March 29, 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-
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 revisions to the FERC Open
Access Transmission Tariff ("OATT") administered by the New York Independent System
Operator, Inc. ("NYISO").1 The proposed changes are being made to certain National Grid-specific
components of the Wholesale Transmission Service Charge ("Wholesale TSC") formula under the
NYISO OATT. The primary purpose of this filing, in addition to certain ministerial changes, is to
amend National Grid’s Scheduling, System Control and Dispatch Costs (“CCC”) formula under the
Wholesale TSC to incorporate costs incurred by the Company for Reliability Support Services
(“RSS”), which are for the purpose of securing the ongoing reliability of National Grid’s
transmission system. National Grid requests that these changes 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. Statement of Nature, Reasons and Basis for Filing
The primary objective of this filing is to incorporate RSS expenses into the CCC component of the
Company’s Wholesale TSC formula rate set forth in Attachment H to the NYISO OATT. RSS
expenses consist of payments made by the Company to generators for the specific purpose of
maintaining reliability on the Company’s transmission system. In addition, the Company is
proposing certain ministerial changes described in the attached testimony of Mr. James Holodak Jr.
1 Capitalized terms used, but not defined in this filing are intended to have the meanings given to such terms in
Attachment H of the NYISO OATT including the April 2009 Settlement filed with the Commission on April 6, 2009.
The Honorable Kimberly D. Bose, Secretary
Page 2
The NYISO OATT specifically provides that the Revenue Requirement (“RR”) component, the
CCC component, and Annual Billing Units ("BU") components of a Transmission Owner's
Wholesale TSC rate may be updated "based on Transmission Owner filings to FERC."2 Under the
terms of Attachment H to the NYISO OATT, Transmission Owners, including the Company, have
rights to amend the components of their respective Wholesale TSC rates on their own initiative by
making the requisite filing for Commission approval under Section 205 of the FPA.3
Since it is the NYISO that administers the NYISO OATT, and specifically Attachment H which contains National Grid’s Wholesale TSC, 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. Background
A. National Grid
National Grid, a New York corporation, is a combination gas and electric utility. National Grid is primarily engaged in the business of transmission and distribution of electricity, and the
distribution and transportation of natural gas in New York State. National Grid serves over 1.6
million retail electric and 0.6 million retail gas customers in Buffalo, Syracuse, Albany, and other portions of upstate New York. National Grid owns approximately 6,000 miles of electric
transmission lines and 8,800 miles of main and distribution gas pipelines. All of National
Grid's bulk transmission facilities are subject to the operational control of the NYISO.
Transmission service and generator interconnections associated with National Grid's facilities are provided to customers on a non-discriminatory basis pursuant to the NYISO OATT.
Approximately 30 municipal electric utilities in upstate New York currently take service under
National Grid's Wholesale TSC. In addition, approximately 80 customers external to the NYISO take service under the Company's Wholesale TSC.
B. The Wholesale TSC
On January 27, 1999, the Commission conditionally accepted the proposal made by National Grid
and the other New York Transmission Owners ("NYTOs") to establish the NYISO in Docket
ER97-1523-000. In conjunction with that filing, on November 17, 1999, the NYTOs filed a joint
settlement agreement among all parties except Sithe/Independence Power Partners, L.P. ("Sithe")
resolving all issues set for hearing in Docket No. ER97-1523-000 ("the NYISO Settlement"). The
NYISO Settlement established as part of Attachment H to the NYISO OATT a settlement Revenue
Requirement and Transmission Service Charge for wholesale transmission services provided using
National Grid's facilities that was made applicable to all parties except those who were excepted.4
2 See NYISO OATT, Attachment H, Section 14.1.2.1.2.
3 Id. With respect to National Grid specifically, see also Section 14.1.9.4.3.6.
4 Non-settling parties were made subject to a separate "filed" Revenue Requirement and
Transmission Service Charge ("Filed TSC"). The NYISO Settlement also required National Grid
The Honorable Kimberly D. Bose, Secretary
Page 3
On February 11, 2008, as supplemented on May 30, 2008, National Grid submitted a filing under Section 205 of the Federal Power Act to replace its stated rates for its Transmission Service Charge in Attachment H to the NYISO OATT with formula rates to become effective May 1, 2008. On July 29, 2008, the Commission accepted and suspended the proposed formula rates, to become
effective October 1, 2008, subject to refund, and establish hearing and settlement judge
procedures.5 On April 6, 2009, National Grid on behalf of the Settling Parties6 filed a Settlement (“April 2009 Settlement”) intended to resolve all issues set for hearing in that proceeding. Among other things, the Settlement set forth the terms of a formula rate for the calculation of National
Grid’s transmission service charge under the NYISO OATT (the “Settlement TSC Formula Rate”), as well as procedures for the annual adjustment of certain inputs to the formula rate. In a letter
order issued June 22, 2009, the Commission approved the Settlement.7
On November 30, 2009, National Grid filed to modify the manner of calculating the long-term debt
cost of capital rate. The filing sought to adjust the determination of the amount of long-term debt
used in the calculation which was based on the average beginning of the year and year end long-
term debt balances. On January 13, 2010 the filing was accepted by the Commission effective
February 1, 2010.8
On March 30, 2012, National Grid submitted a filing to the Commission seeking to revise its
depreciation rates in the RR component of the Wholesale TSC to be identical to those previously approved by the New York Public Service Commission (“NYPSC”) in the state jurisdictional Case 10-E-0050. In addition, Niagara Mohawk proposed to amend Section 14.2 of the NYISO OATT to reflect Niagara Mohawk’s agreement to exclude the costs of a temporary New York assessment from its revenue requirement and to make ministerial changes.
On May 29, 2012, the filing was accepted without modification by the Commission effective January 23, 2011.9
In accordance with the April 2009 Settlement, National Grid is directed to prepare an Annual
Update each year calculating new values for the RR, CCC and BU components of the Settlement
to make a compliance filing revising its Filed TSC under the NYISO OATT based on the outcome of the hearing in Docket No. 0A96-194-000. The NYISO Settlement was approved by the
Commission by letter order dated July 31, 2000. National Grid subsequently filed to revised its Filed TSC rate based on the final outcome of Docket No. 0A96-194-000.
5 Niagara Mohawk Power Corp., Order Accepting and Suspending Formula Rate Subject to Refund and Establishing Hearing and Settlement Judge Procedures, 124 FERC ¶ 61,106 (2008)(“July 29 Order”). Certain Settling Parties
requested rehearing of aspects of the July 29 Order. On February 25, 2009, the Commission issued an Order that
denied rehearing in part and granted rehearing in part. 126 FERC ¶ 61,173 (2009).
6 The signatories consist of National Grid and the following entities: Allegheny Electric Cooperative, Inc., the City of Cleveland, Ohio, Multiple Interveners, Municipal Electric Utilities Association, New York Association of Public
Power, New York Municipal Power Agency, New York State Electric & Gas Corporation, and Rochester Gas &
Electric Corporation (“Settling Parties”).
7 See Niagara Mohawk Power Corp., 127 FERC ¶ 61,289 (2009).
8 See Niagara Mohawk Power Corp., Letter Order, Docket Nos. ER10-328-000, ER10-328-001 (January 13, 2010).
9 See Niagara Mohawk Power Corporation, Letter Order, Docket Nos. ER12-1394-000 (May 29, 2012).
The Honorable Kimberly D. Bose, Secretary
Page 4
TSC Formula Rate based on updated Data Inputs. According to Section 14.1.9.4 in Attachment H to the NYISO OATT, National Grid is directed on or before June 14th of each year to (1) post the Annual Update on the NYISO’s Internet website, (2) submit the Annual Update to the Commission as an informational filing requiring no action by the Commission, and (3) serve the Annual Update electronically on all Interested Parties.
III.Description of Filing
The primary purpose of the filing is to incorporate RSS expenses into the CCC component of the Company’s Wholesale TSC formula rate 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 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.10
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” 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 attached testimony of Mr. James Holodak Jr., 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.11
The inclusion of these costs in the CCC component of the Company’s Wholesale TSC rate is
appropriate because these costs directly relate to the functioning of National Grid’s transmission
system in upstate New York. As Mr. Holodak explains in his testimony, RSS agreements, such as
those between National Grid and NRG, are entered into for the purpose of maintaining reliability
on National Grid’s New York transmission system. Procuring RSS services allows the Company
to continue to reliably operate the transmission system pending, or in lieu of, implementing
upgrades to the transmission system. As such, there is no reason to treat these costs any
10 As explained in Mr. Holodak’s attached testimony, NRG had planned to take offline and place into mothball the
four generating units at the Dunkirk station as of September 10, 2012. Upon receiving notice of NRG’s intent to do so, National Grid conducted an analysis that determined that mothballing all of these units would compromise the
reliability of its transmission system. The first agreement provides for reliability service from two of the Dunkirk units through May 31, 2012, which is the date on which National Grid anticipates completing a portion of the transmission upgrades necessary to resolve the reliability issue. The second agreement provides for reliability service from one
Dunkirk unit from June 1, 2012 through May 31, 2015, which is the date that National Grid expects to complete all of the necessary transmission upgrades. Exh. NMP-3 at 6-8.
11 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.
The Honorable Kimberly D. Bose, Secretary
Page 5
differently than those directly incurred for reinforcements or other upgrades to the transmission system. This outcome is also in accordance with the Commission’s treatment of similar costs incurred by other transmission owners.12
Assuming approval of this filing, the Company will incorporate RSS expenses into the TSC rate formula in time for NMPC’s 2013 Annual Update filing, which will establish TSC rates effective after the date of that filing. NMPC’s revenue requirement for calendar year 2012 will be used as the basis for determining its 2013 Annual Update.
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 described in Mr. Holodak’s testimony.13 None of these proposed ministerial changes has any revenue impact on the TSC rate.
IV.Contents of Filing
• Attachment A, Service List
• Exhibits NMP-1 through NMP-6, which include:
o Exhibit NMP-1 - Clean versions of revised sheets to the tariff
o Exhibit NMP-2 - Black-lined versions of revised sheets to the tariff
o Exhibit NMP-3 - Direct Testimony of James Holodak
o Exhibit NMP-4 - Cost of Service Statements AA through BM
o Exhibit NMP-5 - NYPSC August 16, 2012 Order Deciding Reliability Issues and
Addressing Cost Allocation and Recovery
o Exhibit NMP-6 - Request for Approval of Reliability Support Services Agreement
V.Proposed Effective Date
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. The
Commission has actively encouraged transmission owners to adopt formula rates of the type
implemented by National Grid herein. Consistent with its policy of encouraging formula rates, the Commission’s practice has been to permit such formula rate filings to become effective after a
suspension period of no more than one day.14
12 See, e.g., Pacific Gas and Electric Co., 100 FERC ¶ 61,160 (2002) at PP 15-16, 21 (finding that reliability services, including the costs of reliability agreements with generators, provide a system-wide benefit and “should be paid for by all users of the grid” including wholesale transmission customers).
13 Exh. NMP-3 at 12-14.
14 Allegheny Power System Operating Companies, 111 FERC ¶ 61,308 at P 51 (2005) (accepting a formula rate
proposal for filing and suspending it to become effective one day after the FERC order "where the Commission has, in
The Honorable Kimberly D. Bose, Secretary
Page 6
VI.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:
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
VII. 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, 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.
VIII. 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.
IX.Miscellaneous
No agreement is required by contract for the making of this rate filing. There are no costs included
in this filing that have been alleged or adjudged in an administrative or judicial proceeding to be
illegal, duplicative, or unnecessary costs, nor has any expense or cost been demonstrated to be the
product of discriminatory or employment practices, within the meaning of Section 35.13(d)(3).
X.Conclusion
For the foregoing reasons, National Grid respectfully requests that the Commission accept these proposed tariff changes without suspension, condition or modification.
fact, urged transmission owners to move from stated rates to formula rates"), order on reh'g, 115 FERC li 61,156
(2006).
The Honorable Kimberly D. Bose, Secretary
Page 7
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
Attachment A
E-Mail List of Interested Parties upon Which this Filing was Served
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) Direct Energy Marketing
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
Linda.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
From original service list (without duplicates)
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
Geneva Looker
Dorothy Pierce
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
glooker@wrassoc.com
dorothy.pierce@chguernsey.com
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 29th day of March, 2013.
/s/ Terry Schwennesen
c/o National Grid
40 Sylvan Road
Waltham, MA 02451 (401) 480-9051
