New England States Committee on Electricity

Information Requests to National Grid

Pursuant to the Interim Formula Rate Protocols (the “Protocols”) that the Federal Energy Regulatory Commission (“Commission”) approved on December 28, 2020 in Docket No. ER20-2054-000[1] as part of the settlement agreement resolving all issues in Docket No. EL16-19 (“Settlement Agreement”), the New England States Committee on Electricity (“NESCOE”) submits the following information requests to New England Power Company d/b/a National Grid (“NEP”) regarding the Participating Transmission Owners Administrative Committee’s July 30, 2021 Annual Informational Filing Regarding ISO Tariff Charges in Effect as of June 1, 2021 and January 1, 2022; Docket Nos. RT04-2-000, ER20-2054, et al. (“2021 Informational Filing”).[2]

These information requests are being sent to Patrick.Tarmey@nationalgrid.com and Darek.Wheatley@nationalgrid.com in accordance with Attachment 11 of the 2021 Informational Filing.  Questions regarding these requests may be directed to Jason Marshall at jasonmarshall@nescoe.com and Dorothy Capra at dorothycapra@nescoe.com.

• Section 13(i) of the Settlement Agreement states that “[b]eginning on the Formula Rate Effective Date, [NEP] shall include 50% of [CWIP] in rate base for all transmission projects under construction on or after the Formula Rate Effective Date in the Local Service component of the Settled Formula Rate.” Do NEP’s proposed 2021 or 2022 revenue requirements include any CWIP in rate base?  If yes, please identify the schedules showing the amount of CWIP that is included in rate base.  If not, please explain whether, how, and when NEP plans to include 50% of CWIP in rate base for calendar year 2022.
• Section 13(iii) of the Settlement Agreement states that “[a]s part of the first informational filing under the Settled Formula Rate, National Grid, NSTAR Electric, and CL&P each shall include accounting procedures that comply with the Commission’s requirements documenting how Local Service customers will not be charged for capitalized AFUDC for projects that are included in CWIP in rate base . . . .”  For NEP, please identify where these accounting procedures are contained in the 2021 Informational Filing.
• Please refer to Eversource’s Attachment 10, Worksheet 4 – The Connecticut Light & Power, 2021, 2022 Plant in Service Forecast, which lists Actual/Estimated TCA Submittal Dates by project for its forecasted 2021 and 2022 plant additions. Please provide the same information for all plant additions listed on NEP’s Attachments 9(i)(1) -9(i)(2) and Attachment 10(d) for which a TCA is required pursuant to ISO New England’s Planning Procedure 4.
• Do NEP’s proposed 2021 or 2022 revenue requirements include the costs of any forecasted plant additions for Narragansett Electric Co. (“NECO”) or Massachusetts Electric Co. (“MECO”)? If yes, please identify the schedules that show the dollar amounts for those plant additions.  Also, please show the same information for those plant additions as is shown for the plant additions listed on NEP’s Attachments 9(i)(1) -9(i)(2) and Attachment 10(d).  Please also show the actual/estimated TCA submittal dates for those plant additions for which a TCA is required.
• Please refer to Attachment 2, PDF pages 629 and 632. Both pages purport to show NEP’s 2020 true-up of the transmission revenue requirement for PTF facilities.  However, the amounts shown on the two pages are different: (i) p. 629 shows $13,238,298 for Forecasted Transmission Revenue Requirements (Post-96) while p. 632 lists this as “N/A” and (ii) the bottom two numbers for Post-96 Revenue Requirements (adjusted sub total – sum and annual revenue requirement total) are not the same.  Please explain and reconcile the two schedules.
• Please refer to Attachment 2, PDF pages 646 and 674. Both pages purport to show NEP’s “Determination of the PTF Related Integrated Facilities Charges.”  It appears that all charges from NECO and MECO are included in the pre-97 revenue requirement and that none are included in the post-96 revenue requirement.  Is this correct? If yes, please explain the rationale.