NESCOE’s Second Set of Information Requests — Mystic 8&9

Legal Document

Dated: April 26, 2021

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NESCOE Information Request 2

April 26, 2021

Public Version

 New England States Committee on Electricity 

Information Requests to Constellation Mystic Power, LLC 

Pursuant to Section II.3 of Schedule 3A (the “Protocols”) of the Amended and Restated Cost-of-Service Agreement among Constellation Mystic Power, LLC (“Mystic”), Exelon Generation Company, LLC, and ISO New England Inc. (“Mystic Agreement”),[1] the New England States Committee on Electricity (“NESCOE”) submits the following information requests to Mystic regarding Mystic’s April 1, 2021 Informational Posting (“2021 Informational Posting”).

Questions regarding these information requests may be directed to Phyllis Kimmel at and Jason Marshall at 

The following information request refers to Attachment C of Mystic’s 2021 Informational Posting: 

2-1. Referring to Mystic 8 & 9 Schedule B, Line 8: 

a. Are the property taxes an expense that is being incurred due to the continued operation of Mystic 8 & 9? If yes, please provide supporting documentation that the taxes would not have been due if Mystic 8 & 9 retired on May 31, 2022. If no, please explain why it is appropriate to include these for recovery under the Mystic Agreement. 

b. If the answer to 2-1a, above, is yes, referring to Trial Exhibit No. NES-006 [BEGIN CUI//PRIV-HC]_______________[END CUI//PRIV-HC]. Please confirm or deny if Mystic 8 & 9 Schedule B, Line 8, should be updated. If deny, please provide a detailed explanation as to why not. 

Document Source Citations

[1]     Aspects of the Mystic Agreement and Protocols are still in dispute at the Federal Energy Regulatory Commission and/or the U.S. Court of Appeals for the D.C. Circuit.