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Hearing Order MH-052-2018 Board File OF-Fac-PipeGen-T211 01 National Energy Board Jurisdiction of Coastal GasLink Project February 26, 2019

Michael Sawyer Information Request (IR) No.1 to Coastal GasLink Pipeline Ltd.

Contents 1.0 Topic: 2011 Shell Request for Proposals ...... 1 2.0 Topic: Project Development Agreement ...... 2 3.0 Topic: 2012 CGL Project Description – interconnection with NGTL ...... 4 4.0 Topic: 2012 LNG export application – CGL access to NGTL (Alberta System) ..... 4 5.0 Topic: 2012 LNG export application, Appendix A – CGL connects with NGTL ...... 7 6.0 Topic: NMML Proceeding – CGL interconnects with NGTL ...... 9 7.0 Topic: BC EAO Proceeding – CGL interconnects with NGTL ...... 16 8.0 Topic: 2015 LNG export licence application – CGL connection with NGTL ...... 17 9.0 Topic: TCPL 2013 to 2017 Annual Reports – CGL expected interconnect on NGTL ...... 20 10.0 Topic: CGL denial of connection to NGTL ...... 21 11.0 Topic: CGL’s unawareness of supply arrangements for CGL ...... 23 12.0 Topic: Five separate receipt meters at CGL inlet ...... 26 13.0 Topic: Only one meter station at CGL inlet ...... 27 14.0 Topic: Exclusion of inlet facilities from application to OGC ...... 29 15.0 Topic: CGL Limited Partnership or joint venture? ...... 30 16.0 Topic: CGL’s equity interest ...... 32

1.0 Topic: 2011 Shell Request for Proposals

Reference: i) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019, paragraph 32 Preamble: CGL states: “32. Coastal GasLink is the result of a 2011 request for proposal (RFP) from Shell Canada Energy for the transport of natural gas within BC to supply the LNG Canada Facility.” Sawyer IR1 to CGL February 26, 2019 Jurisdiction of CGL Pipeline Page 2 of 32

Requests: 1.1 Which corporate entity within TCPL responded to Shell’s 2011 RFP?

1.2 What is the date of TCPL’s response to Shell’s 2011 RFP?

1.3 In designing its response to Shell’s 2011 RFP, what did TCPL understand to be the physical source(s) of the gas to be transported?

1.4 Did Shell’s 2011 RFP specify “an area near Groundbirch BC” as the location from which proposals would transport gas? How did Shell’s 2011 RFP describe the location from which proposals would transport gas?

1.5 In designing its response to Shell’s 2011 RFP, did TCPL understand Shell’s ‘need for proposal’ to include access to the WCSB and market hubs?

1.6 Did TCPL’s proposal in response to Shell’s 2011 RFP contemplate a connection to the NGTL System, whether directly or indirectly, whether at the ISD or later, or whether by TCPL or a third party? If so, provide the details with supporting documentation. If not, describe what needs the proposal was designed to meet and provided supporting documentation.

1.7 If TCPL’s proposal in response to Shell’s 2011 RFP was not designed to provide the LNG export shippers with a connection to the NGTL System, access to the Montney region, access to the WCSB or access to the NIT market hub, explain why TCPL publicly described the CGL pipeline proposal as providing those features?

1.8 Provide a copy of TCPL’s response to the 2011 RFP. If TCPL claims confidentiality regarding some or all of the contents of the response to the RFP, provide an undredacted copy to the Board and a redacted version publicly. For each redaction, specify the asserted reason for the claim of confidentiality.

1.9 Was TCPL’s proposal in response to Shell’s 2011 RFP the same in material respects as the CGL Pipeline Project that emerged in 2012? Please describe any significant differences.

1.10 Was TCPL’s proposal in response to Shell’s 2011 RFP designed to meet an explicit or implied requirement that the proposal be within provincial jurisdiction?

1.11 Did TCPL state or imply to Shell that TCPL’s pipeline solution in response to the 2011 RFP would be within provincial jurisdiction?

1.12 Please describe the steps and dates through which TCPL’s response to Shell’s 2011 RFP led to the 2012 Coastal GasLink Pipeline Project.

2.0 Topic: Project Development Agreement

Reference: i) TCPL, 2012 Second Quarterly Report to Shareholders, p.3, https://www.transcanada.com/globalassets/pdfs/investors/reports-and- filings/annual-and-quarterly-reports/2012/transcanada-2012-q2-quarterly- report.pdf, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0,

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p.2, and A97948-4 B. 2012 transcanada-2012-q2-quarterly-report excerpts - A6S0X2 ii) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019 iii) October 29, 2018, A95224-1 Letter to NEB re LNG Canada Development Inc. request for standing - October 29, 2018 - A6J5G8 Preamble: In Reference (i), TCPL says that: “In June 2012, TransCanada announced that it had been selected by Shell Canada Limited (Shell) and its partners to design, build, own and operate the proposed Coastal GasLink project, an estimated $4 billion pipeline that would transport natural gas from the Montney gas-producing region near Dawson Creek, British Columbia to the recently announced LNG Canada liquefied natural gas export facility near Kitimat, British Columbia.” In Reference (ii), CGL says that TCPL’s submission was chosen under the terms of Shell’s 2011 RFP. CGL then describes the Project Development Agreement as follows: “33. TCPL’s submission was chosen under the terms of the RFP. TCPL then entered a Project Development Agreement (PDA) for CGL to construct Coastal GasLink with the following arm’s length counter-parties (including by way of assignment, in the case of PETRONAS) who collectively underwrite 100 percent of Coastal GasLink and own 100 percent of its capacity, both in the following proportions: a. Shell Canada Energy (a subsidiary of Royal Dutch Shell plc) (40%); b. North Montney LNG Limited Partnership (a subsidiary of PETRONAS, owned by a Malaysian state-owned company (SOC)) (25%); c. PetroChina Kitimat LNG Partnership (a subsidiary of PetroChina, owned by a Chinese SOC) (15%); d. Diamond LNG Canada Partnership (a subsidiary of Mitsubishi Corporation) (15%); and, e. Kogas Canada LNG Ltd. (a subsidiary of KOGAS, a Korean SOC) (5%). (collectively, the Participants). ... 40. Construction of Coastal GasLink is governed by the PDA. Under the terms of the PDA, CGL must meet key milestones to provide commissioning gas to the LNG Canada Facility.” While CGL does not list LNG Canada as a counterparty to the PDA, LNG Canada Development Inc. (LNG Canada) says in Reference (iii) that “LNG Canada is party to an agreement with TransCanada PipeLines Limited for the development of the Coastal GasLink Pipeline Project.” Requests: 2.1 Is LNG Canada a party to the Project Development Agreement?

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2.2 Does the term “Project Development Agreement” refer to a single high-level contract or to the entire complex package of interrelated agreements and sub- agreements between and among CGL and the counter-parties?

2.3 Describe in overview the structure of the Project Development Agreement.

2.4 Can CGL warrant that the PDA defines the CGL project in a manner that is consistent with the descriptions of the CGL project provided to the BC EAO, the CEAA, the NEB, the BC OGC, First Nations, and the public?

2.5 Can CGL confirm that the PDA contemplates that CGL will connect with the NGTL System and provide access to the WCSB and the NIT market hub? If not, provide supporting documentation.

2.6 Does the scope of the PDA exclude any gas infrastructure upstream of the receipt meters at the CGL inlet? If so, list all agreements CGL or affiliates have with LNG Canada or LNG Canada participants that include within their scope any gas infrastructure upstream of the receipt meters at the CGL inlet.

3.0 Topic: 2012 CGL Project Description – interconnection with NGTL

3.2 Does CGL agree that it told the NEB, the Canadian Environmental Assessment Agency, the BC Environmental Assessment Office, First Nations, members of the public, and potential investors that the CGL Pipeline Project will have an interconnection with the existing NGTL System at Groundbirch, which will provide access to other western Canadian natural gas supply?

4.0 Topic: 2012 LNG export application – CGL access to NGTL (Alberta System)

Reference: i) July 27, 2012, LNG Canada Development Inc., Application to the NEB for a Licence to Export LNG, - A2V3H8

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ii) TransCanada, Coastal GasLink Pipeline Project Description, CGL4703-CGP-EN- SD-001, October 30, 2012, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, p.2, and A97948-3 A. 2012-11-07 Coastal-GasLink- Project-Description excerpts - A6S0X1 Preamble: In its July 27, 2012 Application to the NEB for a Licence to Export LNG, Reference (i), LNG Canada Development Inc. says that a wholly owned subsidiary of TCPL, Coastal GasLink Pipeline Ltd., will permit, build, own and operate a pipeline that will deliver gas from the WCSB to the LNG Terminal. LNG Canada states: “32. Shell Canada Energy, as Project Administrator, for and on behalf of the Project Owners, has entered into a commercial arrangement with TCPL, whereby a wholly owned subsidiary of TCPL, Coastal GasLink Pipeline Ltd., will permit, build, own and operate a pipeline that will deliver gas from the WCSB to the LNG Terminal. The Project Owners will be individually obligated to contract for service sufficient to transport their respective participating interest share of gas at the LNG Terminal.” LNG Canada’s 2012 LNG export licence application makes it clear that:  the proposed CGL pipeline will connect to the NGTL System,  the LNG Terminal will be connected by pipeline systems to the WCSB market hubs,  the LNG Terminal will be connected to gas resources from the WCSB, not merely to gas resources within the immediate vicinity of the CGL inlet, and  in addition to their own gas production, Project Owners can fulfill their gas supply requirements through market purchases and swaps, which requires an interconnection between CGL and the NGTL System. LNG Canada states in the 2012 LNG export licence application: “15. LNG exported from the LNG Terminal will connect the abundant natural gas resources in the Western Canadian Sedimentary Basin ("WCSB") and the growing worldwide demand for LNG, including in the Asia-Pacific region. The North American gas market has experienced a dramatic shift in recent years, where North American gas supply now exceeds forecasted near - and long-term demand. Increased gas production from new gas fields in the United States, such as the Barnett, Haynesville, and Marcellus plays, have significantly reduced the share of the continental gas market served by the WCSB. In addition, unconventional gas plays in Western Canada have significantly enhanced the resources potential of the WCSB. ... 17. The Application highlights and expands upon the following key elements: ... • the Project Owners can fulfill their gas supply requirements to the LNG Terminal through a portfolio of options, including their own gas production - from existing reserves, contingent resources, prospective resources, and future net acquisitions - and open market purchases or swaps made at WCSB market hubs, as described in Section IV and Appendices A and B; ...

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• North American natural gas markets will continue to function efficiently over the proposed Licence term and natural gas buyers and sellers will continue to establish fair market prices based upon supply and demand fundamentals, as outlined in Section VII and Appendix E; ... IV. GAS SUPPLY ... 19. The Project Owners have the right to supply their participating interest share of natural gas through a portfolio of supply options. The Project Owners can fulfill their supply requirements through a combination of their own gas production - from existing reserves, contingent resources, prospective resources, and future net acquisitions - and open market purchases or swaps made at WCSB market hubs. The choices exercised will be based on the most economically efficient options at any given point in time. ii. Access to and Use of WCSB Gas Market Hubs 20. The sources of gas supply for the LNG Terminal will, by the time of commissioning of the LNG Terminal, be connected by pipeline systems to the principal market hubs where large volumes of gas are traded and market prices are established through trading. 21. The operation of these hubs and of the open and efficient gas markets they support is described in Appendix A. The Project Owners anticipate that they will each be able to secure through purchase arrangements and swaps with third parties such supply volumes as are required, in addition to their own gas production, to fully utilize their respective participating interest capacity in the LNG Terminal. 22. As previously stated, the Project Owners anticipate providing their participating interest share of LNG Terminal natural gas supply through their own gas production, purchases and swaps. Table 1 is a summary of the Project Owners' current aggregate uncommitted WCSB gas reserves and contingent resources, and an estimated daily production capacity that could be achieved to supply the LNG Terminal commencing in 2019. ... 26. The Project Owners will be able to provide gas supply to the LNG Terminal from a portfolio of supply options, including: • production of proved plus probable reserves; • the build-out of that production from contingent and prospective resources; • production from future net acquisitions; and • open-market purchases and swaps at WCSB market hubs. ... VI. TRANSPORTATION ARRANGEMENTS

i. Access to WCSB Market Hubs 31. The Project will be supplied from gas sources throughout the WCSB through connections to pipeline systems serving the principal market hubs. These market hubs will include, but are not limited to, the NOVA Inventory Transfer ("NIT") virtual trading point through access to the TransCanada PipeLines Limited

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("TCPL") Alberta System. This system provides the individual Project Owners with integrated access to gas production throughout the WCSB.” [underline added] Requests: 4.1 Can CGL confirm that the CGL pipeline project described in LNG Canada’s 2012 LNG export licence application (Reference (i)) is the same as the CGL pipeline project described in the 2012 Project Description (Reference (ii))?

4.2 Can CGL confirm that it was aware of the contents of LNG Canada’s 2012 LNG export licence application at the time the application was provided to the NEB?

4.3 Does CGL disagree with any material assertions in the 2012 export licence application? If so, please specify.

4.4 Does CGL agree that the 2012 export licence application said the proposed CGL pipeline will connect to the NGTL System?

4.5 Does CGL agree that the 2012 export licence application said the LNG Facility will be connected by pipeline systems to the WCSB market hubs, including NGTL’s NIT?

4.6 Does CGL agree that the 2012 export licence application said that, in addition to their own gas production, Project Owners can fulfill their gas supply requirements through market purchases and swaps?

4.7 With reference to paragraph 31 of the 2012 LNG export licence application, confirm that the TCPL “Alberta System” is also known as the NGTL System.

5.0 Topic: 2012 LNG export application, Appendix A – CGL connects with NGTL

Reference: i) 2012 LNG Export Application, Appendix A, Overview of Liquid Canadian (North American) Gas Hubs & Considerations in Purchasing Gas to Meet LNG Terminal Supply Requirements, A2V3H9 Preamble: Appendix A of LNG Canada’s 2012 LNG Export Application, Reference (i), says that the Project Owners will source WCSB gas through access to market hubs via the NGTL System. It states: “The Project Owners intend to source WCSB gas flowing through pipeline systems serving the principal market hubs. These market hubs will include but are not limited to NIT market liquidity provided through access to the NGTL system. As a result, they will have full access to the existing infrastructure enabling connectivity to the diverse supply and storage assets the NGTL system provides. It will also allow significant flexibility to manage the supply requirements for the life of the Project.” [underline added] Appendix A makes the point that access to the NGTL System provides supply reliability and flexibility for the LNG Facility because the NGTL System is integrated into the well- developed North American (NYMEX and Henry Hub) and Western Canadian (NGX and

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NITS) financial and physical gas markets. The Appendix emphasizes the large size and liquidity of the NGX electronic trading platform and the NOVA Inventory Transfer (NIT) virtual trading point on the NGTL System. It states: “Western Canadian natural gas can be traded through the NGX electronic trading platform where physical and financial trading is conducted utilizing key trading points such as the NOVA Inventory Transfer (NIT) virtual trading point. Over 200 contracting parties are members of the NGX clearing system and approximately 1.5 Bcf of physical gas is traded for same day delivery at NIT each day through the NGX system. Market Volume and Liquidity Available in Alberta: The NIT is the largest trading hub in Western Canada and represents the natural gas physically delivered on the TransCanada Alberta System (NGTL). Approximately 10 Bcf/d of natural gas production from the WCSB flows into the NGTL system providing supply to meet both local and export demands. Natural gas traded at NIT has access to over 300 Bcf of commercial storage capacity within Alberta, primarily to manage supply and demand imbalances on the pipeline system. The NIT hub is one of the most liquid markets in North America as natural gas originating from this system has access to multiple downstream markets including U.S. markets in the Pacific Northwest, California, the Midwest and Northeast via connectivity to key U.S. pipeline systems.” [underline added] The Appendix adds that access to the NGTL System provides the LNG Facility with access not only to the NIT LGX market but also to gas markets in Central and Eastern Canada. It states in Reference (i): “Furthermore, access to the Central and Eastern Canada market is available through TransCanada’s Canadian Mainline system. Recent export volumes from NGTL system have averaged approximately 6.5 Bcf/d.” In support of the LNG export licence application, the Appendix emphasized that LNG Canada’s “Portfolio Approach to Gas Acquisition” is a key feature given the large gas volumes involved. It states: “Portfolio Approach to Gas Acquisition: One of the keys for larger market participants to manage their supply and demand balance is to develop a portfolio of alternatives. That portfolio may include dealing directly with sellers in addition to using electronic exchanges. Benefits of this option include increased reliability, as the supply comes from a wider selection of wells, processing plants, and storage fields. From a pricing perspective, sellers into the portfolio may have different economic drivers that give them incentives to look at different alternatives in terms of how they sell their natural gas. The variety creates an opportunity for the market participants and the producers to arrive at a solution that is better than either could reach independently. Access to a portfolio of sellers also diversifies performance and credit risk.” [underline added] Requests: 5.1 Does CGL agree that LNG Canada told the NEB that the Project Owners will have full access to the NGTL System to source their gas for the LNG Facility?

5.2 Does CGL agree that LNG Canada told the NEB that the market hubs from which supply could be sourced include but are not limited to the NIT market on the NGTL System?

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5.3 Does CGL agree that LNG Canada told the NEB that the Project Owners would be able to access supply gas from the Central and Eastern Canada market through TransCanada’s Canadian Mainline system and the NGTL System?

5.4 Does CGL agree that LNG Canada told the NEB that the “Portfolio Approach to Gas Acquisition,” in which the Project Owners can access market hubs, is a key feature of the LNG project?

6.0 Topic: NMML Proceeding – CGL interconnects with NGTL

Reference: i) TransCanada, Coastal GasLink Pipeline Project Description, CGL4703-CGP-EN- SD-001, October 30, 2012, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, p.2, and A97948-3 A. 2012-11-07 Coastal-GasLink- Project-Description excerpts - A6S0X1 ii) 2013. North Montney Mainline Project Description - A3J8S7, pdf p.79 iii) February 12, 2013, “LNG Update,” presentation by TransCanada Tolls, Tariff, Facilities and Procedures Committee, at B1-5 Sec 03 Transportation (A3Q6S7), pdf p.241, et seq. iv) November 2013, NGTL Open House Materials for North Montney Project Application, “Project Map,” B1-16 Sec 12. Appendices 12-14 to 12-16 (A3Q6T8), pdf p.28 v) June 12, 2014, Map: Nova Gas Transmission Ltd., North Montney Mainline, Coastal GasLink, and Westcoast Connector Map, B23-9 Information Request Responses to EUG - A3Y0G0, pdf p.10 Preamble: In the 2012 CGL Pipeline Project Description, Reference (i), CGL states: “the Project will have an interconnection with the existing NGTL System at Groundbirch, which will provide access to other western Canadian natural gas supply.” [underline added] In the 2013 NMML Project Description, Reference (ii), the map on pdf p.79 shows an interconnection between the existing NGTL System and the proposed CGL pipeline. Labels on the map show “Existing NGTL Pipeline,” “Existing Groundbirch Meter Station,” and “Coastal GasLink Flow Direction.” A higher resolution version of the map is available online. The following is a lower resolution version:

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In the February 12, 2013, “LNG Update,” by TransCanada Tolls, Tariff, Facilities and Procedures Committee, Reference (iii), TransCanada provides a figure on pdf p.242 showing “Coastal GasLink” with an arrow from the NGTL System to Kitimat, BC. The text states:  “TransCanada and NGTL responding to market demands for transportation solutions,”  “Access to and from NIT valued,”  “Proponents seek to connect supply to NIT ahead of LNG plant in-service dates,”  “Driver for supply response – positive for WCSB development.” The slide on pdf p.242 is reproduced here:

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The figure on pdf p.243 of the TransCanada presentation is titled “Coastal GasLink Project.” It has a copy of the map showing Coastal GasLink flowing westward from the NGTL System to Kitimat and includes the following bullet points:  “Approximately $4 Billion (2011$)”  “650 km, large-diameter natural gas pipeline extending from Dawson Creek, BC to Kitimat, BC”  “Initial capacity of more than 1.8 Bcf/d; with expansion capability to more than 3.6 Bcf/d, as supported by shipper contracts”  “Will serve LNG facility proposed by Shell, Korea Gas, Mitsubishi and PetroChina”  “Opportunity for NGTL shipper participation in TBO to Vanderhoof”  “Expected in-service date towards end of the decade”  “Open season expected Q2 2013.” The slide titled “Coastal GasLink Conceptual Route” on pdf p.244 of the TransCanada presentation shows the interconnection of the CGL proposed pipeline and the existing NGTL System at Groundbirch:

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The next slide, titled “The Opportunity for NGTL Shippers,” on pdf p.245 has a diagram showing gas supply “From NIT” flowing into the CGL pipeline at “Groundbirch Area” and proceeding either straight through to “Kitimat Area” or exiting CGL at “NGTL Delivery Point, Vanderhoof Area.”

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A November 2013 “Project Map” for NGTL’s North Montney Project Application, Reference (iv), shows the southward flow down the proposed NMML and the existing Towerbirch and Groundbirch segments of NGTL, with an interconnection at Groundbirch labelled “Proposed Coast GasLink Project Flow Direction” and an arrow pointing south- west. A copy is reproduced here:

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A June 2014 NGTL map, Reference (v), shows the proposed Coastal GasLink pipeline connecting to the existing NGTL System in the Groundbirch area:

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Requests: 6.1 Can CGL confirm that the CGL pipeline project described in NGTL’s North Montney Mainline application is the same project as the CGL pipeline project described in the 2012 Project Description?

6.2 Does CGL agree that NGTL told the NEB during the North Montney Mainline proceeding that the CGL Pipeline Project would have an interconnection with the NGTL System, and provided the NEB with maps to that effect?

6.3 Does CGL agree that during the NMML proceeding NGTL provided the NEB with a 2013 TransCanada “LNG Update” that shows “Coastal GasLink Flow Direction” from the NGTL System, extols the benefits of CGL’s access to NIT via the connection with the NGTL System, and characterizes CGL and its interconnection with NGTL as a response to market demand from Shell, Korea Gas, Mitsubishi and PetroChina to supply the proposed LNG Canada Facility?

6.4 When and why did TCPL shelve the possibility of an NGTL delivery point on CGL near Vanderhoof?

6.5 Does CGL agree that the concept of an NGTL delivery point on CGL explicitly assumed an interconnection between NGTL and CGL?

6.6 Does CGL agree that CGL contemplated an interconnection with NGTL despite the abandonment of the concept of an NGTL delivery point on CGL? If not, provide documentary support.

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7.0 Topic: BC EAO Proceeding – CGL interconnects with NGTL

Reference: i) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019 ii) TransCanada, Coastal GasLink Pipeline Project Description, CGL4703-CGP-EN- SD-001, October 30, 2012, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, p.2, and A97948-3 A. 2012-11-07 Coastal-GasLink- Project-Description excerpts - A6S0X1 iii) 2014 Coastal GasLink Application to BC Environmental Assessment Office, Executive Summary, and Section 01 – Proposed Project Overview, at https://projects.eao.gov.bc.ca/p/coastal-gaslink-pipeline/docs?folder=55, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, p.2, and A97948- 7 E. 2014 CGL Executive Summary excerpts - A6S0X5, and A97948-8 F. 2014 CGL Section 01-Proposed Project Overview excerpts - A6S0X6 Preamble: In its Additional Written Evidence, Reference (i), CGL states that the BC Government issued an EA Certificate for CGL in 2014 after a process that began with the filing of a project description in October 2012 (Reference (ii)). Under the heading “Project Purpose and Rationale,” the 2012 CGL Project Description states: “In addition, the Project will have an interconnection with the existing NGTL System at Groundbirch, which will provide access to other western Canadian natural gas supply.” [pdf p.14, underline added] The executive summary of the 2014 CGL Application to the BC EAO, Reference (iii), states: “The purpose of the proposed Project is to connect natural gas producing areas in northeast BC with the proposed LNG Canada export facility near Kitimat, BC, to access new global natural gas markets. It is expected that the proposed Project will connect to the NOVA Gas Transmission Ltd. System near Groundbirch, BC.” [underline added] Similarly, the 2014 overview of the proposed CGL project, Reference (iii), states: “It is expected that the proposed Project will connect to the NOVA Gas Transmission Ltd. (NGTL) System near Groundbirch, BC, which will provide access to a variety of western Canadian natural gas supplies.” [underline added] Requests: 7.1 At any time during the BC EA process did CGL change the project description to remove the interconnection with NGTL?

7.2 At any time after the issuance of the EA Certificate for CGL has CGL notified the BC EAO that CGL will not have a connection with the NGTL System?

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8.0 Topic: 2015 LNG export licence application – CGL connection with NGTL

Reference: i) Application For Licence To Export Liquefied Natural Gas, LNG Canada Development Inc., July 2, 2015 - A4R1T9 ii) Appendix A - Description of Expected Gas Supplies and Requirements over the Requested Licence Term - A4R1U0 June 30, 2015, (“Navigant Report”) Preamble: In its July 2015 application for a revised LNG export licence, Reference (i), LNG Canada states in paragraph 11 that “The Project has not changed in any material respect since the LNG Canada Decision [approving the 2012 LNG export licence application]...” In paragraph 27, LNG Canada’s description of the source of the gas to be exported is the same as in the 2012 application. It states: “27. The Project Owners have the right to supply their participating interest share of natural gas through a portfolio of supply options. It is anticipated that the Project Owners will primarily source gas for the Project from the Western Canadian Sedimentary Basin ("WCSB"). The Project Owners will fulfil their supply requirements through a combination of their own gas production – from existing reserves, contingent resources, prospective resources, and future net acquisitions – and open market purchases or swaps made at WCSB market hubs. The choices exercised will be based on the most economically efficient options at any given point in time.” [underline added] Similarly, in paragraph 28, LNG Canada reiterates that the LNG Facility will be supplied with WCSB gas through connections to pipeline systems serving the principal market hubs. It states: “28. The Project will be supplied from gas sources throughout the WCSB through connections to pipeline systems serving the principal market hubs. These market hubs will include, but are not limited to, the NOVA Inventory Transfer virtual trading point through access to the NOVA Gas Transmission Ltd. ("NGTL") System. This system provides the individual Project Owners with integrated access to gas production throughout the WCSB.” [underline added] Next, LNG Canada informs the NEB that CGL received a B.C. EA Certificate in 2004, and reiterates that CGL will deliver gas from the WCSB to the LNG Terminal. LNG Canada states: “29. LNG Canada and the Project Owners have entered into a commercial arrangement with Coastal Gaslink Pipeline Ltd. ("CGL"), a subsidiary of TransCanada Pipelines Limited, whereby CGL will permit, build, own and operate the Pipeline, which will deliver gas from the WCSB to the LNG Terminal. CGL applied to the BC EAO for an EA Certificate for the Pipeline on March 11, 2014. The BC EAO issued an EA Certificate for the Pipeline in October of 2014.” [underline added] The June 2015 Navigant Report, Reference (ii), provided by LNG Canada in support of its application, states expressly that CGL is proposed to connect with the NGTL System: “The CGL is proposed to be a 48-inch diameter and 670-km long natural gas pipeline running from a point or points on the NGTL System infrastructure to the Project with an initial capacity of two to three Bcfd.” [underline added]

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The Navigant report explains the importance to the LNG Project of the CGL interconnection with the NGTL System in terms of the NGTL System providing Participants with integrated access to natural gas production throughout the WCSB. It states: “Natural gas supply for the Project is expected to be sourced primarily in the Western Canadian Sedimentary Basin (“WCSB”), which is composed principally of resources in British Columbia and Alberta. Natural gas supply for the Project may be accessed in a number of ways, including proprietary natural gas holdings of the Participants, and third party agreements with gas producers, marketers, and aggregators. Third party purchases are expected to be transacted at market hubs that may include, but are not limited to, the NOVA Inventory Transfer (“NIT”) virtual trading point through access to the NOVA Gas Transmission Ltd. (“NGTL”) System. This system provides the Participants with integrated access to gas production throughout the WCSB.” [underline added] The Navigant Report states again that a feature of the LNG export is that the CGL pipeline will deliver gas from the WCSB to the LNG Project: “LNG Canada and the Participants have entered into a commercial arrangement with Coastal GasLink Pipeline, Ltd. (“Coastal GasLink”), a subsidiary of TransCanada PipeLines Limited, whereby Coastal GasLink will permit, own, build and operate the Coastal GasLink pipeline (“CGL”) that will deliver gas from the WCSB to the Project. The CGL is proposed to be a 48-inch diameter and 670-km long natural gas pipeline running from a point or points on the NGTL System infrastructure to the Project with an initial capacity of two to three Bcfd. As discussed in detail throughout this report, gas supplies from the WCSB should be readily available for the Project due to the changing North American gas market dynamics, including gas production growth in the U.S.” [underline added] The Navigant Report provides a map of CGL in the context of the “Relevant Project Region Pipelines. Oddly, the map shows CGL connecting to NGTL at a location within Alberta.

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Requests: 8.1 Can CGL confirm that it was aware of the contents of LNG Canada’s 2015 LNG export licence application at the time the application was provided to the NEB?

8.2 Does CGL agree that LNG Canada told the Board in 2015 that the LNG Project has not changed in any material respect since the Board approved the 2012 LNG export licence application?

8.3 Would CGL agree that a decision not to connect CGL with the NGTL System to provide access to the WCSB and NIT would be a material change?

8.4 Does CGL agree that LNG Canada told the Board in 2015 that the source of the gas to be exported is the same as in the 2012 application, which is primarily from the WCSB through the Project Owners’ supply portfolios that include open market purchases or swaps made at WCSB market hubs as well as their own gas production?

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8.5 Does CGL agree that LNG Canada told the Board in 2015 that the LNG Project will be supplied from gas sources throughout the WCSB through connections to pipeline systems serving the principal market hubs; that these market hubs will include, but are not limited to, the NIT virtual trading point through access to the NGTL System; and that this system provides the individual Project Owners with integrated access to gas production throughout the WCSB?

8.6 In CGL’s view, what are the pipeline systems, other than NGTL, that serve principal market hubs of relevance to the CGL pipeline and the LNG Project?

8.7 Does CGL agree that the June 2015 Navigant Report, provided by LNG Canada in support of its application, states expressly that the proposed CGL pipeline would run from a point or points on the NGTL System to the LNG Project?

8.8 Does CGL disagree with any material aspect of the 2015 export licence application? If so, please specify.

8.9 Is the Figure 1 map in the 2015 Navigant Report incorrect in showing the CGL connection to NGTL being located at a point within the Province of Alberta?

9.0 Topic: TCPL 2013 to 2017 Annual Reports – CGL expected interconnect on NGTL

Reference: i) TCPL 2013 Annual Report, pdf p. 44, https://www.transcanada.com/globalassets/pdfs/investors/stock- information/annual-reports/transcanada-2013-annual-report.pdf, A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.12, and A97948-5 C. 2013 transcanada-2013-annual-report excerpts - A6S0X3 ii) TCPL 2014 Annual Report, pdf p.42, https://www.transcanada.com/globalassets/pdfs/investors/stock- information/annual-reports/transcanada-2014-annual-report.pdf, A97948-2 2019- 02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.12, and A97948-6 D. 2014 transcanada-2014-annual-report excerpts - A6S0X4 iii) TCPL 2015 Annual Report, pdf p.34, https://www.transcanada.com/globalassets/pdfs/investors/stock- information/annual-reports/transcanada-2015-annual-report.pdf, A97948-2 2019- 02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.12, and A97948-10 H. 2015 transcanada-2015-annual-report excerpts - A6S0X8 iv) TCPL 2016 Annual Report, pdf p. 35, https://www.transcanada.com/globalassets/pdfs/investors/stock- information/annual-reports/transcanada-2016-annual-report.pdf, A97948-2 2019- 02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.12, and A97948-11 I. 2016 transcanada-2016-annual-report excerpts - A6S0X9 v) TCPL 2017 Annual Report, pdf p. 30, https://www.transcanada.com/globalassets/pdfs/investors/stock- information/annual-reports/transcanada-2017-annual-report.pdf, A97948-2 2019- 02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.12, and A97948-12 J. 2017 TCPL transcanada-annual-report excerpts - A6S0Y0

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Preamble: Every TCPL Annual Report from 2013 to 2017 inclusive (References i, ii, iii, iv, and v) describes the Coastal GasLink project as “To deliver natural gas from the Montney gas producing region at an expected interconnect on NGTL near Dawson Creek, B.C. to LNG Canada’s proposed LNG facility near Kitimat, B.C.” [underline added] The following is an example:

Requests: 9.1 Confirm that every TCPL Annual Report from 2013 to 2017 inclusive says the Coastal GasLink project is “To deliver natural gas from the Montney gas producing region at an expected interconnect on NGTL near Dawson Creek, B.C. to LNG Canada’s proposed LNG facility near Kitimat, B.C.”

9.2 Does TCPL speak for CGL Ltd. when TCPL describes the CGL project in TCPL’s annual report? Does CGL Ltd. take issue with TCPL’s description of the CGL project?

9.3 Were TCPL’s descriptions of the CGL project accurate at the time they were made?

9.4 What does “100% effective ownership” mean in relation to the CGL pipeline in light of CGL’s assertion that the pipeline is fully underwritten by the LNG Partners?

10.0 Topic: CGL denial of connection to NGTL

Reference: i) A93738-1 Coastal GasLink Project_Response to Sawyer Application - A6H0X3 ii) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019 iii) TCPL 2018 Annual Report, pdf p.35, https://www.transcanada.com/globalassets/pdfs/investors/reports-and- filings/annual-and-quarterly-reports/2018/transcanada-2018-annual-report.pdf Preamble: In its August 24, 2018 submission to the Board, Reference (i), CGL said that “there is no current proposal to physically connect the Project to a federal work and undertaking.” CGL said “the Project may connect to upstream provincial sources of supply, including direct connections to provincially-regulated producer facilities.” [underline added]

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In its January 25, 2019 Additional Written Evidence, Reference (ii), CGL states in paragraph 79(c) that “Coastal GasLink is not expected to be integrated with any upstream pipeline, third-party or otherwise.” [underline added] CGL also states in its AWE: “30. CGL has received requests from the pipeline’s underwriters for five connections to its inlet, one for each of them. Presently, CGL is undertaking design work for these connections. To CGL’s knowledge, none of these connections are to physical infrastructure owned by TCC or its subsidiaries.” [underline added] TCPL’s 2018 Annual Report, issued in February 2019, Reference (iii), revises the description of CGL to delete the words “at an expected interconnect on NGTL near Dawson Creek, B.C.” that had been included in each Annual Report from 2013 to 2017. Requests: 10.1 Confirm that TCPL’s 2018 Annual Report, issued in February 2019, changes the wording of the description of CGL compared to the wording in the Annual Report from 2013 to 2017. Confirm that TCPL’s 2018 Annual deletes “at an expected interconnect on NGTL near Dawson Creek, B.C.” in the description of CGL.

10.2 Does TCPL’s deletion of “at an expected interconnect on NGTL near Dawson Creek, B.C.” reflect a material change in the Coastal GasLink project?

10.3 If TCPL’s deletion of “at an expected interconnect on NGTL near Dawson Creek, B.C.” does reflect a material change in the Coastal GasLink project:

10.3.1 Fully describe the change decision, including the terms of the decision, the party(ies) making the decision, the date, the rationale, and the corporate level of approval.

10.3.2 Was the change decision made jointly by CGL and LNG Canada?

10.3.3 Was the change decision made pursuant to the Project Development Agreement? If not, please explain.

10.3.4 Describe and file copies of any announcements or regulatory filings regarding a decision to eliminate CGL’s expected interconnect on NGTL near Dawson Creek.

10.3.5 Was the entry of PECL into the LNG Canada joint venture a material factor in a decision to eliminate the expected CGL and NGTL interconnect?

10.3.6 Was consideration of the implications for constitutional jurisdiction over CGL a factor in a decision to eliminate the expected CGL and NGTL interconnect?

10.3.7 Is it CGL’s intention that a connection between CGL and the NGTL System will be proposed after CGL has been constructed?

10.4 If TCPL’s deletion of “at an expected interconnect on NGTL near Dawson Creek, B.C.” does not reflect a material change in the Coastal GasLink project:

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10.4.1 Explain the deletion of “at an expected interconnect on NGTL near Dawson Creek, B.C.” from the description of CGL in the 2018 Annual Report.

10.4.2 Confirm that CGL is to deliver natural gas from the Montney gas producing region at an expected interconnect on NGTL near Dawson Creek, B.C. to LNG Canada’s proposed LNG facility near Kitimat, B.C.

10.5 Explain how it is possible that the CGL pipeline would not be integrated with any upstream pipeline, third-party or otherwise. Explain “upstream pipeline.” Is this supposed to mean ‘ upstream pipeline system’? Explain “integrated.” Does this mean something other than ‘connected’?

10.6 Is it CGL’s evidence that the CGL pipeline will not be connected physically to NGTL?

10.7 Is it CGL’s evidence that, to its knowledge, none of the five requested receipt meters at the CGL inlet will be connected directly or indirectly to the NGTL System or any other TCPL physical infrastructure?

10.8 Is CGL asserting that the CGL pipeline will be supplied entirely from sales gas coming directly from various gas plants?

10.9 For each receipt meter station, provide the name(s) of the gas plant(s), the distance between each gas plant and the CGL inlet, and the size and capacity of existing or planned sales gas lines to the CGL inlet.

10.10 Reconcile CGL’s August 24, 2018 claim that “there is no current proposal to physically connect the Project to a federal work and undertaking” with the lengthy regulatory history of CGL, NGTL and LNG Canada taking the position that a positive feature of the CGL pipeline is that the interconnection with NGTL will allow LNG exporters physical and financial access to gas supply from the WCSB and beyond.

11.0 Topic: CGL’s unawareness of supply arrangements for CGL

Reference: i) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019 ii) A97947-1 NGTL Written Evidence in CGL Jurisdiction - A6S0W7, February 15, 2019 iii) North Montney LNG Limited Partnership and PETRONAS Energy Canada Ltd., Additional Written Evidence, Appendix B, A97945-2 LNG Canada Additional Written Evidence and Appendices A-E - February 15, 2019 - A6S0W3, pdf p.13, para.28 iv) Testimony of Mr. Keys, January 31, 2018, North Montney Mainline Variance proceeding, A89726-1 18-01-31 - Volume 7 - A5Z8R9, line 9343, pdf p.92. Preamble: CGL claims to be unaware of how the Participants intend to arrange for their gas to be transported to the CGL inlet. In Reference (i), CGL states:

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“20. ... CGL has limited knowledge of these parties’ arrangements for transportation and supply upstream of the Coastal GasLink inlet. In paragraph 79 of Reference (i), CGL avers that its understanding of the LNG Participants’ upstream gas transportation arrangement is limited to the following: 79. ... CGL’s information on Participant plans for upstream supply is limited and is informed by Participant requests to CGL for inlet facilities to connect their supply to Coastal GasLink. CGL’s understanding is as follows: a. CGL has received requests from the Participants to construct five separate receipt meter facilities at the Coastal GasLink inlet, with each meter facility dedicated to a single Participant. The volume of gas from each Participant will be measured on receipt; b. The volume of gas that can be delivered to Coastal GasLink through the five receipt meter facilities is at least 2.1 Bcf/d... c. Coastal GasLink is not expected to be integrated with any upstream pipeline, third-party or otherwise. It is expected that CGL will establish a communications protocol with upstream facilities sufficient to schedule receipts on to Coastal GasLink and to act as its operator; and, d. The number of connections, volumes flowing through those connections, and the use of any upstream service is controlled by the Participants in accordance with the use of their own upstream pipelines, or with their contracts for service on, and the tariffs (if applicable) of, any third-party upstream facility.” In paragraph 84 of Reference (i), CGL states: “CGL is party to an information sharing agreement with LNG Canada and NGTL, which facilitates the parties sharing information about potential future connection to Coastal GasLink and related applications, if any. CGL’s understanding of connections is captured in this evidence at paragraph 79.” In Reference (ii) dated February 15, 2019, NGTL states: “...NGTL is exploring opportunities to supply the LNG industry on BC’s west coast. NGTL has assumed LNG deliveries in future supply and demand forecasting. NGTL is in constant discussions with various parties regarding potential commercial arrangements and service requirements. Those discussions regularly involve potential connections to new markets and NGTL would be interested in supplying Coastal GasLink with gas from the NGTL System.” [underline added] In its February 15, 2019 evidence, para.28, Reference (iii), Petronas says that as of September 2018 it had acquired capacity on the Westcoast Northern (Zone 3) facilities sufficient to supply its entire LNG Canada commitment. In Reference (iv), NGTL’s witness Mr. Keys states: “9343. MR. KEYS: I’d also observe, Mr. Sawyer, that we do keep in fairly close contact with those counterparties to monitor the developments of the upstream side as well. And if there was circumstances where we expected there would be no upstream development and we’d not commence construction of our facilities, at a meter station for example, we might pause and re-evaluate the pace at which we may proceed with facilities.”

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Requests: 11.1 What does CGL mean when it says it has “limited knowledge” of the five Partners’ arrangements for transportation and supply upstream of the Coastal GasLink inlet?

11.2 Is CGL asking the Board to believe that CGL is responsible for building a $6.2- billion pipeline for five shippers and yet it does not know how the five shippers on the pipeline are going to get their gas to the CGL inlet?

11.3 How is it possible for CGL to have only limited knowledge of the five Partners’ arrangements for transportation and supply upstream of the CGL inlet when (a) CGL co-manages and co-controls CGL LP with LNG Canada acting on its own behalf and as agent for the five Partners, and (b) CGL is party to an information sharing agreement with LNG Canada and NGTL, which facilitates the parties sharing information about potential future connection to Coastal GasLink and related applications, if any?

11.4 Is CGL’s knowledge of the five shippers’ arrangements for transportation and supply upstream of the Coastal GasLink inlet truly limited to the information provided in CGL’s Additional Written Evidence? Is CGL willing to support that position with a sworn affidavit?

11.5 In truth, does CGL actually have considerably more knowledge of the five Partners’ intentions for transportation and supply upstream of the Coastal GasLink inlet than CGL disclosed in its Additional Written Evidence?

11.6 Would CGL agree that when NGTL says it is in constant discussions with “various parties” regarding potential commercial arrangements and service requirements associated with supplying Coastal GasLink with gas from the NGTL System the phrase “various parties” would reasonably include some or all of the LNG Canada Participants?

11.7 Please reconcile CGL’s evidence that it has limited knowledge of the LNG parties’ arrangements for transportation and supply upstream of the Coastal GasLink inlet with NGTL’s evidence that it (NGTL) is in “constant discussions” with various parties about potential commercial arrangements and service requirements associated with supply Coastal GasLink with gas from the NGTL System.

11.8 Please elaborate on CGL’s statement that it “is party to an information sharing agreement with LNG Canada and NGTL, which facilitates the parties sharing information about potential future connection to Coastal GasLink and related applications, if any.”

11.8.1 Is this agreement being implemented?

11.8.2 Explain how CGL could have only limited knowledge of the LNG parties’ CGL upstream arrangements when CGL has an information sharing agreement on this very topic with not only the LNG parties but also with NGTL which says it is in constant discussions with various parties on this topic.

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11.9 Reconcile CGL’s evidence that it has limited knowledge of the LNG Partners’ arrangements for transportation of their gas supply to the CGL inlet with the evidence of Petronas that as of September 2018 it had acquired capacity on the Westcoast Northern (Zone 3) facilities sufficient to supply its entire LNG Canada commitment. Did this information come as a surprise to CGL? Does CGL not anticipate a pipeline between Petronas’s receipt meter station at the CGL inlet and the Westcoast transmission system?

11.10 Provide the full extent of CGL’s knowledge of each of the five LNG Partners’ respective arrangements for transportation and supply upstream of the Coastal GasLink inlet.

11.11 Provide a table with a row for each of the five Partners, and columns showing: the size of the incoming pipe at the CGL inlet receipt meter station, the design flow in bcf/d, the names of the gas plants or transmission pipelines from which the supply is sourced, and the distance between the gas plants and the CGL inlet.

11.12 Provide a schematic map showing CGL, NGTL, Westcoast T-North, and, to the full extent of CGL’s knowledge, any other upstream pipelines and gas plants through and from which the Participants will or may transport gas to the CGL inlet. Where the plans are uncertain, please include them on the map and indicate the uncertainty.

11.13 For greater certainty, is it CGL’s evidence that it has no knowledge of any discussions between TCPL and one or more of the LNG Canada participants regarding a pipeline connection between NGTL and the CGL inlet?

11.14 How does CGL reconcile its disavowal of knowledge of the Participants’ intended transportation arrangements upstream of the CGL inlet with Mr. Keys’ testimony to the Board in the NMML Variance proceeding that NGTL does “keep in fairly close contact with those counterparties to monitor the developments of the upstream side as well”?

12.0 Topic: Five separate receipt meters at CGL inlet

Reference: i) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019 Preamble: CGL states: “30. CGL has received requests from the pipeline’s underwriters for five connections to its inlet, one for each of them. 79 (a) CGL has received requests from the Participants to construct five separate receipt meter facilities at the Coastal GasLink inlet, with each meter facility dedicated to a single Participant. The volume of gas from each Participant will be measured on receipt...” Requests:

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12.1 Confirm that the requests for separate receipt meter facilities at the CGL inlet are from each of the Participants and not from LNG Canada.

12.2 Has it always been contemplated that each of the Participants would have a separate receipt meter station at the CGL inlet? If so, provide supporting documentation. If not, explain when and why any change(s) occurred and provide supporting documentation.

12.3 Provide a table showing the history of plans for receipt meter stations at the CGL inlet. Include as applicable the 2011 Shell RFP, TCPL’s proposal, the PDA, the 2012 CGL Project Description, and any subsequent changes to the number, funder, location or size of receipt meter stations at the CGL inlet. Indicate the date on which each Participant requested a separate receipt meter station at the CGL inlet and the size of the requested connection.

12.4 Provide a map showing the five separate receipt meter stations at the CGL inlet and the incoming pipes. Show on the map the land owned or controlled by TCPL or its affiliates.

12.5 Which of TCPL’s corporate entities is responsible for the arrangements with LNG participants for the planning, construction and operation of pipelines or other gas facilities on land owned or controlled by TCPL at the CGL inlet? Does this depend on whether there is to be a connection with NGTL?

13.0 Topic: Only one meter station at CGL inlet

Reference: i) May 15, 2018 CGL SHAR EA Certificate Unofficial Consolidated Version, https://projects.eao.gov.bc.ca/p/coastal-gaslink-pipeline/docs?folder=180, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.22 ii) BC EAO Assessment Report and Appendices for the CGL Project dated October 2014, https://projects.eao.gov.bc.ca/p/coastal-gaslink- pipeline/docs?folder=149, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.22 iii) CGL Pipeline Project, Certified Pipeline Corridor, Sheet 1 of 135, CPD Appendix_ Map Sheets.pdf https://projects.eao.gov.bc.ca/p/coastal-gaslink- pipeline/docs?folder=172 October 24, 2014, and A97948-2 2019-02-15 Sawyer AWE CGL jurisdiction - A6S0X0, pdf p.22, and A97948-9 G. 2014 CPD Appendix_ Map Sheet 1 of 135 - A6S0X7 Preamble: The most recent EA Certificate amendment for CGL on the BC EAO website is dated May 15, 2018. The Unofficial Consolidated Version of the CGL EA Certificate indicates only one receipt meter station at the CGL inlet (referred as “Wilde Lake”). Table 2 on pp.5-6 states:

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This is consistent with the BC EAO’s October 2014 Assessment Report for the CGL Project, Reference (ii), which also refers to only one meter station at the CGL inlet. It states on pdf p.23: “Meter Stations Meter stations measure would measure the volume of all natural gas entering or exiting the natural gas system. The proposed Project is designed to include meter facilities at three locations: • near Groundbirch (approximately KP 0.0), requiring up to 4 ha; • near Vanderhoof (approximately KP 299.0), requiring up to 10 ha; and • near the end point of the pipeline at the proposed LNG Canada export facility (approximately KP 656.5), requiring up to 10 ha.” Reference (iii) is a map showing the CGL inlet area:

Requests: 13.1 Does CGL agree that the BC EA Certificate for CGL includes only one meter station at the CGL inlet?

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13.2 Please confirm that the map in Reference (iii) is an accurate depiction of the locations of the proposed Wilde Lake Compressor Station and Wilde Lake Meter Station as approved under the BC EA Act. Alternatively, please explain and provide the correct map.

13.3 Please provide a version of the map in Reference (iii) with labels for the pipelines shown on the map in Sec 33, TP 78, Rge 19, i.e., in the vicinity of the Wilde Lake Compressor Station and Wilde Lake Meter Station.

13.4 For each of the pipelines in the vicinity of the Wilde Lake Compressor Station and Wilde Lake Meter Station, please list the owner’s name, pipeline size, pipeline direction, pipeline start and end points, and pipeline function, i.e., sour gas or sales gas.

13.5 What is the distance between the proposed Wilde Lake Meter Station and the NGTL System?

13.6 Does CGL, or a TCPL affiliate, own or control the real property between the proposed Wilde Lake Meter Station and the NGTL System?

13.7 Confirm, or otherwise explain, that Spectra’s Sunset Creek compressor station is located 2,300 m northeast of the proposed Wilde Lake compressor station.

14.0 Topic: Exclusion of inlet facilities from application to OGC

Reference: i) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019 Preamble: CGL states: “14. Due to the size of Coastal GasLink, the pipeline was divided into eight sections for the purpose of applying to the OGC for permits to construct. CGL applied for these permits in January and April of 2015. The OGC completed its process and issued the permits between May 15, 2015 and April 29, 2016.” Requests: 14.1 Is it correct that the 2015–2016 OGC approvals for CGL do not include approvals of any receipt meter stations or a compressor station at the CGL inlet?

14.2 Why did CGL exclude inlet facilities from the applications to the OGC for approval of the eight sections of the CGL pipeline?

14.3 Does CGL agree that the CGL pipeline cannot operate without a compressor station and at least one receipt station at the inlet?

14.4 Describe and provide a copy of any application to the OGC for approval of a compressor station(s) or receipt meter station(s) at the CGL inlet.

14.5 Has CGL, or any third party to CGL’s knowledge, applied to the OGC for approval of five separate meter stations at the CGL inlet? If so, provide the full details.

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14.6 Has CGL, or any third party to CGL’s knowledge, applied to the OGC for approval of pipeline to supply sales gas to any of the five separate meter stations at the CGL inlet? If so, provide the full details.

15.0 Topic: CGL Limited Partnership or joint venture?

Reference: i) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019 ii) October 29, 2018, A95224-1 Letter to NEB re LNG Canada Development Inc. request for standing - October 29, 2018 - A6J5G8 Preamble: CGL summarizes that construction of CGL is governed by the Project Development Agreement (PDA): “40. Construction of Coastal GasLink is governed by the PDA. Under the terms of the PDA, CGL must meet key milestones to provide commissioning gas to the LNG Canada Facility.” CGL lists the Participants in the PDA in the following paragraph: 33. TCPL’s submission was chosen under the terms of the [2011 Shell] RFP. TCPL then entered a Project Development Agreement (PDA) for CGL to construct Coastal GasLink with the following arm’s length counter-parties (including by way of assignment, in the case of PETRONAS) who collectively underwrite 100 percent of Coastal GasLink and own 100 percent of its capacity, both in the following proportions: a. Shell Canada Energy (a subsidiary of Royal Dutch Shell plc) (40%); b. North Montney LNG Limited Partnership (a subsidiary of PETRONAS, owned by a Malaysian state-owned company (SOC)) (25%); c. PetroChina Kitimat LNG Partnership (a subsidiary of PetroChina, owned by a Chinese SOC) (15%); d. Diamond LNG Canada Partnership (a subsidiary of Mitsubishi Corporation) (15%); and, e. Kogas Canada LNG Ltd. (a subsidiary of KOGAS, a Korean SOC) (5%). (collectively, the Participants).” CGL describes the structure and operation Coastal GasLink Pipeline Limited Partnership (CGL LP) as follows: “49. CGL is the general partner of the Coastal GasLink Pipeline Limited Partnership (CGL LP). CGL LP is the partnership through which Coastal GasLink is being constructed (collectively, CGL and CGL LP are the CGL Entities). ... CGL does not list the limited partners in CGL LP in its Additional Written Evidence. Regarding construction of the pipeline, CGL states: “53. Construction is controlled by consensus between CGL and LNG Canada Development Inc. (LNG Canada). Decision-making, and thereby control, of

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Coastal GasLink during construction is through a governance structure consisting of committees that make recommendations to an Executive Committee. The Executive Committee takes those recommendations and ultimately issues direction. CGL and LNG Canada each have one equal vote on each committee. LNG Canada acts on its own behalf and as agent for the Participants on these governing committees. 54. The main committees are: a. the Executive Committee, which provides overall supervision, direction, and strategic guidance for Coastal GasLink; b. the Engineering Design and Constructability Committee, which manages Coastal GasLink contracting with third parties; c. the Regulatory, Permitting and Stakeholder Relations Committee; and, d. the Commercial Committee, which is responsible for the major commercial agreements among the Parties to the PDA, including transportation agreements, the receipt interconnect agreements, and the access agreement that governs CGL’s access to its property within the LNG Canada Facility. 55. Each committee, other than the Executive Committee, makes recommendations to the Executive Committee. Decision-making at the Executive Committee is by consensus. If consensus cannot be reached there, then no action is taken, with the exception of any action required for safety. In the exceptional case of no consensus at the Executive Committee, a matter may be referred to senior executives of the parent companies for resolution. 56. CGL has a vote equal to LNG Canada’s on each committee but does not have control of any of the committees.” LNG Canada Development Inc. (LNG Canada) describes itself in Reference (ii) as follows: “LNG Canada is a joint venture comprised of five global energy companies: Shell Canada Energy, North Montney LNG Limited Partnership, Diamond LNG Canada Ltd., PetroChina Kitimat LNG Partnership and Kogas Canada LNG Ltd. (the "Project Owners"). LNG Canada, as Operator of the joint venture, will build and operate a liquefied natural gas ("LNG") export facility in the District of Kitimat, British Columbia ("Export Terminal").” LNG Canada also says in Reference (ii) that “LNG Canada is party to an agreement with TransCanada PipeLines Limited for the development of the Coastal GasLink Pipeline Project,” presumably referring to what CGL calls the Project Development Agreement. Requests: 15.1 Please list the general partner(s) and the limited partner(s) in Coastal GasLink Pipeline Limited Partnership.

15.2 For greater certainty, what is LNG Canada in relation to CGL LP: a general partner, a limited partner, or neither?

15.3 For greater certainty, are the corporate vehicles for Shell, PetroChina, Mitsubishi, Kogas, and Petronas limited partners of CGL LP?

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15.4 Please list the parties to the Project Development Agreement.

15.5 With reference to paragraph 53 of CGL’s additional written evidence, please explain how LNG Canada’s role of controlling construction by consensus with the general partner CGL is consistent with the role of a limited partner in CGL LP.

15.6 What does CGL mean when it says that LNG Canada acts “as agent for the Participants” on the governing committees on which LNG Canada and CGL have one equal vote?

16.0 Topic: CGL’s equity interest

Reference: i) A97628-1 Coastal GasLink - Additional Written Evidence - A6R5I9, January 25, 2019, paragraph 29 Preamble: CGL says that “In November 2018, TCC announced that it intends to sell the majority of its equity interest in Coastal GasLink to one or more arm’s length parties, while retaining a minority equity interest, with CGL to continue as operator.” Requests: 16.1 What is TCC’s equity interest in CGL based on given that the LNG partners are the pipeline’s underwriters?