RE:Pioneerhttps://www2.auc.ab.ca/Proceeding25937/ProceedingDocuments/25937_X0064_ATCO%20Pipelines%20Acquisition%20Reply%20Argument_000076.pdf
With respect, AP could not have anticipated that the UCA would so seriously misrepresent the power demand forecasts in the Wabamun area. AP's Rebuttal Evidence, which included a forecast from the AESO, the potential for large scale brownfield gas-fired generation projects in the Wabamun area, and statements from Capital Power, TransAlta and Tidewater,167 were submitted in direct response to the UCA's misrepresentations regarding the increasing forecast demand in the Wabamun area and its assertions that power generation in the Wabamun area are "shorter-lived developments".168 The UCA's assertion that "it appears clear that there continues to be a great deal of uncertainty with respect to"169 need for further gas supply in the Wabamun area, stands in stark contrast to AP's evidence, including the AESO forecast, which is the primary entity responsible for design capacity needs of the transmission system, and which also forecasts the need for generation in the Wabamun area in the long term