July 1, 2013

By Electronic Filing

The Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, N.E.

Washington, D.C. 20426

Re: Niagara Mohawk Power Corporation d/b/a/ National Grid - Proposed

Amendments to the Wholesale Transmission Service Charge Under the NYISO Open Access Transmission Tariff - Docket No. ER13-1182-000`

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act ("FPA"), 16 U.S.C. § 824d, and Part

35.13 of the Commission's Regulations, 18 C.F.R. Part 35.13, Niagara Mohawk Power Corporation
d/b/a National Grid ("National Grid" or "Company") submits for filing an amendment to its March
29, 2013 filing in this proceeding, in accordance with directions provided by FERC staff in a
deficiency letter issued on June 26, 2013 (“June 26 Letter”). On March 29, 2013, the Company
proposed revisions to the FERC Open Access Transmission Tariff ("OATT") administered by the
New York Independent System Operator, Inc. ("NYISO") to amend National Grid specific
components of the Wholesale Transmission Service Charge ("Wholesale TSC") formula rate under
the NYISO OATT (“March 29 Filing”). Specifically, National Grid proposed changes to its
Scheduling, System Control and Dispatch Costs (“CCC”) formula rate under the Wholesale TSC to
incorporate costs incurred by the Company for Reliability Support Services (“RSS”). In the June

26 Letter, National Grid was directed to answer four questions and to amend its filing within 15 days.1 The Company’s responses to these questions are attached. National Grid requests that the changes proposed in the March 29 Filing be allowed to become effective for transmission services rendered on and after July 1, 2013. National Grid respectfully submits that its proposal is just and reasonable and should be accepted without suspension or hearing.

I.Description of Filing

The primary purpose of the March 29 Filing is to incorporate RSS expenses into the CCC
component of the Company’s Wholesale TSC formula rate which is set forth in Attachment H to
the NYISO OATT. RSS expenses consist of temporary payments made by the Company to
generators or other similar resources for the specific purpose of maintaining reliability on the
Company’s transmission system. NMPC began incurring such charges during calendar year 2012

1 June 26 Letter at 3.

The Honorable Kimberly D. Bose, Secretary
Page 2

under the first of two agreements with NRG Energy, Inc. pursuant to which, NRG will defer

mothballing and continue to operate certain generating units at its Dunkirk generating station in
upstate New York pending the completion of upgrades to the Company’s transmission system.

In order to effectuate this change, National Grid proposes to add a new item to the CCC

component of the TSC formula rate, as set forth in Attachment H. Specifically, National Grid will add a “Reliability Support Services Expense” component to its formula rate that will be defined in Attachment H as “expenses incurred pursuant to agreements entered into with generators or other similar resources for the purpose of supporting transmission reliability.” As explained in the
testimony of Mr. James Holodak Jr. included with the March 29 Filing, among the various FERC Accounts, the Commission’s explanation of costs to be included in FERC Account 561.1 best
matches the description of RSS-type costs.2

As explained in the March 29 Filing, the Company plans to incorporate RSS expenses into
the Wholesale TSC rate formula for the first time as part of National Grid’s 2013 Annual Update
filing which will establish TSC rates for service rendered July 1, 2013 through June 30, 2014. The
Company’s revenue requirement for calendar year 2012 will be used as the basis for determining
its 2013 Annual Update, and the Company’s actual RSS expenses incurred during 2012 under its
agreement with NRG would be the first RSS expenses to be included in the Company’s Wholesale
TSC formula rate.

In addition to these revisions, the Company is proposing certain ministerial changes to

Attachment H of the NYISO OATT to clarify and correct the application and definitions describing the TSC formula rate. These changes are also described in Mr. Holodak’s testimony.3 None of these proposed ministerial changes has any revenue impact on the TSC rate.

As with the March 29 Filing, National Grid has consulted with the NYISO to determine a mutually acceptable means for National Grid to exercise its FPA Section 205 rights with respect to this amendment of the Wholesale TSC. While not sponsoring National Grid’s filing in this
proceeding, the NYISO is submitting this filing on National Grid’s behalf under the Commission’s e-tariff regulations. Thus, the NYISO is facilitating the exercise of National Grid’s FPA Section 205 rights with respect to this portion of the NYISO OATT.

II.Contents of Filing

This filing consists of the following documents:

• Filing Letter

2 March 29 Filing, Exh. NMP-3 at 9-12. There is already a line item for Account 561.1 under the CCC component of
the National Grid’s TSC formula rate. However, as Mr. Holodak explains, RSS expenses will be assigned to Account
561.1 in addition to those, if any, already included in the CCC component. The Company is proposing to add
language to the description of the CCC component in Attachment H to make clear that expenses accounted for in
Account 561.1, to the extent that they are based on RSS costs, will be included in the CCC component.

3 March 29 Filing, Exh. NMP-3 at 12-14.

The Honorable Kimberly D. Bose, Secretary
Page 3

• Attachment A, Service List

• Attachment B, Responses to FERC Staff’s Information Requests

III. Proposed Effective Date; Request for Waiver

National Grid requests an effective date of July 1, 2013 for the revisions to the Wholesale TSC formula rate, which is the effective date proposed in the March 29 Filing, and, to the extent necessary, requests waiver of the notice period required specified in 18 C.F.R. § 35.3(a). The July 1, 2013 effective date remains appropriate and good cause supports National Grid’s request for waiver because, while National Grid is pleased to provide the additional information requested in the June 26 Letter to help Staff evaluate the Company’s filing, that information is not required as part of the March 29 Filing under Part 35 of the Commission’s regulations.

The information requested in the June 26 Letter concerns costs that National Grid may

incur under RSS agreements after July 1, 2013. However, as explained above and in the March 29
Filing, the March 29 Filing did not propose the recovery of specific RSS costs, but rather a change
in the Wholesale TSC formula rate to permit recovery of those costs when and if National Grid
incurs them. That formula rate adjusts Wholesale TSC charges effective on July 1 of each year
based primarily on the costs National Grid incurs during the previous calendar year (see March 29
Filing, transmittal at 5; NYISO OATT, Attachment H, § 14.1.9.4.1.3.1). Thus, the initial charges
under the amended Wholesale TSC formula rate will, commencing with July 1, 2013, recover RSS
costs that National Grid incurred during 2012. National Grid’s statement of the impact of the
proposed rate change during the first year after it takes effect, required by 18 C.F.R. § 35.13(c),
accordingly was based on the 2012 RSS costs. (see March 29 Filing, transmittal at 4-5; Holodak
Testimony at 12; Exh. NMP-4). For these reasons, while National Grid is providing the requested
information regarding RSS costs it expects to incur in 2013 and later years to assist Staff’s
evaluation of the March 29 Filing, that information was not required by the Commission’s
regulations. The omission of that information from the March 29 Filing presents no valid basis for
deferring the effective date of the revisions to the Wholesale TCS rate beyond July 1, 2013.
Rather, deferring the effective date of those revisions would unfairly deprive National Grid of the
opportunity to recover legitimate costs of providing transmission service.

National Grid respectfully requests the formula rate and associated tariff revisions be

accepted for filing effective for transmission bills rendered for service on and after July 1, 2013.
To the extent waiver is needed for this proposed effective date, National Grid hereby requests
waiver.

IV.Communications

National Grid requests that all correspondence, pleadings and other communications
concerning this filing be served upon the following persons to be designated for service:

The Honorable Kimberly D. Bose, Secretary
Page 4

Terry L. SchwennesenJames G. Holodak, Jr.

Attorney for National Gridc/o National Grid

c/o National Grid14th Floor

40 Sylvan RoadOne MetroTech Center

Waltham, Massachusetts 02451Brooklyn, New York 11201

(401) 480-9051(718) 403-2338

Terry.Schwennesen@nationalgrid.comJames.HolodakJR@nationalgrid.com

V.Service

Pursuant to Section 32.5(d) of the Commission's Regulations, a copy of this filing is being served electronically on National Grid's customers under the rate affected by this filing, the New York State Public Service Commission, the NYISO, parties either requesting or granted
intervention in this proceeding and other interested parties to the April 2009 Settlement . The service list for this filing may be found in Attachment A to this filing letter.

VI.Request for Waiver

National Grid respectfully requests waiver of any requirements of the Commission's rules and regulations, as well as any authorization as may be necessary or required, to permit the revised rates to be accepted by the Commission and made effective in the manner proposed herein.

VII. Conclusion

For the foregoing reasons, National Grid respectfully requests that the Commission accept
these proposed tariff changes without suspension, condition or modification, effective July 1, 2013.

Respectfully submitted,

/s/ Terry L. Schwennesen

Terry L. Schwennesen, Esq. c/o National Grid

40 Sylvan Road

Waltham, MA 02451 (401) 480-9051

Fax: (781) 907-1659

Terry.Schwennesen@nationalgrid.com

Attorney for

Niagara Mohawk Power Corporation d/b/a National Grid

Attachments

The Honorable Kimberly D. Bose, Secretary
Page 6

E-Mail List of Interested Parties upon Which this Filing was Served

Village of Akronsydshep@akronvillage.us

Village of Andoverandoverclerk@frontiernet.net

Village of Andovervoashop@frontiernet.net

Village of Arcadelarrykilburn@villageofarcade.org

Village of Bergenbergenelectric@yahoo.com

Municipal Commission of Boonvillekstabb@prodigy.net

Village of Broctonbrocton@stny.rr.com

Village of Churchvillemeghan@churchville.net

Village of Churchvillepaul@churchville.net

Village of Frankfortrvivacquavof@yahoo.com

Village of Holleyholley.electric.water@gmail.com

Village of IlionGregDLight@aim.com

Village of Little Valleydreynoldsvolv@atlanticbbn.net

Village of Mayvillemayville5@fairpoint.net

Village of Mohawkmohawkmuni@hotmail.com

Village of Philadelphiavphil@centralny.twcbc.com

City of Salamancakking@salmun.com

Village of Skaneatelesbob.lotkowictz@gmail.com

Village of Solvayjmontone2@aol.com

Village of Springvilleklux@villageofspringvilleny.com

Village of Theresatheresa@ridgeviewtel.us

Village of Wellsvillebillwhitfield@wellsvilleny.com

Village of Wellsvillepamelareed@adelphia.net

Village of Westfieldbboneberg@villageofwestfield

Village of Fairportmcw@fairportny.com

New York Municipal Power Agency/MEUAtmodafferi@nympa.org

Lake Placidclerk@lpvillage.org

Lake Placidelectric1@lpvillage.org

Oneida Madisonsherwood@oneida-madison.coop

Tupper Lakevilltupplake@centralny.twcbc.com

Tupper Lakejohnbouck@centralny.twcbc.com

Jamestowndleathers@jamestownbpu.com

Jamestowndgustafson@jamestownbpu.com

Green Islandkristin@greenislandpowerauthority.com

Richmondvillervillerpl@nycap.rr.com

Sherrill Power & Lightsherrillpower@twcny.rr.com

Former External TSC Customers

Allegheny Electric CooperativeGary_Wright@ccsenergy.com

Allegheny Electric CooperativeBruce_Erickson@ccsenergy.com

Amerada Hesshjain@hess.com

American Electric Powersepotters@aep.com

Dominion Energy MarketingRobert_J_LaRochelle@dom.com

Dominion Energy MarketingShirley_Flexon@Dom.com

Duke Energyseison@duke-energy.com

Conectiv Energy Supply Coral Power LLC

Dayton Power and Light
El Paso Merchant Energy
Emera Energy Service
Energy Endeavors LLC
Epcor

FPL Energy Marketing Gotham Energy marketing KeyTex Energy LLC

Merchant Energy Group of the Americas Mirant Energy Trading

Model City Energy
AES New Energy
NYSE&G Solutions

Public Service of Colorado Pure Energy

PSEG Energy Resources and Trading PSEG Energy Resources and Trading RBC Energy Services

Seneca Energy II

Shell Energy North America (US) L.P. Split Rock Energy, LLC

Southern Company Energy
TransCanada Power Marketing LTD TXU Energy Trading

Current External TSC Customers

Barclays Bank PLC
Black Oak Capital LLC
Black Oak Energy LLC
BP Energy Company
BP Energy Company

Brookfield Energy Marketing, Inc. Brookfield Energy Marketing, Inc. Bruce Power Inc.

Calpine Energy Service Calpine Energy Service Cargill Alliant, LLC

Centre Lane Trading

BNP Paribas Energy Trading GP formerly Fortis Energy Marketing

Citigroup Energy
Citigroup Energy

City Power Market LLC
City Power Market LLC

Constellation Energy Commondities Group Constellation NewEnergy

Shell Energy North America (formerly Coral Power LLC)

paul.wassil@conectiv.com wilma.chin@shell.com

brenda.haupt@dplinc.com
David.Lazos@ElPaso.com
Karen.Hutt@Emera.com

pjones@energyendeavorsllc.com settle@capitalpower.com

lauren_romero@fpl.com

pjones@gothamenergymarketinglp.com clanager@keytexenergy.com

sterling_koch@transalta.com vicki.lynch@mirant.com

pzeliff@ieslfge.com

Tamlynn.Apfelbaum@AES.com
mbeaudoin@theenergynetwork.com

rodney.d.sgrignoli@xcelenergy.com

delpowell@cox.net

howard.fromer@pseg.com
emily.pestano@pseg.com

iris.chow@rbccm.com

pzeliff@ieslfge.com

John.B.Coleman@shell.com jsolberg@acespower.com vicki.lynch@mirant.com

elaine_beaudry@transcanada.com dbogus1@txu.com

Nicholas.Andrews@barclayscapital.com

ckopp@blackoakcap.com spicard@blackoakenergy.com randy.prescott@bp.com
richard.waswil@bp.com

franklin.francis@brookfieldpower.com chantal.dube@brookfieldpower.com ayman.faddah@brucepower.com

garciab@calpine.com

Bryan.Stevens@calpine.com
lester_welch1@cargill.com

TLui@mackieresearch.com

lloyd.jackson@us.fortis.com Kolby.P.Kettler@citigroup.com laurel.r.adams@citigroup.com kstsingas@citypwr.com

jwebster@citypwr.com

brian.schuppert@constellation.com
brian.schuppert@constellation.com

John.B.Coleman@shell.com

The Honorable Kimberly D. Bose, Secretary
Page 8

Direct Energy MarketingLinda.Gatto@DirectEnergy.com

Dominion Energy MarketingShirley_Flexon@Dom.com

DC Energy LLCwilde@dc-energy.com

DTE Energy Tradinghissongm@dteenergy.com

DTE Energy Tradingpfankucha@dteenergy.com

Dynegy Power Marketingtiffany.e.mccaa@dynegy.com

EDF Trading North America, LLCamie.jackson@edftrading.com

Endura Energy LLCm.white@endureenergy.com

Exelon Generation LLC (formerly PECO)dirk.vanderlaan@exeloncorp.com

First Commoditiesjjtaza@firstcommodities.com

Capital Power Corporationlgatto@capitalpower.com

Hess CorporationElectricSettlements@hess.com

HQ Energy Services (US)bedard.lise@hydro.qc.ca

Iberdrola Renewablesdebbie.skinner@iberdrolaren.com

Integrys (formerly WPS) Energy ServicesDJVerbanac@integrysenergy.com

J. Aron and Companyallison.weingarten@gs.com

J.P. MorganJohn.K.Swint@jpmorgan.com

Louis DreyfusMaria.Arnoldy@LDHEnergy.com

MAG Energy Solutionsmgauthier@magenergysolutions.com

Macquarie Energy LLChope.hernandez@macquarie.com

Merrill Lynchchristen_moody@ml.com

Model City Energyshenningham@innovativeenergysystems.com

Morgan Stanleygospecops@morganstanley.com

NextEra Energy Power Marketing LLCbonny_arena@fpl.com

Noble Americas Gas & PowerDaniellefazio@thisisnoble.com

Northern States Powerrodney.d.sgrignoli@xcelenergy.com

NorthPoint Energysettlements@northpointenergy.com

NRG Power Marketingmichael.evans@nrgenergy.com

NYPAwilliam.palazzo@nypa.gov

NYSEG (LSE)nyseget@nyseg.com

NYSEG (LSE)caroe@nyseg.com

Ontario Power Generationrichard.gell@opg.com

Powerex Corporationtom.bechard@powerex.com

PP&L Energy Plus Cotatlas@pplweb.com

PSEG Energy Resources & Trading, LLCCindy.Midura@pseg.com

Iberdrola Renewables, Inc.debbie.skinner@iberdrolaren.com

Rainbow Energyk.morrison@rainbowenergy.com

Rochester Gas and Electriccaroe@nyseg.com

Saracen Merchant Energy LPlphillips@saracenenergy.com

Sempra Energy Trading LLCMarvina.Robinson@rbssempra.com

SESCO Enterprises LLCmschubiger@sescollc.com

SIG Energy LLPJamie.Miano@sig.com

Strategic Energy, Ltd.kkukic@sel.com

TransAlta Energy Mareric_macdonald@transalta.com

TransCanada Power Marketingmichelle_day@transcanada.com

Twin Cities Power Generationscurtis@tcpowergen.com

Vitol Inc.Lmm@vitol.com

West Oaks Energy NY NE LPms@westoaksenergy.com

XO Energy NYjcharette@xo-energy.com

Tom Rudebusch
Couch White, LLP
Couch White, LLP
Sonnenschein

Sonnenschein
Sonnenschein
NYMPA

Cleveland Public Power Cleveland OH

Central Missouri Electric Cooperative, Inc Thompson Coburn LLP

CCS Energy

State of Vermont
DPS NY State
DPS NY State
NYISO

Hunton & Williams LLP
Van Ness Feldman Law Firm Public Utilities Dept, RI

Duncan & Allen, Counselors at Law

Massachusetts Municipal Wholesale Electric Company Tellurian

Con Edison
Con Edison
NYPA

Thompson Coburn LLP
Saint Regis Mohawk Tribe

Stinson Morrison Hecker LLP Central Maine Power Co

Rochester Gas & Electric Central Hudson

FERC

Municipal Electric Utilities Association of New York State FERC

Couch White, LLP

Van Ness Feldman Law Firm
Van Ness Feldman Law Firm

Duncan, Weinberg, Genzer & Pembroke, P.C Winston & Strawn LLP

Winston & Strawn LLP

Duncan, Weinberg, Genzer & Pembroke, P.C NYSEG

NYPA
NYISO

Black & Veatch

tlr@dwgp.com

rloughney@couchwhite.com
mmager@couchwhite.com
ehand@sonnenschein.com
cvince@sonnenschein.com

WBOOTH@SONNENSCHEIN.com

info@nympa.org
tsmith@cpp.org

hmadorsky@city.cleveland.oh.us gstern@cmeec.org;

dstraus@thompsoncoburn.com david_dulick@ccsenergy.com hans.mertens@state.vt.us

william_heinrich@dps.ny.gov david_drexler@dps.ny.gov rfernandez@nyiso.com

tmurphy@hunton.com jbn@vnf.com

mkirkwood@pud-ri.org
jpc@duncanallen.com
bmckinnon@mmwec.org
ppanj@tellurian.com

nachmiass@coned.com smithce@coned.com

gary.levenson@nypa.gov
gnewell@thompsoncoburn.com dale.white@srmt-nsn.gov
duthie@attglobal.net

hreiter@stinson.com

scott.mahoney@cmpco.com catherine.mccarthy@dl.com marjorie_perlman@rge.com jwatzka@cenhud.com

Roger.St.Vincent@ferc.gov tmodafferi@meua.org

james.pepper@ferc.gov jgoodman@couchwhite.com msc@vnf.com

dpy@vnf.com
rw@dwgp.com

ddankner@winston.com rwuslich@winston.com jea@dwgp.com

RPKinney@nyseg.com micheal.lupo@nypa.gov mlampi@nyiso.com

robertsjl@bv.com

The Honorable Kimberly D. Bose, Secretary
Page 10

Geneva Lookerglooker@wrassoc.com

Dorothy Piercedorothy.pierce@chguernsey.com

Official Service List - Docket No. ER 13-1182

terry.schwennesen@nationalgrid.com; rstalter@nyiso.com;

jzimberlin@nyiso.com;
mlampi@nyiso.com;
jcutting@nyiso.com;
makter@nyiso.com;
aw@dwgp.com;

tlr@dwgp.com;

pjpallas@rvcny.us;

valerie.green@dentons.com;
william.booth@dentons.com;
tmodafferi@meua.org;
markc@plmnet.com;
mgs@dwgp.com;
rw@dwgp.com;

david_dulick@ccsenergy.com; mrr@dwgp.com;

John.Fernandes@ferc.gov;

The Honorable Kimberly D. Bose, Secretary
Page 11

Attachment A

CERTIFICATE OF SERVICE

I hereby certify that I have served by electronic mail the foregoing document upon all

parties on the email service list of Interested Parties provided in Attachment A pursuant to the requirements of the Settlement in the above-captioned proceedings.

Dated at Waltham, MA, this 1st day of July, 2013.

/s/ Terry Schwennesen

c/o National Grid

40 Sylvan Road

Waltham, MA 02451 (401) 480-9051

The Honorable Kimberly D. Bose, Secretary
Page 13

Niagara Mohawk Power Corporation
d/b/a National Grid

FERC Docket No. ER 13-1182
Attachment B

Page 13 of 4

Responses to FERC Staff's Information Requests - Request 1

Request:

National Grid requests that the formula rate and OATT revisions be accepted for filing effective for transmission bills rendered for service on and after July 1, 2013. However, Exhibit No. NMP-4, Statement BG - BL describe rate changes from test year 2011 compared to expected 2012 rates. What, if any, RSS expenses incurred prior to July 1, 2013 will be billed for transmission service that occurs on or after July 1, 2013?

Response:

The Wholesale TSC formula rate charges during each rate year (July 1 through June 30) are based primarily on costs incurred during the previous calendar year. See NYISO OATT, Attachment H, § 14.1.9.4.1.3.1. This is how the proposed revisions to the formula rate would recover RSS costs. Accordingly, the RSS expenses reflected in Exhibit No. NMP-4, Statement BG -BL, were all
incurred in 2012; from the period September, 2012 through December, 2012. Those expenses are to be recovered in charges under the Wholesale TSC formula rate for service rendered July 1, 2013 through June 30, 2014. RSS expenses incurred from the period January, 2013 through December 31, 2013 would recovered in charges billed for services rendered under the Wholesale TSC
formula rate from July 1, 2014 through June 30, 2015.

Prepared by or under the supervision of: James Holodak

The Honorable Kimberly D. Bose, Secretary
Page 14

Niagara Mohawk Power Corporation
d/b/a National Grid

FERC Docket No. ER 13-1182
Attachment B

Page 2 of 4

Responses to FERC Staff's Information Requests - Request 2

Request:

National Grid states that a second agreement provides for reliability service from one Dunkirk unit
from June 1, 2013 through May 31, 2015. Please explain whether all transmission service billing
for RSS under these revisions to the NYISO OATT Attachment H end on or before May 31, 2015?

Response:

Payments under the second agreement for reliability services, similar to the first agreement,

comprise monthly fixed price charges, property tax and take or pay adjustments, and revenue

credits. The company is estimating two small property tax adjustments in the beginning of 2016. RSS expenses incurred in the period January through December, 2015 would be billed through transmission billings from the period July 1, 2016 through June 30, 2017. Costs incurred from the period January 1, 2016 through December 31, 2016 would be billed through transmission billings for service from the period July 1, 2017 through June 30, 2018.

Prepared by or under the supervision of: James Holodak

The Honorable Kimberly D. Bose, Secretary
Page 15

Niagara Mohawk Power Corporation
d/b/a National Grid

FERC Docket No. ER 13-1182
Attachment B

Page 3 of 4

Responses to FERC Staff's Information Requests - Request 3

Request:

The Holodak Testimony describes the expected total increase in the Wholesale Transmission

Service Charge rate as $1,510,443 for 2012. What transmission service billing will occur as a result of the first agreement with Dunkirk ending May 31, 2013 and what transmission service billing is expected to occur as a result of the second agreement that runs through May 31, 2015?

Response:

As explained in response to Request No. 1, the Wholesale TSC charges during the Period July 1, 2013 through June 30, 2014 are entirely associated with costs under the first agreement. In the transmission billings from the period July 1, 2014 through June 30, 2015, the Company estimates that $1,330,705 would be billed as a result of the first agreement with Dunkirk ending May 31, 2013. For the second agreement the company estimates billing $1,451,200 for the period July 1, 2014 through June 30, 2015. Estimated billings under the second agreement for the periods after June 30, 2015 are shown in the response to Request 4.

Prepared by or under the supervision of: James Holodak

The Honorable Kimberly D. Bose, Secretary
Page 16

Niagara Mohawk Power Corporation
d/b/a National Grid

FERC Docket No. ER 13-1182
Attachment B

Page 4 of 4

Responses to FERC Staff's Information Requests - Request 4

Request:

National Grid provides several calculations and expectations as Exhibits No. NMP-1 - 4 to its

filing. However, none of these exhibits describe the expected RSS costs in years 2013, 2014 and
2015 when the second agreement ends. Please provide an update in this record of the total
expected increases in transmission service billing by describing expected changes in both the
Niagara Mohawk Power Corporation Annual Revenue Requirement and Wholesale Transmission
Service Charge.

Response:

Below please find a schedule of estimated RSS costs payable under the Dunkirk agreements and
the years the costs would be recovered. Note that under the Company’s proposal, additional RSS
costs could be incurred under other agreements, but no other agreements are anticipated at this
time.

Estimated Costs

to be included inTotal

SchedulingAnnualWholesaleAmount

System ControlBillingTSC RateForecasted to

and DispatchUnits (BU)RateBillingbe Billed in

Costs (CCC)MWh$/MWhUnitsTSC Rates

Calendar Year 2012 Payments to NRG, Billed Transmission rates July 1 2013 - June 30 201417,691,62537,212,6210.475423,177,0701,510,443

January through May Payments to NRG, Billed Transmission rates July 1 2014 - June 30, 201515,586,38337,212,6210.418853,177,0701,330,705

June through December Payments to NRG, Billed Transmission rates July 1 2014 - June 30,

201516,997,72337,212,6210.456773,177,0701,451,200

Total 2013 Payments Billed, Transmission rates July 1, 2014 - June 30, 201532,584,10637,212,6210.875623,177,0702,781,905

Total 2014 Payments to be Billed through Wholesale rates July 1, 2015 - June 30, 201634,844,08337,212,6210.936353,177,0702,974,854

Total 2015 Payments to be Billed through Wholesale rates July 1, 2016 - June 30, 201717,697,58337,212,6210.475583,177,0701,510,951

Total 2016 Payments to be Billed through Wholesale rates July 1, 2017 - June 30, 20181,240,04137,212,6210.033323,177,070105,870

Prepared by or under the supervision of: James Holodak