Standards of Conduct

11/26/2012

On November 21, 2012, the Massachusetts Department of Public Utilities issued an Information Request to National Grid in DPU Docket 12-77 requesting the increase in transfer capability into the NEMA/Boston zone and anticipated in service date of certain parts of the Greater Boston Transmission Project that will cross the Boston Import Interface. Participants in DPU Docket 12-77 who will be receiving National Grid's response to the DPU's information request include energy suppliers. In the event that National Grid's response regarding the increase in transfer capability and expected in-service date constitutes non-public sensitive transmission system information, National Grid is attaching its response which it will be filing with the DPU today, November 26, 2012.

On July 13, 2009, non-public transmission function information that comprised a small portion of a larger draft audit-related document, was inadvertently sent by email to two marketing function personnel. The non-public transmission function information was critical energy infrastructure information protected from public disclosure by FERC regulations. The marketing function personnel that received the non-public transmission function information did not review that information.

Via email dated Monday, April 20, 2009, correspondence, which may have contained transmission customer information, was inadvertently sent to a marketing function employee. The marketing function employee received the correspondence for the purpose of providing input on a small part of the inquiry from the NYISO and NERC on compliance with reliability standards.

Via email dated Tuesday, February 10, 2009, correspondence, which may have contained transmission customer information, was inadvertently sent to a marketing function employee. The marketing function employee received the correspondence for the purpose of providing service to the transmission customer.

Via email dated Thursday, December 11, 2008, an interconnection study report, which may have contained transmission customer information, was inadvertently sent to a marketing function employee. The proposed interconnection reviewed in the study would be at distribution voltages. As such, it was not apparent that the study involved transmission customer information, and the marketing function employee received the study for the purpose of evaluating state jurisdictional interconnection requirements.

National Grid's metering data services personnel enlisted the assistance of an employee of the sales/marketing function in assessing the impact of unaccounted for energy (UFE) on the company's last resort customers, and in working with NYSPSC and NYISO staff in implementation of new subzone boundaries to resolve the issue. In the course of this analysis, the sales/marketing employee had limited access to subzonal load and injection information. Although such information is routinely posted by the NYISO on an aggregated zone basis, the information about subzones is not typically broken out for the general public. Upon the identification of the potential standards of conduct issue, the sales/marketing employee ceased further work on this project, and will have no further involvement until such time as information is made publicly available to all NYISO market participants. The sales/marketing employee has not acted upon this data in any other capacity.

An employee of the sales/marketing function visited briefly (about 5 minutes) the office of a transmission function employee to discuss in general proposed changes in the NYISO market rules for generation capacity. That office is in an area of transmission function offices where access is generally restricted. However, no nonpublic transmission information was disclosed to the sales/marketing employee, and his visit to the transmission office area was inadvertent.

An email containing information regarding a customer was sent to a group of employees that included one Sales/Marketing employee. The information related to the customer's request for certain services including potential transmission and potential electric commodity services. Because the structuring of the services requested by the customer would be more efficiently addressed in a multidisciplinary team that included both transmission function and sales/marketing function employees, the customer consented to the sharing of its information and its potential transmission service request by employees of both functions. In responding to the customer's request, nonpublic transmission system information will not be shared with sale/marketing employees.

Section 2.1(e)iii of Schedule20A states: "Non-Firm Phase I/II HVDC-TF Service shall be offered on an hourly, daily, weekly or monthly basis, under applicable terms and conditions contained in this Schedule 20A, and shall not exceed one month's reservation." During 2007, 12 sequential months of non-firm service were sold. During 2008, each month will be accepted only through a separate transaction.

The attached slides were part of a presentation at the September 13, 2006 Quarterly Management Meeting attended by both Transmission and Sales/Marketing employees. The information contained in this presentation had previously been presented to the New York Public Service Commission Staff, and the project also received approval under the New York State Environmental Quality Review Act.

An email containing information regarding a potential transmission customer was sent to a group of employees that included one Sales/Marketing employee. The information has no relevance to,  and will not be used in connection with any purchase or sales decisions.

The attached data was included in a report attached to an email list that included a Sales/Marketing employee.

In reviewing information available on the Intranet, the attached files were discovered. Based on the date stamp on the file, this information was posted on or after May 24, 2005. The Intranet links to the information have been disabled.     File 1, File 2, File 3, File 4.

The attached slide was presented during a management meeting on September 30, 2005 at about 9:30 AM EDT. The meeting was attended by Sales/Marketing personnel. All transmission projects listed were public information with the exception of the Gardenville Line Rebuild. That project was filed with the New York Public Utilities Commission on October 5, 2004.

On June 2, 2005 at approximately 4:00PM it was confirmed that a marketing employee had mistakenly been included on the distribution list of emails sent on May 20, 2005 and May 26, 2005 that contained a proposed confidential settlement agreement resolving disputed terms in an interconnection agreement with a transmission customer. An investigation verified that no marketing actions or decisions were impacted by information.

A file containing certain information that may qualify as transmission system information was sent to an Energy Supply employee. Specifically, a file showing hourly line losses for the Genessee Sub Zone for January 1 – 7, 2004 was sent to an Energy Supply employee. The points measured include points that feed into the Rochester Gas & Electric system as well as points that link different Niagara Mohawk Power Company points. The transmission line is not a Niagara Mohawk line.

Employees of the Gas Sales and Marketing function attended a meeting in a conference room located within a facility that houses a control center and to which access is restricted.

In reviewing shared facilities in order to comply with Order 2004, National Grid USA identified certain pages on the Intranet, available to all employees, containing information that may be considered transmission system information, such as incident and outage reports. Upon discovery, the Company took immediate steps to restrict access.

At a meeting of the FERC 2004 Compliance Project Team, a past transformer outage at the Sawyer Ave. Substation was inadvertently used as an example of Standards of Conduct issues related to incident reporting when Sales and Marketing employees were in attendance.