Joel deJesus
Counsel
September 21, 2004
VIA ELECTRONIC FILING
The Honorable Magalie Roman Salas, Esq,
Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Re: Docket Nos. TS04-46-000; RM01-10-003
Dear Secretary Salas:
Please find enclosed for electronic filing in Docket Nos. TS04-46-000 and RM01-10-003,
the Request of National Grid USA for Extension of Time.
Please do not hesitate to contact me if you have any questions or concerns.
Respectfully submitted,
Joel deJesus
Counsel for
National Grid USA
633 Pennsylvania Ave. NW, Sixth Floor
Washington, DC 20004
(202) 783-7959 Fax: (202) 783-1489
joel.dejesus@us.ngrid.com
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
National Grid USA ) Docket No. TS04-46-000
Standards of Conduct for ) Docket No. RM01-10-003
Transmission Providers )
REQUEST OF NATIONAL GRID USA
FOR EXTENSION OF TIME
Pursuant to Rule 212 of the Commissions Rules of Practice and Procedure, 18 C.F.R.
385.212, National Grid USA (National Grid) hereby respectfully requests an extension of
time for compliance with the Commissions standards of conduct.
As provided in 18 C.F.R. 358.4(c) (e) (2), transmission providers are generally required
to be in full compliance with the Commissions standards of conduct for transmission providers
by September 22, 2004 (Compliance Deadline). While National Grid has undertaken to
comply substantially with the Commissions standards of conduct by the Compliance Deadline,
significant issues concerning the nature of National Grids compliance obligations remain
unresolved. In particular, in the above referenced dockets, National Grid has pending waiver and
rehearing requests concerning the issue of whether National Grids electric local distribution
company (LDC) subsidiaries, Granite State Electric Company and Nantucket Electric
Company, must be treated as Energy Affiliates under 18 C.F.R. 358.3(d). If the Commission
does not act on those pleadings before the Compliance Deadline, National Grid respectfully
requests an extension of time to comply with the Commissions standards of conduct. In
addition, if the Commission were to issue one or more orders denying either or both of National
Grids pending requests, National Grid respectfully requests an extension of 90 days from the
date of such rulings to incorporate any directions by the Commission in such order(s).
DISCUSSION
This request for extension of time arises out of questions concerning the possible Energy
Affiliate status of National Grids two small, electric LDC subsidiaries, Granite State Electric
Company and Nantucket Electric Company.1 On February 9, 2004, National Grid filed for a
limited waiver of the Commissions regulations with respect to the ...
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