FPLs Request for Recovery of the Costs Associated with the Seabrook Transmission Substations Pool Transmission Facilities NEPOOL Participants Committee Meeting March 12, 2004

2 Background Seabrook Transmission Substation acquired and transmission line support payments assumed by FPL Energy (FPLE) in November 02 FPLE filed with FERC to transfer the substation to a transmission subsidiary in March 03 seeking EWG status FERC denied EWG status to a transmission subsidiary denies the request in May 03 FPLE files a request with FERC to transfer the assets to a division of FPL in June 03 FERC conditionally approved the transfer on 9/10/03 NH PUC determining degree of regulation over FPL FERC approved FPL NED NEPOOL Participant status as of 10/1/03

Map of NEPOOL Transmission System to be provided during Presentation

4 Seabrook Transmission Substation 345 kV transmission substation Highly Integrated with the NEPOOL Transmission System Used in the provision of regional transmission service continuously Permits delivery of Seabrook Generation Output & Station Service Switching point for three major 345 kV transmission lines Critical to operation of the NEPOOL Transmission System Major contributor to North – South Interface Transfer Capability Most difficult to schedule for planned outages Prior owners that were transmission providers recovered costs under NEPOOL OATT Other current owners, i.e. MMWEC, Hudson and Taunton, afforded cost recovery on an ongoing basis

5 Summary of FPLs Request: FPL seeks cost recovery of the Seabrook Transmission Substation PTF and related Transmission Support Expenses. As such, FPL requests that it be recognized as a Transmission Provider entitling it to cost recovery of the 88.23% share of the Seabrook Transmission Substation PTF Annual Transmission Revenue Requirements pursuant to the NEPOOL Tariff as others have been permitted.

6 Details of FPLs Request: Per RNA Sect. 15.1, FPLE and FPL request that FPL be deemed as if itowned FPLEs share of the Seabrook Transmission Substation effective Oct. 1, 2003 Such action would allow FPL to use the 3 months of FPLEs costs for purposes of calculating 2004 rates FPL seeks to begin recovery of its Seabrook Transmission Substation PTF costs, including the related Transmission Support Expenses per the Tariff - Attachment F Formula Rate effective on the latter of June 1, 2004, or the date upon which FPLE transfers the assets to FPL.

7 FPLs Request Complies With Existing RNA & NEPOOL Tariff RNA Sect approval provides ownership rights to FPL FPL qualifies as a Transmission Provider under the Tariff RNA Sect provides for FPL to receive a distribution of NEPOOL Tariff transmission service revenues Tariff – Attachment F provides for FPLs inclusion of the Seabrook Transmission Substation PTF costs, plus related Transmission Support Expenses No amendments to the RNA or NEPOOL Tariff are required to accommodate FPLs request.

8 NEPOOL Process FPL committed to working in good faith with NEPOOL FPL described in detail its request and objectives to the Tariff Committee and Transmission Settlement Subcommittee through its Briefing Paper and at a number of meetings in Jan. and Feb. TSS raised a number of concerns regarding implementation of FPLs request Tariff Committee approved a series of motions that recommend the Participants Committee approve FPLs request

9 Tariff Committee Conclusions TC concluded that RNA Sect does not preclude recovery of transmission support payments TC concluded that an amendment to Attachment F of the Tariff is not required for FPL to recover ROE TC concluded that FPL may recover its ATRR without a specific Zonal RNS Rate or a Network Load TC concluded that FPLs facilities constitute a Local Network TC recommended to the NPC that FPL be deemed the owner of the Seabrook Transmission Substation as of 10/1/03; that it be considered a Transmission Provider as of the same date; and that FPL be entitled to recover ATRR on the basis of FPLE Seabrooks Oct-Dec 2003 costs for rates effective 6/1/2004

10 FPLs Specific Requests of NEPOOL Participants Committee Approve request to deem FPL owner of Seabrook Transmission Substation effective Oct. 1, 2003 per RNA Sect Accept FPL as a Transmission Provider as of the same date Approve FPL as eligible to receive its prorata share of the transmission service revenues collected by ISO-NE per RNA Sect Approve that FPL be permitted to base its ATRR applicable to June 1, 2004 NOATT rates on the cost of the Seabrook Transmission Substation and Seabrook Transmission Support Expenses during the period 10/01/ /01/03; and that FPL be similarly allowed to compute ATRR for June 1, 2005 by including the costs of the Seabrook Transmission Substation and Seabrook Transmission Support Expenses for that period in 2004 prior to the transfer from FPLE to FPL taking place.

11 FPLs Specific Requests of NEPOOL Participants Committee Designate FPLEs share of the Seabrook Transmission Substation as FPLs Local Network for purposes of the NEPOOL Tariff To the extent the NPC agrees with the TC that FPL is not required to have Network Load, approve FPLs ATRR recovery to be achieved like municipals ATRR is recovered To the extent the NPC does not agree with the TC, then the NPC should specify that the Seabrook Station Service Load is FPLs Network Load and such load should be removed from other TPs load to prevent double counting

12 Conclusion FPL desires to recover the costs associated with these long standing NEPOOL facilities (Substation and 345 kV lines) through the NEPOOL OATT in the same way that previous owners recovered these costs and the other current Seabrook owners presently recover such costs. These transmission facilities are, and have been, a key part of the NEPOOL grid and are essential for the reliability of the NEPOOL transmission system. All of NEPOOL derives the benefits of these facilities. FPL respectfully requests approval by the NPC of its Section 15.1 requests.