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John A. Shope
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jshope@foleyhoag.com

April 30, 2018
E-FILE
Chris Simpson and Mitchell Tannenbaum
Hearing Examiners
Maine Public Utilities Commission
State House Station #18
Augusta, ME 04333-0018
Re:

Petition of Central Maine Power, NECEC Transmission Line, PUC Case No.
2017-00232

Dear Messrs. Simpson and Tannenbaum:
In accordance with the Commission’s procedural schedule and order dated March 30,
2018, intervenors Calpine Corporation, Vistra Energy Corp. (successor by merger to
Dynegy, Inc.), and Bucksport Generation, LLC hereby submit their pre-filed testimony in
the above captioned proceeding, together with associated exhibits. This testimony comes
from three witnesses:
1. James Speyer of Energyzt Advisors, LLC (“JMS-1”). Mr. Speyer testifies
that, contrary to the assertions of CMP, and contrary to Maine public policy,
construction of CMP’s proposed NECEC transmission line through Maine for
the sale of hydroelectric energy from Quebec to Massachusetts would at best
only negligibly reduce the net emissions of carbon dioxide from electric
power generation and may actually increase it. In the modeled year, in fact,
using the market assumptions of CMP’s own expert, Daymark Energy
Advisors, the increase in carbon emissions is the equivalent of adding a new
gas-fired power plant to the generating fleet. Even alternative assumptions
yield a net increase in carbon emissions due to the fact that increasing HydroQuebec exports to New England would reduce such exports to other regions,
such as New York, which would then have to substitute energy from fossil
fuels.
2. William Fowler of Sigma Consultants Inc. (“WSF-1”). Mr. Fowler testifies
that, contrary to the assertions of CMP’s expert, Daymark, the proposed
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 Chris Simpson and Mitchell Tannenbaum
April 30, 2018
Page 2
NECEC project would not qualify for capacity credit within the New England
Power Pool without the concurrent retirement of existing Maine power plants
of equal generating capacity, thus negating the $50 million annual capacity
market benefit to Maine electric ratepayers asserted by CMP. In addition,
Mr. Fowler testifies that, due to transmission constraints and other factors, the
imports from Hydro-Quebec on NECEC would foreclose the development of
additional renewable energy projects in Maine for the foreseeable future, with
resulting loss of job opportunities and tax revenues.
3. Tanya Bodell of Energyzt Advisors, LLC (“TLB-1”). Ms. Bodell testifies
that the purported “benefits” to Maine ratepayers of NECEC are achieved
entirely at the expense of existing Maine generators. In particular, relieving
transmission congestion at certain interfaces as CMP proposes would simply
move transmission constraints further downstream, such that NECEC would
cannibalize existing generators, and prevent the development of new
renewable generation in Maine, including proposed projects such as Aqua
Ventus, with resulting losses of existing and potential permanent jobs and
property tax revenue in Maine.
Sincerely,
s/John A. Shope

John A. Shope

B4828286.5