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SEC Company Response from NEW ENGLAND POWER CO (CIK 0000071337) — Nov 30, 2005

NEW ENGLAND POWER CO (CIK 0000071337)
Date: Nov. 30, 2005 · CIK: 0000071337 · Accession: 0000071297-05-000051

AI Filing Summary & Sentiment

File numbers found in text: 001-6564

Referenced dates: October 21, 2005, September 28, 2005

Date
March 31, 2005
Author
Chief Financial
Form
CORRESP
Company
NEW ENGLAND POWER CO (CIK 0000071337)

Letter

November 30, BY EDGAR Mr. Robert Babula Staff Accountant Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C.

Re: New England Power Company (the "Company") Form 10-K for the fiscal year ended March 31, 2005 (File No. 001-6564)

Dear Mr. Babula:

On November 15, 2005, on behalf of the staff (the "Staff") of the U.S. Securities and Exchange Commission, you provided an additional comment on the above-referenced report in a telephone call to Paul Bailey. The comment related to the Company's response in its letter dated October 21, 2005 to comment 20 in the Staff's letter dated September 28, 2005 (the "Comment Letter"). This letter contains the Company's response to that comment.

For convenience, we have transcribed the Staff's comment below in boldfaced italics and provided our response immediately below it.

Note D - Commitments and Contingencies, page

In your letter to the Staff dated October 21, 2005, you indicated in your response to comment 20 that the Company reflects its entire nuclear decommissioning obligation as long-term because uncertainty exists as to the amount and timing of the payment of the liability. The Staff respectfully disagrees with this determination. The uncertainty of amount and timing of the payments does not preclude recognizing the estimated current portion of the liability and reflecting it as such in the financial statements. The Staff proposes that the Company do so prospectively.

RESPONSE:

We note the Staff's comment. Prospectively, we will estimate the current portion of the liability and classify it as a current liability in our balance sheet. If comparative balance sheets are presented we will conform the historical periods to the new format.

* * *

If you have any questions or require additional information regarding our responses, please direct them to me at 508-389-2000 or by fax at 508-389-2605 or to Paul Bailey, Controller, at 508-389-2000 or by fax at 508-389-2925.

Yours truly,

/s/ John G. Cochrane

John G. Cochrane Chief Financial Officer New England Power Company

Show Raw Text
CORRESP
1
filename1.htm

25 RESEARCH DRIVE,
WESTBOROUGH, MASSACHUSETTS 01582

November 30,
2005

BY
EDGAR

Mr. Robert
Babula
Staff
Accountant
Division of Corporation
Finance
U.S. Securities and Exchange
Commission
100 F Street,
N.E.
Washington, D.C.
20549

Re:     New
England Power Company (the
"Company")
           Form
10-K for the fiscal year ended March 31, 2005 (File No.
001-6564)

Dear Mr.
Babula:

On November 15, 2005, on behalf of the
staff (the "Staff") of the U.S. Securities and Exchange Commission,
you provided an additional comment on the above-referenced report in a telephone
call to Paul Bailey.  The comment related to the Company's response
in its letter dated October 21, 2005 to comment 20 in the Staff's letter
dated September 28, 2005 (the "Comment Letter").  This letter
contains the Company's response to that
comment.

For convenience, we have transcribed
the Staff's comment below in boldfaced italics and provided our response
immediately below it.

Note
D - Commitments and Contingencies, page
30

In your letter to the
Staff dated October 21, 2005, you indicated in your response to comment 20 that
the Company reflects its entire nuclear decommissioning obligation as long-term
because uncertainty exists as to the amount and timing of the payment of the
liability.  The Staff respectfully disagrees with this determination.
 The uncertainty of amount and timing of the payments does not preclude
recognizing the estimated current portion of the liability and reflecting it as
such in the financial statements.  The Staff proposes that the Company do
so prospectively.

RESPONSE:

We
note the Staff's comment.  Prospectively, we will estimate the
current portion of the liability and classify it as a current liability in our
balance sheet.  If comparative balance sheets are presented we will conform
the historical periods to the new format.

*          *          *

If you have any questions or require additional
information regarding our responses, please direct them to me at 508-389-2000 or
by fax at 508-389-2605 or to Paul Bailey, Controller, at 508-389-2000 or by fax
at 508-389-2925.

Yours truly,

/s/
John G. Cochrane

John G.
Cochrane
Chief Financial
Officer
New England Power Company