
characterized by rough topography, linearity, occurrence in narrow restricted bodies of
water or near projecting headlands and strong currents. They possess many other
morphological hallmarks of current scoured depressions. Some depressions are scoured
completely through sediments to bedrock while others contain sediments and are only
partially eroded. The common characteristic of these deep depressions is that they lie in
narrow passages with strong currents. Adjacent regions at broad ends of these
depressions are usually flat areas of thick sediments suggesting that material has been
eroded from the deep scoured regions and transported and deposited in adjacent regions
with lower velocity currents.

The scoured regions of the inner Bay of Fundy represent anomalous areas and
cover only a small proportion of the seabed. The in-stream tidal power demonstration
project is proposed to be located in Minas Passage which is one of these scoured
depressions. The history of development of the scoured regions indicates that they have
been initially formed by glacial erosion with subsequent sediment deposition. Fluctuating
sea levels and modern high current processes have continued to scour the sediments. The
following is a description of Minas Passage and the proposed development area that
includes the geological history, materials at the seabed, and observations on sediment
deposition and transport based on modern marine surveys.


34
Seabed of Minas Passage

The surficial sediments at the seabed of the Crown Lease area are all gravel that
is granules, pebbles, cobbles and boulders. This is interpreted from the MB backscatter
that indicates no mud or sand at the seabed. The sidescan sonograms also show high
reflectivity indicating that the seabed is very hard gravel. The high-resolution
multibeam bathymetry shows large boulders on the gravel and exposed bedrock surfaces.
Boulder measurements indicate that some are up to 5 m in diameter and they often appear
in clusters. Indeed, conditions that occur at the demonstration site are similar to those of
much of Minas Passage.

Questions have been posed about the stability and nature of the device sites and
the potential for local scour and effects on sediment transport and regional morphology
associated with device installations. Sediment samples are a very important component of
sediment modeling but they are very difficult to collect in Minas Passage. Subsurface
sampling is even more difficult because of the widespread occurrence of protective lag
gravel with rounded boulders. Large areas of the seabed of the demonstration site are
exposed bedrock in the form of upturned jagged ridges or flat volcanic areas. Attempts
were made at sampling the gravels and were only partially successful returning a few
gravel clasts in most cases. For an understanding of sediment transport, sediment
deposition and erosion, bottom photographs and video of the seabed provide critical
evidence. Bottom photographs have been collected regionally in the area and over 600
have been analyzed for particle size, shape, sorting, distribution, stability and biological
growth. This information has been integrated with the results from the interpretation of
the sidescan sonograms and high resolution multibeam bathymetry.

No sand sized sediments or silts and clays were observed on the seabed of the
Crown Lease area. Most of the photographs were taken during times of slack water or
close to it, and sand sized material that may have been in suspension as well as silts, clays
and organic matter would be expected to settle temporarily on the seabed. This was not
observed on the photographic data suggesting that in the study area little sand is in
suspension and that silt and clay are either in low concentration in the water column or
dont settle to the seabed. Greenberg and Amos (1983) measured and modeled suspended
sediments in the inner Bay of Fundy and showed that suspended sediments in Minas
Passage were less than 5 mg/l and stable at 2 mg/l throughout the Bay of Fundy to the
west. Additionally, pebbles, cobbles and small boulders have no attached biological
growth (Figure 13). Larger boulders and adjacent bedrock have broad coverings of low
growth that appears to start at about 20 cm above the seabed (Figure 14). This suggests
that the smaller gravel sizes that have clean surfaces may be moving and rolling around
as bedload and preventing growth in the zone immediate to the seabed. The movement is
likely local and confined by the bedrock ridges and large boulders of the region. No
boulders on the photographic imagery showed tilted sediment lines that would indicate
recent movement and repositioning. The seabed therefore, appears as a mature hard
scoured bottom of bedrock and gravel.

35
Most of the gravel clasts in the study area are round to subround in shape. A few
clasts are angular and may have been transported by ice. A simple interpretation is that
the rounding is due to present day active movement. However the larger rounded
boulders that occur in the same area do not move. The rounding is interpreted to have
occurred during times of lowered sea levels. Relative sea level in the region could have
fallen as low as 40 m in early post glacial time as the land quickly rebounded from the
removal of nearby glaciers. At times of lowered sea levels, large regions would have been
above or near sea level and beach processes of high energy during regressions and
transgressions would have produced the roundness of the boulders. Additionally the
lowered sea level would have resulted in erosion of both tills and glaciomarine fine
grained sediments that were previously deposited over bedrock. Thus the present seabed
is largely a relict bottom with modern elements of granule, pebble and cobble bedload
movement as well as sediment deposition by ice rafting. The lag gravel surfaces are
termed relict, that is, they reflect deposition and formation under differing conditions
(very high energy) in the past and have maintained these characteristics for thousands of
years to the present. They are not in dynamic equilibrium with present energy conditions.
For these reasons, samples of the gravel cannot be used in transport models that consider
that the entire seabed is in equilibrium with present conditions and responding to those
energy conditions.

Sediment Bedforms

Within Minas Passage there are five areas of bedforms in sand and gravel. On the
shallow nearshore shelf west of Cape Sharp and on the shelf off North Mountain there are
a series of small amplitude sand and mixed gravel bedforms oriented normal to the
shoreline. To the northwest and southeast of Black rock are areas of gravel waves (Figure
15). Bottom photographs show that these sediments are mostly pebble to cobble in size
and repetitive multibeam mapping shows that they alter their orientation and wavelength
but remain in the same area. Another large area of gravel bedforms occurs in the deep
Minas scoured trench close to the southern shore off Cape Split. This area of bedforms
may be part of a pair located to the west and east of the projection of Cape Split into the
Bay. These paired bedform features are termed banner banks, although in this case the
one in the Minas scour trench is gravel while the one to the west of Cape Split is
composed of coarse sand and fine gravel. The final area of gravel ripples occurs to the
south and southwest of Black Rock in deep water overlying bedrock ridges. Repetitive
multibeam bathymetric surveys over ten years show that these bedforms have slightly
changed their distribution and orientation with time. There are a few bedforms in gravel
within the Crown Lease proposed area in the northeast corner but none within the actual
device site proposed locations. Thus an interpretation of the sediment bedload transport
potential of the proposed area is that the seabed is very stable. Granules, pebbles and
cobbles may move locally but are not thick and abundant enough to form bedforms or the
flow conditions are not strong enough. The gravel is confined between bedrock ridges
and amongst large boulders that are widespread. None of the boulders show evidence for
movement or reorientation.


36
Sub Surface Sediments

What lies beneath the gravel and how thick the gravel and the underlying
sediments are, remains an issue that is not clearly understood. Two of the best high-
resolution seismic reflection systems available were used to penetrate the gravel layer and
resolve the layering and structure to bedrock. This was only successful in a few areas and
is the result of acoustic scattering from the presence of the hard rounded gravel clasts.
The seismic data from adjacent areas, as well as from the slope area to the north clearly
shows that stratified sediments interpreted as glaciomarine muds are the dominant glacial
sediment of the region and not till (Figure 11). Till normally contains over 50% gravel
and in strong currents is only slightly eroded and armoured by the cover of gravel, and
further erosion is suppressed. The fact that Minas Passage is a large deep scoured
depression means that till was not the dominant material that originally filled this
depression as it is not easily eroded in strong currents. Also the fact that the gravel is
relatively thin suggests that it was not derived from till where gravel makes up to 50 % of
that material. Glaciomarine sediments are thick regionally and this suggests that beneath
the gravel lag with boulders, remnants of the glaciomarine sediment could occur that
were once much more extensive. The thickness of the material over bedrock could be
greater closer to shore than further offshore. The wider the flat area between exposed
bedrock ridges, the greater likelihood that the surficial material is of greater thickness.
Some of the material beneath the gravel to the west was sampled with a robust dredge
and the material consisted of a very stiff red marine sediment, likely glaciomarine mud
(Figure 16). Typically this sediment consists of silt, clay, sand and a few gravel clasts. It
was deposited as the glaciers receded from the region through transport by water of sub
ice and englacial debris. Some of the gravel in Minas Passage could also have been
transported to the area by recent ice rafting.


Suspended Sediment

The first comprehensive Bay of Fundy wide assessment of suspended sediment
was conducted by Miller in 1966. Water samples were collected during both mid-flood
and mid-ebb from 43 stations at the bottom, 1 metre from the bottom, 10 metres from the
bottom and at the surface. Concentrations varied from 0.2 to 30.4 mg/l with an average
value of 6.6 mg/l for the 263 samples collected in the study. Sediment concentrations for
the entire water column throughout the tidal cycle greater than 8 mg/l occurred on the
northeast side of the Bay near the New Brunswick coast. Concentrations of less than 4
mg/l were found on the south side of the Bay particularly near the entrance.

Miller also examined the suspended sediment and found sand, silt, clay, plankton
and other organic debris. Silt and organic debris were the major components. Organic
carbon was determined to comprise 0.3 to 2.65 % by weight of the suspended load. From
X-ray diffraction analysis, illite, halloysite, kaolinite, quartz, feldspar and calcite were the
constituents in decreasing abundance.

37
Miller characterized the suspended sediment system in the Bay of Fundy as an
open system. He interpreted 4 components of the system: 1) an oscillating body of turbid
water, 2) a seabed that exchanges sediment with the overlying water, 3) minor fresh
turbid water input and, 4) minor turbid water release to the Gulf of Maine. The northwest
nearshore zone was described as a mud facies in a state of short-term equilibrium with
the overlying water. Seabed sampling at slack water revealed thin layers of fluid mud that
appeared to have settled out on the seabed. As the tide begins to flow it is mobilized. The
south side of Fundy is interpreted to be a winnowed Quaternary bottom of coarse
sediment with a long term transfer of fine-grained material in the suspended load. He
interpreted that this component eventually aggrades to the mud facies of the northwest
side.

Minas Basin

Suspended sediment was measured in Minas Basin by Pelletier and McMullen
(1972) from 60 water samples. Concentrations of particulates varied from 72 to 2680
grams per cubic m. All but three samples had in excess of 90 grams per cubic m and
more than half were between 100 and 200. The higher values came from samples
collected at low tide near the sediment-water interface and the highest ones were
collected after the tide had turned and was flooding across the exposed sediment surface.
Most of the sediment was reported to consist of silt and clay sized particles but some
consisted of fine and medium-grained sand.

Surface water at high tide contained 125 gm per cubic metre of sediment in
suspension. This is a considerable amount of material as compared to the open ocean
which contains on average 2 grams per cubic meter. Pelletier and McMullen (1972)
interpreted that material brought into Minas Basin from the Bay of Fundy proper is the
least important component of the sediment in the Minas Basin system. The major
contributor is the Avon, Salmon and Shubebacadie and other smaller rivers that dump
into Minas Basin. They considered Minas Basin as almost a closed system which is
filling up with fine-grained sediment.

Greenberg and Amos, 1983, studied the size, shape and composition of suspended
particulate matter in Minas Basin through analysis of 48 samples. The majority of the
material consisted of composite sedimentary particles. The modal diameter of the
particles was 30 um. The length of time the critical sheer stress is less than the value for
deposition in Minas Basin is approximately 1 h at high and low water slack periods. This
suggests that suspended particles that move through Minas Passage should fall to the
seabed for this period of time. In contrast to the study of Pelletier and McMullen (1972),
they suggested that the rivers in Minas Basin were not the main source for suspended
sediments and that the sediments came from the open ocean (the Bay of Fundy proper to
the west).




38
Inner Bay of Fundy Geological History and Suspended Sediments

In the inner Bay of Fundy, sediments, morphology, features and seabed processes
are much different than in the outer area. In the 1977 study of Fader et al., the inner
seabed was mapped as sand and gravel (Sambro Sand) with fields of large sand
bedforms. This sedimentary unit was considered to have formed both as a result of
proximity to the low sea level stand but also from modern strong currents generated by
the high tides of the Bay.

Unusual large areas of sub-sand mud were detected on the seismic profiles which
in places cropped out at the seabed. These subsurface deposits were mapped on Map
4011G and considered to be Holocene muds deposited on the underlying till when the
Bay of Fundy was much larger, deeper, and at a time of minimal dynamics. These muds
were later buried by two processes: proximity to the later low sea level stand which
produced transgressions and regressions and the much later increased dynamics of the
system from the development of the high tides. An extensive high-resolution seismic
reflection and sidescan sonar survey conducted in 1998 provided insight into these
interpretations and required a reinterpretation of the buried mud first considered to be the
Holocene LaHave Clay.

The new information clearly shows that the buried mud is glaciomarine Emerald
Silt (Figure 17). This sedimentary formation is coarser than the Holocene clay and
consists of silt, clay, sand and some gravel and was deposited by floating glaciers and
glacial plumes from sub ice water but not directly by ice contact with the seabed as is till.
Cores of these stratified sediments have been examined and consist of brick red thick
clayey silt. They are ice recessional deposits and are widespread over the inner Bay of
Fundy buried beneath sand and thin gravel lags including in Minas Channel. The Emerald
silt is also interbedded with the till in the form of features termed till tongues and these
represent former grounded ice positions.

Through either a low sea level stand associated marine transgression, or the onset
of tidal dynamics, the inner Bay of Fundy seabed has been greatly modified and reflects
more the dynamics of present conditions in contrast to the iceberg scoured relict tills in
the outer Bay which have remained unchanged. Multibeam Bathymetry was collected off
Margaretsville Nova Scotia in the inner Bay of Fundy west of Minas Channel over a field
of large sandy bedforms. An interpretation of these bedforms and associated erosional
moats has provided new insights into modern processes which are thought to contribute
large amounts of glacial age mud to the water column (Fader, 1996). This represents a
new understanding of the sediment budget in the Bay of Fundy and has defined a
previously unknown source of fine-grained sediment. It has implications to sediment
transport, changes observed in the fishery, changes observed in the nature of the mud
flats and their relationship to the semi-palmated sandpiper, and observations on seabed
over deepening.


39
Based on interpretation of the new multibeam bathymetry (2006 2008) collected
by the Canadian Hydrographic Service and the Geological Survey of Canada (Atlantic),
fine-grained sediment in suspension in Minas Passage is interpreted to be sourced from
the inner part of the Bay of Fundy, from adjacent Minas Channel in the west, from the
entrance to Minas Basin in the east and from near shore slope areas of the northern part
of Minas Channel where slumped deposits occur. The multibeam bathymetry from Minas
Channel and the entrance to Minas Passage shows that scouring of the seabed in
glaciomarine sediments is a continuing process over very large areas and that the seabed
has not been scoured down to the bedrock as has Minas Passage. Some sediment may
also be eroded from the northwestern area of Minas Passage where thick sediments cover
the bedrock surface and show evidence of elliptically-shaped scour features with internal
bedforms. This suggests a selective erosion of silt and clay and the formation of bedforms
in residual sand and gravel. Similar scoured depressions and large sand bedforms occur in
Minas Channel to the west (Figure 18).

Sediment traps were placed on the ADCP systems to sample and determine the
nature of sediments in suspension in Minas Passage. Samples from these traps contained
fine-grained muds, minor sand and granules and a few pebbles. It is not clear if the
material in the traps was collected by settling during slack water or inadvertently during
difficult recovery efforts through system dragging. The dominance of marine growth on
bedrock and boulders above a 20 cm exclusion zone suggests that the bedload zone is
confined to the immediate seabed so that granules, pebbles and cobbles would not likely
be transported above that level. Repetitive multibeam bathymetric comparisons show that
the water depths have not changed over a two year interval except in small areas in a
moat region along the north flank of the volcanic platform where granules exist. Such a
lack of erosional and depositional change is also evidence for a stable seabed. Current
measurements at the seabed have a maximum velocity of 5 knots that is not enough to
transport boulders.

The potential for seabed scour associated with gravity platforms depends on the
design that includes the area and shape of the platform feet and whether they are located
on bedrock or gravelly seabeds. The thickness of the gravel at the seabed and the
presence if any of subsurface till or glaciomarine muddy sediments is an important
component of such an assessment. Based on the regional distribution of sediments above
bedrock and between bedrock ridges it is interpreted that the subsurface material would
be patchy in distribution and have a variable thickness.

40


Figures






Figure 13. A bottom photograph of the seabed in Minas Passage showing a typical
bottom of gravel granules, pebbles and cobbles. The clasts consist of a variety of
lithologies ranging from metasedimentary to igneous rocks. Note a lack of growth on the
clasts and an absence of a thin cover of sand or mud despite being collected at slack
water.


41


Figure 14. A bottom photograph from Minas Passage showing a gravel seabed consisting
of granules, pebbles, cobbles and boulders. The larger clasts are small boulders and have
a sponge growth cover above a clean zone that is interpreted as the bedload transport
zone approximately 20 cm in height. This suggests that the granules, pebbles and cobbles
may move in response to currents.




Figure 15. A multibeam bathymetric image of the seabed to the northwest of Black
Rock, Minas Passage showing a zone of gravel ripples. Repetitive multibeam mapping
across these features shows that they have altered their pattern of distribution but that the
field has not changed location. Bottom photographs from this area show the clasts in the
bedforms are pebbles and cobbles.

42


Figure 16. Photograph of a sample of stiff red mud collected by a rock dredge that
penetrated the gravel lag surface in the northern area of Minas Passage. The material is
similar to cored glaciomarine sediments in other areas of the inner Bay of Fundy that
were deposited approximately 13 000 years ago during the retreat of the glaciers from the
region. This material may underlie other areas of flat gravel lag in Minas Passage.



Figure 17. A seismic reflection profile from Minas Channel that shows thick
glaciomarine sediments beneath gravel lag surfaces and sand bedforms. Thin till overlies
the bedrock surface and the glaciomarine sediments are very thick and widespread in this
area of the inner Bay of Fundy.

43





Figure 18. A multibeam bathymetric image of the seabed of Minas Channel. The region
is flat gravel covered glaciomarine sediment. A large scoured region of seabed is shown
that contains many singular symmetric sand waves within the depression. This is an area
of active erosion but the currents are likely not strong enough to transport the sand sized
material out of the depression. Large quantities of silt and clay are eroded from this
feature and are likely transported as suspended sediments.
44
References

Amos, C.L., 1984. An overview of sedimentological research in the Bay of Fundy, in:
Gordon, D. C. and Dadswell, M. J., eds. Canadian Technical Report of Fisheries and
Aquatic Sciences No. 1256, Fisheries and Oceans Canada.

Byrne, T., Hughes Clarke, J.E., Nichols, S. and M-I, Buzeta, 2002, The delineation of the
seaward limits of a Marine Protected Area using non-terrestrial (submarine) boundaries
The Musquash MPA : Canadian Hydrographic Conference Proceedings.

Courtney, R. C. and Fader, G.B.J., 1994. A new understanding of the ocean floor through
multibeam mapping: Science Review 1992 and 1993 of the Bedford Institute of
Oceanography. Dept. of Fisheries and Oceans, p. 9-14.

Curran, K.J., T.G. Milligan, G. Bugden, B. Law, and M. Scotney. 2004. Suspended
Sediment, Water Quality, and Hydrodynamics of the Petitcodiac River Estuary, New
Brunswick (20022003). Can. Tech. Rep. Fish. Aquat. Sci. 2516: xi, 88 p.

Fader, G.B., King, L.H. and MacLean, B, 1977. Surficial Geology of the Eastern Gulf of
Maine and Bay of Fundy; Marine Sciences Paper 19, 23 p. (Geological Survey of Canada
Paper 76-17).

Fader, G.B.J., 1996. Marine aggregate assessment and sediment transport. In workshop
Proceedings, Bay of Fundy Issues: a scientific overview, Wolfville, NS, Jan 29 to
February 1, 1996, Edited by J.A. Percy, P.G. Wells and A.J. Evans, Environment Canada
Report No. 8, Pg. 30 33.

Gordon, D. C. and Dadswell, M. J., 1984. Canadian Technical Report of Fisheries and
Aquatic Sciences No. 1256, Fisheries and Oceans Canada.

Parrott, R; Parsons, M; Li, M; Kostylev, V; Hughes Clarke, J; Tay, K -L;
Multidisciplinary approach to assess sediment transport and environmental impacts at an
offshore disposal site near Saint John, NB. in, The Atlantic Geoscience Society/La
Socit Goscientifique de l'Atlantique - 32nd Colloquium and Annual Meeting, program
with abstracts; 2006; pages 57-58 (ESS Cont.# 2005624)

G.R. Daborn and M.J. Dadswell, 1988, Pages 547-560. Natural and anthropogenic
changes in the Bay of Fundy - Gulf of Maine - Georges Bank System. In Natural and
Man-Made Hazards, edited by M.I. El-Sabh and T.S. Murty. D. Reidel Publishing Co.
(1988).


Pelletier, B. R. and McMullen, R. M. 1972, Sedimentation patterns in the Bay of Fundy
and Minas Basin, in, Tidal Power, eds. T. J. Gray and O. K. Gashus, Plenum Publishing
Corporation, New York, N. Y. p. 153 - 187.

45
Shaw, J., Parrott, D. R., Parsons, M. B., Taylor, R. B. and Patton, E., 2003. Assessing
marine environmental quality in coastal waters of eastern Canada: Effects of offshore
disposal of dredged materials, Geological Survey of Canada, Geoscience for Ocean
Management (GOM) web site.

























46
Seismic Hazard, Faults and Earthquakes: Inner Bay of
Fundy


Introduction
This report provides an assessment of the seismic hazard for the area of the
proposed tidal power demonstration project in Minas Passage, Bay of Fundy, as well as
the regional and local distribution of faults and earthquakes. Within Canada, the Bay of
Fundy area occurs within the Northern Appalachian Seismic Zone (NAN). Figure 19
shows the historical seismicity in eastern Canada and Figure 20 is a more detailed map of
the location of seismicity in NAN during varying time periods.
The Geological Survey of Canada (NRCan) has produced a new seismic hazard
model (GSC Open File #5813, 2008) and a suite of new seismic hazard maps for Canada
and this report draws on the excellent information provided by the GSC that is available
on their web site.

http://earthquakescanada.nrcan.gc.ca/hazard/index_e.php

GSC Open File # 4459 presents the development and rationale for the model, the
detailed model itself, and results for selected cities and areas of Canada. Open file #5813
makes available seismic hazard values for a grid of more than 200,000 points over
Canada and surrounding areas. They were computed using the final methods and model
used for the 2005 National Building Code of Canada. These values represent median
ground motion on firm soils for a probability of exceedance of 2% in 50 years for the five
ground motion parameters (5% damped spectral acceleration of 0.2, 0.5, 1 and 2 second
periods plus peak ground acceleration.
The Northern Appalachians Seismic Zone (NAN) includes most of New
Brunswick, western Nova Scotia and extends into New England. No earthquakes are
shown to occur in the Minas Channel, Minas Passage and Minas Basin region of Nova
Scotia on this compilation.
Background on earthquakes in eastern Canada
The continual movement of large segments of the earth's tectonic plates is the
cause of more than 97% of the world's earthquakes. Eastern Canada is located in a stable
continental region within the North American Plate and has a relatively low rate of
earthquake activity. Nevertheless, large and damaging earthquakes have occurred there in
the past and may occur in the future.
Rate of Activity
Approximately 450 earthquakes occur in eastern Canada each year. Of this
number, perhaps four will exceed magnitude 4, thirty will exceed magnitude 3, and about
47
twenty-five events will be reported just as felt. On average, a decade will include three
events greater than magnitude 5. A magnitude 3 event is sufficiently strong to be felt in
the immediate area, and a magnitude 5 is generally the threshold of damage. The
seismograph network in Canada can detect all events exceeding magnitude 3 in eastern
Canada and all events magnitude 2.5 or greater in densely populated areas.
Causes
The causes of earthquakes in eastern Canada are not well-understood. Unlike
plate boundary regions where the rate and size of seismic activity is directly correlated
with plate interaction, eastern Canada is part of the stable interior of the North American
Plate. Seismic activity in areas like these tends to be related to the regional stress fields,
with the earthquakes concentrated in regions of crustal weakness. Although earthquakes
can and do occur throughout most of eastern Canada, years of instrumental recordings
have identified certain clusters of earthquake activity. In these clusters, earthquakes occur
at depths varying from surface to 30 km deep.

Seismic Hazard in Canada

Although earthquakes occur in all regions of Canada, certain areas have a higher
probability of experiencing damaging ground motions. This probability is used in the
National Building Code to help design and construct buildings that are as earthquake
proof as possible. Figure 21 provides an idea of the likelihood of experiencing strong
earthquake shaking at various locations. This map shows the relative seismic hazard
across Canada for single family dwellings (1-2 story structures). The map indicates that
the site of the proposed tidal power demonstration project in Minas Passage occurs in an
area where the relative hazard is considered to be low.
The damage potential of an earthquake is determined by how the ground moves and
how the buildings within the affected region are constructed. Expected ground motion
can be calculated on the basis of probability, and the expected ground motions are
referred to as seismic hazard.
The evaluation of regional seismic hazard for the purposes of the National Building
Code of Canada (NBC) is the responsibility of the Geological Survey of Canada. The
seismic hazard maps prepared by the Geological Survey are derived from statistical
analysis of past earthquakes and from advancing knowledge of Canada's tectonic and
geological structure. On the maps, seismic hazard is expressed as the most powerful
ground motion that is expected to occur in an area for a given probability level. Contours
delineate regions likely to experience similarly strong of ground motions. The simplified
seismic hazard map (Figure 21) indicates the relative hazard across Canada.

The seismic hazard maps and earthquake load guidelines included in the National
Building Code are used to design and construct buildings to be as earthquake proof as
possible. The provisions of the building code are intended as a minimum standard. They
are meant to prevent structural collapse during major earthquakes and thereby to protect
48
human life. The provisions may not, however, prevent serious damage to individual
structures.
Seismic Hazard Information in the National Building Code (NBC)

Building design for various earthquake loads is addressed in sections 4.1.8,
9.20.1.2, 9.23.10.2, 9.31.6.2, and 6.2.1.3 of the 2005 NBC. In addition, a table in
Appendix C starting on page C-11 of Division B, volume 2 of the Code provides ground
motion design values for many of the larger communities across Canada. While the
National Building Code is chiefly intended for new buildings (Article 1.1.1.1 of Division
A), appendix A (appendix note A-1.1.1.1) outlines the principles by which the code
should also be applied to the use and modification of existing buildings.
The seismic hazard is described by spectral-acceleration values at periods of 0.2,
0.5, 1.0 and 2.0 seconds (Figures 22 -25). Spectral acceleration is a measure of ground
motion that takes into account the sustained shaking energy at a particular period. It is a
better measure of potential damage than the peak measures used by the previous 1995
code, and thus will improve earthquake-resistant design. Peak Ground Acceleration is
still used for foundation design. All parameters are expressed as a fraction of gravity. The
four spectral parameters allow the construction of uniform hazard spectra (UHS) for
every place in Canada.
Ground motion probability values are given in terms of probable exceedence, that
is the likelihood of a given horizontal acceleration or velocity being exceeded during a
particular period. The probability used in the 2005 NBC is 0.000404 per annum,
equivalent to a 2-per-cent probability of exceedence over 50 years. This means that over
a 50-year period there is a 2-per-cent chance of an earthquake causing ground motion
greater than the given expected value.
Calculation of Seismic Hazard
The seismic hazard at a given site is determined from numerous factors. Canada
has been divided into earthquake source regions based on past earthquake activity and
tectonic structure. The relation between earthquake magnitude and the average rate of
occurrence for each region is weighed, along with variations in the attenuation of ground
motion with distance. In calculating seismic hazard, scientists consider all earthquake
source regions within a relevant distance of the proposed site. The four spectral
acceleration seismic hazard maps show levels of ground shaking at periods of 0.2, 0.5,
1.0 and 2.0 seconds (equivalent to frequencies of 5, 2, 1, and 0.5 Hertz). This is important
because different buildings are susceptible to different frequencies of earth motion, and
damage is frequently associated with a resonance between earthquake ground motion and
the building's own natural frequency. A high-rise of ten stories or more may sway with a
natural period of 1 or 2 seconds, whereas in response to the same earthquake a brick
bungalow across the street may vibrate at nearly 10 Hertz. The UHS is a description of
the seismic hazard at a site in terms of building height.
49
In building construction and design, not only the size of a probable earthquake
should be considered, but also the nature of the ground motion most likely to occur at the
site. Seismic hazard calculations provide part of this information. As our understanding
of earthquakes and of their effects on engineered structures continues to develop, the
seismic provisions of the National Building Code are revised to enhance public safety
and minimize earthquake losses.
Earthquakes in New Brunswick

A summary of the historical earthquake activity in the province of New
Brunswick is contained in a report by Burke, (2005). Most of New Brunswick lies within
the Northern Appalachian Zone (NAN), as shown on the map of earthquakes in Eastern
Canada and has experienced several earthquakes in the magnitude 5 to 6 range. The
exception is the northwestern part of the province with a few smaller magnitude
earthquakes, which lies within the Eastern Background Zone. New Brunswick has also
felt the effects of larger events from the Charlevoix-Kamouraska Zone, Lower St.
Lawrence Zone and the Laurentian Slope Zone.
In New Brunswick, epicentres cluster in three regions (Burke, 1984);
Passamaquoddy Bay region, Central Highlands (Miramichi) region, and the Moncton
region. Earthquakes have been more frequent in these regions and sometimes of a size to
be potentially damaging (larger than magnitude 5). Figure 29 shows the distribution of
earthquakes from 2004 to the present and two small ones are located to the west and east
of the proposed tidal power demonstration area.
Faulting in the Bay of Fundy Region
The most widespread and significant fault or fault zone in the Bay of Fundy
region is the Chedabucto-Cobequid fault system. It is part of a much larger transform
fault system that extends from the Grand Manan area of the outer Bay of Fundy, north of
Minas Basin, across Nova Scotia, through Chedabucto Bay to the Laurentian Channel.
The name Glooscap Fault System has been proposed for this system that also includes
the marine sector (King and MacLean, 1976). They further proposed that it might join
with the Newfoundland fracture zone in deep water to the east and involve oceanic crust.
The fault system is essentially Triassic/Jurassic and earlier in age but there is evidence for
additional faulting in Cretaceous time and perhaps recent activity on the eastern Scotian
Shelf and in the adjacent Laurentian Channel.
Map 812H (King and Maclean, 1976) shows the distribution of faults of the
Glooscap Fault System in the Bay of Fundy. It consists of a linear continuous
discontinuous fault that extends from Ile Haut in the east, westerly to a few kilometers off
the south coast of New Brunswick at Cape Spencer where it changes direction and
continues southwesterly to Grand Manan Island in the outer Bay of Fundy. There it joins
a series of other faults bordering pre-Pennsylvanian acoustic basement. North of this
western area of the fault, the Triassic sediments are structurally disturbed in a broad zone
that continues to the Passamaquoddy Bay region in the north.
50
As reported in King and MacLean 1976, in the disturbed zone the aeromagnetic
data shows considerable variation in contrast to the typically smooth signature of the
Triassic/Jurassic rocks through the remainder of the basin. Fader (1989) conducted a
high-resolution seismic reflection survey over the northern part of the disturbed zone to
determine if any of the faults had affected the Quaternary overlying sediments in order to
assess recent activity. The faulted Triassic/Jurassic sediment is overlain by thick
glaciomarine stratified sediments that would record any activity on the faults below. The
survey showed that the overlying sediments were not disturbed in any way indicating no
activity of the faults over the past 15 18 000 years. This is contrast to the eastern
Scotian Shelf were north of Banquereau, both glaciomarine Emerald Silt and LaHave
Clay Holocene sediments are faulted and contorted along the offshore extension of the
Glooscap Fault System.
Seismic activity along the Chedabucto-Cobequid fault near the proposed
development site consists of two small earthquakes epicentres. One occurred off Cape
Chignecto in the Bay of Fundy near the entrance to Chignecto Bay and the other occurred
17 km south east of Springhill. Appendix 1 shows a map of the earthquakes in the region
over the past five years as well as a listing of the dates, times, locations, depths,
magnitudes and regions from the GSC earthquake data base.
Portapique Fault
Within Minas Passage the most evident fault is the Portapique Fault. It lies to the
south of the volcanic platform that projects to the west from Black Rock and extends
from an area off Cape Sharp in the east, to an area to the northwest of Cape Split for a
distance of over 13 km (Figures 5,10). It is manifest on the multibeam bathymetry as a
linear depression that varies in width up to 50 m. Along some parts of the fault, both
northern and southern flanks consist of prominent ridges. The depression associated with
the fault is interpreted to arise from preferential erosion of weaker and fractured rocks. It
is difficult to determine the horizontal offset along this fault as the strike of the exposed
bedrock on both sides is the same. Wade et al., (1996) have mapped a prominent fault on
land to the east that may be the same as the one identified from the multibeam
bathymetry. It is the Portapique Fault that begins in the west near Cape DOr and extends
to the east past Truro, sub parallel to the Cobequid Fault but further to the north. The
Portapique Fault on land sets the Carboniferous rocks against the Triassic deposits which
surround Cobequid Bay. In the offshore the strata exposed on both sides of the fault on
the multibeam bathymetry have the same strike so it is difficult to determine the amount
of strike slip offset. The character of the bedrock exposure on either side of the fault is
quite similar suggesting that the rocks may be of the same age. This is in agreement with
the bedrock geology interpretation from the 1966 Huntec Ltd. survey but not in
agreement with the interpretation by King and MacLean, 1976 that suggested that most of
the rocks in Minas Passage are Triassic (Jurassic).The Huntec Ltd. 1966 survey suggested
that the contact between the Carboniferous rocks and Triassic rocks is interpreted to be
further to the south in the deepest part of Minas Passage in what has been termed the
Minas Passage Scour Trench. Although the Portapique Fault is a prominent fault on the
multibeam bathymetry, there is no evidence for seismic activity on this fault.
51

Deformed proglacial deltaic sediments have been found at Economy Point
Lower Five Islands, Nova Scotia (Broster and MacDougall, 1996). Fluid escape
structures were attributed to the expulsion of groundwater during post glacial seismic
shaking of saturated sediments. Dating of charcoal associated with the fluid escape
structures suggests significant seismic shaking around 1870+- 70 years. The deformation
may have resulted from the 1855 M5+ earthquake that occurred in New Brunswick, 100
km to the northwest near Moncton.
Minas Passage Proposed Tidal Power Site Assessment
An assessment of the proposed tidal power demonstration site has been evaluated
against the 2005 National Building Code of Canada. Appendix 1 below shows the
spectral and peak hazard values for firm ground. The values have been interpolated from
a 10 km spaced grid of points. More than 95% of the interpolated values are within 2% of
the calculated values.

52



Appendix 2
53
Summary and Conclusions
Seismic zoning maps for Canada are derived from the analysis of past earthquakes
and advancing knowledge of Canada's tectonic and geological structure. Canada is
divided into earthquake source regions based on past earthquake activity and tectonic
structure. The relation between earthquake magnitude and the average rate of occurrence
for each region is considered, along with variations in the attenuation of ground motion
with distance. In calculating seismic hazard, scientists consider all earthquake source
regions within a relevant distance of the proposed site. On the maps, seismic hazard is
expressed as the maximum ground motion that is expected to occur in an area with a
given probability. Contours delineate zones likely to experience similar intensities of
shaking.
Minas Passage is located within the Northern Appalachian Seismic Zone (NAN).
Maps of seismic risk in the 2005 code show the area occurs within Zone 1 and is
considered to have a low earthquake risk. In fact, Canada to the east of the Cordillera,
extending north from the United States border to the Arctic Ocean, comprises about two-
thirds of the stable craton of the North American plate. Much of this large area appears to
be substantially aseismic, although it contains several zones of significant seismicity and
a few other regions of lower-level seismicity. Historically, earthquakes in the Minas
Passage region have been infrequent and of small magnitude. The nearest zone of
earthquake activity is likely associated with the Chedabucto-Cobequid Fault System and
consists of two small earthquakes to the west and east. These did not occur within the
proposed tidal power demonstration area.

54
Figures



Figure 19. A map of the historical seismicity in eastern Canada.



Figure 20. A more detailed map of the location of seismicity in the NAN area of eastern
Canada.
55


Figure 21. A simplified seismic hazard map of Canada.

Figure 22. Spectral acceleration for a period of 0.2 seconds in southeastern Canada at a
probability of 2%/50 years for firm ground conditions (NBCC soil class C).
56




Figure 23. Spectral acceleration for a period of 0.5 seconds in southeastern Canada at a
probability of 2%/50 years for firm ground conditions (NBCC soil class C).







57




Figure 24. Spectral acceleration for a period of 1.0 seconds in southeastern Canada at a
probability of 2%/50 years for firm ground conditions (NBCC soil class C).







58




Figure 25. Spectral acceleration for a period of 2.0 seconds in southeastern Canada at a
probability of 2%/50 years for firm ground conditions (NBCC soil class C).







59




Figure 26. Distribution of earthquakes from 2004 to 2009 in the Bay of Fundy region.
60
References

Adams, J; Halchuk, S., 2003. Fourth generation seismic hazard maps of Canada: values
for over 650 Canadian localities intended for the 2005 National Building Code of
Canada; Geological Survey of Canada, Open File 4459; 155 pages.
Burke, K.B.S. 1984: Earthquake activity in the Maritime Provinces, Geoscience Canada,
v. 11, p. 16-22.
Burke, K. S. 2005, A summary of the historical earthquake activity in the province of
New Brunswick. University of New Brunswick Web Site.

Fader, G. B. J., 1989, Cruise Report 88-018, Phase 4 and 88-018, Phase 5, M.V. Navicula
- Passamaquoddy Bay and Bay of Fundy, 22 p.

Halchuk, S; Adams, J., 2008. Fourth generation seismic hazard maps of Canada: Maps
and grid values to be used with the 2005 National Building Code of Canada; Geological
Survey of Canada, Open File 5813; 32 pages.

King, L. H. and MacLean, B., 1976. Geology of the Scotian Shelf, Geological Survey of
Canada paper 74-31. 31 p., enclosure Map 812H.

National Building Code of Canada, 1995. NRCC no. 38726; section 4.1.9.1 sentence 5
and Appendix C: Climatic Information for Building Design in Canada
Richter, C. 1958. Elementary seismology. W.H. Freeman and Co., New York.









61
Glacial, Post Glacial, Present and Projected Sea Levels: Bay of
Fundy

Relative Sea level Change - the Bay of Fundy Region

Former Quaternary shorelines have been identified at elevations as high as 75 m
above present sea level and over 100 m below in Atlantic Canada. In contrast to the
glacial and early post glacial history of sea level change, sea level appears to be rising in
Maritime Canada today at a rate of between 20 and 30 cm/100 years. This has been
attributed to long term climate change and crustal subsidence (Scott et al., 1995). A
summary of the glacial history of the region over the past 100 ka provides an
understanding of the relative sea level change and a perspective on future potential
change.

The sea level history of the region also controls to a large degree the
characteristics of materials deposited in association with both high and low sea level
stands and the intervening areas that have been transgressed and regressed. Within recent
years, an understanding of sea level change associated with global warming has added an
additional amount of potential sea level rise to that predicted from crustal movements
alone. For the proposed tidal power demonstration project in Minas Passage, former sea
level positions have controlled to a large degree the characteristics of the materials on the
seabed and on the adjacent land. An understanding of the future projected change in sea
level that includes effects of global warming is important for the design of project
infrastructure.

Quaternary glaciers played a major role in sea level change and for Atlantic
Canada two opposing glacial models termed maximum and minimum models were put
forth. The maximum model suggests that ice extended across the entire region to the
continental slope from a Laurentide ice centre in Quebec, (Goldthwait, 1924, Denton and
Hughes, 1981, Shaw et al., 2002). The minimum model suggests the presence of only
local thin glaciers during the late Wisconsinan (Grant, 1977; Dyke and Prest, 1987).
Through mapping of the glacial landforms and materials both on land and in the offshore,
a more complex model of Wisconsinan glaciation (the last major ice advance in Atlantic
Canada) has been developed and it appears to be closer to the maximum model.

The following discussion is a summary of findings in Stea et al., 1998; Shaw et
al., 2002 and the results of mapping of sediments in the Bay (Fader et al., 1977, Fader,
1989) and adjacent coastal areas with an emphasis on the Bay of Fundy region. Recently
collected seismic reflection data and multibeam bathymetry in Minas Passage have
provided high resolution information for an understanding of the relative sea level low
stand at the proposed tidal power demonstration site.




62
Sea Levels during the Previous Interglacial

A regional former sea level position prior to the Wisconsinan glaciation has been
mapped and interpreted as an abrasion surface 4 6 m above present sea level in parts of
Nova Scotia. It is overlain in places by peat and wood beyond the range of radiocarbon
dating (Grant 1980). This rock platform has been interpreted as an erosional surface
formed during the last interglacial period (marine isotope stage 5e) approximately 120
000 ybp. Grant interpreted that it represents an important former equilibrium position of
sea level due to glacier melting and crustal subsidence after the previous major glacial
episode. Marine sands have been found in both northern and southern Nova Scotia at
elevations of 25 m and provide further evidence for higher sea levels.

The amount of relative sea level rise during the last interglacial may be an
important indicator of present and future sea level rise in Maritime Canada. Based on the
present rate of sea level rise, and not considering effects of global warming on sea level
rise, it would take approximately 2 ka to raise sea levels by 6 m (the height of the old
abrasion platform). Such estimates represent a minimum as the rate of subsidence is
expected to decrease exponentially (Pirazzoli, 1996).

Late Wisconsinan Sea Levels 20 10 KA

During the earliest Wisconsinan phase of ice flow, ice extended across the region
to the continental slope where it was grounded in over 300 m of water depth and perhaps
as much as 800 m. Deglaciation began earliest in the southwest (outer Gulf of Maine) as
early as 21 ka and progressed across the continental shelf in a time transgressive manner
with the last ice remaining on the eastern Scotian Shelf. Ice retreated rapidly out of the
Gulf of Maine and up the Bay of Fundy because of their great depths and linear
morphological connection to the ice centres. This removal isolated an ice mass on Nova
Scotia (Scotian Ice Divide) that later became an active ice centre. The isolated ice cap
was drawn into the deeper Bay of Fundy where it formed streamlined deposits of till on
the seabed.

In the Bay of Fundy there is an anomalous northeast trend to lower marine limits
from over 40 m at the mouth to 0 near the Bay head (Figure 27). The shorelines are tilted
toward a local late ice centre, the source of the ice flow out of the Bay of Fundy. Stea
(1982) suggested that shorelines around the Bay of Fundy are diachronous and the marine
limit may not be a function of ice thickness but of protracted ice retreat to local ice
centres. This may have prevented the formation of beaches in some areas. Widely
varying ages on raised marine deposits from both sides of the Bay support this idea.


Relative Sea Level History of the Bay of Fundy

The relative sea level history in the Bay of Fundy is very complex with the
lowstand shoreline shallowing from southwest to northeast (Fader, 1989, Fader et al.,
1977, Shaw et al., 2002). The following is a discussion of the high and low stand history
63
of sea levels and new ideas resulting from the collection and interpretation of multibeam
bathymetry in the Bay. Former high sea level stands are relatively easy to locate, interpret
and map. Most are associated with rock platforms, beach sediments of well-sorted sand
and rounded gravel, terraces and sometimes deltaic sediment deposits where rivers and
streams entered the former sea. Lidar imagery and aerial photographs also show
vegetation changes possibly related to textural properties of the sediments that affect
water content and the presence of subtle terrace and beach morphological features. They
are difficult to interpret from on-land field investigations alone.

Determining the position of former lower sea level stands that are presently
submerged is a much more difficult problem. Seabed features indicative of low sea level
stands and subsequent transgressions include: terraces, erosional surfaces and
unconformities, sediment textural characteristics of winnowing, absence of fine-grained
sediment, erosion of glacial till and glaciomarine sediment, muted topography and
relative greater exposures of bedrock. Dating these low sea level stands is also very
difficult as material suitable for dating, such as marine shells, must be confirmed to have
formed in situ in low stand deposits. With the advent of multibeam bathymetric mapping,
subtle morphologic characteristics of low sea level stands are becoming easier to
recognize and interpret. However, in areas of high energy, such as the Bay of Fundy,
overprinting by modern sediment transport processes has resulted in the burial of low
stand features or their removal, making recognition more difficult. The following is a
summary of the low stand sea level evidence from the Bay of Fundy (Fader et al., 1977)
and a discussion and interpretation of recent multibeam bathymetry.

The lowest position of sea level in post glacial time prior to the Holocene marine
transgression is critical to the distribution of sediments, their stratigraphic relationships,
sediment texture and seabed features such as exposed bedrock, former channels, etc. For
the Scotian Shelf and outer Gulf of Maine, this position has been interpreted to occur at a
depth of approximately 115 120 m in the offshore and 65 -70 m in the near shore.

Within the Bay of Fundy, the low sea level stand has been interpreted to occur at
a depth of between 40 to 60 m gradually decreasing in depth from 110 m near German
Bank, Gulf of Maine to the southwest of Yarmouth. In the Fader et al. (1977) study,
glacial till and glaciomarine sediments were found in the Bay of Fundy well above the
depth of occurrence of the low stand on the adjacent Scotian Shelf. At the entrance to the
Bay of Fundy a noted increase in the silt and clay component from sediment samples
supports a decrease in the former sea level position. The grain shape of the gravels in the
outer Bay of Fundy also supports this model. Transgressed gravel surfaces consist of
well-rounded to rounded clasts and the gravels in the Bay below are angular to
subangular in shape.

Along the south-western and south-eastern coasts of Nova Scotia there is no
evidence for a postglacial marine limit higher than the present shoreline. Studies by
Goldthwait (1924), Hickox (1962), Bloom (1963), Swift and Borns (1967), Grant (1971)
and others have found widespread raised marine strandlines and marine deposits in the
area to the north of Yarmouth and along the south and north coasts of the Bay of Fundy
64
and the Gulf of Maine. These features attest to late and post glacial significant rebound.
In Nova Scotia the marine limit increases in elevation from a hinge line slightly north of
Yarmouth and trends generally northeastward on land parallel to the geographic axis of
the Bay of Fundy. Along the Nova Scotian side of the Bay, the highest marine limit is 45
m at Digby Gut (Grant 1971 and Stea et al., 1998). In contrast, the height of the marine
limit in New Brunswick is 73 m above present sea level (Gadd, 1973). A minimum age
for this limit is 13 325 ybp. In central Maine the height of the marine limit is even higher
at 135 m (Stuvier and Borns, 1975) and is dated at 13 000 ybp. This shows that a tilt
existed across the Bay of Fundy due to greater depression of the crust in New Brunswick
and Maine as a result of closer approximation to the Laurentide ice centre. Although
formed at the same time, there is approximately a 30 m difference in the present elevation
of the marine limit in a line of section across the Bay of Fundy from Digby to Saint John.

Sea Level History Post Marine Limit Formation

The marine limit (highest level of marine water on land) formed some time after
the ice retreated or is coequivalent with the timing of ice retreat. In some areas ice cover
may have prevented the formation of raised marine features, hence, they are
discontinuous. The early post glacial body of water that existed in the area of the Bay of
Fundy has been termed the DeGeer Sea and was considerably larger than the present
Bay extending up the Annapolis Valley and the St. John River Valley flooding large
areas of present land.

After 13 500 ybp, isostatic rebound exceeded the rate of eustatic sea level rise
resulting in a marine regression across the former sea bed (elevations presently to a
maximum of 45 m) with a resulting emergence of the land. Through this process of rapid
isostatic rebound, the relative sea level in the Bay of Fundy fell during the time period of
13 000 to approximately 9 500 ybp. Grant (1971) studied aggraded material in intertidal
estuaries and estimated that sea level fell to a position 20 - 30 m below the present level.
Recent studies in coastal and nearshore Maine by Belknap et al. (1989) show the
presence of a widespread unconformity at a present water depth centered around 60 m.
Studies of the surficial geology of Passamaquoddy Bay using seismic reflection profiles
by Pecore and Fader (1991), also recognized a regional unconformity at a depth of 60
below Holocene pockmarked muds that was developed on glaciomarine sediments.
Recently collected multibeam bathymetry from several areas of the Bay of Fundy shows
a variety of previously unrecognized seabed features such as iceberg furrows, fluted till
and sub parallel transverse moraines in water depths greater than 60 m that are likely too
delicate to have survived a marine transgression intact and support the interpretation of a
higher low sea level position. Deltaic deposits have also been found in similar depths
with high-resolution seismic reflection profiles.

After formation of the low sea level stand at approximately 9 500 ybp, relative sea
level began to rise and transgressed areas above 60 m water depth continuing to the
present shoreline. Transgressions can be very effective erosional mechanisms compared
to regressions where sediments tend to be armoured and not undercut and are thus
preserved. In the Bay of Fundy, tills and previously deposited glaciomarine sediments
65
were eroded, armoured with lag gravels and the topography was smoothed and muted in
this transgressed zone of between 60 m water depth and the present shoreline. Subsequent
strong currents resulting from the development of high tides in the Bay of Fundy further
armoured this surface and continue to do so at present.

Amos and Zaitlin (1985) studied the sea level history for the inner Bay of Fundy
in Chignecto Bay. They suggested a relative sea level fall from a high of 48 m at about
13,500 ybp to a low of 25 m at 7000 ybp. Additionally, Amos et al., (1991) suggested
that there were actually two times of macrotidal conditions in Fundy: the first as the
relative sea level fell from the high stand across the present position, and another as the
sea level returned to its former preglacial position sometime after 6000 ybp. Shaw et al.,
2002 combined isobase maps with a digital terrain model of Atlantic Canada to map
coastlines from 13 000 ybp to the present. Their map of the Bay of Fundy inner region for
9000 ybp (Figure 28) shows that much of Minas Basin was subaerially exposed.


Short Term Relative Sea Level Trends in the Bay of Fundy

Tide gauge data from Atlantic Canada extends back almost 100 years and
contains a strong signal of rising sea level (Shaw and Forbes, 1990) (Figure 29). Grant
(1970, 1975) cited rates of 46, 41 and 26 cm/century for St. John, N.B. Carrera and
Vanieck gave rates of 31.4 cm/century for the time period 1966 1985 for Yarmouth,
south of the entrance to the Bay of Fundy.

The sources for compiling tide gauge trends discussed in Shaw and Forbes, 1990,
are Tidal Publication No. 30 published in 1951 by the Canadian Hydrographic service.
They also used data obtained from Marine Environmental Data Services (MEDS), a
branch of the Department of Fisheries and Oceans. The Yarmouth data set from MEDS
sources includes some isolated values for 1900 and 1956 with the continuous set
beginning in 1967. The rate for the period 1900 -1988 is 26.3 cm/century. Excluding the
1906 value, the rate is 26.8. For St. John, N.B. and the rate includes 24 values predating
1929, the first year of MEDS recordings. The record gives a rate of 21.2 cm/century. A
regression using only data from 1929 onwards provides a rate of 28.4 cm/century.

From the above values it is clear that along with many other areas in Atlantic
Canada, the Bay of Fundy is experiencing a rise in relative sea level. The calculated rise
does depend on the length of the record. The two most important causes of sea level rise
are crustal subsidence and eustatic sea level rise. The fact that rates change regionally
suggests regional variations in the crustal component. Grant (1975) also reached this
conclusion. Global climatic warming may play an even larger role in sea level rise than
amounts associated with responses to glacial offloading and crustal movements. This is
discussed in the following section.




66
Global Warming Associated Sea Level Rise
The most recent research on sea level change was presented at the International
Scientific Congress on Climate Change in Copenhagen in March 2009. It showed that the
upper range of sea level rise by 2100 could be in the range of about one meter, or
possibly more. In the lower end of the spectrum it appears increasingly unlikely that sea
level rise will be much less than 50 cm by 2100. The following is a summary of the
Copenhagen meeting.
Dr. John Church of the Centre for Australian Weather and Climate Research,
Australia and the lead speaker in the sea level session, told the conference, "The most
recent satellite and ground based observations show that sea-level rise is continuing to
rise at 3 mm/yr or more since 1993, a rate well above the 20th century average. The
oceans are continuing to warm and expand, the melting of mountain glaciers has
increased, and the ice sheets of Greenland and Antarctica are also contributing to sea
level rise."
New insights reported at the meeting include the loss of ice from the Antarctic
and Greenland Ice Sheets. "The ice loss in Greenland has accelerated over the last
decade. The upper range of sea level rise by 2100 might be above 1m or more on a global
average, with large regional differences depending where the source of ice loss occurs",
says Konrad Steffen, Director of the Cooperative Institute for Research in Environmental
Sciences (CIRES) at the University of Colorado, Boulder and co-chair of the congress
session on sea level rise.
The last assessment report from the IPCC from 2007 projected a sea level rise of
18 - 59 cm. However the report also clearly stated that not all factors contributing to sea
level rise could be calculated at that time. The uncertainty was centered on the ice sheets,
how they react to the effects of a warmer climate, and how they interact with the oceans,
explains Eric Rignot, Professor of Earth System Science at the University of California
Irvine and Senior Research Scientist at NASA's Jet Propulsion Laboratory.
"The numbers from the last IPCC are a lower bound because it was recognized at
the time that there was a lot of uncertainty about ice sheets. The numerical models used at
the time did not have a complete representation of outlet glaciers and their interactions
with the ocean. The results gathered in the last 2-3 years show that these are fundamental
aspects that cannot be overlooked. As a result of the acceleration of outlet glaciers over
large regions, the ice sheets in Greenland and Antarctica are already contributing more
and faster to sea level rise than anticipated. If this trend continues, we are likely to
witness sea level rise one meter or more by year 2100".
"Measurements around the world show that sea level has risen almost 20 cm since
1880," explained Professor Stefan Rahmstorf of the Potsdam Institute for Climate Impact
Research, who gave the plenary speech on sea level rise at the 2009 congress. These data
also reveal that the rate of sea level rise is closely linked to temperature: sea level rises
faster the warmer it gets. "If sea level keeps rising at a constant pace, we will end up in
67
the middle of that 18-59 cm IPCC range by 2100," says Rahmstorf. "But based on past
experience I expect that sea level rise will accelerate as the planet gets hotter."
The results of the 2009 International Scientific Congress on Climate Change in
Copenhagen demonstrate that a clear assessment of the amount of sea level rise due to
global climate warming does not exist and a range of values of between 18 and 100 cm
by 2100 have been proposed. The infrastructure for the tidal power demonstration project
in Minas Passage that includes buildings, cables, gravity based structures and perhaps
water surface piercing structures will use the most up to date information on sea level rise
as a component of the design criteria.

Tidal Variations

Sea surface elevation records taken at Saint John, New Brunswick were analyzed
by Godin (1992) who noted that the amplitude of the M2 tide was increasing at a rate of
10 -15 cm/century. He interpreted this to be the result of changes in resonance resulting
from sea level rise or sediment redistribution at the head of the Bay. Scott and Greenberg
(1983) estimated a 1.5% increase in tidal amplitude for each 1 m rise in sea level. This
would only translate into a 1-2 cm/century increase based on the present knowledge of
sea level rise. Greenberg (1979) suggested that such high increases in tidal amplitude as
suggested by Godin could only occur with major tidal power installations and not
changing sedimentation patterns. Greenberg and Petrie suggested that more study was
required to sort out magnitudes and causes of changing amplitude of the M2 tide. The
tidal range expansion was interpreted as most rapid after 7000 ybp and that it had
decreased by 4000 ybp (Scott and Greenberg, 1987). John Shaw (personal
communication, 2008, in prep.) has proposed a novel idea suggesting that tidal expansion
was delayed in Minas Basin by the existence of a barrier at the junction between Minas
Passage and Minas Basin. This barrier was destroyed perhaps by a large storm in one
event and may represent the legend recorded in the First Nations accounts of the great
flood in the stories of Gloosecap.

Summary of Sea Level History and Implications for the proposed
development of Tidal Power in Minas Passage

The glacial, post glacial and historical sea level knowledge has implications for
the construction of offshore infrastructure as well as on land components. Of utmost
importance to the design of structures that may pierce the sea surface is consideration of
the continued projected rise in sea level. Based on the knowledge of sea level change
over the past 50 years, the facilities will be designed and constructed to anticipate a sea
level rise of 30 cm/century for natural crustal changes combined with a further 18 to 100
cm associated with global climate change. Such a design will also take into consideration
potential change in tidal heights and storm waves associated with higher sea levels.

With regard to the design and construction of the land based facilities, knowledge
that former sea levels were as high as 26 m near Cape Sharp will also be considered in
68
the design and construction. These former and higher sea levels have controlled the
characteristics of glacial outwash and other materials in the near shore zone.

69


Figures





Figure 27. Lines of equal emergence (isopleths) of elevations of the marine limit in Nova
Scotia and New Brunswick. The marine limits are represented by wave-cut terraces,
beaches and deltas. Former interglacial shorelines occur around Cape Breton Island and
north of Yarmouth. In contrast, the low stand shoreline offshore east Nova Scotia at 65 m
is shown. From Stea et al., 2001.










70









Figure 28. A map of the distribution of Atlantic Canada at approximately 9000 ybp
showing the paleogeography of the region. Areas in green represent offshore regions of
subaerial exposure resulting from the position of relative sea level at this time. Note that
most of Minas Basin was land at this time. From Shaw et al., in press (2005).










71










Figure 29. Tidal records and rates of change for a) Charlottetown, P. E. I., b) Yarmouth,
N. S., c) Saint John, N.B., and d) St. Johns, Newfoundland and Labrador. From Shaw
and Forbes, 1990.




72
References

Amos, C. L. and Zaitlin, B. A. 1985. The effect of changes in tidal range on a sublittoral
macrotidal sequence, Bay of Fundy, Canada. Geomarine Letters 4, p. 161 169.

Amos, C.L., Tee, K. T. and Zaitlin, B. A., 1991. The post glacial evolution of Chignecto
Bay, Bay of Fundy, and its modern environment of deposition. In Classic Tidal Deposits,
Canadian Soc. Of Petroleum Geologists Memoir16, p. 59 90.

Belknap, D. F., Shipp, R. C., Stuckenrath, R., Borns, H.W. and Kelly, J. T., 1989.
Holocene sea level change in Maine. In W. A. Anderson and H. W. Borns eds.,
neotectonics of Maine. Maine geological Survey, Augusta, pp. 85 105.

Bloom, A. L., 1963. Late Pleistocene fluctuations of sea level and postglacial crustal
rebound in coastal Maine. American Journal of Science 261, p. 862 869.

Curray, J. R., 1960. Sediments and history of Holocene transgression, continental shelf,
northwest Gulf of Mexico. P. 221 226. In F. P. Shepard, F. B. Phleger, and Tj. H.
vanAndel, eds., Recent sediments, northwest Gulf of Mexico, American Association of
Petroleum Geology.

Denton, G.H. and Hughes, T.J., 1981. The last great ice sheets: Toronto, John Wiley and
Sons. 484 p.

Dyke, A. S. and Prest, V.K., 1987, Late Wisconsinan and Holocene history of the
Laurentide ice sheet, in Fulton, R.J. and Andrews, J. T., eds., The Laurentide ice Sheet:
Geographie Physique et Quaternaire, v. 41, p. 237 264.

Fader, G. B. J., King, L. H. and MacLean, B., 1977 Surficial geology of the eastern Gulf
of Maine and the Bay of Fundy. Geological Survey of Canada paper 76-17, 23 p.

Fader, G. B. J., 1989, A late Pleistocene low sea level stand of the southeast Canadian
offshore, in Scott, D.B., et al., eds., Late Quaternary sea level correlations and
applications: Dordrecht, Netherlands, Kluwer Academic Publishers, p. 71 103.

Fairbanks, R. G., 1989. A 17000-year glacio-eustatic sea level record: Influence of
glacial melting rates on the Younger Dryas event and deep ocean circulation: Nature,
v.342, p. 637 642.

Gadd, N. R., 1973. Quaternary geology of southwest New Brunswick with particular
reference to the Fredericton area. Geological Survey of Canada Paper 71 34: 31p.

Godin, G., 1992. Possibility of rapid changes in the tide of the Bay of Fundy, based on a
scrutiny of the records from St. John. Continental Shelf Research, v.12(2/3) p. 327 338.

73
Goldthwait, J. W., 1924. Physiography of Nova Scotia: Geological Survey of Canada
Memoir 140, p. 60 103.

Grant, D. R., 1970. Recent coastal submergence of the Maritime Provinces; Canadian
Journal of Earth Sciences, v. 7, p. 676 -689.

Grant, D. R. 1971. Glacial deposits, sea level changes and pre-Wisconsinan deposits in
southwest Nova Scotia. Geological Survey of Canada paper 71-B: p. 110 113.

Grant, D. R. 1975. Recent coastal submergence of the Maritime Provinces. Proceedings
of the Nova Scotia Institute of Science, 27supplement 3: p. 83 102.

Grant, D. R., 1977. Glacial style and ice limits, the Quaternary stratigraphic record and
changes of land and ocean level in the Atlantic Provinces, Canada; Geographie Physique
et Quaternaire, v. 31, p. 247 260.

Grant, D. R., 1980. Quaternary sea level change in Atlantic Canada as an indication of
crustal delevelling, in Morner, N. A., ed., Earth rheology, isostasy and eustasy; London,
John Wiley and Sons, p. 201 214.

Greenberg, D. A., 1979. A numerical model investigation of tidal phenomena in the Bay
of Fundy and Gulf of Maine. Marine Geodesy 2. p. 161 187.

Greenberg, D. A. and Petrie, B. D. 1996. Physical oceanographic processes, the physical
environment of the Bay of Fundy, in proceedings of the Fundy Marine Ecosystem
Science Project Workshop, Wolfville, Nova Scotia, January 29 February 1. Eds. J. A.
Percy, P. G. Wells and A. Evans, p. 13 30.

Hickox, C. F. Jr. 1962. Pleistocene geology of the central Annapolis valley. N. S.
Department of Mines Memoir 5, 36 p.

Milliman, J. D. and Emery, K. O., 1968. Sea levels during the past 35000 years. Science
162. p. 1121 1123.

Pecore, S. S and Fader, G. B. J., 1991. Surficial geology, pockmarks and associated
neotectonic features of Passamaquoddy Bay, New Brunswick, Canada. Geological
Survey of Canada Open File report.

Pirazzoli, P. A., 1996. Sea level changes: The last 20000years: New York, John Wiley
and Sons, 207 p.

Scott, D. B. and Greenberg, D. A., 1983. Relative sea level rise and tidal development in
the Fundy tidal system. Canadian Journal of Earth Sciences, 20. p. 1554 -1564.

74
Scott, D. B., Brown, K., Collins, E. S., and Medioli, F. S., 1995. A new sea level curve
from Nova Scotia, evidence for a rapid acceleration of sea level rise in the late- mid
Holocene: Canadian Journal of Earth Sciences, v. 32, p. 2071 2080.

Shaw, J., and Forbes, D.L., 1990. Shore and long term relative sea level trends in Atlantic
Canada: Proceedings, Canadian Coastal Conference 1990, Kingston, Ontario: Ottawa,
National research Council of Canada, p. 291 305.

Shaw, J., Gareau, P. and Courtney, R.C., 2002. Paleogeography of Atlantic Canada,
Quaternary Science Reviews, 21, p. 1861 1878.

Stea, R. R., 1982. The properties, correlation and interpretation of Pleistocene sediments
in central Nova Scotia, M. S. Thesis: Halifax, Nova Scotia, Dalhousie University, 215 p.

Stea, R. R., Piper, D. J. W., Fader, G. B. J. and Boyd, R., 1998, Wisconsinan glacial and
sea level history of Maritime Canada and the adjacent continental shelf: A correlation of
land and sea events. GSA Bulletin, July 1998; v. 110, No 7, p. 821 845.

Stuvier, M., and Borns, H. W. 1975. Late Quaternary marine invasion in Maine: its
chronology and associated crustal movement. Geological Society of America Bulletin 86,
p. 99 104.

Swift, D. J. P. and Borns, H. W. 1967. A raised fluvial marine outwash terrace, north
shore of the Minas Basin, N. S., Journal of geology 75, p. 693 710.









































Appendix E
I. Introduction
Report of Capt. Richard P. Fiske, USN (ret.)
27 July 2012
A. I am Captain Richard P. Fiske, USN (ret). I was retained by PC Landing Corp.
("PCLC") to review and analyze from a marine operations perspective documentation
associated with the application ("Application") of Public Utility District No.1 of
Snohomish County, Washington ("District") for a license to install two underwater tidal
energy turbines and associated cables and infrastructure as the Admiralty Inlet Pilot
Project ("Project"). This documentation includes the Application, the intervention and
protest submitted by PCLC to the Application ("Protest") based on concerns for the
safety of its Pacific Crossing transpacific fiber optic cable system ("PC-1 "), specifically
for the north segment of the cable ("PC-1 North"), the District's subsequent response
("Response") to the Protest dated June 22, 2012, and, the documentation accompanying
each submittal. I also reviewed FERC's Requests for Additional Information, dated July
16, 2012.
B. As reflected in the Application and the Response, the primary purpose of the Project is
to conduct research and gather data. 1
C. My experience and qualifications are included as Attachment 1. Based on my
background, training, and experience with vessel operations and marine proj ects and on
my review of the materials I have been provided, I have concerns with the proposed
location of the Project turbines relative to PC-1 North.
II. Summary
A. Unless they are urgent in nature, most marine operations are carefully planned and
deliberately executed. Alternatives are investigated with the goal of simplifying the
operation, minimizing risk, and developing as completely as possible a list of possible
failures and problems and other variables, such as the operational environment, that
might arise and plans to deal with those problems and failures and variables. Marine
operations are dynamic and cannot, as in terrestrial operations, simply be stopped until a
problem is resolved. This planning is best done by persons experienced in marine
operations. Even with the best planning, unanticipated situations arise and the best way
to deal with both anticipated and unanticipated problems offshore is to use the planning
process to minin1ize risk. The values in planning maritime operations are foresight,
simplicity and common sense. The easiest problems to solve are those that are avoided.
B. The proposed turbine location is environmentally challenging. The Project's own site
surveys report the difficulty in working in the currents at the survey sites. While strong
currents are appropriate for generating electricity, the attendant difficulties and hazards
for marine operations mandate increased caution.
I Application, Exhibit E Environmental Report at xvii.
1
C. The Project is an experimental program using a system with a very limited track
record. As discussed below, two previous installations using the OpenHydro technology
proposed by the District have had documented issues demonstrating the need for caution
and risk reduction measures in planning the Project.
D. The planned Project location, in close proximity to PC-I North, is a sensitive location
from a maritime operational perspective due to the presence of the cable. In maritime
operations, 100 meters is very close proximity. To install a large, heavy experimental
project in close proximity to PC-I North when there are reasonable alternative locations
is to invite problems needlessly.
E. Having reviewed the District documentation, given the close proposed proximity to
PC-l North, I have concerns about technical aspects of the installation, the completeness
of the information provided to FERC, and internal inconsistencies in the information
provided. In addition I have concerns about the arguments provided regarding U.S.
legislation and international treaties with which I am familiar.
F. I note from the materials I reviewed that there appear to be alternate installation
locations with sufficient current flow to accomplish the goals of the project while
minimizing risk to PC-l North.
O. There appears to be some urgency on the part of the District to having FERC approve
the Project as proposed and without further analysis. While developing renewable
sources of electricity is a laudable goal, this is an experin1ental project done electively. It
is a desirable and an appropriate project, but there is no urgency here sufficient to obviate
the need to undertake a complete planning process that minimizes risk to existing
infrastructure.
H. I understand that PCLC has asked that the turbine locations be moved 750 meters or
more from the PC-l North cable. Moving the turbine locations significantly away from
PC-l North makes sense.
I. While I am not predicting a specific problem or that OpenHydro will be unable to
install the turbines safely, I have concerns based on 1) the energetic environmental
conditions, 2) the proximity of the proposed Project turbine locations and the existing
PC-l North cable segment, and 3) technical and credibility issues with the District's
proposal as submitted. I am concerned that the proposed turbine locations create needless
and avoidable risk (even if small) which would have significant consequences and which
can be readily reduced or avoided.
J. Based on the above I recommend that Project approval be withheld until PCLC and
the District can agree on a location that minimizes risk to PC-I North while
accomplishing the District's Project goals.
2
III. Technical Issues
A. Environmental Conditions as Documented by District Surveys. As indicated in
various pre-installation study reports submitted by the District in Appendix L to its
Application, environmental conditions in the proposed Project locations are challenging,
with high currents,
2
low visibility3 and small operational windows between tides.
4
Even
during "slack" water current is present. Project surveys submitted by the District
repeatedly note problems with conducting site surveys due to conditions of high current,
including wrapping of ROV umbilicals around rocks on the bottom.
5
Low visibility
precluded detailed visual inspection of the bottom, and "intense current activity" resulted
in abandonment of a planned sediment sampling program, after multiple unsuccessful
attempts by the District's contractor to recover bottom samples using a grab sampler.
6
The documented issue of Project survey boats dragging anchors in the vicinity of PC-1
North due to strong currents
7
is in itself exemplary and alarming for multiple reasons, and
will be discussed later in this report.
B. Lack of specificity. Broad, general bland statements in the Application and its
supporting documentation do not provide sufficient detail for FERC to gain a full
understanding of the technical challenges of the project and the extent to which those
challenges are understood and have been addressed, given the close proximity to PC-1
North. While some areas of the Application provide massive detail, especially in
addressing marine biological issues, technical aspects of the project need amplification
and clarification.
1. Use of anchors. Project documentation asserts in various places that anchors will
not be used, e.g. "No anchor placements, pilings, or surface-piercing structures would be
involved with the turbine installations or cable.,,8 And again, in its Response the District
asserts, "The installation and maintenance activities do not require or permit the use of
anchors.,,9 However, later in the Application: "A two anchor mooring system is planned
to be installed for installation and operations support. The anchors are installed to the
east of the turbine locations so that they are positioned far away from the existing PC-1
North telecommunications cable."IO (emphasis added). And, "The use of a two anchor
mooring is to provide safety against any emergency situation during installation and
inspection to avoid vessels needing to drop anchors in a power loss or equipment failure
2 Application, Appendix L Pre-Installation Study Reports, L-8 Seafloor Substrate and Benthic Habitat
Characterization of the SnoPUD Admiralty Inlet Pilot Tidal Project Turbine Site Through ROV Video
Observations, para. 2.2 Difficulties Encountered at 5.
3 Application, Appendix L-8 para. 2.2 Difficulties Encountered at 5.
4 Application, Appendix L-8 para. 2.2 Difficulties Encountered at 5.
5 Application, Appendix L-8 para. 2.2 Difficulties Encountered at 5.
6 Application, Appendix L-3 Bathymetric and Geophysical Survey Site Characterization Admiralty Inlet
Pilot Tidal Project, para. 2.10 at 2.6. "However, after multiple unsuccessful attempts at three of the sites,
the fourth site was abandoned."
7 Application, Appendix L-8 at 2 et. seq.
8 Application at 4.
9 Response, Attachment A, Marine Operations Installation Considerations Relating to Telecommunications
Cable PC-l at 1.
10 Application, Exhibit A Project Description at A-5.
3
scenario.,,1! It is not clear whether and how and for what anchors are to be used, when
and how wires from anchors to vessels (during turbine placing operations, during
emergencies?) and where they are to be placed relative to PC-l North. Further, if the
anchors are to be placed to the East of the Project they would be of minimal use in
plumbing the project anyway, as the energetic tidal currents run on a Northwest!
Southeast axis.
However, and despite its assurances, the District elsewhere indicates that it does expect to
anchor, using vessel anchors, in the vicinity of PC-l North while performing work on the
Project turbines. This is not only contemplated, but planned. In its Response to the
PCLC Protest the District asserts, "If the District observes derelict fishing gear snagged
on the Project works, the District will remove the gear as soon as possible. Successful
removal of deep-water fishing gear using ROVs has been demonstrated in Puget Sound
(NRC 2008) .... The removal deployment will generally involve vessel anchoring,
ROV anchoring, ... ,,} (emphasis added). This clearly obviates assurances that there will
be no anchoring on behalf of the District for work on the Project. Further, the fact that
ROV operations have been demonstrated elsewhere "in Puget Sound," absent a
description of the currents in which this demonstration was made, is meaningless as to
the effectiveness of ROV s in the vigorous currents in the vicinity of the Project in
Admiralty Inlet.
2. Navigation. The District plans to use a Wide Area Differential Global Position
System ("W ADGPS") for navigation'3 rather than vessels equipped with Dynamic
Positioning (DP) systems. A W ADGPS system provides information to operators about
the location of the WADGPS antenna (with manual vessel control by the operator and the
operator applying direction and distance offsets from the W ADGPS antenna to the
planned location of the Project). Dynamic Positioning systems, which are commonly
used in the off shore energy industry, on the other hand, are capable of using GPS along
with heading and environment reference systems to control vessel maneuvering directly.
Positions and tracks can be planned and programmed ahead of time, antenna/project
offsets can be programmed in, lag time is minimized and, once properly programmed,
operator error is reduced. In addition, DP systems may have one or more levels of
redundancy built into the system (referred to generally as "DP Class"), that, depending on
the DP Class, are designed to prevent a loss of station keeping ability in the event of one
or more control system failures. The District has not provided information as to where
the W ADGPS antenna is to be located in relation to the center of the turbine platform,
how any offset is to be applied, how the information is to be provided to the tug Masters,
and how the command and control structure is arranged to maneuver each of the tugs and
control the turbine placement system.
3. Detailed Installation Plan. In its Response the District provides two slides
comprising Appendix A to Marine Operations Installation Considerations Relating to
11 Application, Exhibit A Project Description at A-5.
Application, Exhibit E Environmental Report at 142.
13 Response, Attachment A at 3.
4
Telecommunications Cable PC-1 (Installation Considerations).l4 Although asserted to
show the installation methodology "step by step"l5 each of the two slides simply shows
the "concept"l6 for two aspects of the operation. There is much about the installation
process that is missing.
4. Tugs and Barge. The District plans to use a standby tug
l7
in the event that one of
the three planned tugs becomes inoperative. As noted throughout the documentation, the
installation location is subject to strong currents. To disengage a disabled tug, move it
clear of the barge (or in the case of the trailing barge in the OpenHydro Deployment
Concept
l8
keep the disabled tug from being driven by the current into the tug/barge
assembly), transfer wires or rig new wires to the standby tug, and the standby tug to take
a strain, all while currents are driving the entire flotilla, tethered to the bottom by power
cables or by turbine lift wires, timely and without need to repeat steps, presents a not-
insignificant challenge. To accomplish this while avoiding being carried by currents a
short 104m to the West, where lies PC-1 North, seems to be overly optimistic. The
District has not provided sufficient operational detail to demonstrate that such a
contingency could be managed without adverse incident. Loss of control of the flotilla in
such a scenario while the turbines are suspended (mid-installation) in the water column,
or near the seabed, would pose substantial risks to PC-1 North.
5. Launch/Recovery Process and Systems. The Application and Response do not
supply sufficient information to allow FERC to adequately evaluate the turbine launch
and recovery process. There appear to be three winches on the installation barge, two of
which are labeled in Figure 2-13 of the Environmental Report.
l9
If this assumption is
correct, then how are the winches controlled and coordinated? If one assumes that the
controls are in the control cabin several questions then pertain, and are relevant to the
potential failure modes and their resolutions.
A drawing of the turbine installation on the bottom
20
shows a turbine mounted on its
base. In its Response the District mentions a "deployment/recovery frame.,,2l,22 Figure
2-13 shows portions of this base but no deployment/recovery platform. Is it intended that
there be a winch dedicated and a wire linked to each of the three vertices of the gravity
base or to a separate deployment/recovery platform? How is a deployment/recovery
frame incorporated? It is not clear, but the issue is relevant to clarity and completeness of
14 Response, Attachment A at 10, Appendix A Cable Installation Methodology Turbine Installation
Methodology.
15 Response, Attachment A at 3.
16 Response, Attachment A at 5, Table 1 Safeguards for Potential Failure Modes.
17 Response, Attachment A at 5, Table 1.
18Response, Attachment A, Appendix A.
19 Application, Exhibit E Environmental Report at 36, Figure 2-13, Turbine Installation Barge Carrying a 6-
Meter Open Hydro Turbine.
20 Application, Exhibit E at 119, Figure 3-25, Dimensions of Turbines in Relation to Depth at Deployment
Site.
21 Response, Attachment A at 3.
22 Response, Attachment A at 5.
5
what the District has proposed and how it plans to deal with installation problems
presented in the District's Response.
Of more interest, however, are failure modes and recovery. The District asserts in Table
1 that should the release mechanism fail to release, the turbine would be recovered and
the installation aborted.
23
Assuming a launch/recovery frame, is there a single latch to
release all three vertices of the turbine base? Given the apparent system configuration
this is most unlikely. What, then, is the safeguard to PC-I North if one or two of these
latches releases, leaving a single wire attached, to a launch barge live boating without
using a DP system. Similarly, what if a single winch fails at exactly the wrong time in
the launch sequence? Winches typically operate using pressurized hydraulic fluid and if
the problem is more than simple hose replacement (e.g. stripped hose threads in a winch
block, electrical control failure, etc.) it is not hard to envision one or two vertices of the
turbine on the bottom, the remaining vertex still attached to its lift wire as the currents
rise with PC-l North 104m away. Again, this is not a static, terrestrial environment
where one can simply stop the process until repairs are made.
6. Geological Information. The District " ... conducted extensive investigation of the
site prior to site selection.,,24 And further, "The District carried out a bathymetric and
geophysical survey of the proposed deployment zone ... Side scan sonar and multi-beam
bathymetry were used to identify potential deployment sites within the zone. In addition,
a sub-bottom profiler and drop camera were used to identify the seafloor and subsurface
conditions.,,25 Based on these surveys the District asserts that the materials at the site of
the proposed installation are "likely in a medium dense to dense condition. ,,26 The
District's conclusion is that "The seafloor is competent to handle the loading of the
subsea base and turbine.,,27
However, current and visibility conditions made visual characterization of the botton1
difficult.
28
As noted above, after several failures the seabed sampling was unsuccessful
and ultimately abandoned despite multiple attempts at multiple locations near the
proposed turbine sites due to "intense current activity.,,29 "The sub-bottom profile data
showed little or no subsea penetration.,,3o Further, Fugro states in its Executive
Summary: "The thickness of the glacial deposits is unknown as no geotechnical
explorations have been performed and the gravel, cobbles, and boulders on the seafloor
precluded a sub-seafloor penetration and seismic imaging.,,31 There are no indications
23 Response, Attachment 1 at 5, Table 1.
24 Response, Attachment A at 2.
25 Application, Exhibit E at 47.
26 Response Attachment A at 2.
27 Response Attachment A at 2.
28 Application, Appendix L-l 0 Habitat Characterization of the SnoPUD Turbine Site Admiralty Head,
Washington State, para 2.2. "Even though timing of the ROY surveys was selected to occur when tidal
flow was comparatively low, the water mass at the site was always restless and very seldom was true slack
experienced. Quite the contrary, strong currents often over a knot in speed were encountered and affected
the smooth, trouble-free operation of the ROY."
29 Application, Appendix L-3 at 2-6.
30 Application, Exhibit E at 57.
31 Application, Appendix L-3 at ES-I.
6
that samples have been taken to characterize the bottom and its substrate. Yet, the
District asserts that it "performed bathymetric, geophysical, and geological hazard site
surveys.,,32 While the surveys may have been performed, their contributions to
understanding site geology appear to be limited.
7. Site Selection. It is not adequately explained, other than a table of simple current
flow rates of selected sites, why the particular proposed turbine locations were chosen.
Survey data in the District's Response suggest that alternate sites have power densities
approaching those of the selected sites.
33
New analysis does not address alternative
locations in sufficient detail to enable FERC to follow the reasoning as to why particular
sites were selected.
8. No Experience. The District acknowledges that OpenHydro has no experience
installing tidal energy projects in the vicinity of submarine cables,34 no experience with
installations adjacent to submarine cables and no information regarding submarine
cable/tidal energy installations.
35
Given the lack of this particular kind of relevant
experience, increased caution and efforts to minimize risk are appropriate.
9. Hazarding of PC-l North Has Already Occurred. Perhaps most alarming is that the
District has already hazarded PC-l North by the anchoring of contractor vessels in close
proximity to the cable while performing surveys. "The first attempt to collect ROV video
at the SnoPUD tidal energy site was undertaken .... Unfortunately the support vessel. .. was
too small for the tidal conditions and the anchors too light to keep the vessel in
position.,,36 (emphasis added). And further, "The second attempt to obtain video images
of the seafloor within the SnoPUD tidal energy site was undertaken from aboard a large
barge ... after the barge supporting the ROV was properly anchored.,,37
added). The barge was anchored using a " ... four-point anchoring system.,,3 Finally, one
of the barge anchors dragged to the surface in its flukes a small boulder and cobble "at
the turbine site. ,,39 (emphasis added). I find no indication that the District or its
contractors had any appreciation of the presence of an active international
communications cable in the immediate vicinity of its work zone (despite the presence of
PC-l North on navigational charts and in a recorded aquatic lands easement), or that the
District or its contractors notified PCLC that these surveys were being conducted in the
vicinity of PC-l North and that anchoring was undertaken in the vicinity of PC-l North
as a deliberate part of the survey process.
10. Lack of Specificity. The lack of specificity of the Application and its subsequent
submissions demonstrates the District's insufficient appreciation of the technically varied
32 Application, Exhibit E Environmental Report at 56.
33 Response, Attachment 0 Northwest National Marine Renewable Energy Center.
34 Application Vol. III, Appendix N Stakeholder Consultation, Attachment 1 at 10, Response VII.7.
35 Protest at 3.
36 Application, Appendix L-8 at 2.
37 Application, Appendix L-8 at 3.
38 Application, Appendix L-8 Figure 2 at 4.
39 Application, Appendix L-8 Figure 23 at 26.
7
problems that inevitably arise when working offshore and is insufficient to allow FERC
to make an informed decision that would allow the Project to proceed.
IV. Credibility; Issues Not Well Thought Out or Incorrect
The District provides broad, general assertions that frequently are found to be critically
flawed when examined. It provides hyper-analysis in some areas and glosses over others.
Rigorous analysis in one area does not imply the same rigor in all areas.
A. Use of Anchors (or not). The District asserts, frequently, that no anchors will be used
in the installation, maintenance, and removal of the turbines. Yet the District provides
for two large anchors and sophisticated acoustic release systems for the mooring wires.
As described above, the locations for the anchors and wires running to vessels have not
been adequately specified, and the use of these anchors is anticipated for some
operations.
B. Installation Order (Turbines vs. Power Cable or Vice Versa). The District asserts that
"The cables are installed prior to the installation of the turbines. They are installed from
the turbine location to the shore.,,4o However, elsewhere the installation order is
reversed: "The trunk cables are installed from the turbines to the HDD exit point
immediately following the turbine installation.,,41 What is the installation order of the
two major components of the Project? Something so fundamental to the Project as the
installation order is confused.
C. Standby Tug. The District asserts that a stand-by tug will be used.
42
The "Detailed
Installation Methodology" shows three tugs involved in the installation
43
and the
Environmental Report Proposed Actions and Alternatives indicates that the vessels
required to install the turbine and subsea cables to include "Three tugS.,,44 No stand-by
tug is shown or mentioned.
D. Bottom Surveys. As noted above, the District asserts that bottom surveys were
conducted, which may be true ("Conducted ROV video investigations to characterize the
Project area seafloor ... ,,45), but as noted above survey documentation shows the generally
unhelpful and incomplete results of these surveys. Further, PCLC expert Mr. Gordon
Fader notes that no samples were taken that confirm the geology of the bottom.
46
The
District is postulating the composition of the bottom rather than citing to hard data.
E. Site Selection. It appears that alternate sites and their characteristics, evident in
detailed survey information, were not identified in more summary documents. Nor was
the reasoning for selecting the chosen locations and rejecting alternatives. A more
40 Response Attachment A at 1.
41 Application, Exhibit E, Proposed Actions and Alternatives at 24.
42 Response Attachment A at 3.
43 Response Attachment A, Appendix A.
44 Application, Exhibit E, Proposed Actions and Alternatives, at 34.
45 Application, Exhibit E at xix.
46 Protest, Appendix C Fader Report at 2.
8
complete picture of the tidal energy available by location is provided in an attachment to
the District Response, where there appear to be a number of alternate areas with current
energy similar to that of the selected sites.
47
To reject a site that reduces risk to PC-1
North because that site might produce slightly less electrical power, particularly given
that power production is not the primary purpose of this experimental project, fails to
maintain the larger perspective of the Project and the environment in which this
experiment is to be conducted.
Detailed Installation Plan. In its Response the District asserts in Attachment A that it
has provided in its Appendix A, a "step by step" installation methodology.48 Each of the
two slides in the Appendix is labeled as a concept. This step by step plan as provided has
but two steps, both of which are concepts. It will be a challenge for FERC to fully
understand the installation, and its risks, based on this Appendix.
G. ROY Monitoring. The installation methodology/concept shows an ROY monitoring
the cable installation, as well as periodic post-installation ROY monitoring. Given the
visibility and handling problems experienced by District contractors when conducting
simple visual bottom surveys, noted above, the assertion that ROY s will be used to
monitor the cable during and post-installation is not understood.
H. Problems with Earlier Installations. In its Protest PCLC quotes Mr. Fader, who
addresses concerns with previous OpenHydro installations in the Bay of Fundy (location
change without explanation and disintegration of the turbine blading due to
underestimating the current flow), and the Orkney Islands (barged-based construction
method for driving piles hindered by presence of large boulders at the seabed).49 What is
of interest here is that those substantive issues were not addressed by the District in its
response to the PCLC Protest.
1. Treaty and Legislative Issues. Many traditions, dating back to the earliest days of
maritime trade, have become codified over the years in treaty and in law. The District
denigrates the federal Submarine Cable Act of 1888 (47 U.S.C. 21, et seq.) and its
assignment of liability for breaking or injuring a cable whether willfully or through
"culpable negligence," as an "historical relic having virtually no practical utility."sO
However, until replaced or repealed the 1888 Cable Act remains the applicable federal
statute governing vessel operations around and hazards to submarine cables in U.S.
waters. It is surprising that FERC, a federal agency, is being asked by the District to
ignore applicable federal law.
Further, and of interest, after dismissing the 1888 Cable Act, the District bases its
subsequent arguments on the applicability of the 1982 United Nations Convention on the
Law of the Sea (UNCLOS) and other more recent conventions than the International
Convention for the Protection of Submarine Cables (1884) that the 1888 Submarine
47 Response, Attachment D Figure 1.
48 Response, Attachment A, Appendix A at 10.
49 Protest, Appendix C at 6.
50 Protest at 14 citing Douglas R. Burnett, "Cable Vision," U.S. Naval Institute Proceedings 66, 68 (2011).
9
Cable Act was based on. The District points out that" ... these modern treaties address
both submarine cables and energy systems generated from tidal currents and their
relationships in the Exclusive Economic Zone ("EEZ"),,.51 What the District fails to
note, however is that the location of the Project is not in the EEZ. The Territorial Sea of
the United States extends out from the coastline for three miles, and to as far as 12 miles
depending on particular issues or locations. As UNCLOS notes, "The exclusive
economic zone is an area beyond and adjacent to the territorial sea ... ,,52 All surveyed
Project locations are clearly within even the most limited application of the Territorial
Sea. To assert arguments based on a treaty that is effective in the EEZ misleads FERC.
J. Assertions of Inclusion versus Actions. The District asserts that stakeholders were
involved early and frequently. Yet, as discussed above, the District conducted surveys
over and around PC-1 North, including hazarding the cable with anchors, well before
PCLC was made aware of the Project in May, 2011.
53
PCLC notes in its Protest that the
District has failed to comply with notification requirements in FERC regulations. 54
Further, the District's contact list for emergencies includes various agencies but does not
include PCLC.
55
In addition, there was no mention of PC-1 North in the Project
Safeguard Plan as submitted with the Application in February, 2012.
56
K. Ford-Ramsden Financial Analysis (Incremental Cost vs. Absolute Cost). Mr. Ford-
Ramsden did not address the increased likelihood of cable intrusion based on presence of
the Project. If the Project causes the intrusion, it should be subject to a full absolute costs
analysis, not the incremental analysis undertaken by Mr. Ford-Ramsden. Therefore, it is
reasonable to look at absolute costs, since the actions of the District, in conducting the
Project as proposed, increases hazard to PC-l North and the increased likelihood, which
would be minimal otherwise, of a cable repair being required. Alcatel Lucent ("ASN")
has corrected Mr. Ford-Ramsden's estimate of incremental time and cost
57
in its recent
letter. However, it would be helpful for FERC to consider the absolute cost of a cable
repair necessitated by Project operations and the hazard to the Project, pointed out by
ASN,58 in its proposed location engendered by a cable repair.
L. Simultaneous Operations. In the event that simultaneous operations are required, i.e.
installation or service or removal of the Proj ect and repair to PC-l North, which entity
and operation has priority? Should this not be understood and based in an agreement
between the parties established prior to beginning Project installation? The District has
not addressed these questions, or the increased risks posed by simultaneous operations
situations.
5' Protest at 15.
52 UNCLOS Part V Exclusive Economic Zone, Article 55.
53 Protest at 20.
54 Protest at 20.
55 Application, Appendix E, Project Safeguard Plan at 4.
56 Application, Appendix E, Project Safeguard Plan.
57 ASN Letter of 16 July 12.
58 ASN Letter of 16 July 12.
10
M. Public Safety. The District asserts that" ... the Project does not present a risk to PC-
1.,,59 However, PCLC in its various submissions has demonstrated that PC-l North is at
risk. As noted here, the information provided to FERC by the District and on which it is
to rely for its decision indicates otherwise. However, if there is a risk to PC-l North then
there is a risk to public safety and FERC license criteria
60
regarding public safety are not
met.
v. Risk
A. Risk Assessment Process. Some risks are necessary and some risks are elective. An
elective risk need not be taken and can often be reduced through planning, organization
and design. To take an elective risk without justification is to invite problems. This is
motherhood, but it is true, particularly offshore. To look at risk is as simple as
recognizing that the master of an installation tug, having experienced a casualty and been
cut loose from the Project may, despite plans and District commitments to the contrary,
feel it necessary to drop an anchor to slow or stop himself from being driven by the
current and into danger, whether or not he is near a submarine cable. This is the reality of
life on the water, despite assertions that "no anchors will be used."
B. District Approach to Risk. One statement and one omission appear to sum up the
District's approach to risk. On one hand, the District asserts, "Consideration for the
avoidance of risk to PC-l North has been a fundamental design premise for the
planning.,,61 On the other hand, the District's Assessment of Potential Puget Sound
Marine Safety Risk Resultingfrom Installation of the Admiralty Inlet Tidal Energy
Project, 62 makes no mention of PCLC, PC-I North or any risk that the Project presents to
submarine cables. To reconcile these two statements is a challenge and demonstrates a
weakness in the Project's approach to risk.
C. Who or What is at Risk? It is of interest to note that the District's risk analysis, while
superficially thorough in process, appears to focus on interactions between the turbines
and vessel traffic. There are broader risk issues that have yet to be addressed by the
District. They include the risk posed by OpenHydro' s lack of experience and
unexplained problems with previous installations, hazarding of PC-l North -without
notice - by the District's contractors while conducting surveys, incomplete bottom
information, and incomplete launch and recovery information and casualty plans, at a
distance of 100m from PC-l North, all of which cumulatively contribute to the risk of
severing PC-I North.
D. Is There No Risk? Perhaps the District in fact believes that there is no risk to PC-l
North. The Project's Response asserts this expressly, "Because the Project does not
present a risk to PC-l North, it does not present a risk to public safety, as PCLC claims.
59 Response at 12.
60 Federal Energy Regulatory Commission Licensing Hydrokinetic Pilot Projects at 13.
61 Response, Attachment A at 1.
62 Application, Appendix L-13 Assessment of Potential Puget Sound Marine Safety Risk Resulting from
Installation of the Admiralty Inlet Tidal Energy Project.
11
In any event, the District's safeguard plans detail the specific measures the District will
undertake to safeguard the public and environmental resources in its construction,
operation, and maintenance of the Project.,,63 This wording is curious since the safeguard
plan is silent as to PCLC, PC-I North or even submarine cables.
64
Since the District is
hazarding, and indeed has already hazarded, PC-l North while believing that it is and has
not, it is important that FERC protect this aspect of public safety.
E. There is No Imperative. There is no imperative to take the risk to install the Project
turbines in the particular location chosen by the District.
F. To Reduce Risk. The simplest way to reduce risk to PC-1 North, aside from that to
which it has already been exposed by the anchors of District survey vessels, is to locate
the Project turbines farther from PC-1 North. This mayor may not result in a reduction
in power generated, but as the District notes, "The primary purpose of the Project is to
conduct research and gather data, with energy production playing a secondary role.,,65
Let this be so.
VI. Conclusions
This paper has looked at the issue of Project turbine location relative to the submarine
cable PC-1 North and the risk that the Project poses to the cable. It has reviewed
technical concerns with the Project plan as presented by the District, and with credibility
concerns having to do with assertions that are overly broad, unsupported, misleading or
incorrect. The technical and credibility concerns all come down to risk, and the increased
risk that a particular approach or plan (or lack thereof) poses (or has already posed) to the
PC-l North cable from a marine operations standpoint.
In summary, it is not clear how an inexperienced organization conducting an
experimental project at less than recommended separation from a vulnerable but
important trans-pacific cable, having already hazarded that cable by dragging anchors in
high currents in the vicinity of the PC-1 North cable can assert that its Project does not
present a risk to that cable. The District asserts that to gather data is primary, and to
generate power is secondary. Reasonable alternate locations appear to exist that are
sufficiently separated from PC-1 North would avoid or and reduce risk and meet the
Project's stated goals.
There is no reason or urgency to take the elective risk posed by the planned turbine
location. It would be appropriate for FERC to withhold approval until the District and
PCLC can analyze and establish a mutually agreeable locations for the Project that meets
the District's needs while allying PCLC concerns.

RiCl1afClP:FiSk "2 7 July 2012


63 Response at 12.
64 Application, Appendix E, Project Safeguard Plans.
65 Application, Executive Summary at xvii.
12
Attachment I - Experience and Qualifications of Capt. Richard P. Fiske, USN (ret.)
1. I am a retired Captain of the United States Navy, now an independent consultant, with
over 47 years experience in marine operations, including ship operations, ship repair, diving
and salvage, deep ocean search and recovery operations, casualty analysis, and research and
development. Significant positions include U.S. Navy Director of Ocean Engineering I
Supervisor of Salvage and Diving, and Director of Marine Operations for Oceaneering
Technology, Inc. (OTECH). I received graduate engineering degrees from the Massachusetts
Institute of Technology, in Naval Architecture and Marine Engineering (M.A.) and an
Engineers degree in Ocean Engineering (0. Eng.). I am a qualified Navy air and mixed-gas
diver and Salvage Operations Officer. I have a Juris Doctor degree from George Mason
University School of Law and am admitted to the bar of the Commonwealth of Virginia. I
am the author of the Ship Salvage entry in the current McGraw-Hill Encyclopedia of Science
and Technology and co-author of two legal treatises, The International Law of the Shipmaster
(Informa, 2009) and Defending Against Pirates: The International Law of Small Arms,
Armed Guards and Privateers (Intershipmaster, 2011). I am a member of the American
Society of Naval Engineers, the Society of Naval Architects and Marine Engineers, and the
Maritime Law Association. I serve on the Legal Committee of the American Salvage
Association.
2. My earliest offshore work was for the Marine Physical Laboratory of the Scripps
Institution of Oceanography working on communications and power systems for the Navy
Man-In-The-Sea Program's SEALAB II, an experimental submerged habitat project off the
coast of San Diego. As a Navy officer I routinely was involved in both ship operations and
technology development, serving aboard 5 vessels during my Navy career, including
qualifying as an Officer of the Deck, Fleet Steaming and as Pilot I Executive Officer I
Instrumentation Officer of the large experimental hydrofoil Plainview. I worked in ship
repair and offshore with ROV's in marine salvage operations, culminating in the penultimate
Navy assignment noted above. As Supervisor of Salvage I was responsible to the Navy for
United States salvage capability (Title 10, U.S. Code). I led development and establishment
of ship and aircraft salvage procedures and diving procedures used by the U.S. Navy. After
retirement I was Director of Marine Operations for OTECH before becoming an independent
consultant. In both the SUPSALV (and earlier Navy assignments) and OTECH positions I
led developn1ent of equipments and systems for use offshore and execution of complex
marine operations including location and recovery of a Navy helicopter in depth of 17,000+
feet, recovery of the Confederate Submarine CSS Hunley, and recovery of debris from the
crash of EgyptAir flight 990 in the sea off Rhode Island. As a consultant I developed
terrorist scenarios for the National Academies of Science that could close two major Gulf
Coast ports using the same number of terrorists as executed the 911 attacks. I have spoken on
CNN and CNN World as a salvage expert, including review of the recovery plan for the
Russian submarine KURSK. One consulting project required casualty analysis of an incident
where-in the anchor of a ship performing operations in proximity to an inter-island power
cable likely caused the cable to part at some distance from the anchor snag itself.
3. I am familiar with the issues regarding PC-1 North and the proposed turbine installation.
13



















Appendix F
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 1 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 2 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 3 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 4 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 5 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 6 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 7 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 8 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 9 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 10 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 11 of 12
!ase 2:10-cv-00856-RAJ Document 1 Filed 05/21/10 Page 12 of 12
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U.S. Department of Justice
Torts Branch, Civil Division
450 Golden Gate Avenue, P.O. Box 36028
San Francisco, CA 94102, (415) 436-6647
CONSENT JUDGMENT
Case No. C10-856 RAJ 1
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
GENERAL COMMUNICATION, INC.,
Plaintiff,

v.
THE UNITED STATES OF AMERICA,
Defendant.
_____________________________________
)
)
)
)
)
)
)
)
)
)
)
)
Case No. C10-856 RAJ
IN ADMIRALTY
CONSENT JUDGMENT
TONY WEST
Assistant Attorney General
JOHN MCKAY, United States Attorney
BRIAN KIPNIS, Chief, Civil Division
U.S. Attorneys Office
1201 Pacific Avenue, Ste. 400
Tacoma, Washington 98402
R. MICHAEL UNDERHILL
Attorney in Charge, West Coast Office
Torts Branch, Civil Division
ERIC KAUFMAN-COHEN
Trial Attorney
U.S. Department of Justice
Box 36028, 450 Golden Gate Avenue
San Francisco, California 94102-3463
Telephone: (415) 436-6648
Facsimile: (415) 436-6632
E-mail: eric.kaufman-cohen@usdoj.gov
Attorneys for Defendant
UNITED STATES OF AMERICA
!ase 2:10-cv-00856-RAJ Document 18 Filed 05/24/11 Page 1 of 3
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U.S. Department of Justice
Torts Branch, Civil Division
450 Golden Gate Avenue, P.O. Box 36028
San Francisco, CA 94102, (415) 436-6647
CONSENT JUDGMENT
Case No. C10-856 RAJ 2
The above captioned action having been compromised, it is, upon the subjoined
consents of counsel;
ORDERED AND ADJUDGED that defendant, United States of America, shall pay
to General Communications, Inc., the sum of Eight Hundred and Five Thousand, Three
Hundred and Twenty Dollars and No Cents ($805,320.00), plus post-judgment interest only
pursuant to the Public Vessel's Act, 46 U.S.C. 31107, and without costs.
IT IS SO ORDERED.
Dated: 5/23/11
A
The Honorable Richard A. Jones
United States District Judge
We hereby consent to the entry of the foregoing Consent Judgment:
Dated: May 20, 2011 TONY WEST
Assistant Attorney General
JOHN MCKAY, United States Attorney
BRIAN KIPNIS, Chief, Civil Division
U.S. Attorneys Office
R. MICHAEL UNDERHILL
Attorney in Charge, West Coast Office
Torts Branch, Civil Division
/s/ Eric Kaufman-Cohen
ERIC KAUFMAN-COHEN
Trial Attorney
U. S. Dept. of Justice

Attorneys for Defendant
UNITED STATES OF AMERICA
Dated: May 20, 2011 GENERAL COMMUNICATION, INC.
/s/ Martin Weinstein
!ase 2:10-cv-00856-RAJ Document 18 Filed 05/24/11 Page 2 of 3
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U.S. Department of Justice
Torts Branch, Civil Division
450 Golden Gate Avenue, P.O. Box 36028
San Francisco, CA 94102, (415) 436-6647
CONSENT JUDGMENT
Case No. C10-856 RAJ 3
MARTIN WEINSTEIN

Attorney for Plaintiff
GENERAL COMMUNICATION, INC.
!ase 2:10-cv-00856-RAJ Document 18 Filed 05/24/11 Page 3 of 3



















Appendix G
Japan
PC-1 West
Ajigaura, Japan
T5 Shima, Japan
U.S.
PC-1 East
Harb5ur P5inte, WA
T5 Gr5ver Beach, CA
PC-1 S5uth
Gr5ver Beach, CA
T5 Shima Japan
PC-1 N5rth
Harb5ur P5inte, WA
T5 Ajigaura, Japan



















Appendix H
7/31/12 Ship Accidents Sever Data Cables Off East Africa - WSJ.com
1/2 online.wsj.com/article/SB10001424052970203833004577249434081658686.html#printMode
See a sample reprint in PDF f ormat. Order a reprint of this article now
EUROPE NEWS February 28, 2012
By SOLOMON MOORE
NAROB-Underseu duLu cubIes IInkIng EusL AIrIcu Lo LIe MIddIe EusL und Europe were severed In Lwo
sepuruLe sIIppIng uccIdenLs LIIs monLI, cuusIng LeIecommunIcuLIons ouLuges In uL IeusL nIne counLrIes und
uIIecLIng mIIIIons oI nLerneL und pIone users, LeIecom execuLIves und governmenL oIIIcIuIs suId.
A sIIp druggIng ILs uncIor oII LIe cousL oI LIe Kenyun porL cILy oI Mombusu severed u crucIuI nLerneL und
pIone IInk Ior LIe regIon SuLurduy, crIppIIng eIecLronIc communIcuLIons Irom ZImbubwe Lo DjIbouLI, uccordIng
Lo u pubIIc-prIvuLe consorLIum LIuL owns LIe underseu cubIe.
TIe ndIun Oceun IIber-opLIc cubIe, known us TIe EusL AIrIcun MurIne SysLems, or Teums, Is owned by u group
oI LeIecom compunIes und LIe Kenyun governmenL. L wus LIe IourLI cubIe Lo be severed In LIe regIon sInce
eb. 1;.
TIe Teums cubIe Iud been rerouLIng duLu Irom LIree oLIer cubIes severed 1o duys ugo In LIe Red Seu beLween
DjIbouLI und LIe MIddIe EusL. TogeLIer, LIe Iour IIber-opLIc cubIes cIunneI LIousunds oI gIgubyLes oI
InIormuLIon per second und Iorm LIe buckbone oI EusL AIrIcu's LeIecom InIrusLrucLure.
TeIecom compunIes were reeIIng over LIe weekend us engIneers uLLempLed Lo rerouLe duLu souLI uIong LIe EusL
AIrIcun cousL und uround LIe Cupe oI Good Hope.
"L's u very unusuuI sILuuLIon," suId CIrIs Wood, cIIeI execuLIve oI WesL ndIun Oceun CubIe Co., LIe IurgesL
sIureIoIder oI LIe EusLern AIrIcu SubmurIne CubIe SysLem, or Eussy, und u mujor owner oI duLu-cupucILy rIgILs
on LIe Lwo oLIer Red Seu cubIes. " beIIeve LIese were uccIdenLuI IncIdenLs, uILIougI more wIII be known wIen
we brIng LIe cubIes up Irom LIe seu bed."
Mr. Wood suId LIe Eussy cubIe, LIe Europe ndIu GuLewuy (EG) und LIe SouLI EusL AsIu MIddIe EusL WesLern
Europe- (SMW-) cubIes were uII severed uL LIe sume LIme ubouL 6o IeeL beIow LIe Red Seu. TIe cubIes were
uII severed Iur ouL Lo seu, buL Mr. Wood suId LIuL u pussIng sIIp couId Iuve cuused LIe dumuge becuuse LIe Red
Seu Is unusuuIIy sIuIIow.
He suId cubIe sIIps wouId repuIr LIe Red Seu cubIes wILIIn ubouL LIree weeks.
JoeI TunuI, generuI munuger oI Teums, suId pIuns uIso were under wuy Lo IIx LIe Mombusu cubIe.
"We wIsI Lo noLIIy uII our sLukeIoIders oI ongoIng emergency repuIr works und upoIogIze unreservedIy Ior uny
InconvenIence LIIs muy cuuse," Mr. TunuI suId. "TIe cubIe sIouId be IuIIy operuLIonuI wILIIn LIe nexL LIree
weeks."
TIe repuIr operuLIon wIII use remoLe-conLroIIed submurInes Lo survey LIe dumuge und IIIL LIe cubIes Lo LIe
oceun surIuce. EngIneers wIII LIen spIIce LIe cubIes und repuIr LIem In sunILIzed rooms ubourd cubIe sIIps.
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Appendix I


Ship's anchor accidentally slices internet cable cutting off access in six African
countries
x Claims the cables may have been sliced on purpose
By Rob Cooper
UPDATED: 16:03 EST, 1 March 2012

A ship's anchor accidentally sliced an underwater internet cable, cutting off access to six
African countries.
The incident happened as the vessel stopped in the wrong area as it waited to enter a port
in Mombasa, Kenya.
The ship was dragging its anchor when it broke the 3,000 mile long fibre-optic cable on
Saturday. It will take engineers three weeks to repair.

Internet cut: Workers haul part of the fibre optic cable to shore as it is laid in Mombasa in
2009
However, teams have already managed to restore 10 per cent of the cable's function so
services are back up and running at slow speeds, the Wall Street Journal reported.
There are claims that the cable was intentionally sliced as three other cables were also cut
in the Red Sea off the coast of Djibouti just days beforehand.
The broadband line severed last weekend goes from Mombasa to the United Arab
Emirates and was laid in 2009.
The cable - which cost 83million - was half-funded by the Kenyan government and half
by the private sector.
As well as supplying Kenya, the cable provides internet access to Tanzania, Burundi,
Rwanda, Ethiopia, and Juba, which is the capital of South Sudan.
Chris Wood, chief executive of the West Indian Ocean Cable company, told the Wall
Street Journal: 'It's a very unusual situation. I believe these were accidental incidents,
although more will be known when we bring the cables up from the sea bed.'
Since the cable was laid three years ago the number of internet users in Nairobi has
soared from 1.8million to 3.1million - and it has helped drive growth in the area.
Google, Microsoft and Samsung have all opened offices in the area in recent years.
The broadband outage is expected to cost the Kenyan economy in the region of
300million and has led to calls for more internet cables to be laid.
Joel Tanui, manager of The East African Marine Systems company (Teams) who are
responsible for the cable, told the Guardian: 'We wish to notify all our stakeholders of
ongoing emergency repair works and apologise unreservedly for any inconvenience this
may cause.
'The cable should be fully operational within the next three weeks.'




















Appendix J
AECOM 206.624.9349 tel
710 Sec4nd Ave., Ste. 1000 206.623.3793 fax
Seattle, WA 98104
Admiralty Inlet Pil.t Pr.ject
Federal Energy Regulat.ry C.mmissi.n Pr.ject N.. 12690
Supplement t. Assessment .f Tidal Energy Sites Near Admiralty Head
Jena F. Gilman, P.E.
William J. Gerken, P.E.
Peter Grant, P.E.
July 2012
AECOM
2
This rep4rt supplements 4ur May 2012 Assessment 'f Tidal Energy Sites Near Admiralty Head (May
2012 Assessment), prepared at the request 4f PC Landing C4rp. (PCLC), and filed with PCLCs
interventi4n and pr4test (Pr4test) t4 the final license applicati4n f4r the Admiralty Inlet Pil4t Tidal Pr4ject
(Pr4ject) 4f the Sn4h4mish C4unty Public Utility District N4. 1 (Sn4PUD). On June 22, 2012, Sn4PUD
filed Resp4nses t4 all c4mments, including the Pr4test and 4ur May 2012 Assessment. In additi4n, 4n
July 16, 2012, FERC issued Requests f'r Additi'nal Inf'rmati'n t4 PCLC, as well as t4 Sn4PUD, and t4
the Federal C4mmunicati4ns C4mmissi4n which als4 filed c4mments with FERC 4n the Pr4jects likely
impacts 4n the PC-1 submarine cable. This Supplement t4 4ur May 2012 Assessment pr4vides s4me 4f
the additi4nal inf4rmati4n requested by FERC and addresses certain 4ther matters relevant t4 FERCs
inf4rmati4n request t4 Sn4PUD. This Supplement als4 addresses p4rti4ns 4f Sn4PUDs Resp4nse
regarding 4ur May 2012 Assessment, including a paper entitled Rati'nale f'r Admiralty Inlet Tidal energy
Dem'nstrati'n Pr'ject Siting (P4lagye, June 2012). Sn'PUD Resp'nse, Attachment D.
In 4ur May 2012 Assessment, we used a tw4-dimensi4nal, depth averaged finite element numerical
m4del t4 identify multiple p4tentially viable and feasible alternative l4cati4ns f4r the Pr4ject within
Admiralty Inlet that pr4vide a greater separati4n distance fr4m PC-1 and c4ncluded that alternate
l4cati4ns sh4uld be further analyzed in detail by Sn4PUD in 4rder t4 av4id, minimize and mitigate adverse
impacts t4 PC-1. P4lagye (June 2012) pr4vided a detailed critique 4f the m4del we used and presents
the results 4f a new high-res4luti4n c4mputer m4del devel4ped by 4ne 4f Dr. P4lagyes graduate
students, Miss Kristen Thyng (Thyng, 2012). As n4ted bel4w in m4re detail, all m4dels have limitati4ns,
including the m4del we used and the m4dels used by Sn4PUD. We n4te, h4wever, that Thyngs new
high-res4luti4n m4del appears t4 c4nfirm 4ur c4nclusi4ns as it als4 indicates that sites t4 the west 4f the
PC-1 cable are p4tentially feasible fr4m a res4urce intensity and p4tential energy generati4n perspective.
There are n4w three m4deling exercises 4ne c4nducted by AECOM and tw4 by Sn4PUD, that sh4w
multiple l4cati4ns t4 the west 4f PC-1 may pr4duce acceptable p4wer p4tential c4mpared t4 the pr4p4sed
l4cati4ns 100 and 150 meters east 4f PC-1. In additi4n, these sites appear t4 be c4nsistent with
Sn4PUDs 4ther siting criteria such that a detailed analysis is warranted. We als4 agree with Dr. P4lagye
that the appr4priate siting meth4d4l4gy is m4deling t4 measurement. We c4nclude that, based 4n the
results 4f b4th AECOMs simplified and Sn4PUDs s4phisticated m4deling exercises, at this p4int it w4uld
be appr4priate t4 c4nduct stati4nary ADCP measurements at multiple alternative l4cati4ns west 4f the
PC-1 cable where the m4dels have indicated p4tential alternative sites.
In April and May 2012, AECOM undert44k a numerical c4mputer m4deling eff4rt t4 estimate p4wer
pr4ducti4n. At the time AECOM devel4ped its m4del, Sn4PUD had n4t indicated 4r pr4vided a m4del 4f
Admiralty Inlet, while 4ne such m4del had previ4usly been c4mpleted (Thyng, 2010), and a sec4nd m4del
(Thyng, 2012) was under devel4pment and c4mpleted by the time Sn4PUD filed its Resp4nse t4
c4mments. AECOMs m4deling eff4rt was c4nducted under time and res4urces c4nstraints that were
clearly stated in 4ur May 2012 Assessment. Specifically, the AECOM m4del 4ver-predicted p4wer
pr4ducti4n generally by up t4 10%, but 4nly up t4 5% at the pr4p4sed turbine l4cati4ns.
1
Alternative site
l4cati4ns identified in 4ur May 2012 Assessment were pr4vided within 20% 4f the p4wer p4tential 4f
Sn4PUDs pr4p4sed turbine l4cati4ns. These l4cati4ns sh4uld all be c4nsidered as c4mparable
alternatives.
AECOM m4deling results suggest the feasibility 4f alternative sites such as AECOMs m4del stati4n ID
numbers 1360 and 1412 which are l4cated appr4ximately 500-600 meters fr4m PC-1 and exhibit

1
M4ti4n t4 intervene and pr4test 4f PC Landing C4rp., May 23, 2012, Appendix D, Table 1.
AECOM
3
c4mparable kinetic energy density.
2
The AECOM m4deling results identify alternative l4cati4ns that
appear t4 be viable and feasible f4r c4mmercial-scale pr4ject applicati4n based 4n predicted p4wer
4utput. Based 4n these results, AECOM c4ncluded that further detailed investigati4n by Sn4PUD is
warranted t4 address the c4ncerns 4f PCLC.
N4thing in the P4lagye rep4rt changes these c4nclusi4ns. The Thyng (2010) M4SSea m4del, like
AECOMs m4del, indicates that sites t4 the west 4f the PC-1 cable are feasible in terms 4f p4tential p4wer
generati4n see page 5, Figure 3 4f Dr. P4lagyes resp4nse (P4lagye, June 2012). In additi4n, the
M4SSea m4del was later used by Sn4PUD this year t4 nest a higher res4luti4n m4del 4f Admiralty Inlet
(Thyng, 2012) f4r further refinement and accuracy 4f the estimated site c4nditi4ns. The M4SSea m4del is
cited t4 achieve p4wer estimates within 5%.
3
The AECOM m4del and the s4phisticated M4del 4f the Salish Sea (M4SSea) devel4ped by Thyng and
rep4rted in 2012 thr4ugh her graduate w4rk, generally pr4vided similar m4del results, as is indicated by a
c4mparis4n 4f the AECOM and M4SSea results at the ADCP l4cati4ns utilized in the Pr4jects FERC
applicati4n. Indeed, in rep4rting 4n the Thyng 2012 results, P4lagye can 4nly say that results fr4m the
Thyng m4del indicate n4 regi4ns 4f higher p4wer density t4 the west 4f the PC-1 cable. see page 5 4f
Dr. P4lagyes resp4nse (P4lagye, June 2012). Areas t4 the west 4f PC-1 are n4t dismissed as having
insufficient p4wer p4tential under the s4phisticated m4deling (Thyng, 2012), 4r being significantly bel4w
the p4wer p4tential at the pr4p4sed turbine l4cati4n. Figure 4 4n page 6 4f Dr. P4lagyes resp4nse d4es
n4t include inf4rmati4n necessary t4 assess the results 4f the s4phisticated m4deling in the alternative
areas available west 4f the cable. This inf4rmati4n w4uld be helpful t4 understand the results 4f the
m4deling w4rk perf4rmed.
Figure 3 in P4lagye pr4vides a n4rmalized kinetic p4wer density during an ebbing tide f4r Admiralty Inlet.
While the c4l4rati4n 4f the pl4t d4es n4t all4w a refined understanding 4f the deviati4n in kinetic p4wer
between the pr4p4sed turbine sites and the alternative sites, the limited inf4rmati4n pr4vided by the
District suggests s4me 4f the alternative sites are within +/- 20% 4f the pr4p4sed turbine sites kinetic
p4wer density, warranting further evaluati4n with the m4del and subsequent field investigati4n using
stati4nary ADCPs.
M4re4ver, 4utput 4f an4ther m4del cited appr4vingly by P4lagye (Eppler, et al. 2010), appear t4 sh4w
current amplitude 4f appr4ximately 80% t4 perhaps as high as 97% as c4mpared t4 the turbine l4cati4ns
in areas t4 the west 4f PC-1- see page 7 Figure 6 4f Dr. P4lagyes resp4nse (P4lagye, June 2012).
In its siting criteria, Sn4PUD indicates that the pr4p4sed turbine sites sh4uld have High res4urce
intensity t4 be representative 4f c4nditi4ns that w4uld be enc4untered by a c4mmercial-scale pr4ject.
4
In
4ur 4pini4n, the alternative sites, whether under the AECOM m4del 4r under Thyng (2010) 4r Thyng
(2012) are all estimated t4 be representative 4f c4nditi4ns that w4uld be enc4untered by a c4mmercial-
scale pr4ject.

2
M4ti4n t4 Intervene and Pr4test 4f PC Landing C4rp., May 23, 2012, Appendix D, Table 2.
3
Resp4nse 4f Public Utility District N4. 1 4f Sn4h4mish, C4unty, Washingt4n, t4 rec4mmendati4ns, terms
and c4nditi4ns, pr4test, and c4mments, Appendix D, page 3, paragraph 1.
4
M4ti4n t4 Intervene and Pr4test 4f PC Landing C4rp., May 23, 2012, Appendix D, Page 1, first bullet.
DC-9639933 v1
CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person
designated on the official service list compiled by the Secretary in this proceeding.
Dated Washington, D.C. this 1st day of August 2012.



/s/ William M. Keyser
William M. Keyser

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