NESCOE

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

Legal Document

Dated: September 9, 2021

Posted in: ,

Authored by:

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”).[2]

Questions regarding these information requests may be directed to Phyllis Kimmel at pkimmel@pgklawoffice.com and Jason Marshall at jasonmarshall@nescoe.com.

The following information request addresses Mystic’s August 27, 2021 “Responses to the Informal Challenges of the New England States Committee on Electricity.”

  • Regarding the statement in the response to NESCOE A-02 that Mystic is “only seeking to recover the costs for three CRIs as 2022 capital expenditures under the Mystic Agreement; the need to incur the cost for the fourth CRI as a 2022 capital project has been obviated through the use of a spare rotor:”
    1. Is the spare rotor currently part of Mystic’s inventory and included in Mystic’s rate base?
    2. When the spare rotor is placed into service, will the value of the spare rotor be removed from Mystic’s rate base for the term of the Mystic Agreement?
    3. When the spare rotor is placed into service, will the inventory withdraw cost be included as a cost to be reimbursed under the Mystic Agreement?
    4. What is the inventory value of the spare rotor?

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.

[2]     This information request is being submitted after the end of the period in an attempt to narrow the scope of potential formal challenges.