NBP (ATG) IR 01 March 5, Reference: NBP 18.01

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1 NBP (ATG) IR 01 March 5, 2015 Reference: NBP a. Who does NB Power intend to have testify with respect to the evidence? b. In preparing the evidence, who has reviewed or prepared portions of the evidence at NB Power? a. NB Power intends to have a witness panel available that will include Dean Landers, Tony O Hara and Scott Brown. Please see Attachment A 1, A 2 and A 3 for their respective curriculum vitae. b. The evidence (Exhibit NBP 18.01) filed by NB Power was prepared by Dean Landers. As with all evidence filed with the NBEUB, the evidence was reviewed by numerous internal stakeholders, including Tony O Hara and Scott Brown. 1

2 NBP (ATG) IR-02 March 5, 2015 Reference: NBP-18.01; Page 2, Lines New Brunswick Power Corporation s (NB Power) position is that ATG s decision to upgrade its Tinker transformer is premature in light of the following three realities currently affecting the New Brunswick and northern Maine interconnection (the Interface ): the ongoing regulatory proceedings in Maine relating to reliability in northern Maine the existing queued transmission service reservation requests in the NB Power OASIS the uncertain need to upgrade the transformer See also Page 3, Line 15; Page 9, Line 12 a. Which of the above conditions changing, would result in the application of ATG not being premature? It is NB Power s opinion that the three conditions listed above are not mutually exclusive and each outcome or determination ought to be known before an upgrade to the transformer is considered. The key determinant is the outcome of the Maine PUC regulatory process. For example, should that process conclude that another competing option is the appropriate resolution to northern Maine reliability issues, the replacement and upgrade of the Tinker Transformer could result in New Brunswick ratepayers paying for an asset that is no longer useful. 2

3 NBP (ATG) IR 03 March 5, 2015 Reference: Document NBP18.01 Page 6, Line 14 to Page 7, Line 2 On January 30, 2015 the MPUC issued its redacted Bench Analysis report (Attachment F). This is an integral component of Maine s regulatory procedure where the MPUC and its staff provide an analysis of the information presented in a regulatory proceeding and a proposed process to address the particular subject. In this case, the report addresses the least cost resolution to the reliability concern of the northern Maine electricity market. This report supports the adoption of an incremental approach by addressing the least cost reliability option first and then determining how to address the market issues. The MPUC Bench Analysis identifies the Tinker transformer upgrade and the rebuilding of line 6901 from the Tinker transformer substation in New Brunswick to Flo s Inn substation in Maine as potentially the least cost solution when considered in the context of a proposed transmission connection between Houlton and New Brunswick. The report also highlighted ATG s application to the Board for approval of the transformer upgrade, this Matter 256, and the hearing scheduled for March a. Does NB Power agree with the Bench Analysis, Page 34, which states; Each of the above solution options resolves all of the violations under the MPD safe harbor standards; however the Tinker/Line 6901 solution is significantly less costly than the other options. b. If not, why not? c. Please provide any studies or analysis completed by NB Power? d. Is NB Power or any NB Power related party in the MPUC proceeding? e. Has any NB Power entity completed any analysis or studies related to the MPUC proceeding and the Tinker Transformer Upgrade or any reservations made by NB Power entities? Please provide a copy of those studies or analysis. a. It is NB Power s understanding that the Tinker/Line 6901 solution does satisfy the MPD safe harbor standards, but does not satisfy the N 1 1 requirements necessary for Emera Maine to meet NERC reliability requirements. Please refer to the response to NBP (NMISA) IR 6 for additional information. b. See response to a. above for the requested information. c. NB Power has not performed any studies or analysis on the reliability of the Northern Maine system. d. Yes. NB Power and NB Energy Marketing are interested parties in the MPUC proceeding. e. Please refer to Attachments B 1 through B 9 provided in response to NBP (ATG) IR 07 for the requested information. 3

4 NBP (ATG) IR-04 March 5, 2015 Reference: Document NBP page 4, lines Over a period of almost four years stakeholders in the region, including ATG, NB Power, and Emera Maine (formerly Maine Pubic Service) with coordination by the New Brunswick System Operator (NBSO) and NMISA, worked towards identifying a solution to resolve the reliability concern. That work resulted in a draft analysis document prepared by the NBSO and presented to the Market Advisory Committee in New Brunswick. Ultimately, the work to resolve the Interface issue was halted due to a failure to reach a consensus on allocation and recovery of costs in the northern Maine and New Brunswick jurisdictions. a. Please provide a copy of the draft analysis document presented by NBSO to the Market Advisory Committee. Please refer to the response provided in NBP (NBEUB) IR-02 for the requested information. 4

5 NBP (ATG) IR-05 March 5, 2015 Reference: Document NBP page 5, lines NB Power s evidence on these regulatory proceedings underscores the hastiness and prematurity of the ATG application before the Board. As noted below, there is considerable uncertainty regarding the best potential solution, or solutions, to the reliability concern in northern Maine. In fact, the solution(s) stemming from the MPUC process may negate the need for the transformer replacement or upgrade. Therefore, it is untimely for ATG to preempt the conclusion of these proceedings and assess the outcome as it is related to the future operation of its transmission facilities. The alternative may, in fact, result in New Brunswick transmission customers paying for a stranded assets. a. Are the New Brunswick Transmission assets of ATG regulated by MPUC? b. Are the New Brunswick Transmission assets of NB Power regulated by MPUC? a. and b. No. Decisions of the Maine PUC regarding reliability solutions in northern Maine can affect the prudence of investments in transmission assets located in New Brunswick which are used to serve load in northern Maine. 5

6 NBP (ATG) IR-06 March 5, 2015 References: NB Electricity Act Section 147 Transitional Transmission Tariff 147(2) The Corporation shall, with respect to transmission service and ancillary services, administer and comply with the transitional transmission tariff until that tariff is replaced by a new transmission tariff approved or fixed under subsection 113(12). a. Please confirm that under Section 147(2) of the Electricity Act it has been the obligation of NB Power since October 1, 2013 to administer transmission service requests according to the terms and conditions of the NB Transitional Transmission Tariff. a. Confirmed. 6

7 NBP (ATG) IR 07 March 5, 2015 References: Document NBP page 8, lines 3 7 The NB Power OASIS currently has three queued transmission service requests, each with a delivery path into northern Maine, being studied by NBB Power. The details of the requests are as follows: Document NBP 8.06 Response to NBP (WKM) IR 14(a) a. Please confirm if these three queued transmission n service requests are still in study mode. b. Who are the individuals at NB Power who are responsible to complete these studies? c. Please provide any documentation relevant to each study, including; 1. Any description of the scope? 2. Any agreements related to the studies? 3. Any costing of the studies? 4. Internal or external corresponde ence related to the progress of the studies? 5. When does NB Power expect to complete the studies? d. With respect these communications between NB Power and the customers detailed in NBP (WKM) IR 14(a), please provide a copy of thatt correspondence. e. Has progress been made since December 12, that would change the response to NBP (WKM) IR 14 responsee to part e. is yes, pleasee provide thee specific changes for each of the for any of the three queued transmission service requests? f. If the seven responses to NBP (WKM) 1R 14( (a) for any affected service request. g. Please provide copies of any completed System Impact Studies and Facilities Studies for the three requests noted above. h. For any incomplete studiess please provide an indication of the status of the study and a projected date for completion. a. Confirmed. 7

8 NBP (ATG) IR 07 (cont d) March 5, 2015 b. Transmission Planning Engineers at NB Power Head Office perform System Impact Studies ( SIS ) in accordance with the New Brunswick Power Open Access Transmission Tariff for new Transmission Service Requests. These studies may include load flow, short circuit, stability, loss evaluation, economic and other analyses as appropriate. c. Information relevant to each study is as follows: For the 95 MW request 1. The scope is included in the Introduction section of Exhibit ATG 2.09 (Attachment C ATG (NBEUB) IR 11 Transmission Service Request). 2. An SIS agreement is not signed. Please refer to the response to NBP (ATG) IR 10 d. for further information. 3. NB Power s estimate of the cost to complete the SIS is $50, Please refer to the following items: 2013 NB to MPS Interface Upgrade Study (Attachment B 1) NB Power Meeting Minutes (Feb. 24, 2014) (Attachment B 2) Internal NBP Correspondence (Attachment B 3) Other Correspondence between ATG and NBP (Attachment B 4) Letter from ATG dated September 14, 2014 (Attachment B 5) Exhibit ATG 2.20 (Attachment N ATG (NBP) IR 14(9) Correspondence between ATG and NBP) 5. NB Power estimates that the studies will be completed in the next 90 days. For the 53 MW request 1. The scope of the study is similar to the 95 MW request. 2. An SIS agreement is not signed. 3. The cost is unknown at this time. 4. Please refer to Attachment B 6 (ATG IR 07) between NBP and Emera Maine for the requested information. 5. NB Power estimates that the studies will be completed in the next 90 days. 8

9 NBP (ATG) IR 07 (cont d) March 5, 2015 For the 22 MW request 1. Houlton Water Company wishes to be served directly from the NB Power system. The Feasibility Review can be found in Attachment B The Feasibility Review determined that a SIS was not required for this connection. A Facilities Study Agreement was signed and the Facilities Study completed. (Please refer to Attachment B 8). 3. The estimated cost of the Facilities Study is $25,000. d. There is no additional documented correspondence beyond that provided in the response to c. above. e. Yes. f. The Houlton Water Company Facilities Study has been completed. g. Please refer to the following for the requested information. 1. Exhibit ATG 2.09 (Attachment C ATG (EUB) IR 11 Transmission Service Request). 2. Attachment B 9 Additional MPS upgrade combinations (October 2013) h. Please refer to the response to c. above for the requested information. 9

10 NBP (ATG) IR 08 March 5, 2015 References: Document NBP Page 8 Lines 9 12 Whereas the outcome of the engineering studies required for each of these requests is not known and the results may either require the replacement, upgrade or, in fact, may negate the requirement of the transformer outright, it is premature for ATG to request approval of the Board at this time. Question: a. In the above referenced paragraph, who is responsible for the engineering studies? New Brunswick Power Corporation is responsible for these engineering studies. Other studies conducted by ISO New England or Maine PUC could also result in similar outcomes. 10

11 NBP (ATG) IR-09 March 5, 2015 References: Document NBP8.06 Response to NBP(WKM) IR-14(a) The 95 MW application 1) The 95 MW application was received on July 4, ) The customer was informed that a System Impact Study was necessary as required by the OATT. 3) No, a formal System Impact Study agreement was not issued for this application. The initial application for this request was issued in December 2012 by NB Power Generation Marketing. NBSO asked NB Power Transmission to conduct the System Impact Study without NBSO having to sign a new legal agreement. 4) No, a System Impact Study has not been completed 5) No, as it requires a completed System Impact Study. 6) No, as it requires a completed System Impact Study. 7) No, as it requires a completed System Impact Study. a. What happened to the original December 2012 application that required a new application queued on July 4, 2014? b. Wouldn t the rights and obligations with respect to an application under the OATT of NB Power Generation Marketing (a group within NB Power Genco) have transferred under the Electricity Act to New Brunswick Energy Marketing Corporation on October 1, 2013? c. If the response to part b. is yes why would a new application be required? d. If the response to part b. is no please explain why the request application obligations and rights would not be transferred. e. Was the original application withdrawn or altered in sufficient manner to make it be considered as a new application? If altered what are the changed conditions? f. Considering treatment of the July 4, 2014 application, what is the relevance of actions done or not done by NBSO with respect to the December 2012 application? a. The applicant chose to withdraw its December 12, 2012 application and submitted a new application with a new start and end date. b. With respect to this application, the answer is yes. c. and e. Please refer to the response to NBP (ATG) IR-09 a. above for the requested information. d. No response required. f. With respect to the July 4, 2014 application, actions with respect to the December 12, 2012 application does not have relevance. 11

12 NBP (ATG) IR 10 March 5, 2015 References: NB Transitional Transmission Tariff (October 1, 2013) section 19.1 pages Notice of Need for System Impact Study After receiving a request for service, the Transmission Provider shall determine on a nondiscriminatory basis whether a System Impact Study is needed. A description of the Transmission Provider's methodology for completing a System Impact Study is provided in Attachment D. If the Transmission Provider determines that a System Impact Study is necessary to accommodate the requested service, it shall so inform the Eligible Customer, as soon as practicable. In such cases, the Transmission Provider shall within thirty (30) days of receipt of a Completed Application, tender a System Impact Study Agreement pursuant to which the Eligible Customer shall agree to reimburse the Transmission Provider for performing the required System Impact Study. For a service request to remain a Completed Application, the Eligible Customer shall execute the System Impact Study Agreement and return it to the Transmission Provider within fifteen (15) days. If the Eligible Customer elects not to execute the System Impact Study Agreement, its application shall be deemed withdrawn and its deposit, pursuant to Section 17.3, shall be returned with interest System Impact Study Procedures Upon receipt of an executed System Impact Study Agreement, the Transmission Provider will use due diligence to complete the required System Impact Study within a sixty (60) day period. The System Impact Study shall identify any system constraints and redispatch options, additional Direct Assignment Facilities or Network Upgrades required to provide the requested service. In the event that the Transmission Provider is unable to complete the required System Impact Study within such time period, it shall so notify the Eligible Customer and provide an estimated completion date along with an explanation of the reasons why additional time is required to complete the required studies. a. Is it the obligation of NB Power as the Transmission Provider since October 1, 2013 to comply with Sections 19.1 and 19.3 of the Transitional Tariff? b. Did NB Power the Transmission Provider tender a System Impact Study Agreement to NB Energy Marketing within 30 days of the receipt of the completed application on July 4, 2014? c. Does NB Power agree that under the Tariff a System Impact Study Agreement would normally be completed within 45 days following receipt of a Completed Application (ie 30 days to tender the System Impact Study Agreement plus 15 days for it to be executed)? d. As of Dec 12, 2014, 160 days after the receipt of the 95 MW request, the response to NBP (WKM) IR 14(a) indicates that a system impact study agreement was not executed. Please explain why? 12

13 NBP (ATG) IR 10 (cont d) March 5, 2015 e. Why did the Transmission Provider not deem the 95 MW application withdrawn as a result of not receiving an executed System Impact Study Agreement from NB Energy Marketing? f. Has an agreement been executed since Dec 12, 2014? If so please provide a copy of the agreement and indicate the date on which it was executed. g. Does NB Power agree that a System Impact Study according to the Tariff should normally be completed within 60 days following receipt of an executed System Impact Study Agreement which would be within 105 days following receipt of a Completed Application? h. It is apparent that the 105 day target for completion of the System Impact Study for the 95 MW Application has not been achieved as 105 days from July 4 would be October 17 which has passed. Has the Transmission Provider provided NB Energy Marketing with an estimated completion date along with an explanation of the reasons why additional time is required to complete the required studies? i. If the response to part h. is yes, please provide a copy of the notification indicating the completion date and explanation. j. If the response to part h. is no, please explain why not. k. As of the date of submission of these information requests (Feb 19, 2015) 230 days have passed since the receipt of the 95 MW Completed Application which is more than twice the normal target for System Impact Study Completion. 1. What amount of due diligence has NB Power undertaken to complete the study in a timely period? 2. Is the study being done by NB Power in house resources and if so, how many person hours of work to this date has been applied on the study? 3. If the response to 2 is yes, why has NB Power not considered contracting out the study? 4. If NB Power had contracted out the study could it have been completed within fewer than the 230 days that have elapsed since receipt of the request on July 4, 2014? l. Does NB Power monitor its compliance with the Tariff? m. If the response to part l. is yes, please explain how it is done. Is there a "Tariff Compliance Officer" or is compliance the responsibility of some other party? If so, who and what are their specific responsibilities? n. If the response to part l. is no, please explain why not? a. Yes. b. No. c. Yes. 13

14 NBP (ATG) IR 10 (cont d) March 5, 2015 d. Please refer to the Introduction section of Exhibit ATG 2.09 ATG (EUB) IR 11 Attachment C for details of the original Long Term Firm Point to Point Transmission Service request by NB Power Generation Marketing. On July 4th, 2014 NB Energy Marketing withdrew its prior application (December 2012) and submitted a new one with a different start date, the old start date being Nov. 1, There were no other requests for Long Term Firm Point to Point Transmission Service on the EM MPD/NB interface in the queue at this time. A System Impact Study agreement for this new request was not issued due to uncertainty regarding the Tinker Transformer as described below. On February 28, 2014 in a letter to NB Power Transmission (Exhibit ATG 2.20 ATG (NBP) IR 14 (9) Attachment N) Ed Howard of Algonquin Tinker Genco, citing various issues with the Tinker Transformer changed its allowable transfer levels. This letter, along with subsequent letters in March, September and November 2014, did not provide any certainty with respect to the actions that Algonquin Tinker Genco would be taking to remedy issues with the transformer, nor was there any certainty with respect to the timeline of those actions. The allowable transfer levels of the Tinker Transformer must be known in order to properly study and design upgrades to the EM MPD/NB interface. In Exhibit ATG 2.09 ATG (EUB) IR 11 Attachment C, seven of the nine upgrade options studied will be incorrect if the allowable transfer levels of the Tinker Transformer are not modeled properly. e. Please refer to the response in d. above for the requested information. f. No. g. Yes, with note that the Tariff does provide for flexibility that some System Impact Studies, due to their scope, will exceed 60 days. h. Yes. i. There was no written notification. The notification was verbal and provided at a meeting to discuss the request held on Feb. 27, 2015 between NB Power, NB Energy Marketing and Emera Maine. It is expected that the SIS will be completed within the next 90 days. j. No response required. 14

15 NBP (ATG) IR 10 (cont d) March 5, 2015 k. 1. NB Power was unable to obtain a long term rating of the Tinker Transformer from ATG. In order to assist in the resolution of this issue, and as noted in Exhibit ATG 2.20 ATG (NBP) IR 14 (9) Attachment N in the November 10, 2014 letter, several issues regarding the Tinker Transformer have been resolved. NB Power was able to assist Algonquin Tinker Genco with replacement of the transformer bushing and lightning arrestors. 2. No formal SIS study work has been undertaken at this time. The study will be performed jointly by NB Power and Emera Maine. The NB Power work will be carried out using NB Power Transmission Planning personnel. 3. Please see response to d. above for the requested information. 4. No. Please see response to d. above for the requested information. l. NB Power monitors compliance with all regulatory requirements to which it is subject. NB Power s compliance with the Tariff is ultimately the subject of the Board s jurisdiction under section 129 of the Electricity Act. m. No response required. n. Please see response to l. above for the requested information. 15

16 NBP (ATG) IR-11 March 5, 2015 Reference: NBP Document 8.01 page 8 lines As demonstrated in Table 1 above, whether motivated by market demand or a reliability issue in northern Maine, the three requests provide positive evidence the mechanics of an Open Access Transmission Tariff is working... a. How does receipt of the three requests demonstrate that the mechanics of the OATT are working? b. Would the fact that the required system impact study for the 95 MW request was not completed within the targeted 105 day requirement under the OATT indicate that the mechanics of the OATT are working? c. Would the fact that the required system impact study for the 95 MW request has yet to be completed after 230 days indicate that the mechanics of the OATT are working? a. As identified in Exhibit NMISA 1.01, page 9, lines 5-12, there is a need for additional capacity to serve the NMISA market in order for the NMISA to meet its reliability standards without incurring expensive reliability must run contracts with its biomass plants. The three requests demonstrate that there are at least three different parties with proposals to provide additional capacity from New Brunswick via firm transmission service. b. The fact that the system impact study for the 95 MW request requires additional time outside of the target is indicative of: An extensive study scope for multiple levels of transfer involving an interconnection that is fully subscribed. Please refer to Exhibit ATG 2.09 Attachment C ATG (EUB) IR-11 Transmission Service Request. Uncertainty regarding the Tinker Transformer rating. Please refer to Exhibit ATG 2.20, Attachment N ATG (NBP) IR-14(9) Correspondence between ATG and NBP. Please refer to Attachment B-4 (ATG IR-07) Other correspondence between ATG and NBP. c. Please refer to the response to b. above for the requested information. 16

17 NBP (ATG) IR-12 March 5, 2015 References: Document NBP8.06 Response to NBP(WKM) IR-14(a) The 53 MW application 1) The 53 MW application was received on July 24, ) The customer was informed that a System Impact Study may be necessary but was dependent on the 95 MW application ahead of it in the queue. 3) No, the scope, timing and cost determination of this study has not been determined. a. Confirm that the 95 MW application ahead of the Emera Maine application for 53 MW in the queue is the NB Energy Marketing application of July 4, 2014? b. Confirm that, if NB Power the Transmission Provider had, according to Section 19.1 of the Transitional Tariff, deemed the NB Energy Marketing application withdrawn because of lack of an executed System Impact Study Agreement, then the 53 MW application of Emera Maine would not have been considered dependent on the 95 MW application ahead of it in the queue? c. If the 53 MW application was at the top of the queue would NB Power the Transmission Provider: 1. Have been able to determine the scope, timing and cost determination of a System Impact Study? 2. Require execution of a System Impact Study Agreement? d. Could the delay in processing Emera Maine s 53 MW Application because of the Transmission Provider s failure to fulfill its obligations under the Tariff be considered as discriminatory treatment of Emera Maine? e. Could the Transmission Provider s lack of applying Section 19.1 of the Tariff for the 95 MW request of NB Energy Marketing be considered as preferential treatment of its affiliate marketing entity? f. Has the Transmission Provider s treatment of the three service requests for delivery to northern Maine met the Comparability principle? a. Confirmed. b. Section 19.2 of the Transitional Tariff says that the System Impact Study Agreement will clearly indicate the Transmission Provider s estimate of the actual cost, and time for completion of the System Impact Study. Section 19.2 of the Transitional Tariff also states that in performing the System Impact Study, the Transmission Provider shall rely, to the extent reasonably practicable, on existing transmission planning studies. 17

18 NBP (ATG) IR-12 (cont d) March 5, 2015 Without any certainty with respect to the Tinker Transformer rating, the Transmission Provider cannot estimate the actual cost, time for completion, and the extent to which existing transmission planning studies can be used for the 95 MW request. Therefore, a System Impact Study Agreement was not issued to NB Energy Marketing for the 95 MW request submitted on July 4, Provided that the Transmission Provider can offer a System Impact Study Agreement to an eligible customer, and that agreement is not executed according to Section 19.1 of the Transitional Tariff, then an application would be considered withdrawn. c. 1. No. Please see response to NBP (ATG) IR-10 d. for the requested information. 2. Yes, unless there are existing transmission planning studies that can be used. d. No. NB Power does not agree with the statement that the Transmission Provider has failed to comply with obligations in the Tariff. Please refer to the response in b. above. e. No. NB Power does not agree with the statement that the Transmission Provider may be showing preferential treatment to its marketing entity. Please refer to the response in b. above. f. Yes. 18

19 NBP (ATG) IR 13 March 5, 2015 References: Document NBP8.06 Response to NBP(WKM) IR 14(a) The 22 MW application 1) The 22 MW application was received on September 30, ) No, the Feasibility Review determined that a System Impact Study is not required. 3) No, the Feasibility Review determined that a System Impact Study is not required. 4) No, the Feasibility Review determined that a System Impact Study is not required. 5) Yes, a Facilities Study Agreement was sent to the customer on Dec. 5, ) Yes, a Facilities Study Agreement was executed on Dec. 9, ) No, the Facilities Study is in progress. Transitional Transmission Tariff Section 32 ADDITIONAL STUDY PROCEDURES FOR NETWORK INTEGRATION TRANSMISSION SERVICE REQUESTS a. The time from receipt of the Application to tendering of the facilities Study Agreement was 64 days. Is this within the timelines set out in Section 32 of the Tariff for Network Service requests? b. Would completion of facilities and provision of Network Service for Houlton Water s 22 MW of load affect the system conditions for the 95 MW system impact study? c. If the response to part b. is yes, why wouldn t the higher queue position 95 MW application have its system impact study be completed prior to proceeding with the 22 MW request? a. Yes. b. No. The request from Houlton Water Company involves the complete separation of the Houlton Water system from the Northern Maine transmission system. If completed, it would reduce the amount of load on the Northern Maine system, but would not impact the request for an additional 95MW of transfer capability into the Northern Maine system. c. No response required. 19

20 NBP (ATG) IR-14 March 5, 2015 References: Document NBP page 7 lines 8-12 As demonstrated above, the uncertainty in the ultimate solution in northern Maine and whether or not the Tinker transformer is material in that solution will not be determined until the completion on Docket Any decision to upgrade the transformer until a decision has been made may result in stranded costs to be borne by New Brunswick customers. a. Do decisions or actions regarding reliability in an external jurisdiction alter the obligations of NB Power under the NB Transitional Tariff to handle a Completed Application for Long Term Firm Point-to-Point transmission service from NB? b. Please indicate and explain the terms and conditions in the Transitional Tariff that provide the Transmission Provider with the option not to fulfill its obligations regarding a Completed Application for transmission service dependent on the outcome of a hearing in an external jurisdiction. c. If a Transmission Customer executes an agreement for new transmission service that meets the pricing conditions of Attachment K, would this not eliminate the potential for stranded costs to be borne by New Brunswick customers? d. If the response to part c is no, please explain how the suggested stranded costs would occur. a. Yes. The transfer capability limit on an interconnection, for both real-time operations as well as planning, must be agreed to by the Transmission Provider in each jurisdiction. In cases were the transfer capability limits determined by each Transmission Provider are not the same, then the lower limit is chosen in order to meet the reliability requirements for both jurisdictions. Requests for additional transfer capability on an interconnection must therefore involve the Transmission Provider in each jurisdiction to ensure that the design and construction of any upgrades will achieve the requested service. b. Please refer to Section 20 of the New Brunswick Transitional Tariff, PROCEDURES IF THE TRANSMISSION PROVIDER IS UNABLE TO HAVE A TRANSMITTER COMPLETE NEW TRANSMISSION FACILITIES FOR FIRM POINT-TO-POINT TRANSMISSION SERVICE. c. Yes, except that this reference to stranded costs is not about new transmission service under Attachment K of the NB Power OATT. Rather, it is the risk that the Tinker Transformer may not be material to the ultimate solution for Northern Maine in Docket d. Please refer to the response in c. above for the requested information. 20

21 NBP (ATG) IR-15 March 5, 2015 References: Document NBP Page 10; Line In the event that the Tinker transformer is unable to perform for any reason, the short-term solution is that electricity transfers on the Interface are curtailed until transmission operators, under the direction of NB Power, reconfigure the transmission system transmission to a post-event state that would return electricity transfers to pre-event levels. This is a studied and reliable state for transmission system operations. a. Please provide a copy of these studies. b. How would the transmission system be re-configured? c. What would the effect be on the reliability of the system (including the New Brunswick and Northern Maine systems)? a. Please refer to NBP (NMISA) IR-2 (e). for the requested information. b. Please refer to NBP (NMISA) IR-4 (a) and (b). for the requested information. c. Please refer to NBP (NMISA) IR-2 (e). for the requested information. 21