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of market value as prescribed for ad valorem assessments under RSA 75:1. See RSA 83-F:3.
PSNH understands that the DRA advises all communities of the value allocated to each
community under its appraisal. Based on the DRA’s 2017 appraisal, the fair market value of
PSNH?’s taxable real estate in the City of Nashua for 2017 was $67,392,534.
(b) PSNH understands that there have been a number of sales of utility property, all of which
transacted at or about the property’s net book value, the base of utility earnings. Those sales
include the 2012 sale of the assets and operations of Granite State Electric Company, a New
Hampshire electric distribution utility, to Liberty Utilities, which was approved by the New
Hampshire Public Utilities Commission.
(c) The New Hampshire Supreme Court recently affirmed a decision of the Merrimack
County Superior Court in favor of PSNH with respect to its tax appeals involving the Town of
Bow for tax years 2012 and 2013. See PSNH v. Town of Bow, 2018 N.H. Lexis! (January 11,
2018). Among other things, the Supreme Court made clear that net book value is an appropriate
valuation methodology for regulated transmission and distribution property which the finder of
fact can properly rely upon based on its evaluation of the evidence presented.
(7) PSNH reserves the right to present additional information in support of its request for
abatement, including an appraisal by an independent appraisal firm utilizing all applicable approaches to
value.
(8) PSNH hereby requests a hearing before the Aldermen to present and discuss the DRA’s
appraisal, as well as additional relevant information in support of its request for an abatement.
(9) By signing below, PSNH certifies and swears under the penalties of perjury that this
application has a good faith basis and the facts stated are true to the best of its knowledge.
WHEREFORE, PSNH requests (a) that the Board of Aldermen reconsider the matter of a just
and proportional valuation of PSNH’s property for the purpose of ad valorem property taxation as of
April 1, 2017, and re-determine a just and proportional valuation thereof and a just and proportional tax
thereon; and (b) that so much of the taxes assessed against PSNH on account of said property as of April
1, 2017, as may be found to have been unjust, disproportional and unreasonable in light of such re-
determined valuation be abated and refunded to PSNH together with interest from the date of payment
of said taxes to the date of repayment; and (c) such other or further relief on account of said taxes as
may be just and equitable.
Respectfully submitted,
PUBLIC SERVICE COMPANY
OF NEW WC d/b/a VERSOURCE ENERGY
Dated: | 20 | ( SX By: / 7
Christophe J. Allwarden
Senior Courisel, Law Department
780 North Commercial Street
Manchester, NH 03101
(603) 634-2459
