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ITC

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FY2020 Annual Report · ITC
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form 10-K

(Mark One)

☑ ANNUAL  REPORT  PURSUANT  TO  SECTION  13  OR  15(d)  OF  THE  SECURITIES 

EXCHANGE ACT OF 1934
For the fiscal year ended December 31, 2020

OR

☐ TRANSITION  REPORT  PURSUANT  TO  SECTION  13  OR  15(d)  OF  THE  SECURITIES 

EXCHANGE ACT OF 1934

Commission File Number: 001-32576 

ITC HOLDINGS CORP.

(Exact Name of Registrant as Specified in Its Charter)

Michigan
(State or Other Jurisdiction of Incorporation or Organization)

32-0058047
(I.R.S. Employer Identification No.)

27175 Energy Way 
Novi, Michigan 48377 
(Address Of Principal Executive Offices, Including Zip Code)
(248) 946-3000 
(Registrant’s Telephone Number, Including Area Code)
Securities registered pursuant to Section 12(b) of the Act:

Title of Each Class
None

Trading Symbol(s)
None

Name of Each Exchange on Which Registered
None

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes o No þ

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes þ No o
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities 
Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), 
and (2) has been subject to such filing requirements for the past 90 days. Yes o No þ	* (Note: the Registrant is a voluntary filer and 
has not been subject to the filing requirements under Section 13 or 15(d) of the Securities Exchange Act of 1934 for the preceding 12 
months.)

Indicate  by  check  mark  whether  the  registrant  has  submitted  electronically  every  Interactive  Data  File  required  to  be  submitted 
pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the 
registrant was required to submit such files). Yes þ No o

Indicate  by  check  mark  whether  the  registrant  is  a  large  accelerated  filer,  an  accelerated  filer,  a  non-accelerated  filer,  a  smaller 
reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting 
company,” and "emerging growth company" in Rule 12b-2 of the Exchange Act.

Large accelerated filer 

Accelerated filer 

Non-accelerated filer

Smaller Reporting 
Company 

Emerging growth 
company 

o

o

☑

☐

☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for 

complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. o

Indicate  by  check  mark  whether  the  Registrant  has  filed  a  report  on  and  attestation  to  its  management’s  assessment  of  the 
effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the 
registered public accounting firm that prepared or issued its audit report. ☐

Indicate by check mark whether the Registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ☐ No þ
The aggregate market value of the registrant’s common stock held by non-affiliates on June 30, 2020 was $0.

All shares of outstanding common stock of ITC Holdings Corp. are held by its parent company, ITC Investment Holdings Inc., which 
is an indirect subsidiary of Fortis Inc. There were 224,203,112 shares of common stock, no par value, outstanding as of February 11, 
2021.

None

DOCUMENTS INCORPORATED BY REFERENCE

Table of Contents

ITC Holdings Corp.

Form 10-K for the Fiscal Year Ended December 31, 2020 

INDEX

PART I

Item 1.

Business

Item 1A.

Risk Factors

Item 1B.

Unresolved Staff Comments

Item 2.

Item 3.

Item 4.

PART II

Item 5.

Item 6.

Item 7.

Properties

Legal Proceedings

Mine Safety Disclosures

Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases 
of Equity Securities

Selected Financial Data

Management's Discussion and Analysis of Financial Condition and Results of Operations

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

Item 8.

Item 9.

Financial Statements and Supplementary Data

Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

Item 9A.

Controls and Procedures

Item 9B. Other Information

PART III

Item 10.

Directors, Executive Officers and Corporate Governance

Item 11.

Executive Compensation

Item 12.

Item 13.

Security Ownership of Certain Beneficial Owners and Management and Related 
Stockholder Matters
Certain Relationships and Related Transactions, and Director Independence

Item 14.

Principal Accountant Fees and Services

PART IV
Item 15.

Exhibits and Financial Statement Schedules

Item 16.

Form 10-K Summary

Signatures

Page

7

7

15

22

22

22

23

23

23
23

23

40

42

86

86

86

86

86

90

118

119

121

122

122

134

135

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Unless otherwise noted or the context requires, all references in this report to:

ITC Holdings Corp. and its subsidiaries

• “ITC Great Plains” are references to ITC Great Plains, LLC, a wholly-owned subsidiary of ITC Holdings;

• “ITC Holdings” are references to ITC Holdings Corp. and not any of its subsidiaries;

• “ITC  Interconnection”  are  references  to  ITC  Interconnection  LLC,  a  wholly-owned  subsidiary  of  ITC 

Holdings;

• “ITC Midwest” are references to ITC Midwest LLC, a wholly-owned subsidiary of ITC Holdings;

• “ITCTransmission”  are  references  to  International Transmission  Company,  a  wholly-owned  subsidiary  of 

ITC Holdings;

• “METC”  are  references  to  Michigan  Electric Transmission  Company,  LLC,  a  wholly-owned  subsidiary  of 

MTH;

• “MISO  Regulated  Operating  Subsidiaries”  are  references  to  ITCTransmission,  METC  and  ITC  Midwest 

together;

• “MTH” are references to Michigan Transco Holdings, LLC, the sole member of METC and a wholly-owned 

subsidiary of ITC Holdings;

• “Regulated  Operating  Subsidiaries”  are  references  to  ITCTransmission,  METC,  ITC  Midwest,  ITC  Great 

Plains and ITC Interconnection together; and

• “Company”, “we,” “our” and “us” are references to ITC Holdings together with all of its subsidiaries.

Other definitions

• “2017 Omnibus Plan” are references to the Company’s February 27, 2017 long-term equity incentive plan 

as amended July 10, 2017 and February 4, 2020;

• “ACPB” are references to an award under the annual corporate performance bonus plan;

• “ADIT” are references to accumulated deferred income tax;

• “AFUDC” are references to an allowance for funds used during construction;

• “ALJ” are references to an administrative law judge;

• “Ancillary  Services  Agreement”  are  references  to  the  Amended  and  Restated  Purchase  and  Sale 
Agreement  for  Ancillary  Services  entered  into  by  METC  and  Consumers  Energy  dated  as  of  April  29, 
2002;

• “AOCI” are references to accumulated other comprehensive income or (loss);

• “ARAM” are references to the average rate assumption method of amortization;

• “CIA” are references to the Coordination and Interconnection Agreement entered into by ITCTransmission 

and DTE Electric dated as of February 28, 2003;

• “Consumers Energy” are references to Consumers Energy Company, a wholly-owned subsidiary of CMS 

Energy Corporation;

• “COVID-19”  are  references  to  the  Coronavirus  disease  that  the  World  Health  Organization  declared  a 

pandemic in March 2020;

• “D.C. Circuit Court” are references to the U.S. Court of Appeals for the District of Columbia Circuit; 

• “DCF” are references to discounted cash flow;

• “DOE” are references to the Department of Energy;

• “DTE Electric” are references to DTE Electric Company, a wholly-owned subsidiary of DTE Energy;

• “DTE Energy” are references to DTE Energy Company;

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• “DTIA”  are  references  to  the  Distribution-Transmission  Interconnection  Agreement  entered  into  by  ITC 
Midwest and IP&L dated as of December 17, 2007 and amended and restated effective as of December 
1, 2016;

• “DT Interconnection Agreement” are references to the Amended and Restated Distribution-Transmission 
Interconnection Agreement entered into by METC and Consumers Energy dated April 1, 2001 and most 
recently amended and restated effective as of January 1, 2015;

• “Easement Agreement” are references to the Amended and Restated Easement Agreement entered into 

by METC and Consumers Energy dated April 29, 2002 and as further supplemented;

• “Eiffel” are references to Eiffel Investment Pte Ltd, a private limited company duly organized and validly 
existing  under  the  laws  of  Singapore  that  is  the  GIC  subsidiary  that  is  a  minority  investor  in  ITC 
Investment Holdings and successor to Finn Investment Pte Ltd;

• “ESPP” are references to the Fortis Amended and Restated 2012 Employee Share Purchase Plan;

• “Exchange Act” are references to the Securities Exchange Act of 1934, as amended;

• “Executive Omnibus Plan” are references to the Company’s February 4, 2020 long-term equity incentive 

plan;

• “FASB” are references to the Financial Accounting Standards Board;

• “FERC” are references to the Federal Energy Regulatory Commission;

• “Formula  Rate”  are  references  to  a  FERC-approved  formula  template  used  to  calculate  an  annual 

revenue requirement;

• “Fortis” are references to Fortis Inc.;

• “FortisUS” are references to FortisUS Inc., an indirect subsidiary of Fortis;

• “FPA” are references to the Federal Power Act;

• “GAAP” are references to accounting principles generally accepted in the United States of America;

• “Generator  Interconnection  Agreement”  are  references  to  the  Amended  and  Restated  Generator 
Interconnection Agreement entered into by Consumers Energy and METC dated as of April 29, 2002 and 
most recently amended effective as of November 1, 2018;

• “GIAs” are references to generator interconnection agreements;

• “GIC” are references to GIC Private Limited;

• “GIOA”  are  references  to  the  Generator  Interconnection  and  Operation Agreement  entered  into  by  DTE 

Electric and ITCTransmission dated as of February 28, 2003;

• “Initial Complaint” are references to a November 2013 complaint to the FERC under Section 206 of the 

FPA regarding the base ROE;

• “ITC  Investment  Holdings”  are  references  to  ITC  Investment  Holdings  Inc.,  a  majority  owned  indirect 

subsidiary of Fortis in which GIC has an indirect minority ownership interest;

• “IP&L” are references to Interstate Power and Light Company, an Alliant Energy Corporation subsidiary;

• “IRS” are references to the Internal Revenue Service;

• “ISO” are references to Independent System Operators;

• “KCC” are references to the Kansas Corporation Commission;

• “kV” are references to kilovolts (one kilovolt equaling 1,000 volts);

• “kW” are references to kilowatts (one kilowatt equaling 1,000 watts);

• “LBA” are references to a Local Balancing Authority;

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• “LGIA”  are  references  to  the  Large  Generator  Interconnection Agreement  entered  into  by  ITC  Midwest, 

IP&L, and MISO dated as of December 20, 2007 and amended as of August 2, 2017;

• “LIBOR” are references to the London Interbank Offered Rate;

• “May 2020 Order” are references to an order issued by the FERC on May 21, 2020 regarding MISO ROE 

Complaints;

• “MECS” are references to the Michigan Electric Coordinated Systems;

• “Merger  Agreement”  are  references  to  the  agreement  and  plan  of  merger  between  Fortis,  FortisUS, 

Element Acquisition Sub, Inc. and ITC Holdings for the merger;

• “Mid-Kansas” are references to Mid-Kansas Electric Company LLC;

• “Mid-Kansas Agreement” are references to an Amended and Restated Maintenance Agreement entered 
into  by  Mid-Kansas  and  ITC  Great  Plains  dated  as  of  August  24,  2010,  and  most  recently  amended 
effective as of March 6, 2017;

• “MISO”  are  references  to  the  Midcontinent  Independent  System  Operator,  Inc.,  a  FERC-approved  RTO 
which  oversees  the  operation  of  the  bulk  power  transmission  system  for  a  substantial  portion  of  the 
Midwestern  United  States  and  Manitoba,  Canada,  and  of  which  ITCTransmission,  METC  and  ITC 
Midwest are members;

• “MISO ROE Complaints” are references to the Initial Complaint and the Second Complaint;

• “MOA”  are  references  to  the  Master  Operating  Agreement  entered  into  by  ITCTransmission  and  DTE 

Electric dated as of February 28, 2003;

• “Moody’s” are references Moody’s Investor Service, Inc.;

• “MVPs”  are  references  to  multi-value  projects,  which  have  been  determined  by  MISO  to  have  regional 

value while meeting near-term system needs;

• “MW” are references to megawatts (one megawatt equaling 1,000,000 watts);

• “NERC” are references to the North American Electric Reliability Corporation;

• “NOLs” are references to net operating loss carryforwards for income taxes;

• “NOPR” are references to a Notice of Proposed Rulemaking issued by the FERC;

• “November 2018 Order” are references to an order issued by the FERC on November 15, 2018 regarding 

MISO ROE Complaints;

• “November 2019 Order” are references to an order issued by the FERC on November 21, 2019 regarding 

MISO ROE Complaints;

• “NYSE” are references to the New York Stock Exchange;

• “Operating Agreement” are references to the Amended and Restated Operating Agreement entered into 

by Consumers Energy and METC dated as of April 29, 2002;

• “OSA” are references to the Operations Services Agreement for 34.5 kV Transmission Facilities entered 

into by ITC Midwest and IP&L effective as of January 1, 2011;

• “PBU” are references to a performance-based unit;

• “PCBs” are references to polychlorinated biphenyls;

• “PJM” are references to PJM Interconnection LLC, a FERC-approved RTO which oversees the operation 
of the bulk power transmission system for a substantial portion of the Eastern United States, and of which 
ITC Interconnection is a member;

• “ROE” are references to return on equity;

• “RSGM” are references to the Reverse South Georgia Method of amortization;

• “RTO” are references to Regional Transmission Organizations;

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• “SBU” are references to a service-based unit; 

• “SEC” are references to the Securities and Exchange Commission;

• “Second Complaint” are references to an additional complaint filed on February 12, 2015 with the FERC 

under Section 206 of the FPA regarding the base ROE;

• “September  2016  Order”  are  references  to  an  order  issued  by  the  FERC  on  September  28,  2016 

regarding the Initial Complaint;

• “Shareholders Agreement” are references to the Shareholders’ Agreement, dated as of October 14, 2016 
by and among the Company, ITC Investment Holdings, FortisUS, Eiffel (as successor to Finn Investment 
Pte Ltd), and any other person that becomes a shareholder of ITC Investment Holdings pursuant to such 
agreement;

• “SOFR” are references to the Secured Overnight Financing Rate;

• “SPP”  are  references  to  Southwest  Power  Pool,  Inc.,  a  FERC-approved  RTO  which  oversees  the 
operation  of  the  bulk  power  transmission  system  for  a  substantial  portion  of  the  South  Central  United 
States, and of which ITC Great Plains is a member;

• “S&P” are references to S&P Global Ratings;

• “TCJA” are references to the Tax Cuts and Jobs Act of 2017, a comprehensive tax reform bill enacted on 

December 22, 2017;

• “TO” are references to transmission owner;

• “ULCS” are references to Utility Lines Construction Services, LLC; and

• “USD” are references to the United States dollar

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ITEM 1. 

BUSINESS.

Overview

PART I

Our  business  consists  primarily  of  the  electric  transmission  operations  of  our  Regulated  Operating 
Subsidiaries.  ITC  Holdings  is  a  wholly-owned  subsidiary  of  ITC  Investment  Holdings.  Fortis  owns  a  majority 
indirect  equity  interest  in  ITC  Investment  Holdings,  with  GIC  holding  an  indirect  equity  interest  of  19.9%. 
Through our Regulated Operating Subsidiaries, we own and operate high-voltage electric transmission systems 
in Michigan’s Lower Peninsula and portions of  Iowa, Minnesota, Illinois, Missouri, Kansas and Oklahoma that 
transmit electricity from generating stations to local distribution facilities connected to our transmission systems. 

ITC Holdings provides safe and reliable electric transmission service to connect consumers to cleaner and 
more cost-effective energy resources. ITC Holdings is leading the way in making investments in a modernized 
grid  to  maintain  reliability  and  accommodate  future  demands  as  our  economy  and  lifestyles  become 
increasingly  dependent  on  electricity.  We  are  actively  involved  in  planning  an  integrated  energy  network  to 
serve our customers, communities and the greater grid.

Our  business  strategy  is  focused  on  owning,  operating,  maintaining  and  investing  in  transmission 
infrastructure  and  grid  solutions  in  order  to  enhance  system  reliability,  protect  critical  infrastructure,  reduce 
transmission  constraints,  interconnect  new  renewable  generation  resources,  expand  access  to  electricity 
markets and lower the overall cost of delivered energy.

Our  Regulated  Operating  Subsidiaries  earn  revenues  for  the  use  of  their  electric  transmission  systems  by 
their  customers,  which  include  investor-owned  utilities,  municipalities,  cooperatives,  power  marketers  and 
alternative  energy  suppliers.  As  independent  transmission  companies,  our  Regulated  Operating  Subsidiaries 
are  subject  to  rate  regulation  only  by  the  FERC,  and  our  cost-based  rates  are  discussed  in  “Item  7 
Management’s  Discussion  and  Analysis  of  Financial  Condition  and  Results  of  Operations  —  Cost-Based 
Formula Rates with True-Up Mechanism.”

Development of Business

As we move toward a cleaner and more electrified economy, the power grid is experiencing a transformation. 
Technology deployment and innovation are occurring at an accelerated rate within our industry, so ITC Holdings 
is actively identifying and investing in infrastructure required to meet evolving system needs and energy policy 
objectives.  Our  long-term  growth  plan  includes  ongoing  investments  in  our  current  regulated  transmission 
systems  and  the  identification  of  incremental  strategic  projects  primarily  located  in  and  around  our  service 
territories. 

We  expect  to  invest  approximately  $3.9  billion  from  2021  through  2025  at  our  Regulated  Operating 
Subsidiaries.  Included  in  this  amount  are  capital  expenditures  to:  (1)  maintain  and  replace  our  current 
transmission infrastructure including enhancing system integrity and reliability and accommodating load growth; 
(2)  upgrade  physical  and  technological  grid  security;  (3)  promote  the  transformation  of  the  generation  fleet  to 
cleaner and more sustainable resources through required interconnections and transmission build-out; and (4) 
develop and build regional transmission infrastructure.

Refer to “Item 7 Management’s Discussion and Analysis of Financial Condition and Results of Operations — 
Capital Investment and Operating Results Trends” for additional details about our long-term capital investments. 
Refer to the discussion of risks associated with our strategic investment opportunities in “Item 1A Risk Factors.”

Operations

As  transmission-only  companies,  our  Regulated  Operating  Subsidiaries  function  as  conduits,  allowing  for 
power  from  generators  to  be  transmitted  to  local  distribution  systems  either  entirely  through  our  Regulated 
Operating  Subsidiaries’  own  systems  or  in  conjunction  with  neighboring  transmission  systems.  Third  parties 
then  transmit  power  through  these  local  distribution  systems  to  end-use  consumers.  The  transmission  of 
electricity  by  our  Regulated  Operating  Subsidiaries  is  a  central  function  to  the  provision  of  electricity  to 
residential,  commercial  and  industrial  end-use  consumers.  The  operations  performed  by  our  Regulated 
Operating Subsidiaries fall into the following categories:

• asset planning;

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• engineering;

• asset protection and performance;

• cyber security operations center; and

• real time operations.

Asset Planning

The Asset Planning group uses detailed system models and load forecasts to develop our system expansion 
capital plans. Expansion capital plans identify projects that address reliability issues and/or produce economic 
savings for customers by eliminating constraints.

The  Asset  Planning  group  submits  projects  into  the  MISO  and  SPP  planning  processes.  As  the  regional 
planning authorities, MISO and SPP administer open and transparent processes through which the submitted 
Asset  Planning  group  plans  are  vetted.  MISO  and  SPP  produce  transmission  expansion  plans,  which  include 
projects  to  be  constructed  by  their  members,  including  our  MISO  Regulated  Operating  Subsidiaries  and  ITC 
Great Plains.

Engineering

The  Engineering  group  is  composed  of  the  Design,  Capital  Projects  and  Asset  Management  teams.  The 
Engineering  group  works  with  outside  contractors  to  perform  various  aspects  of  our  design,  construction  and 
maintenance, but retains internal technical experts who have experience with respect to the key elements of the 
transmission system such as substations, lines, equipment and protective relaying systems.

Design  —  The  Design  team  is  responsible  for  the  design  of  our  transmission  systems  and  setting  the 

standards for equipment used on our systems.

Capital  Projects  —  The  Capital  Projects  team  is  responsible  for  project  and  construction  management  for 
capital  projects,  which  includes  the  construction  of  new  transmission  infrastructure  as  well  as  asset  renewal 
projects.

Asset Management — The Asset Management team performs the following activities:

• manages our vegetation management program;

• provides engineering technical support to the field;

• specifies,  maintains  and  troubleshoots  the  protection  and  controls  system  that  is  used  to  protect  and  

monitor our transmission infrastructure; and

• develops  and  tracks  preventative  maintenance  to  promote  safe  and  reliable  systems  adhering  to 

mandatory requirements of the NERC and FERC.

 By performing preventive maintenance on our assets, we can minimize the need for reactive maintenance, 
resulting  in  improved  reliability  and  cost  savings  for  our  customers.  Our  Regulated  Operating  Subsidiaries 
contract  with  ULCS,  which  is  a  division  of  Asplundh  Tree  Expert  Co.,  to  perform  the  majority  of  their 
maintenance.  The  agreement  with  ULCS  provides  us  with  access  to  an  experienced  and  scalable  workforce 
with knowledge of our system at an established rate.

Asset Protection and Performance

The Asset  Protection  and  Performance  group  is  responsible  for  safety,  human  performance,  security,  and 
emergency  preparedness  and  response.  Given  the  inherent  hazardous  nature  of  the  utilities  industry,  we 
proactively work to ensure that all personnel are free to perform in a safe and secure environment. Our focus is 
not  to  compromise  the  safety  of  our  employees,  contractors  or  the  public  in  the  course  of  providing  the  most 
reliable electricity transmission services. We maintain a safety program that includes proactive measures rooted 
in human performance tools to achieve that focus. Our emergency response plans ensure that we are prepared 
for  a  crisis  and  can  maintain  continuity  of  our  business  and  service  during  said  crisis.  We  operate  a  security 
command  center  from  our  headquarters  facility  in  Michigan  that  monitors  our  most  critical  assets  on  a 
continuous basis. The security command center also gathers intelligence and works with our government and 
industry partners to prevent threats to our assets.

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Cyber Security Operations Center

The Cyber Security Operations Center is responsible for reducing the risk of cyber-attacks, data breaches, 
and data theft by deploying advanced monitoring techniques, technical controls, and administrative policies. As 
the  threat  landscape  becomes  increasingly  sophisticated  and  expansive,  we  continue  to  educate  our  user 
community and advance our protections against ongoing cyber threats.

Real Time Operations

System  Operations  —  From  our  operations  facilities  in  Michigan,  transmission  system  operators 
continuously  monitor  the  performance  of  the  transmission  systems  of  our  Regulated  Operating  Subsidiaries, 
using software and communication systems to perform analysis to plan for contingencies and maintain security 
and  reliability  following  any  unplanned  events  on  the  system.  Transmission  system  operators  are  also 
responsible for the switching and protective tagging function, taking equipment in and out of service to ensure 
capital construction projects and maintenance programs can be completed safely and reliably.

Local  Balancing  Authority  Operator  —  Under  the  functional  control  of  MISO,  ITCTransmission  and  METC 
operate  their  electric  transmission  systems  as  a  combined  LBA  area,  known  as  MECS.  From  our  operations 
facilities  in  Michigan,  our  employees  perform  the  LBA  functions  as  outlined  in  MISO’s  Balancing  Authority 
Agreement.  These  functions  include  actual  interchange  data  administration  and  verification  as  well  as  MECS 
LBA  area  emergency  procedure  implementation  and  coordination.  Besides  ITCTransmission  and  METC,  our 
other Regulated Operating Subsidiaries are not responsible for LBA functions for their respective assets.

Operating Contracts 

Our Regulated Operating Subsidiaries have various operating contracts, including numerous interconnection 
agreements  with  generation  and  transmission  providers  that  address  terms  and  conditions  of  interconnection. 
The following significant agreements exist at our Regulated Operating Subsidiaries:

ITCTransmission

DTE  Electric  operates  an  electric  distribution  system  that  is  interconnected  with  ITCTransmission’s 
transmission  system.  A  set  of  three  operating  contracts  sets  forth  the  terms  and  conditions  related  to  DTE 
Electric’s and ITCTransmission’s interconnected systems. These contracts include the following:

Master  Operating  Agreement.  The  MOA  governs  the  primary  day-to-day  operational  responsibilities  of 
ITCTransmission  and  DTE  Electric.  The  MOA 
that 
ITCTransmission provides to DTE Electric and certain generation-based support services that DTE Electric is 
required to provide to ITCTransmission.

identifies  control  area  coordination  services 

Generator  Interconnection  and  Operation  Agreement.  The  GIOA  established,  re-established  and 
maintains  the  direct  electricity  interconnection  of  DTE  Electric’s  electricity  generating  assets  with 
ITCTransmission’s  transmission  system  for  the  purpose  of  transmitting  electric  power  from  and  to  the 
electricity generating facilities. 

Coordination and Interconnection Agreement. The CIA outlines the rights, obligations and responsibilities 
of  ITCTransmission  and  DTE  Electric  regarding,  among  other  things,  the  operation  and  interconnection  of 
DTE Electric’s distribution system and ITCTransmission’s transmission system, and the construction of new 
facilities or modification of existing facilities. Additionally, the CIA allocates costs for operation of supervisory, 
communications and metering equipment. 

METC

Consumers Energy operates an electric distribution system that is interconnected with METC’s transmission 
system. METC is a party to a number of operating contracts with Consumers Energy that govern the operations 
and maintenance of its transmission system. These contracts include the following:

Amended  and  Restated  Easement  Agreement.  Under  the  Easement  Agreement,  Consumers  Energy 
provides  METC  with  an  easement  to  the  land  on  which  a  majority  of  METC’s  transmission  towers,  poles, 
lines  and  other  transmission  facilities  used  to  transmit  electricity  for  Consumers  Energy  and  others  are 
located.  METC  pays  Consumers  Energy  an  annual  rent  for  the  easement  and  also  pays  for  any  rentals, 
property taxes and other fees related to the property covered by the Easement Agreement.

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Amended and Restated Operating Agreement. Under the Operating Agreement, METC is responsible for 
maintaining  and  operating  its  transmission  system,  providing  Consumers  Energy  with  information  and 
access to its transmission system and related books and records, administering and performing the duties of 
control area operator (that is, the entity exercising operational control over the transmission system) and, if 
requested  by  Consumers  Energy,  building  connection  facilities  necessary  to  permit  interaction  with  new 
distribution facilities built by Consumers Energy. 

Amended  and  Restated  Purchase  and  Sale  Agreement  for  Ancillary  Services.  Since  METC  does  not 
own  any  generating  facilities,  it  must  procure  ancillary  services  from  third  party  suppliers,  such  as 
Consumers Energy. Currently, under the Ancillary Services Agreement, METC pays Consumers Energy for 
providing  certain  generation-based  services  necessary  to  support  the  reliable  operation  of  the  bulk  power 
grid, such as voltage support and generation capability and capacity to balance loads and generation.

Amended  and  Restated  Distribution-Transmission  Interconnection  Agreement.  The  DT  Interconnection 
Agreement  provides  for  the  interconnection  of  Consumers  Energy’s  distribution  system  with  METC’s 
transmission  system  and  defines  the  continuing  rights,  responsibilities  and  obligations  of  the  parties  with 
respect to the use of certain of their own and the other party’s properties, assets and facilities.

Amended  and  Restated  Generator 

Interconnection 
Agreement  specifies  the  terms  and  conditions  under  which  Consumers  Energy  and  METC  maintain  the 
interconnection of Consumers Energy’s generation resources and METC’s transmission assets.

Interconnection  Agreement.  The  Generator 

ITC Midwest

IP&L operates an electric distribution system that interconnects with ITC Midwest’s transmission system. ITC 
Midwest is a party to a number of operating contracts with IP&L that govern the operations and maintenance of 
their respective systems. These contracts include the following:

Distribution-Transmission Interconnection Agreement. The DTIA governs the rights, responsibilities and 
obligations  of  ITC  Midwest  and  IP&L,  with  respect  to  the  use  of  certain  of  their  own  and  the  other  party’s 
property, assets and facilities and the construction of new facilities or modification of existing facilities.

Large  Generator  Interconnection  Agreement.  ITC  Midwest,  IP&L  and  MISO  entered  into  the  LGIA  in 
order  to  establish,  re-establish  and  maintain  the  direct  electricity  interconnection  of  IP&L’s  electricity 
generating  assets  with  ITC  Midwest’s  transmission  system  for  the  purposes  of  transmitting  electric  power 
from and to the electricity generating facilities.

Operations Services Agreement For 34.5 kV Transmission Facilities. ITC Midwest and IP&L entered into 
the  OSA  under  which  IP&L  performs  certain  operations  functions  for  ITC  Midwest’s  34.5  kV  transmission 
system. The OSA provides that when ITC Midwest upgrades 34.5 kV facilities to higher operating voltages it 
may notify IP&L of the change and the OSA is no longer applicable to those facilities.

ITC Great Plains

Amended  and  Restated  Maintenance  Agreement.  Mid-Kansas  and  ITC  Great  Plains  have  entered  into 
the  Mid-Kansas Agreement  pursuant  to  which  Mid-Kansas  has  agreed  to  perform  various  field  operations 
and maintenance services related to certain ITC Great Plains assets.

ITC Interconnection

ITC Interconnection acquired certain transmission assets from a merchant generating company and placed a 
345kV  transmission  line  in  service.  As  a  result,  ITC  Interconnection  is  a  TO  in  PJM  and  is  subject  to  rate 
regulation by the FERC. The revenues earned by ITC Interconnection are based on its facilities reimbursement 
agreement with the merchant generating company.

Regulatory Environment

Many regulators and public policy makers support the need for further investment in the transmission grid. 
The growth and changing mix of electricity generation, wholesale power sales and consumption combined with 
historically inadequate transmission investment have resulted in significant transmission constraints across the 
United  States  and  increased  stress  on  aging  equipment.  These  problems  will  continue  without  increased 
investment in transmission infrastructure. Transmission system investments can also increase system reliability 
and  reduce  the  frequency  of  power  outages.  Such  investments  can  reduce  transmission  constraints  and 

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improve access to lower cost generation resources, resulting in a lower overall cost of delivered electricity for 
end-use  consumers. The  DOE  has  established  the  Office  of  Electricity  that  focuses  on  working  with  reliability 
experts from the power industry, state governments and their Canadian counterparts to improve grid reliability 
and increase investment in the country’s electric infrastructure. In addition, the FERC has signaled its desire for 
substantial new investment in the transmission sector by implementing various financial and other incentives.

The  FERC  has  also  issued  orders  to  promote  non-discriminatory  transmission  access  for  all  transmission 
customers.  In  the  United  States,  electric  transmission  assets  are  predominantly  owned,  operated  and 
maintained by utilities that also own electricity generation and distribution assets, known as vertically integrated 
utilities.  The  FERC  has  recognized  that  the  vertically-integrated  utility  model  inhibits  the  provision  of  non-
discriminatory  transmission  access  and,  in  order  to  alleviate  this  potential  discrimination,  the  FERC  has 
mandated that all transmission systems over which it has jurisdiction must be operated in a comparable, non-
discriminatory  manner  such  that  any  seller  of  electricity  affiliated  with  a  TO  or  transmission  operator  is  not 
provided  with  preferential  treatment.  The  FERC  has  also  indicated  that  independent  transmission  companies 
can play a prominent role in furthering its policy goals and has encouraged the legal and functional separation 
of transmission operations from generation and distribution operations.

The  FERC  requires TOs  to  comply  with  certain  reliability  standards  and  may  take  enforcement  actions  for 
violations, including the imposition of substantial fines. NERC is responsible for developing and enforcing these 
mandatory reliability standards. We continually assess our transmission systems against standards established 
by NERC, as well as the standards of applicable regional entities under NERC that have been delegated certain 
authority for the purpose of proposing and enforcing reliability standards. 

Finally, utility holding companies are subject to FERC regulations related to access to books and records in 
addition  to  the  requirement  of  the  FERC  to  review  and  approve  mergers  and  consolidations  involving  utility 
assets and holding companies in certain circumstances.

Federal Regulation

As electric transmission companies, our Regulated Operating Subsidiaries charge rates that are regulated by 
the  FERC.  The  FERC  is  an  independent  regulatory  commission  within  the  DOE  that  regulates  the  interstate 
transmission and certain wholesale sales of natural gas, the transmission of oil and oil products by pipeline and 
the  transmission  and  wholesale  sales  of  electricity  in  interstate  commerce.  The  FERC  also  administers 
accounting and financial reporting regulations and standards of conduct for the companies it regulates. In order 
to  facilitate  open  access  transmission  for  participants  in  wholesale  power  markets,  FERC  Order  No.  888 
encourages investor owned utilities to cede operational control over their transmission systems to ISOs, which 
are not-for-profit entities.

As  an  alternative  to  ceding  operating  control  of  their  transmission  assets  to  ISOs,  certain  investor  owned 
utilities began to promote the formation of for-profit transmission companies, which would assume control of the 
operation  of  the  grid.  FERC  Order  No.  2000  encourages  utilities  to  voluntarily  transfer  operational  control  of 
their  transmission  systems  to  RTOs.  RTOs,  as  envisioned  in  Order  No.  2000,  would  assume  many  of  the 
functions of an ISO, but the FERC permitted greater flexibility with regard to the organization and structure of 
RTOs  than  it  had  for  ISOs.  RTOs  could  accommodate  the  inclusion  of  independently  owned,  for-profit 
companies that own transmission assets within their operating structure. Independent ownership would facilitate 
not  only  the  independent  operation  of  the  transmission  systems,  but  also  the  formation  of  companies  with  a 
greater  financial  interest  in  maintaining  and  augmenting  the  capacity  and  reliability  of  those  systems.  RTOs, 
such  as  MISO  and  SPP,  monitor  electric  reliability  and  are  responsible  for  coordinating  the  operation  of  the 
wholesale electric transmission system and ensuring fair, non-discriminatory access to the transmission grid.

FERC Order No. 1000 amended certain existing transmission planning and cost allocation requirements to 
ensure that FERC-jurisdictional services are  provided  at just and reasonable rates and on a basis that is just 
and reasonable and not unduly discriminatory or preferential.

Revenue Requirement Calculations and Cost Sharing for Projects with Regional Benefits

The cost-based Formula Rates used by our Regulated Operating Subsidiaries include revenue requirement 
calculations for various types of projects. Network revenues continue to be the largest component of revenues 
recovered  through  our  Formula  Rates.  However,  regional  cost  sharing  revenues  have  experienced  long-term 
growth as a result of projects that have been identified as having regional benefits and are therefore eligible for 

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regional cost recovery. Separate calculations of revenue requirement are performed for projects that have been 
approved for regional cost sharing.

We  have  projects  that  are  eligible  for  regional  cost  sharing  under  the  MISO  tariff,  such  as  certain  network 
upgrade  projects,  and  the  MVPs.  Additionally,  certain  projects  at  ITC  Great  Plains  are  eligible  for  recovery 
through a region-wide charge in the SPP tariff, including three regional cost sharing projects in Kansas.

State Regulation

The regulatory agencies in the states where our Regulated Operating Subsidiaries’ assets are located do not 
have jurisdiction over our rates or terms and conditions of service. However, they typically have jurisdiction over 
siting  of  transmission  facilities  and  related  matters  as  described  below.  Additionally,  we  are  subject  to  the 
regulatory  oversight  of  various  state  environmental  quality  departments  for  compliance  with  any  state 
environmental standards and regulations.

ITCTransmission, METC and ITC Interconnection

Michigan

The  Michigan  Public  Service  Commission  has  jurisdiction  over  the  siting  of  certain  transmission  facilities. 
Additionally,  ITCTransmission,  METC  and  ITC  Interconnection  have  the  right  as  independent  transmission 
companies  to  condemn  property  in  the  state  of  Michigan  for  the  purposes  of  building  or  maintaining 
transmission facilities.

ITCTransmission, METC and ITC Interconnection are also subject to the regulatory oversight of the Michigan 
Department  of  Environmental  Quality,  the  Michigan  Department  of  Natural  Resources  and  certain  local 
authorities for compliance with all environmental standards and regulations.

ITC Midwest

Iowa

The Iowa Utilities Board has the power of supervision over the construction, operation and maintenance of 
transmission  facilities  in  Iowa  by  any  entity,  which  includes  the  power  to  issue  franchises.  Iowa  law  further 
provides  that  any  entity  granted  a  franchise  by  the  Iowa  Utilities  Board  is  vested  with  the  power  of 
condemnation in Iowa  to the extent the Iowa  Utilities  Board approves and deems necessary for public use. A 
city  has  the  power,  pursuant  to  Iowa  law,  to  grant  a  franchise  to  erect,  maintain  and  operate  transmission 
facilities within the city, which franchise may regulate the conditions required and manner of use of the streets 
and public grounds of the city and may confer the power to appropriate and condemn private property.

ITC  Midwest  also  is  subject  to  the  regulatory  oversight  of  certain  state  agencies  (including  the  Iowa 
Department of Natural Resources) and certain local authorities with respect to the issuance of environmental, 
highway, railroad and similar permits.

Minnesota

The  Minnesota  Public  Utilities  Commission  has  jurisdiction  over  the  construction,  siting  and  routing  of  new 
transmission  lines  or  upgrades  of  existing  lines  through  Minnesota’s  Certificate  of  Need  and  Route  Permit 
Processes.  Transmission  companies  are  also  required  to  participate  in  the  state’s  Biennial  Transmission 
Planning Process and are subject to the state’s preventative maintenance requirements. Pursuant to Minnesota 
law, ITC Midwest has the right as an independent  transmission company to condemn property in the state of 
Minnesota for the purpose of building new transmission facilities.

ITC  Midwest  is  also  subject  to  the  regulatory  oversight  of  the  Minnesota  Pollution  Control  Agency,  the 
Minnesota Department of Natural Resources, the Minnesota Public Utilities Commission in conjunction with the 
Department of Commerce and certain local authorities for compliance with applicable environmental standards 
and regulations.

Illinois

The Illinois Commerce Commission exercises jurisdiction over the siting of new transmission lines through its 
requirements for Certificates of Public Convenience and Necessity and Right-Of-Way acquisition that apply to 
construction of new or upgraded facilities.

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ITC Midwest is also subject to the regulatory  oversight  of the Illinois Environmental Protection Agency, the 
Illinois  Department  of  Natural  Resources,  the  Illinois  Pollution  Control  Board  and  certain  local  authorities  for 
compliance with all environmental standards and regulations.

Missouri

Because  ITC  Midwest  is  a  “public  utility”  and  an  “electrical  corporation”  under  Missouri  law,  the  Missouri 
Public  Service  Commission  has  jurisdiction  to  determine  whether  ITC  Midwest  may  operate  in  such  capacity. 
The  Missouri  Public  Service  Commission  also  exercises  jurisdiction  with  regard  to  other  non-rate  matters 
affecting its sole Missouri asset such as transmission substation construction, general safety and the transfer of 
the franchise or property.

ITC Midwest is also subject to the regulatory oversight of the Missouri Department of Natural Resources for 

compliance with all environmental standards and regulations relating to this transmission line.

Wisconsin

ITC  Midwest  is  a  “public  utility”  and  independent  TO  in  Wisconsin.  The  Public  Service  Commission  of 
Wisconsin  granted  ITC  Midwest  a  certificate  of  authority  to  transact  public  utility  business  in  the  state.  The 
Public  Service  Commission  of  Wisconsin  also  recognized  ITC  Holdings  as  a  public  utility  holding  company 
under Wisconsin statutes.

The Public Service Commission of Wisconsin exercises jurisdiction over the siting of new transmission lines 
through  the  issuance  of  certificates  of  authority  and  certificates  of  public  convenience  and  necessity.  Upon 
receipt  of  such  certificates  for  a  transmission  project,  ITC  Midwest  has  condemnation  authority  as  a  foreign 
transmission provider under Wisconsin law. ITC Midwest is also subject to the jurisdiction of certain local and 
state agencies, including the Wisconsin Department of Natural Resources, relating to environmental and road 
permits.

ITC Great Plains

Kansas

ITC  Great  Plains  is  a  “public  utility”  and  an  “electric  utility”  in  Kansas  pursuant  to  state  statutes. The  KCC 
issued  an  order  approving  the  issuance  of  a  limited  certificate  of  convenience  to  ITC  Great  Plains  for  the 
purposes of building, owning and operating SPP transmission projects in Kansas. In addition to its certificate of 
authority, the KCC has jurisdiction over the siting of electric transmission lines.

ITC  Great  Plains  is  also  subject  to  the  regulatory  oversight  of  the  Kansas  Department  of  Health  and 
Environment for compliance with all environmental standards and regulations relating to the construction phase 
of any transmission line.

Oklahoma

ITC  Great  Plains  has  approval  from  the  Oklahoma  Corporation  Commission  to  operate  in  Oklahoma, 
pursuant to Oklahoma statutes as an electric public utility providing only transmission services. The Oklahoma 
Corporation Commission does not exercise jurisdiction over the siting of any transmission lines.

ITC Great Plains is subject to the regulatory oversight of Oklahoma Department of Environmental Quality for 
compliance  with  environmental  standards  and  regulations  relating  to  construction  of  certain  proposed 
transmission lines.

Sources of Revenue

See  “Item  7  Management’s  Discussion  and Analysis  of  Financial  Condition  and  Results  of  Operations  — 
Significant  Components  of  Results  of  Operations  —  Revenues”  for  a  discussion  of  our  principal  sources  of 
revenue.

Seasonality

The cost-based Formula Rates in effect for our Regulated Operating Subsidiaries, as discussed in “Item 7 
Management’s  Discussion  and  Analysis  of  Financial  Condition  and  Results  of  Operations  —  Cost-Based 
Formula Rates with True-Up Mechanism,” mitigate the seasonality of net income for our Regulated Operating 
Subsidiaries.  Our  Regulated  Operating  Subsidiaries  accrue  or  defer  revenues  to  the  extent  that  the  actual 

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revenue requirement for the reporting period is higher or lower, respectively, than the amounts billed relating to 
that reporting period. For example, to the extent that amounts billed are less than our revenue requirement for a 
reporting  period,  a  revenue  accrual  is  recorded  for  the  difference  and  the  difference  results  in  no  net  income 
impact.

Operating cash flows are seasonal at our MISO Regulated Operating Subsidiaries, in that cash received for 

revenues is typically higher in the summer months when peak load is higher.

Principal Customers

Our  principal  transmission  service  customers  are  DTE  Electric,  Consumers  Energy  and  IP&L,  which 
accounted for approximately 21.6%, 23.9% and 23.9%, respectively, of our consolidated billed revenues for the 
year  ended  December  31,  2020.  One  or  more  of  these  customers  together  have  consistently  represented  a 
significant  percentage  of  our  operating  revenue.  These  percentages  of  total  billed  revenues  of  DTE  Electric, 
Consumers  Energy  and  IP&L  include  the  collection  of  2018  revenue  accruals  and  deferrals  and  exclude  any 
amounts for the 2020 revenue accruals and deferrals that were included in our 2020 operating revenues, but 
will  not  be  billed  to  our  customers  until  2022.  Refer  to  “Item  7  Management’s  Discussion  and  Analysis  of 
Financial  Condition  and  Results  of  Operations  —  Cost-Based  Formula  Rates  with True-Up  Mechanism”  for  a 
discussion  on  the  difference  between  billed  revenues  and  operating  revenues.  Our  remaining  revenues  were 
generated  from  providing  service  to  other  entities  such  as  alternative  energy  suppliers,  power  marketers  and 
other wholesale customers that provide electricity to end-use consumers and from transaction-based capacity 
reservations. Nearly all of our revenues are from transmission customers in the United States. Although we may 
recognize allocated revenues from time to time from Canadian entities reserving transmission over the Ontario 
or Manitoba interface, these revenues have not been and are not expected to be material to us.

Billing

MISO and SPP are responsible for billing and collecting the majority of our transmission service revenues as 
well  as  independently  administering  the  transmission  tariff  in  their  respective  service  territory.  As  the  billing 
agents for our MISO Regulated Operating Subsidiaries and ITC Great Plains, MISO and SPP independently bill 
DTE Electric, Consumers Energy, IP&L and other customers on a monthly basis and collect fees for the use of 
our transmission systems. 

See “Item 7A Quantitative and Qualitative Disclosures about Market Risk — Credit Risk” for discussion of our 

credit policies.

Competition

Each  of  our  MISO  Regulated  Operating  Subsidiaries  operates  the  primary  transmission  system  in  its 
respective service area and has limited competition for certain projects. However, due to the implementation of 
the  FERC  Order  No.  1000,  other  entities  with  transmission  development  initiatives  may  compete  with  us  by 
seeking approval to be named the party authorized to build new capital projects that we are also pursuing. Our 
subsidiaries may also compete with other entities on development opportunities for transmission investment in 
locations  outside  of  our  existing  service  areas.  See  further  discussion  of  Order  No.  1000  above  under 
“Regulatory Environment — Federal Regulation.”

Human Capital Resources

ITC Holdings places significant emphasis on attracting, developing and retaining individuals who exemplify 
the values that are the cornerstone of our company. As of December 31, 2020, we had 698 employees, with low 
employee  turnover  and  no  significant  change  in  the  number  of  employees  from  the  prior  year.  None  of  our 
employees  are  covered  by  collective  bargaining  agreements.  In  addition,  we  work  with  many  outside  firms  to 
provide  additional  resources  to  support  our  business.  We  utilize  human  capital  resources  employed  by  these 
firms  to  assist  with  construction,  maintenance,  field  operations  and  other  corporate  functions  of  our  business. 
We believe that we have good relationships with our suppliers of contracted services.

We  believe  that  our  compensation  and  benefit  programs  have  been  appropriately  designed  to  attract  and 
retain talent. Compensation for employees is made up of a combination of base salary, short-term incentive and 
long-term incentive pay structures. In addition, we offer a comprehensive package of additional benefits for all of 
our employees and various professional development opportunities through internal and external programs.

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Safety  is  of  the  utmost  importance  for  our  employees,  and  we  consider  safety  to  be  a  key  priority  for  our 
company.  Our  safety  policies,  procedures  and  training  practices  have  resulted  in  safety  performance  metrics 
that consistently rank ITC Holdings in the top decile among comparable electric utilities.

We  strive  to  provide  an  inclusive  and  diverse  environment  for  all  of  our  employees.  We  believe  that  by 
recognizing  and  valuing  our  employees’  similarities,  as  well  as  their  differences,  we  make  our  shared  goals 
possible. In addition to our internal commitments to inclusion and diversity, we are also implementing a supplier 
diversity  program.  This  effort  will  further  diversify  our  supplier  base  through  the  recruitment  and  growth  of 
businesses owned by minorities, women and veterans. 

Environmental Matters

See “Environmental Matters” in Note 18 to the consolidated financial statements.

Available Information Under the Securities Exchange Act of 1934

Our Internet address is http://www.itc-holdings.com. Visit our website to learn more about us. Financial and 
other material information regarding us is routinely posted on our website and is readily accessible. All of our 
reports filed pursuant to Section 13(a) or 15(d) of the Exchange Act, including our annual reports on Form 10-K, 
quarterly  reports  on  Form  10-Q,  current  reports  on  Form  8-K,  and  any  amendments  to  those  reports,  can  be 
accessed free of charge through our website. These reports are available as soon as practicable after they are 
electronically filed with the SEC. The information on our website is not incorporated by reference into this report.

ITEM 1A.   RISK FACTORS.

Risks Related to Our Business

Certain  elements  of  our  Regulated  Operating  Subsidiaries’  Formula  Rates  have  been  and  can  be 
challenged, which could result in lowered rates and/or refunds of amounts previously collected and 
thus may have an adverse effect on our business, financial condition, results of operations and cash 
flows.

Our Regulated Operating Subsidiaries provide transmission service under rates regulated by the FERC. The 
FERC has approved the cost-based Formula Rates used by our Regulated Operating Subsidiaries to calculate 
their  respective  annual  revenue  requirements,  but  it  has  not  expressly  approved  the  amount  of  actual  capital 
and  operating  expenditures  to  be  used  in  the  Formula  Rates.  All  aspects  of  our  Regulated  Operating 
Subsidiaries’  rates  approved  by  the  FERC,  including  the  Formula  Rate  templates,  the  rates  of  return  on  the 
actual equity portion of their respective capital structures, ROE adders for independent transmission ownership, 
the approved capital structures and other aspects of our rates, are subject to challenge by interested parties at 
the  FERC,  or  by  the  FERC  on  its  own  initiative  in  a  proceeding  under  Section  206  of  the  FPA.  In  addition, 
interested  parties  may  challenge  the  annual  implementation  and  calculation  by  our  Regulated  Operating 
Subsidiaries of their projected rates and Formula Rate true up pursuant to their approved Formula Rates under 
the Regulated Operating Subsidiaries’ Formula Rate implementation protocols. End-use consumers and entities 
supplying  electricity  to  end-use  consumers  may  also  attempt  to  influence  government  and/or  regulators  to 
change the rate setting methodologies that apply to our Regulated Operating Subsidiaries, particularly if rates 
for delivered electricity increase substantially. If a challenger can establish that any of these aspects are unjust, 
unreasonable,  unduly  discriminatory  or  preferential,  then  the  FERC  will  make  adjustments  to  them  and/or 
disallow any of our Regulated Operating Subsidiaries’ inclusion of those aspects in the rate setting formula. This 
could result in lowered rates and/or refunds of amounts collected, any of which could have a material adverse 
effect on our business, financial condition, results of operations and cash flows.

Our actual capital investment may be lower than planned, which would cause a lower than anticipated 
rate base and would therefore result in lower revenues, earnings and associated cash flows compared 
to  our  current  expectations.  In  addition,  we  may  incur  expenses  related  to  the  pursuit  of  strategic 
investment opportunities, which may be higher than forecasted.

Each of our Regulated Operating Subsidiaries’ rate base, revenues, earnings and associated cash flows are 
determined  in  part  by  additions  to  property,  plant  and  equipment  and  when  those  additions  are  placed  in 
service.  If  our  operating  subsidiaries’  capital  investment  and  the  resulting  in-service  property,  plant  and 
equipment  are  lower  than  anticipated  for  any  reason,  our  operating  subsidiaries  will  have  a  lower  than 

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anticipated rate base, thus causing their revenue requirements and future earnings and cash flows to be lower 
than anticipated.

Any capital investment at our Regulated Operating Subsidiaries may be lower than our published estimates 

due to, among other factors, the impact of:

•

•

•

•

actual or forecasted loads;

regional economic conditions;

weather conditions;

union strikes or labor shortages;

• material and equipment prices and availability;

•

•

•

•

•

•

•

variances between estimated and actual costs of construction contracts awarded;

our ability to obtain financing for such expenditures, if necessary;

limitations  on  the  amount  of  construction  that  can  be  undertaken  on  our  system  or  transmission 
systems owned by others at any one time;

regulatory requirements relating to our rate construct, including our ability to recover costs;

the potential for greater competition;

environmental, siting or regional planning issues; and

legal proceedings.

Our ability to engage in construction projects resulting from pursuing these initiatives is subject to significant 
uncertainties, including the factors discussed above, and will depend on obtaining any necessary regulatory and 
other  approvals  for  the  project  and  for  us  to  initiate  construction,  our  achieving  status  as  the  builder  of  the 
project in some circumstances and other factors. In addition, projects may be canceled, the scope of planned 
projects may change, or projects may not be completed on time, any of which may adversely affect our level of 
investment or cause our projected investments to be inaccurate.

In  addition,  we  may  incur  expenses  to  pursue  strategic  investment  opportunities.  If  these  payments  or 
expenses are higher than anticipated, our future results of operations, cash flows and financial condition could 
be materially and adversely affected.

The  regulations  to  which  we  are  subject  may  limit  our  ability  to  raise  capital  and/or  pursue 
acquisitions, development opportunities or other transactions or may subject us to liabilities.

Each of our Regulated Operating Subsidiaries is a “public utility” under the FPA and, accordingly, is subject 
to regulation by the FERC. Approval of the FERC is required under Section 203 of the FPA for a disposition or 
acquisition  of  regulated  public  utility  facilities,  either  directly  or  indirectly  through  a  holding  company.  Such 
approval is also required to acquire a significant interest in securities of a public utility. Section 203 of the FPA 
also provides the FERC with explicit authority over utility holding companies’ purchases or acquisitions of, and 
mergers or consolidations with, a public utility. Finally, each of our Regulated Operating Subsidiaries must also 
seek  approval  by  the  FERC  under  Section  204  of  the  FPA  for  issuances  of  its  securities  (including  debt 
securities). If we are unable to obtain the necessary FERC approvals for potential acquisitions, dispositions or 
merger activities, or to raise capital, our strategic and growth opportunities may be limited. This could have an 
adverse impact on our consolidated results of operations, cash flows and financial condition.

We  are  also  pursuing  development  projects  for  construction  of  transmission  facilities  and  interconnections 
with generating resources. These projects may require regulatory approval by Federal agencies, including the 
FERC, applicable RTOs and state and local regulatory agencies. Failure to secure such regulatory approval for 
new  strategic  development  projects  could  adversely  affect  our  ability  to  grow  our  business  and  increase  our 
revenues. If we fail to obtain these approvals when necessary, we may incur liabilities for such failure.

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Changes  in  energy  laws,  regulations  or  policies  could  impact  our  business,  financial  condition, 
results of operations and cash flows.

Each of our Regulated Operating Subsidiaries is regulated by the FERC as a “public utility” under the FPA 
and is a TO in MISO, SPP or PJM. We cannot predict whether the approved rate methodologies for any of our 
Regulated  Operating  Subsidiaries  will  be  changed.  In  addition,  the  U.S.  Congress  periodically  considers 
enacting energy legislation that could assign new responsibilities to the FERC, modify provisions of the FPA or 
provide  the  FERC  or  another  entity  with  increased  authority  to  regulate  transmission  matters.  Our  Regulated 
Operating Subsidiaries may be affected by any such changes in federal energy laws, regulations or policies in 
the  future.  While  our  Regulated  Operating  Subsidiaries  are  subject  to  the  FERC’s  exclusive  jurisdiction  for 
purposes  of  rate  regulation,  changes  in  state  laws  affecting  other  matters,  such  as  transmission  siting  and 
construction, could limit investment opportunities available to us.

The  widespread  outbreak  of  an  illness  or  other  communicable  disease,  including  the  COVID-19 
pandemic,  or  any  other  public  health  crisis,  could  have  a  material  adverse  impact  on  our  business, 
results of operations, financial condition, cash flows and credit metrics.

We  could  be  negatively  impacted  by  the  widespread  outbreak  of  an  illness  or  any  other  communicable 
diseases, or any other public health crisis that results in economic and trade disruptions, including the disruption 
of global supply chains. COVID-19 is currently impacting the global economy, supply chains and markets. As a 
result of efforts to limit the spread of COVID-19, such as through various “stay in place” orders issued by states 
served  by  our  transmission  systems,  many  of  the  businesses  that  use  our  transmission  systems,  including 
those  with  large  manufacturing  operations,  have  and  may  continue  to  experience  operating  restrictions  or 
temporarily shut down operations. The impact of efforts to limit the spread of COVID-19 on our business, results 
of operations and financial condition is uncertain and will ultimately depend on the duration and severity of the 
pandemic,  the  length  that  the  various  business  restrictions  are  in  effect,  the  impact  of  recent  resurgences  of 
COVID-19 cases and deaths in the United States, and the efficacy and distribution of COVID-19 vaccines.

We cannot predict whether, and the extent to which, COVID-19 will have a material impact on our liquidity, 
financial  condition,  and  results  of  operations.  We  require  access  to  the  capital  markets  to  fund  capital 
investments. To the extent that our access to the capital markets is adversely affected by COVID-19, we may 
need to consider alternative sources of funding for our operations and for working capital, any of which may not 
be  available  and  may  increase  our  cost  of  capital.  The  extent  to  which  COVID-19  may  impact  our  liquidity, 
financial condition, and results of operations will depend on future developments, which are highly uncertain and 
cannot be predicted; an extended period of global supply chain and economic disruption could materially impact 
our business, results of operations, financial condition, cash flows and credit metrics.

Each  of  our  MISO  Regulated  Operating  Subsidiaries  depends  on  its  primary  customer  for  a 
substantial  portion  of  its  revenues,  and  any  material  failure  by  those  primary  customers  to  make 
payments  for  transmission  services  could  have  a  material  adverse  effect  on  our  business,  financial 
condition, results of operations and cash flows.

Each  of  ITCTransmission,  METC  and  ITC  Midwest  derive  a  substantial  portion  of  their  revenues  from  the 
transmission  of  electricity  to  the  local  distribution  facilities  of  DTE  Electric,  Consumers  Energy  and  IP&L, 
respectively. Each of these customers is expected to constitute the majority of the revenues of the respective 
MISO  Regulated  Operating  Subsidiary  for  the  foreseeable  future.  Any  material  failure  by  DTE  Electric, 
Consumers Energy or IP&L to make payments for transmission services could have an adverse effect on our 
business, financial condition, results of operations and cash flows.

A  significant  amount  of  the  land  on  which  our  assets  are  located  is  subject  to  easements,  mineral 
rights  and  other  similar  encumbrances.  As  a  result,  we  must  comply  with  the  provisions  of  various 
easements, mineral rights and other similar encumbrances, which may adversely impact our ability to 
complete construction projects in a timely manner.

METC does not own the majority of the land on which its electric transmission assets are located. Instead, 
under  the  provisions  of  the  Easement  Agreement,  METC  pays  an  annual  rent  to  Consumers  Energy  in 
exchange for rights-of-way, leases, fee interests and licenses which allow METC to use the land on which its 
transmission lines are located. Under the terms of the Easement Agreement, METC’s easement rights could be 
eliminated if METC fails to meet certain requirements, such as paying contractual rent to Consumers Energy in 
a  timely  manner.  Additionally,  a  significant  amount  of  the  land  on  which  our  other  subsidiaries’  assets  are 

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located is subject to easements, mineral rights and other similar encumbrances. As a result, they must comply 
with the provisions of various easements, mineral rights and other similar encumbrances, which may adversely 
impact their ability to complete their construction projects in a timely manner.

We contract with third parties to provide services for certain aspects of our business. If any of these 
agreements are terminated, we may face a shortage of labor or replacement contractors to provide the 
services formerly provided by these third parties.

We enter into various agreements and arrangements with third parties to provide services for construction, 
maintenance and operations of certain aspects of our business, and we utilize the services of contractors to a 
significant extent. If any of these agreements or arrangements is terminated for any reason, it could result in a 
shortage of a readily available workforce to provide such services and we may face difficulty finding a qualified 
replacement workforce. In such a situation, if we are unable to find adequate replacements for contractors in a 
timely  manner,  it  could  have  an  adverse  effect  on  our  results  of  operations  and  the  ability  to  carry  on  our 
business.

Hazards  associated  with  high-voltage  electricity  transmission  may  result  in  suspension  of  our 
operations, costly litigation or the imposition of civil or criminal penalties.

Our  operations  are  subject  to  the  usual  hazards  associated  with  high-voltage  electricity  transmission, 
including  explosions,  fires,  mechanical  failure,  unscheduled  downtime,  equipment  interruptions,  remediation, 
chemical  spills,  discharges  or  releases  of  toxic  or  hazardous  substances  or  gases  and  other  environmental 
risks. These hazards can cause personal injury and loss of life, severe damage to or destruction of property and 
equipment  and  environmental  damage,  and  may  result  in  suspension  of  operations,  litigation  by  aggrieved 
parties  and  the  imposition  of  civil  or  criminal  penalties  which  may  have  a  material  adverse  effect  on  our 
business, financial condition and results of operations. We maintain property and casualty insurance, but we are 
not  fully  insured  against  all  potential  hazards  incident  to  our  business,  such  as  damage  to  poles,  towers  and 
lines or losses caused by outages.

We  are  subject  to  environmental  regulations  and  to  laws  that  can  give  rise  to  substantial  liabilities 
from environmental contamination.

We are subject to federal, state and local environmental laws and regulations, which impose limitations on 
the discharge of pollutants into the environment, establish standards for the management, treatment, storage, 
transportation and disposal of solid and hazardous wastes and hazardous materials, and impose obligations to 
investigate  and  remediate  contamination  in  certain  circumstances.  Liabilities  relating  to  investigation  and 
remediation of contamination, as well as other liabilities concerning hazardous materials or contamination such 
as  claims  for  personal  injury  or  property  damage,  may  arise  at  many  locations,  including  formerly  owned  or 
operated  properties  and  sites  where  wastes  have  been  treated  or  disposed  of,  as  well  as  properties  we 
currently  own  or  operate.  Such  liabilities  may  arise  even  where  the  contamination  does  not  result  from 
noncompliance with applicable environmental laws. Under a number of environmental laws, such liabilities may 
also be joint and several, meaning that a party can be held responsible for more than its share of the liability 
involved, or even the entire share.

We  have  incurred  expenses  in  connection  with  environmental  compliance,  and  we  anticipate  that  we  will 
continue  to  do  so  in  the  future.  Failure  to  comply  with  the  extensive  environmental  laws  and  regulations 
applicable  to  us  could  result  in  significant  civil  or  criminal  penalties  and  remediation  costs.  Our  assets  and 
operations also involve the use of materials classified as hazardous, toxic or otherwise dangerous. Some of our 
facilities  and  properties  are  located  near  environmentally  sensitive  areas  such  as  wetlands  and  habitats  of 
endangered or threatened species. In addition, certain properties in which we operate are, or are suspected of 
being,  affected  by  environmental  contamination.  Compliance  with  these  laws  and  regulations,  and  liabilities 
concerning contamination or hazardous materials, may adversely affect our costs and, therefore, our business, 
financial condition and results of operations.

If  amounts  billed  for  transmission  service  for  our  Regulated  Operating  Subsidiaries’  transmission 
systems  are  lower  than  expected,  or  our  actual  revenue  requirements  are  higher  than  expected,  the 
timing of actual collection of our total revenues would be delayed.

If  amounts  billed  for  transmission  service  are  lower  than  expected,  the  timing  of  actual  collections  of  our 
Regulated Operating Subsidiaries’ total revenue requirement would likely be delayed until such circumstances 

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are adjusted through the true-up mechanism, which would be settled within a two-year period, in our Regulated 
Operating Subsidiaries’ Formula Rates. Lower than expected amounts collected could result from lower network 
load or point-to-point transmission service on our Regulated Operating Subsidiaries’ transmission systems due 
to  a  weak  economy,  changes  in  the  nature  or  composition  of  the  transmission  assets  of  our  Regulated 
Operating Subsidiaries and surrounding areas, poor transmission quality of neighboring transmission systems, 
or  for  any  other  reason.  In  addition,  if  the  revenue  requirements  of  our  Regulated  Operating  Subsidiaries  are 
higher  than  expected,  the  timing  of  actual  collection  of  our  Regulated  Operating  Subsidiaries'  total  revenue 
requirements  would  likely  be  delayed  until  such  circumstances  are  reflected  through  the  true-up  mechanism, 
which would be settled within a two-year period, in our Regulated Operating Subsidiaries' Formula Rates. This 
could  be  due  to  higher  actual  expenditures  compared  to  the  forecasted  expenditures  used  to  develop  their 
billing rates or for any other reason. The effect of such under-collection would be to reduce the amount of our 
available cash resources from what we had expected, until such under-collection is corrected through the true-
up mechanism in the Formula Rate template, which may require us to increase our outstanding indebtedness, 
thereby reducing our available borrowing capacity, and may require us to pay interest at a rate that exceeds the 
interest to which we are entitled in connection with the operation of the true-up mechanism. 

We  are  subject  to  various  regulatory  requirements,  including  reliability  standards;  contract  filing 
requirements;  reporting,  recordkeeping  and  accounting  requirements;  and  transaction  approval 
requirements.  Violations  of  these  requirements,  whether  intentional  or  unintentional,  may  result  in 
penalties  that,  under  some  circumstances,  could  have  a  material  adverse  effect  on  our  business, 
financial condition, results of operations and cash flows.

The various regulatory requirements to which we are subject include reliability standards established by the 
NERC,  which  acts  as  the  nation’s  Electric  Reliability  Organization  approved  by  the  FERC  in  accordance  with 
Section 215 of the FPA. These standards address operation, planning and security of the bulk power system, 
including  requirements  with  respect  to  real-time  transmission  operations,  emergency  operations,  vegetation 
management, critical infrastructure protection and personnel training. Failure to comply with these requirements 
can  result  in  monetary  penalties  as  well  as  non-monetary  sanctions.  Monetary  penalties  vary  based  on  an 
assigned  risk  factor  for  each  potential  violation,  the  severity  of  the  violation  and  various  other  circumstances, 
such as whether the violation was intentional or concealed, whether there are repeated violations, the degree of 
the  violator’s  cooperation  in  investigating  and  remediating  the  violation  and  the  presence  of  a  compliance 
program,  and  such  penalties  can  be  substantial.  Non-monetary  sanctions  include  potential  limitations  on  the 
violator’s  activities  or  operation  and  placing  the  violator  on  a  watchlist  for  major  violators.  If  any  of  our 
subsidiaries  violate  the  NERC  reliability  standards,  even  unintentionally,  in  any  material  way,  any  penalties  or 
sanctions imposed against us could have a material adverse effect on our business, financial condition, results 
of operations and cash flows.

Certain  of  our  subsidiaries  are  also  subject  to  requirements  under  Sections  203  and  205  of  the  FPA  for 
approval of transactions; reporting, recordkeeping and accounting requirements; and for filing contracts related 
to  the  provision  of  jurisdictional  services.  Under  the  FERC  policy,  failure  to  file  jurisdictional  agreements  on  a 
timely basis may result in foregoing the time value of revenues collected under the agreement, but not to the 
point  where  a  loss  would  be  incurred.  The  failure  to  obtain  timely  approval  of  transactions  subject  to  FPA 
Section  203,  or  to  comply  with  applicable  reporting,  recordkeeping  or  accounting  requirements  under  FPA 
Section 205, could subject us to penalties that could have a material adverse effect on our financial condition, 
results of operations and cash flows.

Acts  of  war,  terrorist  attacks,  natural  disasters,  severe  weather  and  other  catastrophic  events  may 
have  a  material  adverse  effect  on  our  business,  financial  condition,  results  of  operations  and  cash 
flows.

Acts of war, terrorist attacks, natural disasters, severe weather and other catastrophic events may negatively 
affect  our  business,  financial  condition  and  cash  flows  in  unpredictable  ways,  such  as  increased  security 
measures and disruptions of markets. Energy related assets, including, for example, our transmission facilities 
and  DTE  Electric’s,  Consumers  Energy’s  and  IP&L’s  generation  and  distribution  facilities  that  we  interconnect 
with, may be at risk of acts of war and terrorist attacks, as well as natural disasters, severe weather and other 
catastrophic events. Such events or threats may have a material effect on the economy in general and could 
result in a decline in energy consumption, which may have a material adverse effect on our business, financial 
condition, results of operations and cash flows.

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A cyber-attack or incident could have a material adverse effect on our business, financial condition, 
results of operations and cash flows.

Various  U.S.  Government  agencies  have  noted  that  external  threat  sources  continue  to  seek  to  exploit, 
through  cyber  attacks,  potential  vulnerabilities  in  the  U.S.  energy  infrastructure  including  electric  transmission 
assets.  These  cyber  threats  and  attacks  are  becoming  more  sophisticated  and  dynamic.  Cyber  security 
incidents  could  harm  our  business  by  limiting  our  transmission  capabilities,  delay  our  development  and 
construction of new facilities or capital improvement projects on existing facilities or expose us to liability. Cyber 
attacks  targeting  our  information  systems  could  also  impair  our  records,  networks,  systems  and  programs,  or 
transmit viruses to other systems. Such events or the threat of such events may increase costs associated with 
heightened security requirements. In addition, if our major customers or suppliers experience a cyber attack it 
may reduce their ability to use our transmission facilities or service our transmission assets. If our business or 
those of our customers and suppliers are subject to a cyber attack, it may have a material adverse effect on our 
business, financial condition, results of operations and cash flows.

Changes  in  tax  laws  or  regulations  may  negatively  affect  our  results  of  operations,  net  income, 
financial condition, cash flows and credit metrics. 

We  are  subject  to  taxation  by  various  taxing  authorities  at  the  federal,  state  and  local  levels.  Various 
representatives of the government, corporations, industry groups and the public continue to pursue changes to 
tax laws and regulations, and corporate tax reform continues to be a priority in many jurisdictions. Due to unique 
aspects  of  the  treatment  of  taxes  for  regulated  utilities,  the  impacts  of  changes  in  tax  laws  for  us  and  our 
Regulated  Operating  Subsidiaries  may  differ  from  the  impacts  to  other  corporations  generally.  Changes  in 
federal, state or local tax rates or other aspects of tax laws could materially and adversely affect our results of 
operations, net income, financial condition, cash flows, and credit metrics.

Advances  in  technology  may  negatively  impact  our  business,  financial  condition,  results  of 
operations and cash flows.

Research  and  development  efforts  continue  to  seek  improvements  to  existing  or  new  alternative 
technologies  to  produce,  store  and  distribute  power,  including  fuel  cells,  microturbines,  distributed  generation 
and battery storage. It is possible that adoption of such alternative technologies could be significant enough to 
cause a reduction in the demand for electricity from the traditional bulk electric system or could make portions of 
our  transmission  systems  obsolete  before  the  end  of  their  useful  lives.  Such  advances  in  alternative 
technologies could decrease the need for capital investments in our transmission systems over time or increase 
cost, and as a result could have an adverse effect on our business, financial condition, results of operations and 
cash flows.

Risks Relating to Our Corporate and Financial Structure

ITC  Holdings  is  a  holding  company  with  no  operations,  and  unless  we  receive  dividends  or  other 
payments from our subsidiaries, we may be unable to fulfill our cash obligations.

As  a  holding  company  with  no  business  operations,  ITC  Holdings’  material  assets  consist  primarily  of  the 
stock  and  membership  interests  in  our  subsidiaries.  Our  only  sources  of  cash  to  meet  our  obligations  are 
dividends and other payments received by us from time to time from our subsidiaries, the proceeds raised from 
the  sale  of  our  securities  and  borrowings  under  our  various  credit  agreements.  Each  of  our  subsidiaries, 
however, is legally distinct from us and has no obligation, contingent or otherwise, to make funds available to 
us. The ability of each of our Regulated Operating Subsidiaries and our other subsidiaries to pay dividends and 
make other payments to us is subject to, among other things, the availability of funds, after taking into account 
capital  expenditure  requirements,  the  terms  of  its  indebtedness,  applicable  state  laws  and  regulations  of  the 
FERC  and  the  FPA.  Our  Regulated  Operating  Subsidiaries  target  a  FERC-approved  capital  structure  of  60% 
equity and 40% debt that may limit the ability of our Regulated Operating Subsidiaries to use net assets for the 
payment of dividends to ITC Holdings. In addition, ITC Holdings’ right to receive any assets of any subsidiary, 
and therefore the right of its creditors to participate in those assets, will be effectively subordinated to the claims 
of that subsidiary’s creditors. If ITC Holdings does not receive cash or other assets from our subsidiaries, it may 
be unable to pay principal and interest on its indebtedness. 

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We  have  a  considerable  amount  of  debt  and  our  reliance  on  debt  financing  may  limit  our  ability  to 
fulfill our debt obligations and/or to obtain additional financing.

We have a considerable amount of debt and our consolidated indebtedness includes various debt securities 
and borrowings, which utilize indentures, revolving and term loan credit agreements and commercial paper that 
we rely on as sources of capital and liquidity. Our capital structure can have several important consequences, 
including, but not limited to, the following:

• If future cash flows are insufficient, we may not be able to make principal or interest payments on our debt 
obligations, which could result in the occurrence of an event of default under one or more of those debt 
instruments.

• We may need to increase our indebtedness in order to make the capital expenditures and other expenses 

or investments planned by us.

• Our  indebtedness  has  the  general  effect  of  reducing  our  flexibility  to  react  to  changing  business  and 
economic  conditions  insofar  as  they  affect  our  financial  condition. A  substantial  portion  of  the  dividends 
and payments in lieu of taxes we receive from our subsidiaries will be dedicated to the payment of interest 
on our indebtedness, thereby, reducing our available cash.

• In the event that we are liquidated, the creditors of our subsidiaries will be entitled to payment in full of the 
subsidiaries’  indebtedness  prior  to  making  any  payments  to  ITC  Holdings  for  the  payment  of  its 
indebtedness.

• We  currently  have  debt  instruments  outstanding  with  short-term  maturities  or  relatively  short  remaining 
maturities. Our ability to secure additional financing prior to or after these facilities mature, if needed, may 
be substantially restricted by the existing level of our indebtedness and the restrictions contained in our 
debt  instruments. Additionally,  the  interest  rates  at  which  we  might  secure  additional  financings  may  be 
higher  than  our  currently  outstanding  debt  instruments  or  higher  than  forecasted  at  any  point  in  time, 
which could adversely affect our business, financial condition, results of operations and cash flows.

• Market  conditions  could  affect  our  access  to  capital  markets,  restrict  our  ability  to  secure  financing  to 
make  the  capital  expenditures  and  investments  and  pay  other  expenses  planned  by  us  which  could 
adversely affect our business, financial condition, cash flows and results of operations.

We  may  incur  substantial  additional  indebtedness  in  the  future.  The  incurrence  of  additional  indebtedness 

would increase the leverage-related risks described above.

Adverse changes in our credit ratings may negatively affect us.

Our ability to access capital markets is important to our ability to operate our business. Increased scrutiny of 
the  energy  industry  and  the  impact  of  regulation,  as  well  as  changes  in  our  financial  performance  and 
unfavorable conditions in the capital markets could result in credit agencies reexamining and downgrading our 
credit ratings. In addition, because we are a subsidiary of Fortis, a downgrade in Fortis’ credit rating could cause 
our  credit  rating  to  be  downgraded  as  well,  even  if  our  creditworthiness  has  not  otherwise  deteriorated.  A 
downgrade  in  our  credit  ratings  could  restrict  or  discontinue  our  ability  to  access  capital  markets  at  attractive 
rates  and  increase  our  borrowing  costs.  A  rating  downgrade  could  also  increase  the  interest  we  pay  on 
commercial paper and under our revolving and term loan credit agreements.

Certain provisions in our debt instruments limit our financial and operating flexibility.

Our debt instruments on a consolidated basis, including senior notes, secured notes, first mortgage bonds, 
revolving  and  term  loan  credit  agreements  and  commercial  paper,  contain  numerous  financial  and  operating 
covenants that place significant restrictions on, among other things, our ability to:

• incur additional indebtedness;

• engage in sale and lease-back transactions;

• create liens or other encumbrances;

• enter  into  mergers,  consolidations,  liquidations  or  dissolutions,  or  sell  or  otherwise  dispose  of  all  or 

substantially all of our assets;

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• create and acquire subsidiaries; and

• pay dividends or make distributions on our stock or on the stock or member capital of our subsidiaries.

In  addition,  the  covenants  require  us  to  meet  certain  financial  ratios,  such  as  maintaining  certain  debt  to 
capitalization ratios and certain funds from operations to debt levels. Our ability to comply with these and other 
requirements  and  restrictions  may  be  affected  by  changes  in  economic  or  business  conditions,  results  of 
operations or other events beyond our control. A failure to comply with the obligations contained in any of our 
debt  instruments  could  result  in  acceleration  of  related  debt  and  the  acceleration  of  debt  under  other 
instruments evidencing indebtedness that may contain cross-acceleration or cross-default provisions.

ITEM 1B.   UNRESOLVED STAFF COMMENTS.

None.

ITEM 2. 

PROPERTIES.

Our  Regulated  Operating  Subsidiaries’  transmission  facilities  are  located  in  Michigan,  Iowa,  Minnesota, 
Illinois,  Missouri,  Kansas  and  Oklahoma.  Our  MISO  Regulated  Operating  Subsidiaries  and  ITC  Great  Plains 
have agreements with other utilities for the joint ownership of specific substations, transmission lines and other 
transmission  assets.  See  Note  16  to  the  consolidated  financial  statements  for  more  information  on  the  jointly 
owned assets.

Our Regulated Operating Subsidiaries own the assets of transmission systems and related assets, including:

• approximately 16,000 circuit miles of overhead and underground transmission lines rated at voltages of 

34.5 kV to 345 kV, along with related transmission towers and poles;

• station assets, such as transformers and circuit breakers, at approximately 673 stations and substations 
which  either  interconnect  our  Regulated  Operating  Subsidiaries’  transmission  facilities  or  connect  our 
Regulated Operating Subsidiaries’ facilities with generation or distribution facilities owned by others;

• other  transmission  equipment  necessary  to  safely  operate  the  system  (e.g.,  monitoring  and  metering 

equipment);

• warehouses and related equipment; and

• associated land held in fee, rights-of-way and easements.

ITCTransmission owns a corporate headquarters facility and operations control room in Novi, Michigan and a 
facility in Ann Arbor, Michigan that includes a back-up operations control room, along with associated furniture, 
fixtures and office equipment for these facilities.

METC does not own the majority of the land on which its assets are located, but under the provisions of the 
Easement Agreement, METC has an easement to use the land, rights-of-way, leases and licenses in the land 
on  which  its  transmission  lines  are  located  that  are  held  or  controlled  by  Consumers  Energy.  See  “Item  1 
Business - Operating Contracts - METC - Amended and Restated Easement Agreement.”

Certain  of  our  Regulated  Operating  Subsidiaries  have  issued  First  Mortgage  Bonds  and  Senior  Secured 
Notes. Under the terms of these instruments, the respective bondholders and noteholders have the benefit of a 
first  mortgage  lien  on  substantially  all  of  the  assets  of  the  corresponding  debt  issuer.  Refer  to  Note  10  to  the 
consolidated  financial  statements  for  more  information  on  the  outstanding  debt  of  our  Regulated  Operating 
Subsidiaries.  As  of  December  31,  2020,  there  were  no  liens  or  encumbrances  on  the  assets  of  ITC 
Interconnection.

The assets of our Regulated Operating Subsidiaries are suitable for electric transmission and adequate for 
the electricity demand in our service territory. We prioritize capital spending based in part on meeting reliability 
standards within the industry. This includes replacing and upgrading existing assets as needed.

ITEM 3.  

LEGAL PROCEEDINGS.

We  are  involved  in  certain  legal  proceedings  before  various  courts,  governmental  agencies  and  mediation 
panels  concerning  matters  arising  in  the  ordinary  course  of  business.  These  proceedings  include  certain 
contract  disputes,  regulatory  matters  and  pending  judicial  matters.  We  cannot  predict  the  final  disposition  of 

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such  proceedings.  We  regularly  review  legal  matters  and  record  provisions  for  claims  that  are  considered 
probable of loss. 

Refer  to  Notes  6  and  18  to  the  consolidated  financial  statements  for  a  description  of  certain  pending  legal 

proceedings, which description is incorporated herein by reference. 

ITEM 4.   MINE SAFETY DISCLOSURES.

Not applicable.

PART II

ITEM 5. MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND 

ISSUER PURCHASES OF EQUITY SECURITIES.

ITC Holdings is a wholly-owned subsidiary of ITC Investment Holdings and ITC Holdings’ common stock is 

not publicly traded.

ITC Holdings paid dividends of $330 million and $250 million to our parent, ITC Investment Holdings, during 
the years ended December 31, 2020 and 2019, respectively. ITC Holdings also paid dividends of $58 million to 
ITC Investment Holdings in January 2021. The timing and amount of future dividends is subject to an approved 
dividend  declaration  from  our  Board  of  Directors,  and  is  dependent  upon  cash  flows,  capital  requirements, 
legislative and regulatory developments, and financial condition of ITC Holdings, among other factors deemed 
relevant.

ITEM 6.  

SELECTED FINANCIAL DATA.

Information  required  by  Item  6  of  Form  10-K  is  omitted  pursuant  to  the  SEC’s  adoption  of  amendments  to 

Regulation S-K effective February 10, 2021.

ITEM 7. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF 

OPERATIONS.

Safe Harbor Statement Under The Private Securities Litigation Reform Act of 1995

Our  reports,  filings  and  other  public  announcements  contain  certain  statements  that  describe  our 
management’s  beliefs  concerning  future  business  conditions,  plans  and  prospects,  growth  opportunities,  the 
outlook for our business and the electric transmission industry, and expectations with respect to various legal 
and regulatory proceedings based upon information currently available. Such statements are “forward-looking” 
statements within the meaning of the Private Securities Litigation Reform Act of 1995. Wherever possible, we 
have  identified  these  forward-looking  statements  by  words  such  as  “will,”  “may,”  “anticipates,”  “believes,” 
“intends,”  “estimates,”  “expects,”  “forecasted,”  “projects,”  “likely”  and  similar  phrases.  These  forward-looking 
statements  are  based  upon  assumptions  our  management  believes  are  reasonable.  Such  forward-looking 
statements  are  based  on  estimates  and  assumptions  and  subject  to  significant  risks  and  uncertainties  which 
could cause our actual results, performance and achievements to differ materially from those expressed in, or 
implied  by,  these  statements,  including,  among  others,  the  risks  and  uncertainties  listed  in  this  report  under 
“Item 1A Risk Factors” and in our other reports filed with the SEC from time to time.

Forward-looking statements speak only as of the date made and can be affected by assumptions we might 
make or by known or unknown risks and uncertainties. Many factors mentioned in our discussion in this report 
will  be  important  in  determining  future  results.  Consequently,  we  cannot  assure  you  that  our  expectations  or 
forecasts  expressed  in  such  forward-looking  statements  will  be  achieved.  Except  as  required  by  law,  we 
undertake no obligation to publicly update any of our forward-looking or other statements, whether as a result of 
new information, future events or otherwise.

Statement on Prior Period Comparisons

This section of this Form 10-K generally discusses the financial condition, changes in financial condition and 
results of operations for the years ended December 31, 2020 and 2019 and provides year-to-year comparisons 
between  the  years  ended  December  31,  2020  and  2019.  Discussions  of  such  information  for  the  year  ended 
December 31, 2018 and year-to-year comparisons between the years ended December 31, 2019 and 2018 that 
are  not  included  in  this  Form  10-K  can  be  found  in  “Management’s  Discussion  and  Analysis  of  Financial 

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Condition and Results of Operations” in Part II, Item 7 of the Company’s Annual Report on Form 10-K for the 
fiscal year ended December 31, 2019.

Overview

ITC  Holdings  and  its  subsidiaries  are  engaged  in  the  transmission  of  electricity  in  the  United  States.  ITC 
Holdings  is  a  wholly-owned  subsidiary  of  ITC  Investment  Holdings.  Through  our  Regulated  Operating 
Subsidiaries,  we  own  and  operate  high-voltage  electric  transmission  systems  in  Michigan’s  Lower  Peninsula 
and  portions  of  Iowa,  Minnesota,  Illinois,  Missouri,  Kansas  and  Oklahoma  that  transmit  electricity  from 
generating stations to local distribution facilities connected to our transmission systems. 

ITC Holdings provides safe and reliable electric transmission service to connect consumers to cleaner and 
more cost-effective energy resources. ITC Holdings is leading the way in making investments in a modernized 
grid  to  maintain  reliability  and  accommodate  future  demands  as  our  economy  and  lifestyles  become 
increasingly  dependent  on  electricity.  We  are  actively  involved  in  planning  an  integrated  energy  network  to 
serve our customers, communities and the greater grid.

Our  business  strategy  is  focused  on  owning,  operating,  maintaining  and  investing  in  transmission 
infrastructure  and  grid  solutions  in  order  to  enhance  system  reliability,  protect  critical  infrastructure,  reduce 
transmission  constraints,  interconnect  new  renewable  generation  resources,  expand  access  to  electricity 
markets and lower the overall cost of delivered energy. 

Our  Regulated  Operating  Subsidiaries  earn  revenues  for  the  use  of  their  electric  transmission  systems  by 
their  customers,  which  include  investor-owned  utilities,  municipalities,  cooperatives,  power  marketers  and 
alternative  energy  suppliers.  As  independent  transmission  companies,  our  Regulated  Operating  Subsidiaries 
are subject to rate regulation only by the FERC, and our cost-based rates are discussed below under “— Cost-
Based Formula Rates with True-Up Mechanism” as well as in Note 6 to the consolidated financial statements.

Our Regulated Operating Subsidiaries’ primary operating responsibilities include maintaining, improving and 
expanding their transmission systems to meet their customers’ ongoing needs, scheduling outages on system 
elements  to  allow  for  maintenance  and  construction,  maintaining  appropriate  system  voltages  and  monitoring 
flows over transmission lines and other facilities to ensure physical limits are not exceeded.

Significant recent matters that influenced our financial condition, results of operations and cash flows for the 

year ended December 31, 2020 or that may affect future results include:

• The outbreak of the COVID-19 pandemic that led to efforts to control the spread of the virus, which have 
resulted in impacts to businesses and facilities in various industries around the world, such as operating 
restrictions and closures, and disruptions to the global economy and supply chains;

• Our capital expenditures of $885 million at our Regulated Operating Subsidiaries during the year ended 
December  31,  2020,  as  described  below  under  “—  Capital  Investment  and  Operating  Results  Trends” 
resulted  primarily  from  our  focus  on  improving  system  reliability,  increasing  system  capacity  and 
upgrading  the  transmission  network  to  support  new  generating  resources,  which  included  electric 
transmission  asset  acquisitions  from  Consumers  Energy  of  $58  million,  of  which  $29  million  was  an 
acquisition premium that was excluded from rate base;

• Debt issuances, other borrowings and repayments as described in Note 10 to the consolidated financial 
statements  to  fund  capital  investment  at  our  Regulated  Operating  Subsidiaries  as  well  as  for  general 
corporate purposes;

• Issuance  of  the  May  2020  Order  related  to  the  MISO  ROE  Complaints,  as  described  in  Note  18  to  the 
consolidated financial statements, which reaffirmed the decision in the November 2019 Order to dismiss 
the Second Complaint and the revised methodology outlined in the November 2019 Order for determining 
the base ROE for the period of the Initial Complaint and the period subsequent to the September 2016 
Order; and

• Issuance of a NOPR by the FERC on March 20, 2020 that included a proposal to update the transmission 
incentives policy, among other things, to grant incentives to transmission projects based upon benefits to 
customers  ensuring  reliability  and  reducing  the  cost  of  delivered  power  by  reducing  transmission 

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congestion,  to  eliminate  the  ROE  adder  for  independent  transmission  ownership,  and  to  increase  the 
ROE adder for RTO participation.

These  items  are  discussed  in  more  detail  throughout  “Item  7  Management’s  Discussion  and  Analysis  of 

Financial Condition and Results of Operations.”

Cost-Based Formula Rates with True-Up Mechanism

Our Regulated Operating Subsidiaries calculate their revenue requirements using cost-based Formula Rates 
that  are  effective  without  the  need  to  file  rate  cases  with  the  FERC,  although  the  rates  are  subject  to  legal 
challenge  at  the  FERC.  Under  their  cost-based  formula,  each  of  our  Regulated  Operating  Subsidiaries 
separately  calculates  a  revenue  requirement  based  on  financial  information  specific  to  each  company.  The 
calculation of projected revenue requirement for a future period is used to establish the transmission rate used 
for billing purposes. The calculation of actual revenue requirements for a historic period is used to calculate the 
amount of revenues recognized in that period and determine the over- or under-collection for that period.

Under  these  Formula  Rates,  our  Regulated  Operating  Subsidiaries  recover  expenses  and  earn  an 
authorized return on and recover investments in property, plant and equipment on a current basis. The Formula 
Rates  for  a  given  year  reflect  forecasted  expenses,  property,  plant  and  equipment,  point-to-point  revenues, 
network load at our MISO Regulated Operating Subsidiaries and other items for the upcoming calendar year to 
establish projected revenue requirements for each of our Regulated Operating Subsidiaries that are used as the 
basis for billing for service on their systems from January 1 to December 31 of that year. Our Formula Rates 
include  a  true-up  mechanism,  whereby  our  Regulated  Operating  Subsidiaries  compare  their  actual  revenue 
requirements to their billed revenues for each year to determine any over- or under-collection of revenue. The 
over- or under-collection typically results from differences between the projected revenue requirement used as 
the basis for billing and actual revenue requirement at each of our Regulated Operating Subsidiaries, or from 
differences  between  actual  and  projected  monthly  network  peak  loads  at  our  MISO  Regulated  Operating 
Subsidiaries. In the event billed revenues in a given year are more or less than actual revenue requirements, 
which  are  calculated  primarily  using  information  from  that  year’s  FERC  Form  No.  1,  our  Regulated  Operating 
Subsidiaries  will  refund  or  collect  additional  revenues,  with  interest,  within  a  two-year  period  such  that 
customers  pay  only  the  amounts  that  correspond  to  actual  revenue  requirements  for  that  given  period.  This 
annual  true-up  ensures  that  our  Regulated  Operating  Subsidiaries  recover  their  allowed  costs  and  earn  their 
authorized returns.

See  “Cost-Based  Formula  Rates  with  True-Up  Mechanism”  in  Note  6  to  the  consolidated  financial 
statements for further discussion of our Formula Rates and see “Rate of Return on Equity Complaints” in Note 
18 to the consolidated financial statements for detail on ROE matters.

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Illustrative Example of Formula Rate Setting

The  Formula  Rate  setting  example  shown  below  is  for  illustrative  purposes  only  and  is  not  based  on  our 

actual financial data.

Line

1 Rate base (a)

Item

Instructions

2 Multiply by 13-month weighted average cost of capital (b)

3

Authorized return on rate base

(Line 1 x Line 2)

4 Recoverable operating expenses (including depreciation and 

amortization)

5

Income taxes (c)

6 Gross revenue requirement

____________________________

(Line 3 + Line 4 + Line 5)

Amount

1,000,000 

 8.46 %

84,600 

150,000 

37,500 

272,100 

$ 

$ 

$ 

$ 

(a) Consists primarily of in-service property, plant and equipment, net of accumulated depreciation.

(b) The weighted average cost of capital for purposes of this illustration is calculated below. The cost of capital 
for debt is included at a flat interest rate for purposes of this illustration and is not based on our actual cost 
of capital. The cost of capital rate for equity represents the current maximum allowed MISO ROE per the 
May 2020 Order on the Initial Complaint. See Note 18 to the consolidated financial statements for detail on 
ROE matters.

Debt
Equity

Percentage of
Total Capitalization
40.00%
60.00%
100.00%

Cost of Capital

5.00% =
10.77% =

Weighted
Average
Cost of
Capital
 2.00 %
 6.46 %
 8.46 %

(c) Represents an approximation of the federal and state income tax expense for purposes of this illustration 

and is not based on our actual tax expense.

Revenue Accruals and Deferrals — Effects of Monthly Peak Loads

For  our  MISO  Regulated  Operating  Subsidiaries,  monthly  network  peak  loads  are  used  for  billing  network 
revenues, which currently is the largest component of our operating revenues. One of the primary factors that 
impacts  the  revenue  accruals  and  deferrals  at  our  MISO  Regulated  Operating  Subsidiaries  is  actual  monthly 
network  peak  loads  experienced  as  compared  to  those  forecasted  in  establishing  the  annual  network 
transmission  rate.  Under  their  cost-based  Formula  Rates  that  contain  a  true-up  mechanism,  our  MISO 
Regulated Operating Subsidiaries accrue or defer revenues to the extent that their actual revenue requirement 
for the reporting period is higher or lower, respectively, than the amounts billed relating to that reporting period. 
Although  monthly  network  peak  loads  do  not  impact  operating  revenues  recognized,  network  load  affects  the 
timing  of  our  cash  flows  from  transmission  service.  The  monthly  network  peak  load  of  our  MISO  Regulated 
Operating Subsidiaries is generally impacted by weather and economic conditions and seasonally shaped with 
higher load in the summer months when cooling demand is higher.

ITC Great Plains does not receive revenue based on a peak load or a dollar amount per kW each month. 
Therefore, peak load does not have a seasonal effect on operating cash flows. The SPP tariff applicable to ITC 
Great Plains is billed ratably each month based on its annual projected revenue requirement posted annually by 
SPP.

Capital Investment and Operating Results Trends

We expect a long-term upward trend in rate base resulting from our anticipated capital investment, in excess 
of  depreciation  and  any  acquisition  premiums,  from  our  Regulated  Operating  Subsidiaries’  long-term  capital 
investment programs to improve reliability, increase system capacity and upgrade the transmission network to 
support new generating resources. Investments in property, plant and equipment, when placed in-service upon 
completion of a capital project, are added to the rate base of our Regulated Operating Subsidiaries. While we 
expect increases in rate base to result in a corresponding long-term upward trend in revenues and earnings, our 

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revenues  and  earnings  are  also  impacted  by  changes  in  our  ROE  or  required  refunds  resulting  from  the 
resolution of the incentive adders complaints and MISO ROE Complaints, as described in Note 6 and Note 18 
to the consolidated financial statements, or other future increases or decreases to our rates for incentive adders 
and base ROE.

Our Regulated Operating Subsidiaries strive for high reliability of their systems and improvement in system 
accessibility for all generation resources. The FERC requires compliance with certain reliability standards and 
may  take  enforcement  actions  against  violators,  including  the  imposition  of  substantial  fines.  NERC  is 
responsible  for  developing  and  enforcing  these  mandatory  reliability  standards.  We  continually  assess  our 
transmission systems against standards established by NERC, as well as the standards of applicable regional 
entities  under  NERC  that  have  been  delegated  certain  authority  for  the  purpose  of  proposing  and  enforcing 
reliability standards. We believe that we meet the applicable standards in all material respects, although further 
investment  in  our  transmission  systems  and  an  increase  in  maintenance  activities  will  likely  be  needed  to 
maintain compliance, improve reliability and address any new standards that may be promulgated.

We also assess our transmission systems against our own planning criteria that are filed annually with the 
FERC. Based on our planning studies, we see needs to make capital investments to: (1) maintain and replace 
our current transmission infrastructure including enhancing system integrity and reliability and accommodating 
load  growth;  (2)  upgrade  physical  and  technological  grid  security;  (3)  promote  the  transformation  of  the 
generation fleet to cleaner and more sustainable resources through required interconnections and transmission 
build-out;  and  (4)  develop  and  build  regional  transmission  infrastructure.  We  do  not  currently  expect  any 
material decrease in planned capital expenditures due to COVID-19; however, we continue to evaluate potential 
impacts  of  COVID-19  on  our  forecasted  capital  expenditures.  Depending  on  the  length  and  severity  of  future 
impacts  of  COVID-19,  certain  planned  capital  expenditures  may  be  shifted  to  later  years  of  the  forecast. The 
following table shows our actual and expected capital expenditures at our Regulated Operating Subsidiaries:

Actual Capital

Forecasted

Expenditures for the 

Capital

year ended 

Expenditures

(In millions of USD)

Expenditures for property, plant and equipment (a)

____________________________

December 31, 2020
$ 

885  $ 

2021 — 2025
3,864 

(a) Amounts represent the cash payments to acquire or construct property, plant and equipment, as presented 
in the consolidated statements of cash flows. These amounts exclude non-cash additions to property, plant 
and equipment for the AFUDC equity as well as accrued liabilities for construction, labor and materials that 
have not yet been paid.

Our long-term growth plan includes ongoing investments in our current regulated transmission systems and 
the identification of incremental strategic projects primarily located in and around our service territories. Refer to 
“Item 1 Business — Development of Business” for additional information.

Investments  in  property,  plant  and  equipment  could  be  lower  than  expected  due  to  a  variety  of  factors,  as 
discussed  in  “Item  1A  Risk  Factors”.  In  addition,  investments  in  transmission  network  upgrades  for  generator 
interconnection projects could change from prior estimates significantly due to changes in the MISO queue for 
generation projects and other factors beyond our control.

Recent Developments

COVID-19 Pandemic

In  March  2020,  the  World  Health  Organization  declared  COVID-19  a  pandemic.  Efforts  to  control  the 
outbreak  of  COVID-19  have  resulted  in  impacts  to  businesses  and  facilities  in  various  industries  around  the 
world,  such  as  operating  restrictions  and  closures,  and  disruptions  to  the  global  economy  and  supply  chains. 
The COVID-19 pandemic has and will continue to impact our customers throughout our operating footprint. To 
date,  COVID-19  has  not  had  a  material  impact  on  our  net  income.  However,  we  have  implemented  various 
temporary cost saving measures related to operating expenses, including operation and maintenance expenses 
and  general  and  administrative  expenses,  in  an  attempt  to  reduce  costs  that  are  collected  from  customers 
through our Formula Rates.

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The total impact on our operations from COVID-19 is unknown at this time and will ultimately depend on the 
duration and severity of the pandemic, the length that the various business restrictions are in effect, the impact 
of recent resurgences of COVID-19 cases and deaths in the United States, and the efficacy and distribution of 
COVID-19  vaccines.  We  are  continuing  to  monitor  developments  involving  our  workforce,  customers  and 
suppliers  and  cannot  predict  whether  COVID-19  will  have  a  material  impact  on  our  consolidated  results  of 
operations, cash flows or financial condition. We are also monitoring the evolving situation and guidance from 
federal, state and local public health authorities. We are taking steps to mitigate the potential risks to us and our 
employees  posed  by  COVID-19,  including  enabling  remote  work  arrangements  for  employees  when 
appropriate, and are following all government requirements to reduce the transmission of COVID-19.

Monthly Network Peak Load

For  our  MISO  Regulated  Operating  Subsidiaries,  monthly  network  peak  loads  are  used  for  billing  network 
revenues, which currently is the largest component of our operating revenues. One of the primary factors that 
impacts  our  collection  of  revenues  is  actual  monthly  network  peak  load,  which  is  impacted  by  a  number  of 
factors  including  network  usage  and  weather.  Although  monthly  network  peak  loads  do  not  impact  our 
recognition  of  operating  revenues,  actual  network  load  affects  the  timing  of  collection  of  our  cash  flows  from 
transmission  service.  During  2020,  actual  monthly  network  peak  load  for  our  MISO  Regulated  Operating 
Subsidiaries decreased compared to pre-COVID-19 forecasted load. This decrease was primarily as a result of 
reductions in, or suspension of, operations for many businesses and facilities in our operating footprint due to 
COVID-19.  While  the  decrease  in  monthly  network  peak  load  was  significant  in  the  early  months  of  the 
pandemic, the impact of COVID-19 on monthly network peak loads became less pronounced over the second 
half of the year. We are unable to predict the possible future impacts of COVID-19, weather and other factors on 
monthly network peak loads at our MISO Regulated Operating Subsidiaries.

Liquidity and Access to Capital Markets

The COVID-19 pandemic has caused a disruption in capital markets and has resulted in periods of limited 
access  to  certain  types  of  funding  in  the  United  States,  including  borrowings  on  commercial  paper  programs. 
We  rely  on  both  internal  and  external  sources  of  liquidity  to  provide  working  capital  and  fund  capital 
investments. During 2020, we were able to successfully access the capital markets to satisfy our liquidity needs. 
However,  if  further  disruption  to  the  capital  markets  occurs  due  to  the  COVID-19  pandemic,  we  may  have 
limited access to capital markets and encounter increased borrowing costs.

Rate of Return on Equity Complaints

Two  complaints  were  filed  with  the  FERC  by  combinations  of  consumer  advocates,  consumer  groups, 
municipal  parties  and  other  parties  challenging  the  base  ROE  in  MISO.  In  addition  to  the  MISO  ROE 
Complaints, complaints were filed with the FERC regarding the regional base ROE rate for ISO New England 
TOs.  See  Note  18  to  the  consolidated  financial  statements  for  a  summary  of  the  MISO  ROE  Complaints  and 
related proceedings.

Related FERC Orders

In April  2017,  the  D.C.  Circuit  Court  vacated  certain  precedent-setting  FERC  orders  that  established  and 
applied the two-step DCF methodology for the determination of base ROE for ISO New England TOs. The court 
remanded the orders to the FERC for further justification of its establishment of the new base ROE for the ISO 
New  England TOs. The  vacated  orders  in  the  ISO  New  England  matters  also  provided  the  precedent  for  the 
September  2016  Order  on  the  Initial  Complaint  and  the ALJ  initial  decision  on  the  Second  Complaint  for  our 
MISO Regulated Operating Subsidiaries. On October 16, 2018, in the New England matters, the FERC issued 
an order on remand which proposed a new methodology for 1) determining when an existing ROE is no longer 
just and reasonable; and 2) setting a new just and reasonable ROE if an existing ROE has been found not to be 
just and reasonable.

The FERC issued a similar order, the November 2018 Order, in the MISO ROE Complaints, establishing a 
paper  hearing  on  the  application  of  the  proposed  new  methodology  to  the  proceedings  pending  before  the 
FERC  involving  the  ROE  of  the  MISO  TOs,  including  our  MISO  Regulated  Operating  Subsidiaries.  The 
November  2018  Order  included  illustrative,  non-binding  calculations  for  the  ROE  that  could  have  been 
established for the Initial Complaint using the FERC's proposed methodology. The November 2018 Order and 
our response to the order through briefs and reply briefs did not provide a reasonable basis for a change to the 
reserve or ROEs utilized for any of the complaint refund periods nor all subsequent periods.

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November 2019 Order

On November 21, 2019, the FERC issued an order on the MISO ROE Complaints. The FERC did not adopt 
the  methodology  proposed  in  the  November  2018  Order,  but  rather  applied  a  methodology  to  the  Initial 
Complaint  period  that  used  two  financial  models  to  determine  the  base  ROE. The  FERC  determined  that  the 
base ROE for the Initial Complaint should be 9.88% and the top of the range of reasonableness for that period 
should be 12.24% and that this base ROE should apply during the first refund period of November 12, 2013 to 
February 11, 2015 and from the date of the September 2016 Order prospectively. In the November 2019 Order, 
the  FERC  also  dismissed  the  Second  Complaint.  Therefore,  based  on  the  November  2019  Order,  for  the 
Second  Complaint  refund  period  from  February  12,  2015  to  May  11,  2016,  no  refund  is  due. As  a  result,  we 
reversed  the  aggregate  estimated  current  liability  we  had  previously  recorded  for  the  Second  Complaint,  as 
noted below in “Financial Statement Impacts”. In addition, for the period from May 12, 2016 to September 27, 
2016, no refund is due because no complaint had been filed for that period. The FERC ordered refunds to be 
made  in  accordance  with  the  November  2019  Order  and,  on  December  18,  2019,  the  FERC  granted  an 
extension until December 23, 2020 for settlement of the refunds. The MISO TOs, including our MISO Regulated 
Operating Subsidiaries, and several other parties filed requests for rehearing of the November 2019 Order. The 
MISO TOs filed their request for rehearing primarily on the basis that the methodology applied by the FERC in 
the November 2019 Order does not allow the MISO TOs to earn a reasonable rate of return on their investment, 
as  required  by  precedent.  On  January  21,  2020,  the  FERC  issued  an  order  granting  rehearing  for  further 
consideration.

May 2020 Order

On May 21, 2020, the FERC issued an order on rehearing of the November 2019 Order. In this order, the 
FERC  revised  its  November  2019  Order  methodology,  finding  that  three  financial  models  should  be  used  to 
determine the base ROE, among other revisions. By applying the new methodology, FERC determined that the 
base ROE for the Initial Complaint should be 10.02% and the top of the range of reasonableness for that period 
should  be  12.62%.  The  FERC  determined  that  this  base  ROE  should  apply  during  the  first  refund  period  of 
November 12, 2013 to February 11, 2015 and from the date of the September 2016 Order prospectively. The 
FERC  ordered  refunds  to  be  made  in  accordance  with  the  May  2020  Order  by  December  23,  2020,  and  on 
October  8,  2020,  the  FERC  granted  an  extension  to  September  23,  2021.  In  the  May  2020  Order,  the  FERC 
also reaffirmed its decision to dismiss the Second Complaint and its finding that no refunds would be ordered on 
the  Second  Complaint.  Our  MISO  Regulated  Operating  Subsidiaries  are  parties  to  multiple  appeals  of  the 
September 2016 Order, November 2019 Order and May 2020 Order at the D.C. Circuit Court.

Financial Statement Impacts

As  of  December  31,  2020,  we  had  recorded  an  aggregate  current  regulatory  asset  and  current  regulatory 
liability of $8 million and $13 million, respectively, and as of December 31, 2019, we had recorded an aggregate 
current  regulatory  liability  of  $70  million  in  the  consolidated  statements  of  financial  position.  These  impacts 
reflect  amounts  owed  from  or  due  to  customers  under  the  terms  outlined  in  the  May  2020  Order  and  the 
November  2019  Order  on  the  Initial  Complaint  and  the  periods  subsequent  to  the  September  2016  Order. 
During the year ended December 31, 2020, we refunded $31 million of the regulatory liability to customers. We 
had  recorded  an  aggregate  estimated  current  regulatory  liability  in  the  consolidated  statements  of  financial 
position of $151 million as of December 31, 2018 for the Second Complaint, which was reversed in November 
2019 following the November 2019 Order. Although the November 2019 Order and May 2020 Order dismissed 
the Second Complaint with no refunds required, it is possible upon appeal that our MISO Regulated Operating 
Subsidiaries  will  be  required  to  provide  refunds  related  to  the  Second  Complaint  and  these  refunds  could  be 
material.

Our  MISO  Regulated  Operating  Subsidiaries  currently  record  revenues  at  the  base  ROE  of  10.02% 
established in the May 2020 Order plus applicable incentive adders. See Note 6 to the consolidated financial 
statements for a summary of incentive adders for transmission rates.

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The  recognition  of  the  obligations  associated  with  the  MISO  ROE  Complaints  resulted  in  the  following 

impacts to the consolidated statements of comprehensive income:

(In millions of USD)

Revenue increase

Interest expense (decrease) increase

Estimated net income increase (decrease)

Year Ended December 31,

2020

2019

2018

$ 

32  $ 

(3)   

25 

69  $ 

(12)   

61 

1 

7 

(4) 

As  of  December  31,  2020,  our  MISO  Regulated  Operating  Subsidiaries  had  a  total  of  approximately  $5 
billion of equity in their collective capital structures for ratemaking purposes. Based on this level of aggregate 
equity, we estimate that each 10 basis point change in the authorized ROE would impact annual consolidated 
net income by approximately $5 million.

Challenges to Incentive Adders for Transmission Rates

On March 20, 2020, the FERC issued a NOPR including a proposal to update the transmission incentives 
policy  to  grant  incentives  to  transmission  projects  based  upon  benefits  to  customers.  The  outcome  of  this 
proposal may impact the incentive adders that our Regulated Operating Subsidiaries are authorized to apply to 
their base ROEs on a prospective basis. See Note 6 to the consolidated financial statements for a summary of 
incentive adders for transmission rates.

MISO Regulated Operating Subsidiaries

On April 20, 2018, Consumers Energy, IP&L, Midwest Municipal Transmission Group, Missouri River Energy 
Services,  Southern  Minnesota  Municipal  Power  Agency  and  WPPI  Energy  filed  a  complaint  with  the  FERC 
under section 206 of the FPA, challenging the adders for independent transmission ownership that are included 
in  transmission  rates  charged  by  the  MISO  Regulated  Operating  Subsidiaries.  The  adders  for  independent 
transmission ownership allowed up to 50 basis points or 100 basis points to be added to the MISO Regulated 
Operating  Subsidiaries’  authorized  ROE,  subject  to  any  ROE  cap  established  by  the  FERC.  On  October  18, 
2018,  the  FERC  issued  an  order  granting  the  complaint  in  part,  setting  revised  adders  for  independent 
transmission  ownership  for  each  of  the  MISO  Regulated  Operating  Subsidiaries  to  25  basis  points,  and 
requiring the MISO Regulated Operating Subsidiaries to include the revised adders, effective April 20, 2018, in 
their  Formula  Rates.  In  addition,  the  order  directed  the  MISO  Regulated  Operating  Subsidiaries  to  provide 
refunds,  with  interest,  for  the  period  from  April  20,  2018  through  October  18,  2018.  The  MISO  Regulated 
Operating  Subsidiaries  began  reflecting  the  25  basis  point  adder  for  independent  transmission  ownership  in 
transmission rates in November 2018. Refunds of $7 million were primarily made in the fourth quarter of 2018 
and were completed in the first quarter of 2019. The MISO Regulated Operating Subsidiaries sought rehearing 
of  the  FERC’s  October  18,  2018  order,  and  on  July  18,  2019,  the  FERC  denied  the  rehearing  request.  On 
September  11,  2019,  the  MISO  Regulated  Operating  Subsidiaries  filed  an  appeal  of  the  FERC’s  order  in  the 
D.C.  Circuit  Court.  On  December  16,  2019,  the  D.C.  Circuit  Court  established  a  briefing  schedule  for  the 
appeal.  An  initial  brief  was  filed  on  January  27,  2020  and  a  reply  brief  was  filed  on  April  24,  2020.  Oral 
argument  on  the  appeal  was  held  on  September  23,  2020.  We  do  not  expect  the  final  resolution  of  this 
proceeding to have a material adverse impact on our consolidated results of operations, cash flows or financial 
condition.

ITC Great Plains

On June 11, 2019, KCC filed a complaint with the FERC under section 206 of the FPA, challenging the ROE 
adder for independent transmission ownership that is included in the transmission rate charged by ITC Great 
Plains.  The  complaint  argues  that  because  ITC  Great  Plains  is  similarly  situated  to  our  MISO  Regulated 
Operating  Subsidiaries  with  respect  to  ownership  by  Fortis  and  GIC,  the  same  rationale  by  which  the  FERC 
lowered  the  MISO  Regulated  Operating  Subsidiaries  adders  for  independent  transmission  ownership,  as 
discussed above, also applies to ITC Great Plains. The adder for independent transmission ownership allowed 
up  to  100  basis  points  to  be  added  to  the  ITC  Great  Plains  authorized  ROE,  subject  to  any  ROE  cap 
established by the FERC. ITC Great Plains filed an answer to the complaint on July 1, 2019 asking the FERC 
to deny the complaint since KCC showed no evidence that ITC Great Plains’ independence or the benefits they 
provide as an independent TO has been compromised or reduced as a result of the Fortis and GIC acquisition. 
On July 16, 2020, the FERC issued an order granting the complaint, setting the revised adder for independent 

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transmission ownership for ITC Great Plains to 25 basis points, and requiring ITC Great Plains to include the 
revised adder, effective June 11, 2019, in their Formula Rates. In addition, the order directed ITC Great Plains 
to provide refunds, with interest, for the period from June 11, 2019 through July 16, 2020 within 60 days of the 
date of the order. On September 15, 2020, the FERC granted an extension to issue refunds until November 19, 
2020. On August 17, 2020, ITC Great Plains filed a request for rehearing of the order and on September 17, 
2020, the FERC denied the rehearing request. On November 12, 2020, ITC Great Plains filed an appeal of the 
July 16, 2020 order, and on December 14, 2020, ITC Great Plains filed an appeal of the September 17, 2020 
order,  both  of  which  were  filed  in  the  D.C.  Circuit  Court.  As  of  December  31,  2019,  we  had  recorded  an 
estimated current regulatory liability of $2 million related to this complaint and during 2020 refunds of $4 million 
were  made  to  settle  the  refund  liability.  We  do  not  expect  the  final  resolution  of  this  proceeding  to  have  a 
material adverse impact on our consolidated results of operations, cash flows or financial condition.

Significant Components of Results of Operations

Revenues

We derive nearly all of our revenues from providing transmission, scheduling, control and dispatch services 
and  other  related  services  over  our  Regulated  Operating  Subsidiaries’  transmission  systems  to  DTE  Electric, 
Consumers Energy, IP&L and other entities, such as alternative energy suppliers, power marketers and other 
wholesale customers that provide electricity to end-use consumers, as well as from transaction-based capacity 
reservations on our transmission systems. MISO and SPP are responsible for billing and collecting the majority 
of transmission service revenues. As the billing agents for our MISO Regulated Operating Subsidiaries and ITC 
Great  Plains,  MISO  and  SPP  collect  fees  for  the  use  of  our  transmission  systems,  invoicing  DTE  Electric, 
Consumers Energy, IP&L and other customers on a monthly basis.

Network Revenues are generated from network customers for their use of our electric transmission systems 
and are based on the actual revenue requirements as a result of our accounting under our cost-based Formula 
Rates that contain a true-up mechanism. Refer below under “— Critical Accounting Policies and Estimates — 
Revenue Recognition under Cost-Based Formula Rates with True-Up Mechanism” for a discussion of revenue 
recognition relating to network revenues.

Network revenues from ITC Great Plains include the annual revenue requirements specific to projects that 
are  charged  exclusively  within  one  pricing  zone  within  SPP  or  are  classified  as  direct  assigned  network 
upgrades under the SPP tariff and contain a true-up mechanism.

Regional Cost Sharing Revenues are generated from transmission customers throughout RTO regions for 
their use of our MISO Regulated Operating Subsidiaries’ network upgrade projects that are eligible for regional 
cost  sharing  under  provisions  of  the  MISO  tariff,  including  MVPs.  Additionally,  certain  projects  at  ITC  Great 
Plains are eligible for recovery through a region-wide charge under provisions of the SPP tariff. Regional cost 
sharing  revenues  are  treated  as  a  reduction  to  the  net  network  revenue  requirement  under  our  cost-based 
Formula Rates.

Point-to-Point Revenues consist of revenues generated from a type of transmission service for which the 
customer pays for transmission capacity reserved along a specified path between two points on an hourly, daily, 
weekly or monthly basis. Point-to-point revenues also include other components pursuant to schedules under 
the  MISO  and  SPP  transmission  tariffs.  Point-to-point  revenues  are  treated  as  a  revenue  credit  to  network  or 
regional  customers  and  are  a  reduction  to  gross  revenue  requirement  when  calculating  net  revenue 
requirement under our cost-based Formula Rates.

Scheduling, Control and Dispatch Revenues are allocated to our MISO Regulated Operating Subsidiaries 
by  MISO  as  compensation  for  the  services  performed  in  operating  the  transmission  system.  Such  services 
include  monitoring  of  reliability  data,  current  and  next  day  analysis,  implementation  of  emergency  procedures 
and outage coordination and switching.

Other  Revenues  consist  of  rental  revenues,  easement  revenues,  revenues  relating  to  utilization  of  jointly 
owned  assets  under  our  transmission  ownership  and  operating  agreements  and  amounts  from  providing 
ancillary services to customers. The majority of other revenues are treated as a revenue credit and taken as a 
reduction  to  gross  revenue  requirement  when  calculating  net  revenue  requirement  under  our  cost-based 
Formula Rates.

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Operating Expenses

Operation  and  Maintenance  Expenses  consist  primarily  of  the  costs  for  contractors  that  operate  and 

maintain our transmission systems as well as our personnel involved in operation and maintenance activities.

Operation expenses include activities related to control area operations, which involve balancing loads and 
generation  and  transmission  system  operations  activities,  including  monitoring  the  status  of  our  transmission 
lines  and  stations.  Rental  expenses  relating  to  land  easements,  including  METC’s  Easement Agreement,  are 
also recorded within operation expenses.

Maintenance  expenses  include  preventive  or  planned  activities,  such  as  vegetation  management,  tower 

painting and equipment inspections, as well as reactive maintenance for equipment failures.

General  and  Administrative  Expenses  consist  primarily  of  costs  for  personnel  in  our  legal,  information 
technology,  finance,  regulatory,  human  resources,  community  relations  and  communication  functions,  general 
office  expenses  and  fees  for  professional  services.  Professional  services  are  principally  composed  of  outside 
legal, consulting, audit and information technology services.

Depreciation  and  Amortization  Expenses  consist  primarily  of  depreciation  of  property,  plant  and 
equipment  using  the  straight-line  method  of  accounting.  Additionally,  this  consists  of  amortization  of  various 
regulatory and intangible assets.

Taxes Other than Income Taxes consist primarily of property taxes and payroll taxes.

Other Items of Income or Expense

Interest  Expense  consists  primarily  of  interest  on  debt  at  ITC  Holdings  and  our  Regulated  Operating 
Subsidiaries. Additionally, the amortization of debt financing expenses and loss on extinguishment of debt are 
recorded to interest expense. An allowance for borrowed funds used during construction is included in property, 
plant  and  equipment  accounts  and  treated  as  a  reduction  to  interest  expense. The  amortization  of  gains  and 
losses on settled and  terminated derivative  financial  instruments is recorded to interest expense. The interest 
portion of the refunds relating to the MISO ROE Complaints is also recorded to interest expense.

Allowance  for  Equity  Funds  Used  During  Construction  (“AFUDC  equity”)  is  recorded  as  an  item  of 
other income and is included in property, plant and equipment accounts. The allowance represents a return on 
equity  at  our  Regulated  Operating  Subsidiaries  used  for  construction  purposes  in  accordance  with  the  FERC 
regulations.  The  capitalization  rate  applied  to  the  construction  work  in  progress  balance  is  based  on  the 
proportion  of  equity  to  total  capital  (which  currently  includes  equity  and  long-term  debt)  and  the  authorized 
return on equity for our Regulated Operating Subsidiaries.

Income Tax Provision

Income tax provision consists of current and deferred federal and state income taxes.

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Results of Operations

The following table summarizes historical operating results for the periods indicated:

(In millions of USD)

OPERATING REVENUES

Year Ended
December 31,

2020

2019

Increase
(Decrease)

Percentage
Increase
(Decrease)

Year Ended
December 31,
2018

Increase
(Decrease)

Percentage
Increase
(Decrease)

Transmission and other services

$ 

1,290  $ 

1,286  $ 

Formula Rate true-up

Total operating revenue

OPERATING EXPENSES

Operation and maintenance

General and administrative

Depreciation and amortization

Taxes other than income taxes

Other operating (income) and 

expenses, net

Total operating expenses

OPERATING INCOME

OTHER EXPENSES (INCOME)

Interest expense, net

Allowance for equity funds used during 

construction

Other (income) and expenses, net

Total other expenses (income)

INCOME BEFORE INCOME TAXES

INCOME TAX PROVISION

8 

1,298 

41 

1,327 

87 

115 

219 

124 

— 

545 

753 

240 

(27) 

(3) 

210 

543 

136 

113 

138 

203 

118 

— 

572 

755 

224 

(29) 

— 

195 

560 

132 

4 

(33) 

(29) 

(26) 

(23) 

16 

6 

— 

(27) 

(2) 

16 

2 

(3) 

15 

(17) 

4 

 — % $ 

1,192  $ 

 (80) %  

 (2) %  

(36) 

1,156 

 (23) %  

 (17) %  

 8 %  

 5 %  

n/a  

 (5) %  

 — %  

109 

127 

180 

109 

(4) 

521 

635 

 7 %  

224 

 (7) %  

n/a  

 8 %  

 (3) %  

 3 %  

(33) 

3 

194 

441 

111 

NET INCOME

$ 

407  $ 

428  $ 

(21) 

 (5) % $ 

330  $ 

Operating Revenues

94 

77 

171 

4 

11 

23 

9 

4 

51 

120 

— 

4 

(3) 

1 

119 

21 

98 

 8 %

 (214) %

 15 %

 4 %

 9 %

 13 %

 8 %

 (100) %

 10 %

 19 %

 — %

 (12) %

 (100) %

 1 %

 27 %

 19 %

 30 %

Year ended December 31, 2020 compared to year ended December 31, 2019 

The  following  table  sets  forth  the  components  of  and  changes  in  operating  revenues  for  the  year  ended 
December  31,  2020  and  2019  which  included  revenue  accruals  and  deferrals  in  Note  6  to  the  consolidated 
financial statements:

2020

2019

Amount

Percentage

Amount

Percentage

Increase
(Decrease)

Percentage
Increase
(Decrease)

(In millions of USD)

Network revenues (a)

Regional cost sharing revenues (a)

Point-to-point

Scheduling, control and dispatch (a)

Other

Recognition of net liabilities for MISO 

ROE Complaints

$ 

852 

362 

13 

20 

19 

32 

 66 % $ 

 28 %  

 1 %  

 2 %  

 1 %  

 2 %  

836 

371 

13 

17 

21 

69 

 63 % $ 

 28 %  

 1 %  

 1 %  

 2 %  

 5 %  

Total

$  1,298 

 100 % $  1,327 

 100 % $ 

____________________________

16 

(9) 

— 

3 

(2) 

(37) 

(29) 

 2 %

 (2) %

 — %

 18 %

 (10) %

 (54) %

 (2) %

(a) Includes a portion of the Formula Rate true-up of $8 million and $41 million for the year ended December 

31, 2020 and 2019, respectively.

Operating revenues decreased during the year ended December 31, 2020, compared to the same period in 
2019, primarily due to differences in the amount of adjustments that were made in each period to the net refund 
liabilities recorded related to the MISO ROE Complaints, as described in Note 18 to the consolidated financial 

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statements. The adjustments resulted in a net increase in operating revenues of $32 million for the year ended 
December 31, 2020, compared to an increase in operating revenues of $69 million for the year ended 2019. 

Excluding the impact of the adjustments for the MISO ROE Complaints, operating revenues increased due to 
a  higher  rate  base  associated  with  higher  balances  of  property,  plant  and  equipment  in  service  for  the  year 
ended  December  31,  2020,  compared  to  the  same  period  in  2019.  The  increase  was  partially  offset  by  cost 
saving  measures  that  were  implemented  as  a  result  of  the  COVID-19  pandemic,  which  resulted  in  lower 
revenue requirements to customers as these costs are recovered through rates.

Operating Expenses

Operation and maintenance expenses

Year ended December 31, 2020 compared to year ended December 31, 2019

Operation and maintenance expense decreased primarily due to lower expenses associated with substation 
and overhead line maintenance activities and vegetation management resulting from the temporary cost saving 
measures that were implemented in response to the COVID-19 pandemic.

General and administrative expenses

Year ended December 31, 2020 compared to year ended December 31, 2019

General  and  administrative  expenses  decreased  due  to  reduced  general  business  expenses  of  $4  million 
and  professional  advisory  services  of  $7  million  primarily  resulting  from  the  temporary  cost  saving  measures 
that  were  implemented  in  response  to  the  COVID-19  pandemic.  The  decrease  was  also  due  to  lower 
compensation-related  expenses,  primarily  due  to  a  decrease  in  share-based  compensation  expense  of 
$7 million.

Depreciation and amortization expenses

Year ended December 31, 2020 compared to year ended December 31, 2019

Depreciation and amortization expenses increased primarily due to a higher depreciable base resulting from 

property, plant and equipment in-service additions. 

Other Expenses (Income)

Interest Expense, Net

Year ended December 31, 2020 compared to year ended December 31, 2019

Interest expense, net increased due to a decrease in the amount of reversals of interest expense recorded in 
2020, as compared to the amount recorded in 2019, pursuant to FERC orders on the MISO ROE Complaints, 
as described in Note 18 to the consolidated financial statements. Interest expense, net also increased due to 
higher debt balances and higher amortization of interest as a result of losses on interest rate swaps terminated 
in 2020, as discussed in Note 10 to the consolidated financial statements.

Income Tax Provision

Year ended December 31, 2020 compared to year ended December 31, 2019

Our  effective  tax  rates  for  the  years  ended  December  31,  2020  and  2019  were  25.0%  and  23.6%, 
respectively.  Our  effective  tax  rate  as  of  December  31,  2020  exceeded  our  21%  statutory  federal  income  tax 
rate primarily due to state income taxes, partially offset by AFUDC equity. The amount of income tax expense 
relating to AFUDC equity was recognized as a regulatory asset and is not included in the income tax provision. 
See Note 11 to the consolidated financial statements for further discussion regarding our income tax provision. 

Liquidity and Capital Resources

We expect to maintain our approach of funding our future capital requirements with cash from operations at 
our  Regulated  Operating  Subsidiaries,  our  existing  cash  and  cash  equivalents,  future  issuances  under  our 
commercial  paper  program  and  amounts  available  under  our  revolving  credit  agreements  (the  terms  of  which 
are described in Note 10 to the consolidated financial statements). In addition, we may from time to time secure 
debt  funding  in  the  capital  markets,  although  we  can  provide  no  assurance  that  we  will  be  able  to  obtain 
financing on favorable terms or at all. As market conditions warrant, we may also from time to time repurchase 

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debt  securities  issued  by  us,  in  the  open  market,  in  privately  negotiated  transactions,  by  tender  offer  or 
otherwise. We expect that our capital requirements will arise principally from our need to:

• Fund  capital  expenditures  (including  purchase  commitments  as  described  in  Note  18)  at  our  Regulated 
Operating Subsidiaries. Our plans with regard to property, plant and equipment investments are described 
in detail above under “— Capital Investment and Operating Results Trends.”

• Fund our debt service requirements, including principal repayments and periodic interest payments, which 

are further described in detail below.

• Fund working capital requirements.

In addition to the expected capital requirements above, any adverse determinations or settlements relating to 
the  regulatory  matters  or  contingencies  described  in  Notes  6  and  18  to  the  consolidated  financial  statements 
would result in additional capital requirements. 

We  believe  that  we  have  sufficient  capital  resources  to  meet  our  currently  anticipated  short-term  needs. 
However, we rely on both internal and external sources of liquidity to provide working capital and fund capital 
investments. The COVID-19 pandemic has impacted the global economy and capital markets in various ways, 
including  negative  impacts  which  have  varied  in  duration  and  magnitude.  An  extended  period  of  economic 
disruption  could  impact  our  ability  to  access  the  capital  markets  requiring  us  to  seek  alternative  forms  of 
financing which could negatively impact our liquidity and capital resources. ITC Holdings’ sources of cash are 
dividends and other payments received by us from our Regulated Operating Subsidiaries and any of our other 
subsidiaries  as  well  as  the  proceeds  raised  from  the  sale  of  our  debt  securities.  Each  of  our  Regulated 
Operating Subsidiaries, while wholly-owned by ITC Holdings, is legally distinct from ITC Holdings and has no 
obligation, contingent or otherwise, to make funds available to us.

We expect to continue to utilize our commercial paper program and revolving credit agreements as well as 
our cash and cash equivalents as needed to meet our short-term cash requirements. As of December 31, 2020, 
we had consolidated indebtedness under our revolving credit agreements of $198 million, with unused capacity 
under our revolving credit agreements of $702 million. ITC Holdings had $67 million of commercial paper issued 
and outstanding, net of discount, as of December 31, 2020, with the ability to issue an additional $333 million 
under the commercial paper program. In 2020, we paid $9 million of interest and commitment fees under our 
revolving and term loan credit agreements and commercial paper program.

To address our future capital requirements, we expect that we will need to obtain additional long-term debt 
financing. As of December 31, 2020, we had various notes and bonds outstanding with terms, including fixed 
interest  rate  and  principal  payment  terms,  specific  to  each  borrowing.  Maturity  dates  for  these  long-term  debt 
issuances  range  from  2022  to  2055.  Total  future  interest  payment  obligations  associated  with  these  existing 
fixed-rate, long-term debt obligations were $4 billion as of December 31, 2020, with expected interest payment 
obligations of $240 million due within the next twelve months. Certain of our capital projects could be delayed if 
we  experience  difficulties  in  accessing  capital  pursuant  to  complications  from  COVID-19,  or  otherwise.  We 
expect  to  be  able  to  obtain  such  additional  financing  as  needed,  in  amounts  and  upon  terms  that  will  be 
acceptable to us due to our strong credit ratings and our historical ability to obtain financing. See Note 10 to the 
consolidated financial statements for a detailed discussion of our debt activity, including the commercial paper 
program and our term loan and revolving credit agreements, during the years ended December 31, 2020 and 
2019.

METC has a contractual obligation through December 31, 2050 for an Easement Agreement for transmission 
purposes and rights-of-way, leasehold interests, fee interests and licenses associated with the land over which 
the  transmission  lines  cross.  The  cost  for  use  of  the  rights-of-way  is  $10  million  per  year.  See  Note  18  for 
additional details related to the easement.

We  have  certain  obligations  including  contingent  liabilities  and  other  current  and  long-term  liabilities,  that 
have uncertainty regarding the timing and any amount of future cash flows necessary to settle these obligations. 
Such items include:

•

•

•

long-term incentive awards; 

pension and other postretirement obligations;

regulatory liabilities related to asset removal costs and refundable income taxes; and

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•

liabilities to refund deposits from generators for transmission network upgrades.

We have material exposure to LIBOR through the revolving credit agreements of ITC Holdings and certain of 
our Regulated Operating Subsidiaries. It is expected that LIBOR will be phased out beginning in late 2021. We 
believe that SOFR, the rate selected as the preferred alternative to LIBOR, will be an acceptable replacement 
rate when LIBOR is discontinued. However, we cannot reasonably estimate the expected impact of the planned 
discontinuation of LIBOR at this time.

Credit Ratings

Credit ratings by nationally recognized statistical rating agencies are an important component of our liquidity 
profile. Credit ratings relate to our ability to issue debt securities and the cost to borrow money and should not 
be viewed as a recommendation to buy, sell or hold securities. Ratings are subject to revision or withdrawal at 
any time and each rating should be evaluated independently of any other rating. Our current credit ratings are 
displayed  in  the  following  table. An  explanation  of  these  ratings  may  be  obtained  from  the  respective  rating 
agency.

ITC Holdings
 Senior Unsecured Notes
 Commercial Paper
ITCTransmission
 First Mortgage Bonds
METC
 Senior Secured Notes
ITC Midwest
 First Mortgage Bonds
ITC Great Plains
 First Mortgage Bonds

Covenants

S&P

Moody’s

Rating

Outlook

Rating

Outlook

BBB+
A-2

A

A

A

A

Negative
Negative

Negative

Negative

Negative

Negative

Baa2
Prime-2

A1

A1

A1

A1

Stable
Stable

Stable

Stable

Stable

Stable

Our debt instruments contain numerous financial and operating covenants that place significant restrictions 
on  certain  transactions,  such  as  incurring  additional  indebtedness,  engaging  in  sale  and  lease-back 
transactions,  creating  liens  or  other  encumbrances,  entering  into  mergers,  consolidations,  liquidations  or 
dissolutions, creating or acquiring subsidiaries and selling or otherwise disposing of all or substantially all of our 
assets. In addition, the covenants require us to meet certain financial ratios, such as maintaining certain debt to 
capitalization ratios and certain funds from operations to debt levels. As of December 31, 2020, we were not in 
violation of any debt covenant. In the event of a downgrade in our credit ratings, none of the covenants would 
be directly impacted, although the borrowing costs under our revolving credit agreements may increase.

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Cash Flows

The following table summarizes cash flows for the periods indicated:

(In millions of USD)

CASH FLOWS FROM OPERATING ACTIVITIES

Net income

Adjustments to reconcile net income to net cash provided by operating activities:

Depreciation and amortization expense

Recognition, refund and collection of revenue accruals and deferrals — including 

accrued interest

Deferred income tax expense

Other

Net cash provided by operating activities

CASH FLOWS FROM INVESTING ACTIVITIES

Expenditures for property, plant and equipment

Contributions in aid of construction

Other

Net cash used in investing activities

CASH FLOWS FROM FINANCING ACTIVITIES

Net issuance/repayment of debt (including commercial paper and revolving and term 

loan credit agreements)

Dividends to ITC Investment Holdings

Refundable deposits from and repayments to generators for transmission network 

upgrades, net

Settlement of interest rate swaps

Other

Net cash provided by financing activities

NET INCREASE (DECREASE) IN CASH, CASH EQUIVALENTS AND RESTRICTED 
CASH

CASH, CASH EQUIVALENTS AND RESTRICTED CASH — Beginning of period

CASH, CASH EQUIVALENTS AND RESTRICTED CASH — End of period

$ 

Cash Flows From Operating Activities

Year ended December 31, 2020 compared to year ended December 31, 2019

Year Ended December 31,

2020

2019

2018

$ 

407  $ 

428  $ 

330 

219 

203 

(47)   
138 
(85)   
632 

(885)   
2 
5 
(878)   

(55)   
135 
(82)   
629 

(865)   
10 
1 
(854)   

180 

17 
107 
19 
653 

(769) 
21 
1 
(747) 

561 
(330)   

463 
(250)   

238 
(200) 

50 
(23)   
(12)   
246 

11 
— 
(3)   

221 

— 
6 
6  $ 

(4)   
10 

6  $ 

3 
— 
(5) 
36 

(58) 
68 
10 

Net cash provided by operating activities was $632 million and $629 million for the year ended December 31, 
2020 and 2019, respectively. The increase in cash provided by operating activities was due primarily to lower 
payments for operation and maintenance expenses and general and administrative expenses and the timing of 
the settlement of payables for operating activities. This increase was partially offset by an increase in payments 
pursuant  to  our  long-term  incentive  plans  of  $22  million,  the  refunds,  including  interest,  related  to  the  MISO 
ROE  Complaints  of  $31  million  and  higher  property  tax  payments  of  $14  million  during  the  year  ended 
December 31, 2020 compared to the same period in 2019.

Cash Flows From Investing Activities

Year ended December 31, 2020 compared to year ended December 31, 2019

Net  cash  used  in  investing  activities  was  $878  million  and  $854  million  for  the  year  ended  December  31, 
2020 and 2019, respectively. The increase in cash used in investing activities was primarily due to an increase 
in capital expenditures of $20 million during the year ended December 31, 2020 compared to the same period in 
2019.

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Cash Flows From Financing Activities

Year ended December 31, 2020 compared to year ended December 31, 2019

Net cash provided by financing activities was $246 million and $221 million for the year ended December 31, 
2020  and  2019,  respectively.  The  increase  in  cash  provided  by  financing  activities  was  due  primarily  to  an 
increase  in  issuances  of  long-term  debt  of  $855  million,  a  decrease  in  retirement  of  long-term  debt  of 
$168 million and an increase in net refundable deposits for transmission network upgrades of $39 million during 
the year ended December 31, 2020 compared to the same period in 2019. These increases were partially offset 
by  increases  in  net  repayments  under  our  revolving  and  term  loan  credit  agreements  of  $592  million,  net 
repayments  of  commercial  paper  of  $333  million,  dividend  payments  of  $80  million  and  settlement  of  interest 
rate swaps of $23 million during the year ended December 31, 2020 compared to the same period in 2019. See 
Note 10 to the consolidated financial statements for detail on the issuances and retirements of debt, borrowings 
under  our  term  loan  credit  agreement  and  a  description  of  our  revolving  credit  agreements  and  commercial 
paper program.

Critical Accounting Policies and Estimates

Our  consolidated  financial  statements  are  prepared  in  accordance  with  GAAP.  The  preparation  of  these 
consolidated  financial  statements  requires  the  application  of  appropriate  technical  accounting  rules  and 
guidance, as well as the use of estimates. The application of these policies requires judgments regarding future 
events.

These  estimates  and  judgments,  in  and  of  themselves,  could  materially  impact  the  consolidated  financial 
statements  and  disclosures  based  on  varying  assumptions,  as  future  events  rarely  develop  exactly  as 
forecasted, and even the best estimates routinely require adjustment.

The  following  accounting  policies  are  the  most  significant  to  the  portrayal  of  our  financial  condition  and 

results of operations and/or that require management’s most difficult, subjective or complex judgments.

Regulation

Our  Regulated  Operating  Subsidiaries  are  subject  to  rate  regulation  by  the  FERC.  As  a  result,  we  apply 
accounting principles in accordance with the standards set forth by the FASB for accounting for the effects of 
certain  types  of  regulation.  Use  of  this  accounting  guidance  results  in  differences  in  the  application  of  GAAP 
between regulated and non-regulated businesses and requires the recording of regulatory assets and liabilities 
for certain transactions that would have been treated as expense or revenue in non-regulated businesses. As 
described  in  Note  7  to  the  consolidated  financial  statements,  we  had  regulatory  assets  and  liabilities  of  $264 
million  and  $626  million,  respectively,  as  of  December  31,  2020.  Future  changes  in  the  regulatory  and 
competitive environments could result in discontinuing the application of the accounting standards for the effects 
of certain types of regulations. If we were to discontinue the application of this guidance on the operations of our 
Regulated Operating Subsidiaries, we may be required to record losses relating to certain regulatory assets or 
gains relating to certain regulatory liabilities. We also may be required to record losses of $29 million relating to 
intangible assets at December 31, 2020 that are described in Note 9 to the consolidated financial statements.

We believe that currently available facts support the continued applicability of the standards for accounting 
for  the  effects  of  certain  types  of  regulation  and  that  all  regulatory  assets  and  liabilities  are  recoverable  or 
refundable under our current rate environment.

Revenue Recognition under Cost-Based Formula Rates with True-Up Mechanism

Our  Regulated  Operating  Subsidiaries  recover  expenses  and  earn  an  authorized  return  on  and  recover 
investments  in  property,  plant  and  equipment  on  a  current  basis,  under  their  forward-looking  cost-based 
Formula Rates with a true-up mechanism.

Under their Formula Rates, our Regulated Operating Subsidiaries use forecasted expenses, property, plant 
and  equipment,  point-to-point  revenues  and  other  items  for  the  upcoming  calendar  year  to  establish  their 
projected  revenue  requirement  and  for  the  MISO  Regulated  Operating  Subsidiaries,  their  component  of  the 
billed  network  rates  for  service  on  their  systems  from  January  1  to  December  31  of  that  year.  Our  Formula 
Rates  include  a  true-up  mechanism,  whereby  our  Regulated  Operating  Subsidiaries  compare  their  actual 
revenue  requirements  to  their  billed  revenues  for  each  year  to  determine  any  over-  or  under-collection  of 
revenue.  The  over-  or  under-collection  typically  results  from  differences  between  the  projected  revenue 

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requirement used as the basis for billing and actual revenue requirement at each of our Regulated Operating 
Subsidiaries,  or  from  differences  between  actual  and  projected  monthly  network  peak  loads  at  our  MISO 
Regulated Operating Subsidiaries.

The  true-up  mechanisms  under  our  Formula  Rates  meet  the  GAAP  requirements  for  accounting  for  rate-
regulated  utilities  and  the  effects  of  certain  alternative  revenue  programs. Accordingly,  revenue  is  recognized 
during  each  reporting  period  based  on  actual  revenue  requirements  calculated  using  the  cost-based  Formula 
Rates. Our Regulated Operating Subsidiaries accrue or defer revenues to the extent that their actual revenue 
requirement  for  the  reporting  period  is  higher  or  lower,  respectively,  than  the  amounts  billed  relating  to  that 
reporting  period.  The  true-up  amount  is  automatically  reflected  in  customer  bills  within  two  years  under  the 
provisions of the Formula Rates. See Note 7 to the consolidated financial statements for the regulatory assets 
and  liabilities  recorded  at  our  Regulated  Operating  Subsidiaries’  as  a  result  of  the  Formula  Rate  revenue 
accruals and deferrals.

Contingent Obligations

We are subject to a number of federal and state laws and regulations, as well as other factors and conditions 
that  potentially  subject  us  to  environmental,  litigation,  income  tax  and  other  contingencies.  We  periodically 
evaluate our exposure to such contingencies and record liabilities for those matters where a loss is considered 
probable  and  reasonably  estimable.  Our  liabilities  exclude  any  estimates  for  legal  costs  not  yet  incurred 
associated  with  handling  these  matters,  which  could  be  material. The  adequacy  of  liabilities  recorded  can  be 
significantly affected by external events or conditions that can be unpredictable; thus, the ultimate outcome of 
such matters could materially affect our consolidated financial statements. These events or conditions include, 
without limitation, the following:

• Changes  in  existing  state  or  federal  regulation  by  governmental  authorities  having  jurisdiction  over  air 
quality,  water  quality,  control  of  toxic  substances,  hazardous  and  solid  wastes  and  other  environmental 
matters.

• Changes in existing federal income tax laws or IRS regulations.

• Identification  and  evaluation  of  lawsuits  or  complaints  in  which  we  may  be  or  have  been  named  as  a 

defendant.

• Resolution or progression of existing matters  through the legislative process, the courts, the FERC, the 

NERC, the IRS or the Environmental Protection Agency.

Refer  to  Note  18  to  the  consolidated  financial  statements  for  discussion  on  contingencies,  including  the 

MISO ROE Complaints.

Pension and Postretirement Costs

We  sponsor  certain  retirement  benefits  for  our  employees,  which  include  retirement  pension  plans  and 
certain  postretirement  health  care,  dental  and  life  insurance  benefits.  Our  periodic  costs  and  obligations 
associated  with  these  plans  are  developed  from  actuarial  valuations  derived  from  a  number  of  assumptions, 
including rates of return on plan assets, discount rates, the rate of increase in health care costs, the amount and 
timing  of  plan  sponsor  contributions  and  demographic  factors  such  as  retirements,  mortality  and  turnover, 
among  others.  We  evaluate  these  assumptions  annually  and  update  them  periodically  to  reflect  our  actual 
experience.  Three  critical  assumptions  in  determining  our  periodic  costs  and  obligations  are  discount  rate, 
expected  long-term  return  on  plan  assets  and  the  rate  of  increases  in  health  care  costs.  The  discount  rate 
represents  the  market  rate  for  synthesized AA-rated  zero-coupon  bonds  with  durations  corresponding  to  the 
expected durations of the benefit obligations and is used to calculate the present value of the expected future 
cash flows for benefit obligations under our plans. In determining our long-term rate of return on plan assets, we 
consider the current and expected asset allocations, as well as historical and expected long-term rates of return 
on  those  types  of  asset  classes. Assumed  health  care  cost  trend  rates  may  have  a  significant  effect  on  the 
amounts reported for the health care plans.

Off-Balance Sheet Arrangements

We have no off-balance sheet arrangements that have or are reasonably likely to have a material effect on 

our financial condition.

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Recent Accounting Pronouncements

See Note 2 to the consolidated financial statements.

ITEM 7A.   QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK.

Commodity Price Risk

We have commodity price risk at our Regulated Operating Subsidiaries arising from market price fluctuations 
for  materials  such  as  copper,  aluminum,  steel,  oil  and  gas  and  other  goods  used  in  construction  and 
maintenance  activities.  Higher  costs  of  these  materials  are  passed  on  to  us  by  the  contractors  for  these 
activities.  These  items  affect  only  cash  flows,  as  the  amounts  are  included  as  components  of  net  revenue 
requirement and any higher costs are included in rates under their cost-based Formula Rates.

Interest Rate Risk

Fixed Rate Debt

Based on the borrowing rates currently available for bank loans with similar terms and average maturities, 
the fair value of our consolidated long-term debt and debt maturing within one year, excluding revolving credit 
agreements  and  commercial  paper,  was  $7,119  million  at  December  31,  2020.  The  total  book  value  of  our 
consolidated long-term debt and debt maturing within one year, net of discount and deferred financing fees and 
excluding  revolving  credit  agreements  and  commercial  paper,  was  $6,097  million  at  December  31,  2020.  We 
performed an analysis calculating the impact of changes in interest rates on the fair value of long-term debt and 
debt maturing within one year, excluding revolving credit agreements and commercial paper at December 31, 
2020.  An  increase  in  interest  rates  of  10%  (from  5.0%  to  5.5%,  for  example)  at  December  31,  2020  would 
decrease the fair value of debt by $213 million, and a decrease in interest rates of 10% at December 31, 2020 
would increase the fair value of debt by $227 million at that date.

Revolving Credit Agreements 

At  December  31,  2020,  we  had  a  consolidated  total  of  $198  million  outstanding  under  our  revolving  credit 
agreements, which are variable rate loans and fair value approximates book value. A 10% increase or decrease 
in borrowing rates under the revolving credit agreements compared to the weighted average rates in effect at 
December 31, 2020 would increase or decrease interest expense by less than $1 million for an annual period 
with a constant borrowing level of $198 million.

Commercial Paper

At  December  31,  2020,  ITC  Holdings  had  $67  million  of  commercial  paper  issued  and  outstanding,  net  of 
discount, under the commercial paper program. Due to the short-term nature of these financial instruments, the 
carrying value approximates fair value. A 10% increase or decrease in interest rates for commercial paper would 
increase  or  decrease  interest  expense  by  less  than  $1  million  for  an  annual  period  with  a  continuous  level  of 
commercial paper outstanding of $67 million.

Derivative Instruments and Hedging Activities

We use derivative financial instruments, including interest rate swap contracts, to manage our exposure to 
fluctuations in interest rates. The use of these financial instruments mitigates exposure to these risks and the 
variability of our operating results. We are not a party to leveraged derivatives and do not enter into derivative 
financial instruments for trading or speculative purposes. 

In May 2020, we terminated $450 million of 5-year interest rate swap contracts that managed interest rate 
risk  associated  with  the  $700  million  Senior  Notes  at  ITC  Holdings  with  a  maturity  date  of  May  14,  2030  as 
described in Note 10 to the consolidated financial statements. At December 31, 2020, ITC Holdings did not have 
any interest rate swaps outstanding.

Credit Risk

Our  credit  risk  is  primarily  with  DTE  Electric,  Consumers  Energy  and  IP&L,  which  were  responsible  for 
approximately  21.6%,  23.9%  and  23.9%,  respectively,  or  $265  million,  $292  million  and  $292  million, 
respectively,  of  our  consolidated  billed  revenues  for  the  year  ended  December  31,  2020.  These  percentages 
and  amounts  of  total  billed  revenues  of  DTE  Electric,  Consumers  Energy  and  IP&L  include  the  collection  of 
2018 revenue accruals and deferrals and exclude any amounts for the 2020 revenue accruals and deferrals that 

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were  included  in  our  2020  operating  revenues  but  will  not  be  billed  to  our  customers  until  2022.  Refer  to 
“Management’s  Discussion  and  Analysis  of  Financial  Condition  and  Results  of  Operations  —  Cost-Based 
Formula  Rates  with  True-Up  Mechanism”  for  a  discussion  on  the  difference  between  billed  revenues  and 
operating  revenues.  Under  DTE  Electric’s  and  Consumers  Energy’s  current  rate  structure,  DTE  Electric  and 
Consumers  Energy  include  in  their  retail  rates  the  actual  cost  of  transmission  services  provided  by 
ITCTransmission and METC, respectively, in their billings to their customers, effectively passing through to end-
use consumers the total cost of transmission service. IP&L currently includes in their retail rates an allowance 
for  transmission  services  provided  by  ITC  Midwest  in  their  billings  to  their  customers.  However,  any  financial 
difficulties experienced by DTE Electric, Consumers Energy or IP&L may affect their ability to make payments 
for  transmission  service  to  ITCTransmission,  METC,  and  ITC  Midwest,  which  could  negatively  impact  our 
business.  MISO,  as  our  MISO  Regulated  Operating  Subsidiaries’  billing  agent,  bills  DTE  Electric,  Consumers 
Energy,  IP&L  and  other  customers  on  a  monthly  basis  and  collects  fees  for  the  use  of  the  MISO  Regulated 
Operating  Subsidiaries’  transmission  systems.  SPP  is  the  billing  agent  for  ITC  Great  Plains  and  bills 
transmission  customers  for  the  use  of  ITC  Great  Plains  transmission  systems.  MISO  and  SPP  have 
implemented strict credit policies for its members’ customers, which include customers using our transmission 
systems.  Specifically,  MISO  and  SPP  require  a  letter  of  credit  or  cash  deposit  equal  to  the  credit  exposure, 
which  is  determined  by  a  credit  scoring  model  and  other  factors,  from  any  customer  using  a  member’s 
transmission system.

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ITEM 8.   FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA.

The following financial statements and schedules are included herein:

Management’s Report on Internal Control over Financial Reporting

Report of Independent Registered Public Accounting Firm

Consolidated Statements of Financial Position as of December 31, 2020 and 2019

Consolidated Statements of Comprehensive Income for the Years Ended December 31, 2020, 2019 and 2018

Consolidated Statements of Changes in Stockholder’s Equity for the Years Ended December 31, 2020, 2019 and 
2018

Consolidated Statements of Cash Flows for the Years Ended December 31, 2020, 2019 and 2018

Notes to Consolidated Financial Statements

Schedule I — Condensed Financial Information of Registrant

Page

43

44

46

47

48

49

50

129

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MANAGEMENT’S REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING

Management  is  responsible  for  establishing  and  maintaining  adequate  internal  control  over  financial 
reporting.  Our  internal  control  over  financial  reporting  is  designed  to  provide  reasonable,  not  absolute, 
assurance  as  to  the  reliability  of  our  financial  reporting  and  the  preparation  of  financial  statements  in 
accordance  with  generally  accepted  accounting  principles.  Internal  control  over  financial  reporting,  no  matter 
how well designed, has inherent limitations. Therefore, internal control over financial reporting determined to be 
effective  can  provide  only  reasonable  assurance  with  respect  to  financial  statement  preparation  and  may  not 
prevent or detect all misstatements.

Under management’s supervision, an evaluation of the design and effectiveness of our internal control over 
financial  reporting  was  conducted  based  on  the  criteria  set  forth  in  Internal  Control  —  Integrated  Framework 
(2013)  issued  by  the  Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission  (COSO).  Our 
assessment  included  documenting,  evaluating  and  testing  of  the  design  and  operating  effectiveness  of  our 
internal  control  over  financial  reporting.  Based  on  this  evaluation,  management  concluded  that  our  internal 
control over financial reporting was effective as of December 31, 2020.

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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors and Stockholder of
ITC Holdings Corp. 
Novi, Michigan

Opinion on the Financial Statements

We  have  audited  the  accompanying  consolidated  statements  of  financial  position  of  ITC  Holdings  Corp.  and 
subsidiaries  (the  "Company")  as  of  December  31,  2020  and  2019,  the  related  consolidated  statements  of 
comprehensive  income,  changes  in  stockholder’s  equity,  and  cash  flows  for  each  of  the  three  years  in  the 
period  ended  December  31,  2020,  and  the  related  notes  and  the  schedule  listed  in  the  Index  at  Item  15 
(collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all 
material respects, the financial position of the Company as of December 31, 2020 and 2019, and the results of 
its  operations  and  its  cash  flows  for  each  of  the  three  years  in  the  period  ended  December  31,  2020,  in 
conformity with accounting principles generally accepted in the United States of America.

Basis for Opinion

These  financial  statements  are  the  responsibility  of  the  Company's  management.  Our  responsibility  is  to 
express an opinion on the Company's financial statements based on our audits. We are a public accounting firm 
registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to 
be  independent  with  respect  to  the  Company  in  accordance  with  the  U.S.  federal  securities  laws  and  the 
applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We  conducted  our  audits  in  accordance  with  the  standards  of  the  PCAOB  and  in  accordance  with  auditing 
standards  generally  accepted  in  the  United  States  of  America.  Those  standards  require  that  we  plan  and 
perform  the  audit  to  obtain  reasonable  assurance  about  whether  the  financial  statements  are  free  of  material 
misstatement,  whether  due  to  error  or  fraud. The  Company  is  not  required  to  have,  nor  were  we  engaged  to 
perform, an audit of its internal control over financial reporting. As part of our audits, we are required to obtain 
an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on 
the  effectiveness  of  the  Company’s  internal  control  over  financial  reporting. Accordingly,  we  express  no  such 
opinion.

Our  audits  included  performing  procedures  to  assess  the  risks  of  material  misstatement  of  the  financial 
statements,  whether  due  to  error  or  fraud,  and  performing  procedures  that  respond  to  those  risks.  Such 
procedures  included  examining,  on  a  test  basis,  evidence  regarding  the  amounts  and  disclosures  in  the 
financial  statements.  Our  audits  also  included  evaluating  the  accounting  principles  used  and  significant 
estimates made by management, as well as evaluating the overall presentation of the financial statements. We 
believe that our audits provide a reasonable basis for our opinion.

Critical Audit Matter

The  critical  audit  matter  communicated  below  is  a  matter  arising  from  the  current-period  audit  of  the  financial 
statements that was communicated or required to be communicated to the audit committee and that (1) relates 
to  accounts  or  disclosures  that  are  material  to  the  financial  statements  and  (2)  involved  our  especially 
challenging, subjective, or complex judgments. The communication of critical audit matters does not alter in any 
way our opinion on the financial statements, taken as a whole, and we are not, by communicating the critical 
audit matter below, providing a separate opinion on the critical audit matter or on the accounts or disclosures to 
which it relates.

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Regulatory Matters  — Impact of rate regulation on the financial statements — Refer to Notes 3, 6 and 7 
to the financial statements

Critical Audit Matter Description

The  Company’s  regulated  operating  subsidiaries  are  subject  to  rate  regulation  by  the  Federal  Energy 
Regulatory  Commission  (the  “regulatory  agency”).  Management  has  determined  it  meets  the  requirements 
under  accounting  principles  generally  accepted  in  the  United  States  of  America  to  prepare  its  financial 
statements  applying  the  specialized  rules  to  account  for  the  effects  of  cost-based  rate  regulation.  The 
Company’s  rates  are  subject  to  regulatory  rate-setting  processes  through  a  formula  rate  with  a  true-up 
mechanism,  including  an  authorized  return  on  equity.  Regulatory  decisions  can  have  an  impact  on  rates, 
recovery of certain costs, including the costs of transmission assets and regulatory assets, conditions of service, 
accounting, financing authorization and operating-related matters, the timely recovery of costs and the return on 
equity.  Accounting  for  the  economics  of  rate  regulation  impacts  multiple  financial  statement  line  items  and 
disclosures,  such  as  property,  plant,  and  equipment;  regulatory  assets  and  liabilities;  operating  revenues  and 
expenses; and income taxes. 

We identified the impact of rate regulation as a critical audit matter due to the significant judgments made by 
management to support its assertions about impacted account balances and disclosures and the high degree of 
subjectivity  involved  in  assessing  the  potential  impact  of  future  regulatory  orders  on  the  financial  statements. 
Management  judgments  include  assessing  the  likelihood  of  recovery  of  costs  incurred  or  potential  refunds  to 
customers.  While the Company has indicated they expect to recover costs from customers through regulated 
rates,  there  is  a  risk  that  the  formula  inputs  remain  subject  to  legal  challenge  at  the  regulatory  agency.    The 
Company uses the formula to calculate annual revenue requirements unless the regulatory agency determines 
the  resulting  rates  to  be  unjust  and  unreasonable.  Auditing  these  judgments  required  especially  subjective 
judgment and specialized knowledge of accounting for rate regulation and the rate-setting process due to their 
inherent complexities.

How the Critical Audit Matter Was Addressed in the Audit

Our  audit  procedures  related  to  the  uncertainty  of  future  decisions  by  the  regulatory  agency  included  the 
following, among others:

• We  evaluated  the  effectiveness  of  controls  over  the  monitoring  and  evaluation  of  regulatory 
developments that may affect the likelihood of recovering costs in future rates or of a future reduction in 
rates. 

• We assessed relevant regulatory orders, regulatory statutes and interpretations, as well as procedural 
memorandums,  utility  and  intervener  filings,  and  other  publicly  available  information  to  evaluate  the 
likelihood of recovery in future rates or of future reduction in rates and the ability to earn a reasonable 
return on equity.
For regulatory matters in process, we inspected the annual formula rate filings and open complaints for 
any  evidence  that  might  contradict  management’s  assertions.  We  obtained  an  analysis  from 
management, regarding cost recoveries or potential future reduction in rates.

•

• We  evaluated  the  Company’s  disclosures  related  to  the  impacts  of  rate  regulation,  including  the 

balances recorded and regulatory developments. 

/s/ DELOITTE & TOUCHE LLP

Detroit, Michigan
February 11, 2021  

We have served as the Company's auditor since 2001.

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ITC HOLDINGS CORP. AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF FINANCIAL POSITION

(In millions of USD, except share data)

ASSETS

Current assets

Cash and cash equivalents

Accounts receivable

Inventory

Regulatory assets

Prepaid and other current assets

Total current assets

Property,  plant  and  equipment  (net  of  accumulated  depreciation  and  amortization  of  $2,055  and 

$1,930, respectively)

Other assets

Goodwill

Intangible assets (net of accumulated amortization of $46 and $42, respectively)

Regulatory assets

Other assets

Total other assets

TOTAL ASSETS

LIABILITIES AND STOCKHOLDER’S EQUITY

Current liabilities

Accounts payable

Accrued compensation

Accrued interest

Accrued taxes

Regulatory liabilities

Refundable deposits and advances for construction

Debt maturing within one year

Other current liabilities

Total current liabilities

Accrued pension and postretirement liabilities

Deferred income taxes

Regulatory liabilities

Refundable deposits

Other liabilities

Long-term debt

Commitments and contingent liabilities (Notes 6 and 18)

TOTAL LIABILITIES

STOCKHOLDER’S EQUITY

Common stock, without par value, 235,000,000 shares authorized, 224,203,112 shares issued and 

outstanding at December 31, 2020 and 2019

Retained earnings

Accumulated other comprehensive (loss) income

Total stockholder’s equity

December 31,

2020

2019

$ 

4  $ 

114 

42 

52 

12 

224 

4 

117 

39 

12 

15 

187 

9,327 

8,582 

950 

29 

212 

83 

950 

33 

229 

77 

1,274 

1,289 

$ 

10,825  $ 

10,058 

$ 

130  $ 

55 

55 

61 

14 

37 

67 

18 

437 

59 

1,013 

612 

65 

50 

6,295 

82 

61 

48 

66 

123 

27 

235 

16 

658 

73 

873 

584 

19 

47 

5,572 

8,531 

7,826 

892 

1,410 

(8) 

2,294 

892 

1,333 

7 

2,232 

TOTAL LIABILITIES AND STOCKHOLDER’S EQUITY

$ 

10,825  $ 

10,058 

See notes to consolidated financial statements.

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ITC HOLDINGS CORP. AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME

(In millions of USD)

OPERATING REVENUES

Transmission and other services

Formula Rate true-up

Total operating revenue

OPERATING EXPENSES

Operation and maintenance

General and administrative

Depreciation and amortization

Taxes other than income taxes

Other operating (income) and expense, net

Total operating expenses

OPERATING INCOME

OTHER EXPENSES (INCOME)

Interest expense, net

Allowance for equity funds used during construction

Other (income) and expenses, net

Total other expenses (income)

INCOME BEFORE INCOME TAXES

INCOME TAX PROVISION

NET INCOME

OTHER COMPREHENSIVE (LOSS) INCOME

Derivative instruments, net of tax (Note 14)

TOTAL OTHER COMPREHENSIVE (LOSS) INCOME, NET OF TAX 

Year Ended December 31,

2020

2019

2018

$ 

1,290  $ 

1,286  $ 

1,192 

8 

1,298 

41 

1,327 

(36) 

1,156 

87 

115 

219 

124 

— 

545 

753 

240 

(27) 

(3) 

210 

543 

136 

407 

(15) 

(15) 

113 

138 

203 

118 

— 

572 

755 

224 

(29) 

— 

195 

560 

132 

428 

3 

3 

109 

127 

180 

109 

(4) 

521 

635 

224 

(33) 

3 

194 

441 

111 

330 

1 

1 

TOTAL COMPREHENSIVE INCOME

$ 

392  $ 

431  $ 

331 

See notes to consolidated financial statements.

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ITC HOLDINGS CORP. AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF CHANGES IN 
STOCKHOLDER’S EQUITY

Accumulated
Other

Total

Common Stock

Retained Comprehensive Stockholder’s
Earnings

Income (Loss)

Equity

(In millions of USD)

BALANCE, DECEMBER 31, 2017

Opening balance reclassification

Net income

Dividends to ITC Investment Holdings

Other comprehensive income, net of tax (Note 14)

BALANCE, DECEMBER 31, 2018

Net income

Dividends to ITC Investment Holdings

Other comprehensive income, net of tax (Note 14)

BALANCE, DECEMBER 31, 2019

Net income

Dividends to ITC Investment Holdings

Other comprehensive (loss), net of tax (Note 14)

BALANCE, DECEMBER 31, 2020

$ 

892  $ 

1,026  $ 

2  $ 

1,920 

— 

— 

— 

— 

(1) 

330 

(200) 

— 

1 

— 

— 

1 

— 

330 

(200) 

1 

892  $ 

1,155  $ 

4  $ 

2,051 

— 

— 

— 

428 

(250) 

— 

— 

— 

3 

428 

(250) 

3 

892  $ 

1,333  $ 

7  $ 

2,232 

— 

— 

— 

407 

(330) 

— 

— 

— 

(15) 

407 

(330) 

(15) 

892  $ 

1,410  $ 

(8)  $ 

2,294 

$ 

$ 

$ 

See notes to consolidated financial statements.

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ITC HOLDINGS CORP. AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CASH FLOWS 

(In millions of USD)

CASH FLOWS FROM OPERATING ACTIVITIES

Net income

Adjustments to reconcile net income to net cash provided by operating activities:

Depreciation and amortization expense

Recognition, refund and collection of revenue accruals and deferrals — including accrued interest

Deferred income tax expense

Allowance for equity funds used during construction

Share-based compensation

Other

Changes in assets and liabilities, exclusive of changes shown separately:

Accounts receivable

Income tax receivable 

Accounts payable

Accrued interest
Accrued compensation

Accrued taxes

Net refund payments and adjustments related to return on equity complaints

Other current and non-current assets and liabilities, net

Net cash provided by operating activities

CASH FLOWS FROM INVESTING ACTIVITIES

Expenditures for property, plant and equipment

Contributions in aid of construction

Other

Net cash used in investing activities

CASH FLOWS FROM FINANCING ACTIVITIES

Issuance of long-term debt

Borrowings under revolving credit agreements

Borrowings under term loan credit agreements

Net (repayment) issuance of commercial paper

Retirement of long-term debt — including extinguishment of debt costs

Repayments of revolving credit agreements

Repayments of term loan credit agreements

Dividends to ITC Investment Holdings
Refundable deposits from generators for transmission network upgrades

Repayment of refundable deposits from generators for transmission network upgrades
Settlement of interest rate swaps
Other

Net cash provided by financing activities

NET INCREASE (DECREASE) IN CASH, CASH EQUIVALENTS AND RESTRICTED CASH

CASH, CASH EQUIVALENTS AND RESTRICTED CASH — Beginning of period

Year Ended December 31,

2020

2019

2018

$ 

407  $ 

428  $ 

330 

219 

(47) 

138 

(27) 

25 

4 

— 

— 

4 

7 
(14) 

(3) 

(65) 

(16) 

632 

203 

(55) 

135 

(29) 

32 

10 

(10) 

1 

(11) 

(2) 
10 

3 

(82) 

(4) 

629 

180 

17 

107 

(33) 

6 

4 

17 

14 

6 

(10) 
1 

7 

6 

1 

653 

(885) 

(865) 

(769) 

2 

5 

10 

1 

21 

1 

(878) 

(854) 

(747) 

1,030 

1,495 

275 

(133) 

(35) 

(1,596) 

(475) 

(330) 
60 

(10) 
(23) 
(12) 

246 

— 

6 

175 

1,090 

200 

200 

(203) 

(999) 

— 

(250) 
19 

(8) 
— 
(3) 

221 

(4) 

10 

400 

832 

— 

— 

(100) 

(844) 

(50) 

(200) 
6 

(3) 
— 
(5) 

36 

(58) 

68 

10 

CASH, CASH EQUIVALENTS AND RESTRICTED CASH — End of period

$ 

6  $ 

6  $ 

See notes to consolidated financial statements.

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1.  GENERAL

ITC HOLDINGS CORP. AND SUBSIDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

ITC  Holdings  and  its  subsidiaries  are  engaged  in  the  transmission  of  electricity  in  the  United  States.  ITC 
Holdings is a wholly-owned subsidiary of ITC Investment Holdings. Fortis owns a majority indirect equity interest 
in  ITC  Investment  Holdings,  with  GIC  holding  an  indirect  equity  interest  of  19.9%.  Through  our  Regulated 
Operating Subsidiaries, we own, operate, maintain and invest in high-voltage electric transmission systems in 
Michigan’s  Lower  Peninsula  and  portions  of  Iowa,  Minnesota,  Illinois,  Missouri,  Kansas,  and  Oklahoma  that 
transmit electricity from generating stations to local distribution facilities connected to our transmission systems.

Our Regulated Operating Subsidiaries are independent electric transmission utilities, with rates regulated by 
the  FERC  and  established  on  a  cost-of-service  model.  ITCTransmission’s  service  area  is  located  in 
southeastern  Michigan,  while  METC’s  service  area  covers  approximately  two-thirds  of  Michigan’s  Lower 
Peninsula  and  is  contiguous  with  ITCTransmission’s  service  area.  ITC  Midwest’s  service  area  is  located  in 
portions of Iowa, Minnesota, Illinois and Missouri and ITC Great Plains currently owns assets located in Kansas 
and Oklahoma. MISO bills and collects revenues from the MISO Regulated Operating Subsidiaries’ customers. 
SPP bills and collects revenue from ITC Great Plains’ customers. ITC Interconnection currently owns assets in 
Michigan  and  earns  revenues  based  on  its  facilities  reimbursement  agreement  with  a  merchant  generating 
company.

Recent Developments Regarding the COVID-19 Pandemic

In March 2020, the World Health Organization declared COVID-19 a pandemic. Efforts to control the recent 
outbreak  of  COVID-19  have  resulted  in  impacts  to  businesses  and  facilities  in  various  industries  around  the 
world,  such  as  operating  restrictions  and  closures,  and  disruptions  to  the  global  economy  and  supply  chains. 
The COVID-19 pandemic has and will continue to impact our customers throughout our operating footprint. To 
date,  COVID-19  has  not  had  a  material  impact  on  our  net  income.  However,  we  have  implemented  various 
temporary cost saving measures related to operating expenses, including operation and maintenance expenses 
and  general  and  administrative  expenses,  in  an  attempt  to  reduce  costs  that  are  collected  from  customers 
through our Formula Rates.

The duration and total impact on our operations from COVID-19 is unknown at this time and will ultimately 
depend  on  the  duration  and  severity  of  the  pandemic,  the  length  that  the  various  business  restrictions  are  in 
effect, the impact of recent resurgences of COVID-19 cases and deaths in the United States, and the efficacy 
and  distribution  of  COVID-19  vaccines.  We  are  continuing  to  monitor  developments  involving  our  workforce, 
customers and suppliers and cannot predict whether COVID-19 will have a material impact on our consolidated 
results  of  operations,  cash  flows  or  financial  condition.  We  are  also  monitoring  the  evolving  situation  and 
guidance  from  federal,  state  and  local  public  health  authorities.  We  are  taking  steps  to  mitigate  the  potential 
risks  to  us  and  our  employees  posed  by  COVID-19,  including  enabling  remote  work  arrangements  for 
employees  when  appropriate,  and  are  following  all  government  requirements  to  reduce  the  transmission  of 
COVID-19.

Monthly Network Peak Load

For  our  MISO  Regulated  Operating  Subsidiaries,  monthly  network  peak  loads  are  used  for  billing  network 
revenues, which currently is the largest component of our operating revenues. One of the primary factors that 
impacts  our  collection  of  revenues  is  actual  monthly  network  peak  load,  which  is  impacted  by  a  number  of 
factors  including  network  usage  and  weather.  Although  monthly  network  peak  loads  do  not  impact  our 
recognition  of  operating  revenues,  actual  network  load  affects  the  timing  of  collection  of  our  cash  flows  from 
transmission  service.  During  2020,  actual  monthly  network  peak  load  for  our  MISO  Regulated  Operating 
Subsidiaries decreased compared to pre-COVID-19 forecasted load. This decrease was primarily as a result of 
reductions in, or suspension of, operations for many businesses and facilities in our operating footprint due to 
COVID-19.  While  the  decrease  in  monthly  network  peak  load  was  significant  in  the  early  months  of  the 
pandemic, the impact of COVID-19 on monthly network peak loads became less pronounced over the second 
half of the year. We are unable to predict the possible future impacts of COVID-19, weather and other factors on 
monthly network peak loads at our MISO Regulated Operating Subsidiaries.

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2. RECENT ACCOUNTING PRONOUNCEMENTS

Recently Adopted Pronouncements

Accounting for Cloud Computing Arrangements

In August 2018, the FASB issued authoritative guidance to address the accounting for implementation costs 
incurred in a cloud computing agreement that is a service contract. The new standard aligns the accounting for 
implementation costs incurred in a cloud computing arrangement as a service contract with existing guidance 
on  capitalizing  costs  associated  with  developing  or  obtaining  internal-use  software.  In  addition,  the  new 
guidance requires entities to expense capitalized implementation costs of a cloud computing arrangement that 
is a service contract over the term of the agreement and to present the expense in the same income statement 
line  item  as  the  hosting  fees. The  guidance  was  effective  for  fiscal  years  beginning  after  December  15,  2019 
with either prospective or retrospective adoption permitted. We adopted the standard prospectively on January 
1, 2020. Adoption of this standard did not have a material impact on our consolidated financial statements.

3.  SIGNIFICANT ACCOUNTING POLICIES

A  summary  of  the  major  accounting  policies  followed  in  the  preparation  of  the  accompanying  consolidated 

financial statements, which conform to GAAP, is presented below:

Principles of Consolidation — ITC Holdings consolidates its majority owned subsidiaries. We eliminate 

all intercompany balances and transactions.

Use  of  Estimates  —  The  preparation  of  the  consolidated  financial  statements  requires  us  to  use 
estimates  and  assumptions  that  impact  the  reported  amounts  of  assets,  liabilities,  revenues  and 
expenses,  and  the  disclosure  of  contingent  assets  and  liabilities.  Actual  results  may  differ  from  our 
estimates.

Regulation  —  Our  Regulated  Operating  Subsidiaries  are  subject  to  the  regulatory  jurisdiction  of  the 
FERC,  which  issues  orders  pertaining  to  rates,  recovery  of  certain  costs,  including  the  costs  of 
transmission assets and regulatory assets, conditions of service, accounting, financing authorization and 
operating-related  matters.  The  utility  operations  of  our  Regulated  Operating  Subsidiaries  meet  the 
accounting standards set forth by the FASB for the accounting effects of certain types of regulation. These 
accounting  standards  recognize  the  cost  based  rate  setting  process,  which  results  in  differences  in  the 
application  of  GAAP  between  regulated  and  non-regulated  businesses.  These  standards  require  the 
recording  of  regulatory  assets  and  liabilities  for  certain  transactions  that  would  have  been  recorded  as 
revenue  and  expense  in  non-regulated  businesses.  Regulatory  assets  represent  costs  that  will  be 
included as a component of future tariff rates and regulatory liabilities represent amounts provided in the 
current tariff rates that are intended to recover costs expected to be incurred in the future or amounts to 
be refunded to customers.

Cash  and  Cash  Equivalents  —  We  consider  all  unrestricted  highly-liquid  temporary  investments  with 

an original maturity of three months or less at the date of purchase to be cash equivalents.

Restricted Cash and Restricted Cash Equivalents — Restricted cash and restricted cash equivalents 
include cash and cash equivalents that are legally or contractually restricted for use or withdrawal or are 
formally set aside for a specific purpose.

Accounts Receivable Reserve — We recognize losses for uncollectible accounts based on the current 
expected  credit  loss  model.  As  of  December  31,  2020,  2019  and  2018  we  did  not  have  an  accounts 
receivable reserve.

Inventories — Materials and supplies inventories are valued at average cost. Additionally, the costs of 

warehousing activities are recorded here and included in the cost of materials when requisitioned.

Property,  Plant  and  Equipment  —  Depreciation  and  amortization  expense  on  property,  plant  and 

equipment was $209 million, $194 million and $170 million for 2020, 2019 and 2018, respectively.

Property,  plant  and  equipment  in  service  at  our  Regulated  Operating  Subsidiaries  is  stated  at  its 
original  cost  when  first  devoted  to  utility  service.  The  gross  book  value  of  assets  retired  less  salvage 
proceeds is charged to accumulated depreciation. The provision for depreciation of transmission assets is 
a significant component of our Regulated Operating Subsidiaries’ cost of service under FERC-approved 

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rates.  Depreciation  is  computed  over  the  estimated  useful  lives  of  the  assets  using  the  straight-line 
method for financial reporting purposes and accelerated methods for income tax reporting purposes. The 
composite  depreciation  rate  for  our  Regulated  Operating  Subsidiaries  included  in  our  consolidated 
statements  of  comprehensive  income  was  2.0%  for  2020,  2019  and  2018.  The  composite  depreciation 
rates include depreciation primarily on transmission station equipment, towers, poles and overhead and 
underground lines that have a useful life ranging from 45 to 60 years. The portion of depreciation expense 
related  to  asset  removal  costs  is  added  to  regulatory  liabilities  or  deducted  from  regulatory  assets  and 
removal  costs  incurred  are  deducted  from  regulatory  liabilities  or  added  to  regulatory  assets.  Certain  of 
our Regulated Operating Subsidiaries capitalize to property, plant and equipment AFUDC in accordance 
with  the  FERC  regulations. AFUDC  represents  the  composite  cost  incurred  to  fund  the  construction  of 
assets, including interest expense and a return on equity capital devoted to construction of assets. The 
interest  component  of AFUDC  was  a  reduction  to  interest  expense  of  $7  million  for  2020,  $8  million  for 
2019 and $9 million for 2018.

For  acquisitions  of  property,  plant  and  equipment  greater  than  the  net  book  value  (other  than  asset 
acquisitions  accounted  for  under  the  purchase  method  of  accounting  that  result  in  goodwill),  the 
acquisition  premium  is  recorded  to  property,  plant  and  equipment  and  amortized  over  the  estimated 
remaining  useful  lives  of  the  assets  using  the  straight-line  method  for  financial  reporting  purposes  and 
accelerated methods for income tax reporting purposes.

Property, plant and equipment includes capital equipment inventory stated at original cost consisting of 

items that are expected to be used exclusively for capital projects.

Property,  plant  and  equipment  at  our  non-regulated  subsidiaries  is  stated  at  its  acquired  cost. 
Proceeds from salvage less the net book value of the disposed assets is recognized as a gain or loss on 
disposal.  Depreciation  is  computed  based  on  the  acquired  cost  less  expected  residual  value  and  is 
recognized over the estimated useful lives of the assets on a straight-line method for financial reporting 
purposes and accelerated methods for income tax reporting purposes.

Generator  Interconnection  Projects  and  Contributions  in  Aid  of  Construction  —  Certain  capital 
investment at our Regulated Operating Subsidiaries relates to investments made under GIAs. The GIAs 
typically consist of both transmission network upgrades, which are a category of upgrades deemed by the 
FERC  to  benefit  the  transmission  system  as  a  whole,  as  well  as  direct  connection  facilities,  which  are 
necessary  to  interconnect  the  generating  facility  to  the  transmission  system  and  primarily  benefit  the 
generating  facility.  As  a  result,  GIAs  typically  require  the  generator  to  make  a  contribution  in  aid  of 
construction to our Regulated Operating Subsidiaries to cover the cost of certain investments made by us 
as part of the agreement.

Our  investments  in  transmission  facilities  are  recorded  to  property,  plant  and  equipment,  and  are 
recorded  net  of  any  contribution  in  aid  of  construction.  We  also  receive  refundable  deposits  from  the 
generator  for  certain  investment  in  network  upgrade  facilities  in  advance  of  construction,  which  are 
recorded to current or non-current liabilities depending on the expected refund date.

Jointly  Owned  Utility  Plant/Coordinated  Services  —  Certain  of  our  Regulated  Operating  Subsidiaries 
have agreements with other utilities for the joint ownership of substation assets and transmission lines as 
described  in  Note  16.  We  account  for  these  jointly  owned  assets  by  recording  property,  plant  and 
equipment  for  the  percentage  of  our  undivided  ownership  interest.  Various  agreements  provide  the 
authority for construction of capital improvements and the operating costs associated with the substations 
and lines. Generally, each party is responsible for the capital, operation and maintenance and other costs 
of  these  jointly  owned  facilities  based  upon  each  participant’s  undivided  ownership  interest,  and  each 
participant is responsible for providing its own financing. Our participating share of expenses associated 
with these jointly held assets are primarily recorded within operation and maintenance expenses on our 
consolidated statements of comprehensive income.

Fair  Value  Through  Net  Income  —  We  have  certain  investments  in  mutual  funds,  including  fixed 
income  securities  and  equity  securities  that  are  classified  as  fair  value  through  net  income.  The  fixed 
income security investments primarily fund our two supplemental nonqualified, noncontributory, retirement 
benefit plans for selected management employees as described in Note 12. Gains and losses associated 
with our mutual funds as described in Note 13 are recorded in earnings.

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Impairment  of  Long-Lived  Assets  —  Other  than  goodwill,  our  long-lived  assets  are  reviewed  for 
impairment whenever events or changes in circumstances indicate the carrying amount of an asset may 
not be recoverable. If the carrying amount of the asset exceeds the expected undiscounted future cash 
flows generated by the asset, the asset is written down to its estimated fair value and an impairment loss 
is recognized in our consolidated statements of comprehensive income.

Goodwill and Other Intangible Assets — Goodwill is not subject to amortization; however, goodwill is 
required to be assessed for impairment, and a resulting write-down, if any, is to be reflected in operating 
expense. We have goodwill recorded relating to our acquisitions of ITCTransmission and METC and ITC 
Midwest’s acquisition of the IP&L transmission assets. Goodwill is reviewed at the reporting unit level at 
least annually for impairment and whenever facts or circumstances indicate that the value of goodwill may 
be impaired. Our reporting units are ITCTransmission, METC and ITC Midwest as each entity represents 
an individual operating segment to which goodwill has been assigned.

In order to perform an impairment analysis, we have the option of performing a qualitative assessment 
to  determine  whether  the  existence  of  events  or  circumstances  leads  to  a  determination  that  it  is  more 
likely than not that the fair value of a reporting unit is greater than its carrying amount, in which case no 
further  testing  is  required.  If  an  entity  bypasses  the  qualitative  assessment  or  performs  a  qualitative 
assessment but determines that it is more likely than not that a reporting unit’s fair value is less than its 
carrying  amount,  a  quantitative,  fair  value-based  test  is  performed  to  assess  and  measure  goodwill 
impairment, if any. If a quantitative assessment is performed, we determine the fair value of our reporting 
units  using  valuation  techniques  based  on  discounted  future  cash  flows  under  various  scenarios  and 
consider  estimates  of  market-based  valuation  multiples  for  companies  within  the  peer  group  of  our 
reporting units. 

We completed our annual goodwill impairment test for our reporting units as of October 1, 2020 and 
determined  that  no  impairment  exists.  There  were  no  events  subsequent  to  October  1,  2020  that 
indicated impairment of our goodwill. Our intangible assets other than goodwill have finite lives and are 
amortized over their useful lives. Refer to Note 9 for additional discussion on our goodwill and intangible 
assets.

Deferred Financing Fees and Discount or Premium on Debt — Costs related to the issuance of long-
term debt are generally recorded as a direct deduction from the carrying amount of the related debt and 
amortized over the life of the debt issue. Debt issuance costs incurred prior to the associated debt funding 
are  presented  as  an  asset.  Unamortized  debt  issuance  costs  associated  with  the  revolving  credit 
agreements, commercial paper and other similar arrangements are presented as an asset (regardless of 
whether there are any amounts outstanding under those credit facilities) and amortized over the life of the 
particular  arrangement.  The  debt  discount  or  premium  related  to  the  issuance  of  long-term  debt  is 
recorded to long-term debt and amortized over the life of the debt issue. We recorded $5 million during 
the years ended December 31, 2020, 2019 and 2018 to interest expense for the amortization of deferred 
financing fees and debt discounts.

Asset  Retirement  Obligations  —  A  conditional  asset  retirement  obligation  is  a  legal  obligation  to 
perform an asset retirement activity in which the timing and/or method of settlement are conditional on a 
future  event  that  may  or  may  not  be  within  our  control.  We  have  identified  conditional  asset  retirement 
obligations primarily associated with the removal of equipment containing PCBs and asbestos. We record 
a liability at fair value for a legal asset retirement obligation in the period in which it is incurred. When a 
new legal obligation is recorded, we capitalize the costs of the liability by increasing the carrying amount 
of the related long-lived asset. We accrete the liability to its present value each period and depreciate the 
capitalized cost over the useful life of the related asset. At the end of the asset’s useful life, we settle the 
obligation for its recorded amount. We recognize regulatory assets for the timing differences between the 
incurred costs to settle our legal asset  retirement  obligations and the recognition of such obligations as 
applicable  for  our  Regulated  Operating  Subsidiaries.  There  were  no  significant  changes  to  our  asset 
retirement obligations in 2020. Our asset retirement obligations as of December 31, 2020 and 2019 of $6 
million are included in other liabilities.

Derivatives and Hedging — We may use derivative financial instruments, including interest rate swap 
contracts, to manage our exposure to fluctuations in interest rates. For derivative instruments that have 
been  designated  and  qualify  as  cash  flow  hedges  of  the  exposure  to  variability  in  expected  future  cash 

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flows, the unrealized gain or loss on the derivative is initially reported, net of tax, as a component of other 
comprehensive income (loss) and reclassified to the consolidated statements of comprehensive income 
when the underlying hedged transaction affects net income. Cash flows related to interest rate swaps that 
are  designated  in  hedging  relationships  are  generally  classified  on  the  consolidated  statements  of  cash 
flows within cash flows from financing activities. The fair values of derivatives are recognized as current or 
long-term assets and liabilities depending on the timing of settlements and resulting cash flows. Refer to 
Note 10 for additional discussion regarding derivative instruments.

Contingent  Obligations  —  We  are  subject  to  a  number  of  federal  and  state  laws  and  regulations,  as 
well as other factors and conditions that potentially subject us to environmental, litigation and other risks. 
We periodically evaluate our exposure to such risks and record liabilities for those matters when a loss is 
considered probable and reasonably estimable. We reverse the liabilities recorded for those matters when 
a loss is no longer considered probable or the liabilities are otherwise settled. Our liabilities exclude any 
estimates  for  legal  costs  not  yet  incurred  associated  with  handling  these  matters.  The  adequacy  of 
liabilities can be significantly affected by external events or conditions that can be unpredictable; thus, the 
ultimate outcome of such matters could materially affect our consolidated financial statements.

Revenues  —  Substantially  all  of  our  revenue  from  contracts  with  customers  is  generated  from 
providing transmission services to customers based on tariff rates, as approved by the FERC. Revenues 
from the transmission of electricity are recognized as services are provided based on our FERC-approved 
cost-based  Formula  Rates.  We  record  a  reserve  for  revenue  subject  to  refund  when  such  refund  is 
probable  and  can  be  reasonably  estimated.  This  reserve  is  recorded  as  a  reduction  to  operating 
revenues.

The cost-based Formula Rates at our Regulated Operating Subsidiaries include a true-up mechanism 
that  compares  the  actual  revenue  requirements  of  our  Regulated  Operating  Subsidiaries  to  their  billed 
revenues for each year to determine any over- or under-collection of revenue requirements and we record 
a  revenue  deferral  or  accrual  for  the  difference. The  true-up  mechanisms  under  our  Formula  Rates  are 
considered alternative revenue programs of rate-regulated utilities. Operating revenues arising from these 
alternative revenue programs are presented on our consolidated statements of comprehensive income in 
the  line  “Formula  Rate  true-up”,  which  is  separate  from  the  reporting  of  our  tariff  revenues,  which  are 
presented  in  the  line  “Transmission  and  other  services”.  Only  the  initial  origination  of  our  alternative 
revenue program revenue is reported in the Formula Rate true-up line on our consolidated statements of 
comprehensive income. When those amounts are subsequently included in the price of utility service and 
billed or refunded to customers, we account for that event as the recovery or settlement of the associated 
regulatory  asset  or  regulatory  liability,  respectively.  Refer  to  Note  6  under  “Cost-Based  Formula  Rates 
with  True-Up  Mechanism”  and  Note  4  under  “Formula  Rate  True-Up”  for  a  discussion  of  our  revenue 
accounting under our cost-based Formula Rates.

Share-Based  Payment  and  Employee  Share  Purchase  Plan  —  Under  our  long-term  incentive  plans, 
we  grant  long-term  incentive  awards  consisting  of  PBUs  and  SBUs.  Generally,  each  PBU  and  SBU 
granted  is  valued  based  on  one  share  of  Fortis  common  stock  traded  on  the  Toronto  Stock  Exchange, 
converted to U.S. dollars and settled only in cash. However, certain SBUs granted to the executives may 
settle  in  cash,  100%  Fortis  common  stock,  or  50%  cash  and  50%  Fortis  common  stock  depending  on 
executives’ settlement elections and whether certain share ownership requirements are met. The awards 
are  classified  as  liability  awards  and  vest  on  the  date  specified  in  the  applicable  grant  agreements, 
provided  the  service  and  performance  criteria,  as  applicable,  are  satisfied.  The  PBUs  and  SBUs  earn 
dividend equivalents which are also re-measured and settled consistent with the target award at the end 
of the vesting period.

Compensation  cost  is  recognized  over  the  expected  vesting  period  and  remeasured  each  reporting 
period based on Fortis’ stock price. The PBUs are also remeasured each reporting period based on the 
applicable  market  and  performance  conditions  in  the  awards.  Compensation  cost  is  adjusted  for 
forfeitures in the period in which they occur and the final measure of compensation cost for the awards is 
based on the cash settlement amount.

We also have an Employee Share Purchase Plan which enables ITC employees to purchase shares of 
Fortis  common  stock.  Our  cost  of  the  plan  is  based  on  the  value  of  our  contribution,  as  additional 
compensation to a participating employee, equal to 10% of an employee’s contribution up to a maximum 

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annual  contribution  of  1%  of  an  employee’s  base  pay  and  an  amount  equal  to  10%  of  all  dividends 
payable by Fortis on the Fortis shares allocated to an employee’s ESPP account.

Refer to Note 15 for additional discussion of the plans.

Comprehensive  Income  (Loss)  —  Comprehensive  income  (loss)  is  the  change  in  common 
stockholder’s  equity  during  a  period  arising  from  transactions  and  events  from  non-owner  sources, 
including net income and any gain or loss arising from our interest rate swaps.

Income Taxes — Deferred income taxes are recognized for the expected future tax consequences of 
events  that  have  been  recognized  in  the  consolidated  financial  statements  or  tax  returns.  Deferred 
income  tax  assets  and  liabilities  are  determined  based  on  the  differences  between  the  financial 
statements and the tax bases of various assets and liabilities, using the tax rates expected to be in effect 
for  the  year  in  which  the  differences  are  expected  to  reverse,  and  classified  as  non-current  in  our 
consolidated statements of financial position.

The  accounting  standards  for  uncertainty  in  income  taxes  prescribe  a  recognition  threshold  and  a 
measurement  attribute  for  tax  positions  taken,  or  expected  to  be  taken,  in  a  tax  return  that  may  not  be 
sustainable. As of December 31, 2020, we have not recognized any uncertain income tax positions.

We file our federal and Michigan income tax returns as part of the FortisUS consolidated tax returns 
and we are a party to an intercompany tax sharing agreement that establishes the method for determining 
tax  liabilities  that  are  due  and  allocating  tax  attributes  that  are  utilized  on  the  consolidated  income  tax 
returns. We continue to file with various other state and city jurisdictions where we have a separate return 
filing  obligation.  Our  prior  consolidated  federal  tax  returns  are  no  longer  subject  to  U.S.  federal  tax 
examinations for tax years 2017 and earlier. State and city jurisdictions that remain subject to examination 
range from tax years 2016 to 2019. In the event we are assessed interest or penalties by any income tax 
jurisdictions,  interest  and  penalties  would  be  recorded  as  interest  expense  and  other  expense, 
respectively, in our consolidated statements of comprehensive income.

Refer to Notes 7 and 11 for additional discussion on income taxes.

4.  REVENUE 

Our total revenues are comprised of revenues which arise from three classifications including transmission 
services, other services, and Formula Rate true-up. As other services revenue is immaterial, it is presented in 
combination with transmission services on the consolidated statements of comprehensive income.

Transmission Services

transmission  systems.  As 

Through  our  Regulated  Operating  Subsidiaries,  we  generate  nearly  all  our  revenue  from  providing  electric 
transmission  services  over  our 
transmission  companies,  our 
transmission services are provided and revenues are received based on our tariffs, as approved by the FERC. 
The  transmission  revenue  requirements  at  our  Regulated  Operating  Subsidiaries  are  set  annually  using 
Formula Rates and remain in effect for a one-year period. By updating the inputs to the formula and resulting 
rates on an annual basis, the revenues at our Regulated Operating Subsidiaries reflect changing operating data 
and financial performance, including the amount of network load on their transmission systems (for our MISO 
Regulated  Operating  Subsidiaries),  operating  expenses  and  additions  to  property,  plant  and  equipment  when 
placed in service, among other items.

independent 

We  recognize  revenue  for  transmission  services  over  time  as  transmission  services  are  provided  to 
customers (generally using an output measure of progress based on transmission load delivered). Customers 
simultaneously receive and consume the benefits provided by the Regulated Operating Subsidiaries’ services. 
We  recognize  revenue  in  the  amount  to  which  we  have  the  right  to  invoice  because  we  have  a  right  to 
consideration in an amount that corresponds directly with the value to the customer of performance completed 
to date. As billing agents, MISO and SPP independently bill our customers on a monthly basis and collects fees 
for  the  use  of  our  transmission  systems.  No  component  of  the  transaction  price  is  allocated  to  unsatisfied 
performance obligations.

Transmission  service  revenue  includes  an  estimate  for  unbilled  revenues  from  service  that  has  been 
provided but not billed by the end of an accounting period. Unbilled revenues are dependent upon a number of 
factors  that  require  management’s  judgment  including  estimates  of  transmission  network  load  (for  the  MISO 

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Regulated Operating Subsidiaries) and preliminary information provided by billing agents. Due to the seasonal 
fluctuations of actual load, the unbilled revenue amount generally increases during the spring and summer and 
decreases during the fall and winter. See Note 5 for information on changes in unbilled accounts receivable.

Other Services

Other  services  revenue  consists  of  rental  revenues,  easement  revenues,  and  amounts  from  providing 
ancillary services. A portion of other services revenue is treated as a revenue credit and reduces gross revenue 
requirement when calculating net revenue requirement under our Formula Rates. Total other services revenue 
was $5 million, $7 million and $5 million for the years ended December 31, 2020, 2019 and 2018, respectively.

Formula Rate True-Up

The  true-up  mechanism  under  our  Formula  Rates  is  considered  an  alternative  revenue  program  of  a  rate-
regulated utility given it permits our Regulated Operating Subsidiaries to adjust future rates in response to past 
activities or completed events in order to collect our actual revenue requirements under our Formula Rates. In 
accordance with our accounting policy, only the current year origination of the true-up is reported as a Formula 
Rate true-up. See “Cost-Based Formula Rates with True-Up Mechanism” in Note 6 for more information on our 
Formula Rates.

5.  ACCOUNTS RECEIVABLE

The  following  table  presents  the  components  of  accounts  receivable  on  the  consolidated  statements  of 

financial position:

(In millions of USD)

Trade accounts receivable

Unbilled accounts receivable

Other

Total accounts receivable

6.  REGULATORY MATTERS

December 31,

2020

2019

2018

2017

$ 

2  $ 

2  $ 

2  $ 

102 

10 

102 

13 

92 

8 

2 

108 

9 

$ 

114  $ 

117  $ 

102  $ 

119 

Cost-Based Formula Rates with True-Up Mechanism

The  transmission  revenue  requirements  at  our  Regulated  Operating  Subsidiaries  are  set  annually  using 
Formula Rates and remain in effect for a one-year period. By updating the inputs to the formula and resulting 
rates  on  an  annual  basis,  the  revenues  at  our  Regulated  Operating  Subsidiaries  reflect  changing  operational 
data  and  financial  performance,  including  the  amount  of  network  load  on  their  transmission  systems  (for  our 
MISO  Regulated  Operating  Subsidiaries),  operating  expenses  and  additions  to  property,  plant  and  equipment 
when placed in service, among other items. The formula used to derive the rates does not require further action 
or  FERC  filings  each  year,  although  the  formula  inputs  remain  subject  to  legal  challenge  at  the  FERC.  Our 
Regulated Operating Subsidiaries will continue to use the formula to calculate their respective annual revenue 
requirements  unless  the  FERC  determines  the  resulting  rates  to  be  unjust  and  unreasonable  and  another 
mechanism is determined by the FERC to be just and reasonable. See “Rate of Return on Equity Complaints” in 
Note  18  for  detail  on  ROE  matters  for  our  MISO  Regulated  Operating  Subsidiaries  and  "Incentive Adders  for 
Transmission Rates" discussed in Note 6 herein.

The cost-based Formula Rates at our Regulated Operating Subsidiaries include a true-up mechanism that 
compares the actual revenue requirements of our Regulated Operating Subsidiaries to their billed revenues for 
each  year  to  determine  any  over-  or  under-collection  of  revenue  requirements.  Revenue  is  recognized  for 
services  provided  during  each  reporting  period  based  on  actual  revenue  requirements  calculated  using  the 
formula. Our Regulated Operating Subsidiaries accrue or defer revenues to the extent that the actual revenue 
requirement  for  the  reporting  period  is  higher  or  lower,  respectively,  than  the  amounts  billed  relating  to  that 
reporting period. The amount of accrued or deferred revenues is reflected in future revenue requirements and 
thus flows through to customer bills within two years under the provisions of our Formula Rates.

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The net changes in regulatory assets and liabilities associated with our Regulated Operating Subsidiaries’ 
Formula Rate revenue accruals and deferrals, including accrued interest, were as follows during the year ended 
December 31, 2020:

(In millions of USD)

Net regulatory assets as of December 31, 2019

Net refund of 2018 revenue deferrals and accruals, including accrued interest

Net revenue accrual for the year ended December 31, 2020

Net accrued interest payable for the year ended December 31, 2020

Net regulatory assets as of December 31, 2020

Total

3 

40 

8 

(1) 

50 

$ 

$ 

Regulatory  assets  and  liabilities  associated  with  our  Regulated  Operating  Subsidiaries’  Formula  Rate 
revenue  accruals  and  deferrals,  including  accrued  interest,  are  recorded  in  the  consolidated  statements  of 
financial position as follows:

(In millions of USD)

Current regulatory assets

Non-current regulatory assets

Current regulatory liabilities

Non-current regulatory liabilities

Net regulatory assets

Incentive Adders for Transmission Rates

December 31,

2020

2019

$ 

44  $ 

19 

(1)   

(12)   

$ 

50  $ 

12 

43 

(51) 

(1) 

3 

The  FERC  has  authorized  the  use  of  ROE  incentives,  or  adders,  that  can  be  applied  to  the  rates  of TOs 
when certain conditions are met. Our MISO Regulated Operating Subsidiaries and ITC Great Plains utilize ROE 
adders related to independent transmission ownership and RTO participation.

MISO Regulated Operating Subsidiaries

On April 20, 2018, Consumers Energy, IP&L, Midwest Municipal Transmission Group, Missouri River Energy 
Services,  Southern  Minnesota  Municipal  Power  Agency  and  WPPI  Energy  filed  a  complaint  with  the  FERC 
under section 206 of the FPA, challenging the adders for independent transmission ownership that are included 
in  transmission  rates  charged  by  the  MISO  Regulated  Operating  Subsidiaries.  The  adders  for  independent 
transmission ownership allowed up to 50 basis points or 100 basis points to be added to the MISO Regulated 
Operating  Subsidiaries’  authorized  ROE,  subject  to  any  ROE  cap  established  by  the  FERC.  On  October  18, 
2018,  the  FERC  issued  an  order  granting  the  complaint  in  part,  setting  revised  adders  for  independent 
transmission  ownership  for  each  of  the  MISO  Regulated  Operating  Subsidiaries  to  25  basis  points,  and 
requiring the MISO Regulated Operating Subsidiaries to include the revised adders, effective April 20, 2018, in 
their  Formula  Rates.  In  addition,  the  order  directed  the  MISO  Regulated  Operating  Subsidiaries  to  provide 
refunds,  with  interest,  for  the  period  from  April  20,  2018  through  October  18,  2018.  The  MISO  Regulated 
Operating  Subsidiaries  began  reflecting  the  25  basis  point  adder  for  independent  transmission  ownership  in 
transmission rates in November 2018. Refunds of $7 million were primarily made in the fourth quarter of 2018 
and were completed in the first quarter of 2019. The MISO Regulated Operating Subsidiaries sought rehearing 
of  the  FERC’s  October  18,  2018  order,  and  on  July  18,  2019,  the  FERC  denied  the  rehearing  request.  On 
September  11,  2019,  the  MISO  Regulated  Operating  Subsidiaries  filed  an  appeal  of  the  FERC’s  order  in  the 
D.C.  Circuit  Court.  On  December  16,  2019,  the  D.C.  Circuit  Court  established  a  briefing  schedule  for  the 
appeal.  An  initial  brief  was  filed  on  January  27,  2020  and  a  reply  brief  was  filed  on  April  24,  2020.  Oral 
argument  on  the  appeal  was  held  on  September  23,  2020.  We  do  not  expect  the  final  resolution  of  this 
proceeding to have a material adverse impact on our consolidated results of operations, cash flows or financial 
condition.

For each of the years ended December 31, 2020, 2019 and 2018, the authorized incentive adders for the 
MISO  Regulated  Operating  Subsidiaries  included  a  25  basis  point  adder  for  independent  transmission 

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ownership and a 50 basis point adder for RTO participation. See Note 18 for information regarding the MISO 
ROE Complaints and the associated impact to the base ROE of our MISO Regulated Operating Subsidiaries.

ITC Great Plains

On June 11, 2019, KCC filed a complaint with the FERC under section 206 of the FPA, challenging the ROE 
adder  for  independent  transmission  ownership  that  is  included  in  the  transmission  rate  charged  by  ITC  Great 
Plains.  The  complaint  argues  that  because  ITC  Great  Plains  is  similarly  situated  to  our  MISO  Regulated 
Operating  Subsidiaries  with  respect  to  ownership  by  Fortis  and  GIC,  the  same  rationale  by  which  the  FERC 
lowered  the  MISO  Regulated  Operating  Subsidiaries  adders  for  independent  transmission  ownership,  as 
discussed above, also applies to ITC Great Plains. The adder for independent transmission ownership allowed 
up to 100 basis points to be added to the ITC Great Plains authorized ROE, subject to any ROE cap established 
by the FERC. ITC Great Plains filed an answer to the complaint on July 1, 2019 asking the FERC to deny the 
complaint since KCC showed no evidence that ITC Great Plains’ independence or the benefits they provide as 
an independent TO has been compromised or reduced as a result of the Fortis and GIC acquisition. On July 16, 
2020, the FERC issued an order granting the complaint, setting the revised adder for independent transmission 
ownership for ITC Great Plains to 25 basis points, and requiring ITC Great Plains to include the revised adder, 
effective  June  11,  2019,  in  their  Formula  Rates.  In  addition,  the  order  directed  ITC  Great  Plains  to  provide 
refunds, with interest, for the period from June 11, 2019 through July 16, 2020 within 60 days of the date of the 
order. On September 15, 2020, the FERC granted an extension to issue refunds until November 19, 2020. On 
August 17, 2020, ITC Great Plains filed a request for rehearing of the order and on September 17, 2020, the 
FERC denied the rehearing request. On November 12, 2020, ITC Great Plains filed an appeal of the July 16, 
2020 order, and on December 14, 2020, ITC Great Plains filed an appeal of the September 17, 2020 order, both 
of which were filed in the D.C. Circuit Court. As of December 31, 2019, we had recorded an estimated current 
regulatory  liability  of  $2  million  related  to  this  complaint  and  during  2020  refunds  of  $4  million  were  made  to 
settle  the  refund  liability.  We  do  not  expect  the  final  resolution  of  this  proceeding  to  have  a  material  adverse 
impact on our consolidated results of operations, cash flows or financial condition.

For each of the years ended December 31, 2019 and 2018, the authorized ROE used by ITC Great Plains 
was  12.16%  and  was  composed  of  a  base  ROE  of  10.66%  with  a  100  basis  point  adder  for  independent 
transmission ownership and a 50 basis point adder for RTO participation. Based on the July 16, 2020 order and 
as  of  December  31,  2020,  the  authorized  ROE  used  by  ITC  Great  Plains  was  revised  to  11.41%  and  is 
composed of a base ROE of 10.66% with a 25 basis point adder for independent transmission ownership and a 
50 basis point adder for RTO participation.

Rate of Return on Equity Complaints

See “Rate of Return on Equity Complaints” in Note 18 for a discussion of the MISO ROE Complaints.

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7.  REGULATORY ASSETS AND LIABILITIES

Regulatory Assets

The following table summarizes the regulatory asset balances:

(In millions of USD)

Regulatory Assets:

Current:

Revenue accruals (including accrued interest of $2 and $1 as of December 31, 
2020 and 2019, respectively) (a)
Refund related to the Initial Complaint (including accrued interest of $2 as of 
December 31, 2020) (b)

Total current

Non-current:

Revenue accruals (including accrued interest of less than $1 and $1 as of 
December 31, 2020 and 2019, respectively) (a)
ITCTransmission ADIT deferral (net of accumulated amortization of $54 and $51 
as of December 31, 2020 and 2019, respectively)
METC ADIT deferral (net of accumulated amortization of $33 and $31 as of 
December 31, 2020 and 2019, respectively)
METC regulatory deferrals (net of accumulated amortization of $11 and $10 as 
of December 31, 2020 and 2019, respectively)

Income taxes recoverable related to AFUDC equity
ITC Great Plains start-up, development and pre-construction (net of 
accumulated amortization of $7 and $6 as of December 31, 2020 and 2019, 
respectively)

Pensions and postretirement
Income taxes recoverable related to implementation of the Michigan Corporate 
Income Tax

Accrued asset removal costs

Total non-current

Total

____________________________

December 31,

2020

2019

$ 

44  $ 

8 

52 

19 

7 

10 

4 

106 

6 

30 

6 

24 

212 

$ 

264  $ 

12 

— 

12 

43 

10 

12 

5 

99 

7 

25 

7 

21 

229 

241 

(a) Refer  to  discussion  of  revenue  accruals  in  Note  6  under  “Cost-Based  Formula  Rates  with  True-Up 
Mechanism.” Our Regulated Operating Subsidiaries do not earn a return on the balance of these regulatory 
assets,  but  do  accrue  interest  carrying  costs,  which  are  subject  to  rate  recovery  along  with  the  principal 
amount of the revenue accrual.

(b) Refer to discussion of the refund liability in Note 18 under “Rate of Return on Equity Complaints.”

ITCTransmission ADIT Deferral

The  carrying  amount  of  the  ITCTransmission  ADIT  Deferral  is  the  remaining  unamortized  balance  of  the 
portion  of  ITCTransmission’s  purchase  price  in  excess  of  fair  value  of  net  assets  acquired  from  DTE  Energy 
approved for inclusion in future rates by the FERC. The original amount recorded for this regulatory asset of $61 
million  is  recognized  in  rates  and  amortized  on  a  straight-line  basis  over  20  years  beginning  March  1,  2003. 
ITCTransmission  includes  the  remaining  unamortized  balance  of  this  regulatory  asset  in  rate  base. 
ITCTransmission  recorded  amortization  expense  of  $3  million  annually  during  2020,  2019  and  2018,  which  is 
included  in  depreciation  and  amortization  in  our  consolidated  statements  of  comprehensive  income  and 
recovered through ITCTransmission’s cost-based Formula Rate template.

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METC ADIT Deferral

The  carrying  amount  of  the  METC  ADIT  Deferral  is  the  remaining  unamortized  balance  of  the  portion  of 
METC’s purchase price in excess of the fair value of net assets acquired at the time MTH acquired METC from 
Consumers  Energy  approved  for  inclusion  in  future  rates  by  the  FERC.  The  original  amount  approved  for 
recovery recorded for this regulatory asset of $43 million is recognized in rates and amortized on a straight-line 
basis  over  18  years  beginning  January  1,  2007.  METC  includes  the  remaining  unamortized  balance  of  this 
regulatory  asset  in  rate  base.  METC  recorded  amortization  expense  of  $2  million  annually  during  2020,  2019 
and 2018, which is included in depreciation and amortization in our consolidated statements of comprehensive 
income and recovered through METC’s cost-based Formula Rate template.

METC Regulatory Deferrals

The carrying amount of the METC Regulatory Deferrals is the amount METC has deferred, as a regulatory 
asset, of depreciation and related interest expense associated with new transmission assets placed in service 
from  January  1,  2001  through  December  31,  2005  that  were  included  on  METC’s  balance  sheet  at  the  time 
MTH  acquired  METC  from  Consumers  Energy. The  original  amount  recorded  for  this  regulatory  asset  of  $15 
million, and approved for inclusion in future rates by the FERC, is recognized in rates and amortized over 20 
years beginning January 1, 2007. METC includes the remaining unamortized balance of this regulatory asset in 
rate base. METC recorded amortization expense of $1 million annually during 2020, 2019 and 2018, which is 
included  in  depreciation  and  amortization  in  our  consolidated  statements  of  comprehensive  income  and 
recovered through METC’s cost-based Formula Rate template.

Income Taxes Recoverable Related to AFUDC Equity

Accounting  standards  for  income  taxes  provide  that  a  regulatory  asset  be  recorded  if  it  is  probable  that  a 
future increase in taxes payable, relating to the book depreciation of AFUDC equity that has been capitalized to 
property, plant and equipment, will be recovered from customers through future rates. The regulatory asset for 
the  tax  effects  of  AFUDC  equity  is  recovered  over  the  life  of  the  underlying  book  asset  in  a  manner  that  is 
consistent  with  the  depreciation  of  the  AFUDC  equity  that  has  been  capitalized  to  property,  plant  and 
equipment. This regulatory asset and the related offsetting deferred income tax liabilities do not affect rate base.

ITC Great Plains Start-Up, Development and Pre-Construction

In 2013, ITC Great Plains made a filing with the FERC, under Section 205 of the FPA, to recover start-up, 
development and pre-construction expenses in future rates. These expenses included certain costs incurred by 
ITC Great Plains for two regional cost sharing projects in Kansas prior to construction. In March 2015, FERC 
accepted ITC Great Plains’ request to commence amortization of the authorized regulatory assets, subject to 
refund.  In  December  2015,  the  FERC  issued  an  order  accepting  an  uncontested  settlement  agreement 
establishing the amounts of the regulatory assets and associated carrying charges to be recovered. ITC Great 
Plains includes the unamortized balance of these regulatory assets in rate base and will amortize them over a 
10-year period, beginning in the second quarter of 2015. The amortization expense is recorded to general and 
administrative expenses in our consolidated statements of comprehensive income and recovered through ITC 
Great Plains’ cost-based Formula Rate.

Pensions and Postretirement

Accounting  standards  for  defined  benefit  pension  and  other  postretirement  plans  for  rate-regulated  entities 
allow for amounts that otherwise would have been charged to AOCI to be recorded as a regulatory asset. As the 
unrecognized  amounts  recorded  to  this  regulatory  asset  are  recognized,  expenses  will  be  recovered  from 
customers  in  future  rates  under  our  cost  based  Formula  Rates.  This  regulatory  asset  is  not  included  when 
determining rate base.

Income Taxes Recoverable Related to Implementation of the Michigan Corporate Income Tax

Under  the  Michigan  Corporate  Income  Tax,  we  are  taxed  at  a  rate  of  6.0%  on  federal  taxable  income 
attributable  to  our  operations  in  the  state  of  Michigan,  subject  to  certain  adjustments.  In  2011,  due  to  certain 
Michigan tax law changes we were required to establish new deferred income tax balances under the Michigan 
Corporate  Income  Tax,  and  the  net  result  was  incremental  deferred  state  income  tax  liabilities  at  both 
ITCTransmission and METC. Under our cost-based Formula Rate, the future tax receivable as a result of the 
tax law change has resulted in the recognition of a regulatory asset, which will be collected from customers for 

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the  23-year  period  and  the  32-year  period  for  ITCTransmission  and  METC,  respectively,  beginning  in  2016. 
ITCTransmission and METC include this regulatory asset within deferred taxes for rate-making purposes when 
determining rate base.

Accrued Asset Removal Costs

The carrying amount of the accrued asset removal costs represents the difference between incurred costs to 
remove  property,  plant  and  equipment  and  the  estimated  removal  costs  included  and  collected  in  rates.  The 
portion of depreciation expense included in our depreciation rates related to asset removal costs reduces this 
regulatory asset and removal costs incurred are added to this regulatory asset. In addition, this regulatory asset 
has also been adjusted for timing differences between incurred costs to settle legal asset retirement obligations 
and  the  recognition  of  such  obligations  under  the  standards  set  forth  by  the  FASB.  Our  Regulated  Operating 
Subsidiaries  include  this  item,  excluding  the  cost  component  related  to  the  recognition  of  our  legal  asset 
retirement obligations under the standards set forth by the FASB, as a reduction to accumulated depreciation for 
rate-making purposes, when determining rate base.

Regulatory Liabilities

The following table summarizes the regulatory liability balances:

(In millions of USD)

Regulatory Liabilities:

Current:

Revenue deferrals (including accrued interest of less than $1 and $4 as of 
December 31, 2020 and 2019, respectively) (a)
Refund related to the Initial Complaint (including accrued interest of $1 and $6 
as of December 31, 2020 and 2019, respectively) (b)

Refund related to ITC Great Plains incentive adder complaint (c)

Total current 

Non-current:

Revenue deferrals (including accrued interest of less than $1 as of December 
31, 2020 and 2019) (a)

Accrued asset removal costs

Excess state income tax deductions

Income taxes refundable related to implementation of the TCJA

Pensions and postretirement

Other

Total non-current

Total

____________________________

December 31,

2020

2019

$ 

1  $ 

13 

— 

14 

12 

73 

3 

507 

16 

1 

612 

$ 

626  $ 

51 

70 

2 

123 

1 

72 

2 

509 

— 

— 

584 

707 

(a) Refer  to  discussion  of  revenue  deferrals  in  Note  6  under  “Cost-Based  Formula  Rates  with  True-Up 
Mechanism.”  Our  Regulated  Operating  Subsidiaries  accrue  interest  on  the  true-up  amounts  which  will  be 
refunded through rates along with the principal amount of revenue deferrals in future periods.

(b) Refer to discussion of the refund liability in Note 18 under “Rate of Return on Equity Complaints.”

(c) Refer  to  discussion  of  the  ITC  Great  Plains  incentive  adder  in  Note  6  under  “Incentive  Adders  for 

Transmission Rates.”

Accrued Asset Removal Costs

The carrying amount of the accrued asset removal costs represents the difference between incurred costs to 
remove  property,  plant  and  equipment  and  the  estimated  removal  costs  included  and  collected  in  rates.  The 
portion of depreciation expense included in our depreciation rates related to asset removal costs is added to this 
regulatory  liability  and  removal  expenditures  incurred  are  charged  to  this  regulatory  liability.  Our  Regulated 

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Operating  Subsidiaries  include  this  item  within  accumulated  depreciation  for  rate-making  purposes  and 
determining rate base.

Excess State Income Tax Deductions

Our  Regulated  Operating  Subsidiaries  have  taken  state  income  tax  deductions  associated  with  property 
additions  that  exceed  the  tax  basis  of  property,  and  the  unrealized  income  tax  benefits  resulting  from  these 
deductions  are  expected  to  be  refunded  to  customers  through  future  rates  when  the  income  tax  benefits  are 
realized. This  regulatory  liability  is  included  within  deferred  taxes  for  rate-making  purposes  when  determining 
rate base.

Income Taxes Refundable Related to Implementation of the TCJA

Under the TCJA the income tax rate changed from 35% to 21% effective for tax years beginning after 2017. 
The Company was required to revalue its deferred tax assets and liabilities at the new federal corporate income 
tax rate as of the date of the enactment of the TCJA, which resulted in lower net deferred tax liabilities and the 
establishment  of  a  net  regulatory  liability  for  excess  deferred  taxes  at  our  Regulated  Operating  Subsidiaries. 
The  excess  deferred  taxes  are  generally  the  result  of  accelerated  federal  tax  deductions  realized  by  our 
Regulated Operating Subsidiaries in periods when the U.S. federal corporate income tax rate was 35% and now 
would  be  returned  to  customers  in  a  period  where  the  U.S.  federal  corporate  income  tax  rate  is  21%. As  the 
excess  deferred  taxes  must  be  returned  to  customers  this  net  regulatory  liability  is  recognized.  For  our 
Regulated Operating Subsidiaries, our deferred taxes are subject to a normalization method of accounting for 
the  excess  tax  reserves  resulting  from  the  change  in  the  federal  statutory  tax  rate  which  involves  the  use  of 
ARAM  for  the  determination  of  the  timing  of  the  return  of  the  excess  deferred  taxes  to  customers  associated 
with  public  utility  property.  In  addition,  a  portion  of  our  excess  deferred  taxes  at  our  Regulated  Operating 
Subsidiaries are associated with other types of deferred taxes that are not related to public utility property and 
are subject to amortization. We have elected to amortize these excess deferred taxes using RSGM. During the 
years ended December 31, 2020 and 2019, we recorded $2 million and $1 million, respectively, of amortization 
related  to  the  excess  deferred  taxes  under  ARAM  and  RSGM.  The  net  regulatory  liability  is  included  within 
deferred taxes for rate-making purposes when determining rate base.

Pensions and Postretirement

Accounting  standards  for  defined  benefit  pension  and  other  postretirement  plans  for  rate-regulated  entities 
allow for amounts that otherwise would have been credited to AOCI to be recorded as a regulatory liability. As 
the  unrecognized  amounts  recorded  to  this  regulatory  liability  are  recognized,  amounts  will  be  returned  to 
customers  in  future  rates  under  our  cost  based  Formula  Rates.  This  regulatory  liability  is  not  included  when 
determining rate base.

8.  PROPERTY, PLANT AND EQUIPMENT

Property, plant and equipment — net consisted of the following:

(In millions of USD)

Property, plant and equipment

Regulated Operating Subsidiaries:

December 31,

2020

2019

Property, plant and equipment in service

$ 

10,661  $ 

Construction work in progress

Capital equipment inventory

Other

ITC Holdings and other

Total

Less: Accumulated depreciation and amortization

Property, plant and equipment, net

523 

103 

81 

14 
11,382 

(2,055)   

$ 

9,327  $ 

9,973 

375 

99 

51 

14 
10,512 

(1,930) 

8,582 

Additions  to  property,  plant  and  equipment  in  service  and  construction  work  in  progress  during  2020  and 
2019 were due primarily to asset acquisitions and projects to upgrade or replace existing transmission plant and 

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update grid security to improve the reliability of our transmission systems as well as transmission infrastructure 
to support generator interconnections and investments that provide regional benefits such as our MVPs.

9.  GOODWILL AND INTANGIBLE ASSETS

Goodwill

At December 31, 2020 and 2019, we had goodwill balances recorded at ITCTransmission, METC and ITC 
Midwest of $173 million, $454 million and $323 million, respectively, which resulted from the ITCTransmission 
and METC acquisitions and ITC Midwest’s acquisition of the IP&L transmission assets, respectively.

Intangible Assets

METC has recorded intangible assets with finite lives derived from the portion of regulatory assets recorded 
on  METC’s  historical  FERC  financial  statements  that  were  not  recorded  on  METC’s  historical  GAAP  financial 
statements. These intangible assets are associated with the METC Regulatory Deferrals and the METC ADIT 
Deferral  as  described  in  Note  7.  The  carrying  amounts  of  the  intangible  asset  for  the  METC  Regulatory 
Deferrals and the METC ADIT Deferral were $12 million and $4 million (net of accumulated amortization of $28 
million  and  $15  million),  respectively,  as  of  December  31,  2020,  and  $14  million  and  $5  million  (net  of 
accumulated  amortization  of  $26  million  and  $14  million),  respectively,  as  of  December  31,  2019.  The 
amortization  periods  for  the  METC  Regulatory  Deferrals  and  the  METC  ADIT  Deferral  are  20  and  18, 
respectively, beginning January 1, 2007. METC earns an equity return on the remaining unamortized balance of 
both  intangible  assets  and  recovers  the  amortization  expense  through  METC’s  cost-based  Formula  Rate 
template.

ITC Great Plains has recorded intangible assets for payments made by and obligations of ITC Great Plains 
to certain TOs to acquire rights, which are required under the SPP tariff to designate ITC Great Plains to build, 
own and operate projects within the SPP region, including three regional cost sharing projects in Kansas. The 
carrying amount of these intangible assets was $13 million and $14 million (net of accumulated amortization of 
$3 million and $2 million) as of December 31, 2020 and 2019, respectively. The amortization period for these 
intangible assets is 50 years, beginning March 31, 2011.

We recognized $4 million, $3 million, and $4 million of amortization expense of our intangible assets during 
the years ended December 31, 2020, 2019 and 2018, respectively, recorded in depreciation and amortization 
on the consolidated statements of comprehensive income. We expect the annual amortization of our intangible 
assets that have been recorded as of December 31, 2020 to be as follows:

(In millions of USD)

2021

2022

2023

2024

2025

2026 and thereafter

Total

$ 

$ 

3 

3 

4 

3 

3 

13 

29 

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10.  DEBT

Amounts  of  outstanding  debt  were  classified  as  debt  maturing  within  one  year  and  long-term  debt  in  the 

consolidated statements of financial position as follows:

(In millions of USD)

December 31,

2020

2019

ITC Holdings 6.375% Senior Notes, due September 30, 2036

$ 

200  $ 

ITC Holdings 4.05% Senior Notes, due July 1, 2023

ITC Holdings 3.65% Senior Notes, due June 15, 2024

ITC Holdings 5.30% Senior Notes, due July 1, 2043

ITC Holdings 3.25% Notes, due June 30, 2026

ITC Holdings 2.70% Senior Notes, due November 15, 2022 

ITC Holdings 3.35% Senior Notes, due November 15, 2027 

ITC Holdings 2.95% Senior Notes, due May 14, 2030

ITC Holdings Term Loan Credit Agreement, due June 11, 2021

ITC Holdings Revolving Credit Agreement, due October 21, 2023

ITC Holdings Commercial Paper Program (a)

ITCTransmission 6.125% First Mortgage Bonds, Series C, due March 31, 2036

ITCTransmission 4.625% First Mortgage Bonds, Series E, due August 15, 2043

ITCTransmission 4.27% First Mortgage Bonds, Series F, due June 10, 2044

ITCTransmission 4.00% First Mortgage Bonds, Series G, due March 30, 2053

ITCTransmission 3.30% First Mortgage Bonds, Series H, due August 28, 2049

ITCTransmission Revolving Credit Agreement, due October 21, 2023

METC 5.64% Senior Secured Notes, due May 6, 2040

METC 3.98% Senior Secured Notes, due October 26, 2042

METC 4.19% Senior Secured Notes, due December 15, 2044

METC 3.90% Senior Secured Notes, due April 26, 2046

METC 4.55% Senior Secured Notes, due January 15, 2049

METC 4.65% Senior Secured Notes, due July 10, 2049

METC 3.02% Senior Secured Notes, due October 14, 2055

METC Revolving Credit Agreement, due October 21, 2023 

ITC Midwest 6.15% First Mortgage Bonds, Series A, due January 31, 2038

ITC Midwest 7.27% First Mortgage Bonds, Series C, due December 22, 2020 (a)

ITC Midwest 4.60% First Mortgage Bonds, Series D, due December 17, 2024

ITC Midwest 3.50% First Mortgage Bonds, Series E, due January 19, 2027

ITC Midwest 4.09% First Mortgage Bonds, Series F, due April 30, 2043

ITC Midwest 3.83% First Mortgage Bonds, Series G, due April 7, 2055

ITC Midwest 4.16% First Mortgage Bonds, Series H, due April 18, 2047

ITC Midwest 4.32% First Mortgage Bonds, Series I, due November 1, 2051

ITC Midwest 3.13% First Mortgage Bonds, Series J, due July 15, 2051

ITC Midwest Revolving Credit Agreement, due October 21, 2023

ITC Great Plains 4.16% First Mortgage Bonds, Series A, due November 26, 2044

ITC Great Plains Revolving Credit Agreement, due October 21, 2023

Total principal

Unamortized deferred financing fees and discount

Total debt

____________________________

250 

400 

300 

400 

500 

500 

700 

— 

37 

67 

100 

285 

100 

225 

75 

33 

50 

75 

150 

200 

50 

50 

150 

20 

175 

— 

75 

100 

100 

225 

200 

175 

180 

75 

150 

33 

200 

250 

400 

300 

400 

500 

500 

— 

200 

34 

200 

100 

285 

100 

225 

75 

24 

50 

75 

150 

200 

50 

50 

— 

79 

175 

35 

75 

100 

100 

225 

200 

175 

— 

130 

150 

32 

6,405 

(43) 

$ 

6,362  $ 

5,844 

(37) 

5,807 

(a) As of December 31, 2020 and 2019 there was $67 million and $235 million, respectively, of debt included 

within debt maturing within one year in the consolidated statements of financial position.

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The annual maturities of debt as of December 31, 2020 are as follows:

(In millions of USD)

2021

2022

2023

2024

2025

2026 and thereafter

Total

ITC Holdings

Senior Unsecured Notes

$ 

$ 

67 

500 

448 

475 

— 

4,915 

6,405 

On May 14, 2020, ITC Holdings completed the private offering of $700 million aggregate principal amount of 
unsecured 2.95% Senior Notes, due May 14, 2030. The net proceeds from this offering were used to repay the 
amount outstanding under ITC Holdings’ $400 million term loan credit agreement, to repay $122 million under 
ITC  Holdings’  revolving  credit  agreement,  and  to  repay  $92  million  under  ITC  Holdings’  commercial  paper 
program, with remaining proceeds to be used for general corporate purposes. These Senior Notes were issued 
under ITC Holdings’ indenture, dated April 18, 2013.

Term Loan Credit Agreement

On  June  12,  2019,  ITC  Holdings  entered  into  an  unsecured,  unguaranteed  $400  million  term  loan  credit 
agreement  with  a  maturity  date  of  June  11,  2021,  under  which  ITC  Holdings  borrowed  $200  million.  The 
proceeds were used for the early redemption of the $200 million 5.50% Senior Notes due January 15, 2020. In 
January  2020,  ITC  Holdings  drew  upon  the  remaining  $200  million  under  the  term  loan  credit  agreement  to 
repay  outstanding  commercial  paper  balances.  These  borrowings  were  repaid  in  full  in  May  2020  from  the 
proceeds  of  the  ITC  Holdings  Senior  Notes  issued  on  May  14,  2020.  The  weighted-average  interest  rate 
throughout the life of the loan was 2.27%.

Commercial Paper Program

ITC Holdings has an ongoing commercial paper program for the issuance and sale of unsecured commercial 
paper  in  an  aggregate  amount  not  to  exceed  $400  million  outstanding  at  any  one  time. As  of  December  31, 
2020,  ITC  Holdings  had  $67  million  of  commercial  paper,  net  of  discount,  issued  and  outstanding  under  the 
program, with a weighted-average interest rate of 0.3% and weighted average remaining days to maturity of 14 
days. The amount outstanding as of December 31, 2020 was classified as debt maturing within one year in the 
consolidated  statements  of  financial  position.  As  of  December  31,  2019,  ITC  Holdings  had  $200  million  of 
commercial paper issued and outstanding.

ITCTransmission

First Mortgage Bonds

On  August  28,  2019,  ITCTransmission  issued  $75  million  aggregate  principal  amount  of  3.30%  First 
Mortgage  Bonds,  due  August  28,  2049.  The  proceeds  were  used  to  repay  existing  indebtedness  under  the 
revolving credit agreement and will also be used to partially fund capital expenditures and for general corporate 
purposes. All of ITCTransmission’s First Mortgage Bonds are issued under its First Mortgage and Deed of Trust 
and secured by a first mortgage lien on substantially all of its real property and tangible personal property.

METC

Senior Secured Notes

On  October  14,  2020,  METC  issued  $150  million  of  3.02%  Senior  Secured  Notes,  due  October  14,  2055. 
The  proceeds  from  the  issuance  were  used  to  repay  amounts  outstanding  under  METC’s  term  loan  credit 
agreement, to repay borrowings under its revolving credit agreement, to partially fund capital expenditures and 
for  general  corporate  purposes.  All  of  METC’s  Senior  Secured  Notes  are  issued  under  its  first  mortgage 

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indenture  and  secured  by  a  first  mortgage  lien  on  substantially  all  of  its  real  property  and  tangible  personal 
property.

On January 15, 2019, METC issued $50 million of 4.55% Senior Secured Notes, due January 15, 2049. On 
July  10,  2019,  METC  issued  an  additional  $50  million  of  Senior  Secured  Notes  at  4.65%  with  terms  and 
conditions  identical  to  those  of  the  4.55%  Senior  Secured  Notes  except  the  interest  rate  which  includes  a  10 
basis point premium and the due date which is 30 years from the date of the issuance. The proceeds from both 
issuances were used to repay borrowings under the METC revolving credit agreement, to partially fund capital 
expenditures and for general corporate purposes. All of METC’s Senior Secured Notes are issued under its first 
mortgage  indenture  and  secured  by  a  first  mortgage  lien  on  substantially  all  of  its  real  property  and  tangible 
personal property.

Term Loan Credit Agreement

On  January  23,  2020,  METC  entered  into  an  unsecured,  unguaranteed  term  loan  credit  agreement,  due 
January  23,  2021,  under  which  METC  borrowed  the  maximum  of  $75  million  available  under  the  agreement. 
The  proceeds  were  used  for  general  corporate  purposes,  primarily  the  repayment  of  borrowings  under  the 
METC revolving credit agreement. This borrowing was repaid in full on October 14, 2020 from the proceeds of 
the METC Senior Secured Notes issued on October 14, 2020. The weighted-average interest rate throughout 
the life of the loan was 1.08%.

ITC Midwest

First Mortgage Bonds

On July 15, 2020, ITC Midwest issued an aggregate of $180 million of 3.13% First Mortgage Bonds due July 
15,  2051.  The  proceeds  were  used  to  partially  repay  existing  indebtedness  under  the  ITC  Midwest  revolving 
credit  agreement,  partially  fund  capital  expenditures  and  for  general  corporate  purposes.  ITC  Midwest’s  First 
Mortgage Bonds were issued under its first mortgage and deed of trust and secured by a first mortgage lien on 
substantially all of its real property and tangible personal property.

Derivative Instruments and Hedging Activities

In  May  2020,  we  terminated  $450  million  of  5-year  interest  rate  swap  contracts  that  managed  the  interest 
rate  risk  associated  with  the  ITC  Holdings  $700  million  Senior  Notes  with  a  maturity  date  of  May  14,  2030. A 
summary of the terminated interest rate swaps is provided below:

Interest Rate Swaps
(in millions of USD, 
except percentages)
5-year interest rate 
swaps

Notional 
Amount

Weighted Average 
Fixed Rate of 
Interest Rate Swaps

Comparable 
Reference Rate 
of Notes

Loss on Derivatives

Settlement Date

$ 

450 

 1.41 %

0.38%

$ 

23  May 2020

The interest rate swaps qualified for cash flow hedge accounting treatment and the cumulative pre-tax loss 
of  $23  million  was  recognized  in  May  2020  for  the  effective  portion  of  the  hedges  and  recorded  net  of  tax  in 
AOCI. This amount is being amortized as a component of interest expense over the initial five years of the term 
of the related debt. Consistent with our accounting policy, the swap settlement payment was recognized within 
cash  flows  from  financing  activities  in  the  consolidated  statements  of  cash  flows. At  December  31,  2020,  ITC 
Holdings  did  not  have  any  interest  rate  swaps  outstanding.  As  of  December  31,  2019,  ITC  Holdings  had 
$200 million of interest rate swaps outstanding.

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Revolving Credit Agreements

On January 10, 2020, ITC Holdings, ITCTransmission, METC, ITC Midwest and ITC Great Plains amended 
and  restated  their  respective  revolving  credit  agreements  each  dated  October  23,  2017.  The  amendments 
extend  the  maturity  date  of  the  revolving  credit  agreements  from  October  2022  to  October  2023.  The 
determination  of  the  applicable  interest  rates  and  commitment  fee  rates  in  the  new  agreements  is  consistent 
with  the  previous  agreements  and  remain  subject  to  adjustment  based  on  the  borrower’s  credit  rating.  At 
December  31,  2020,  ITC  Holdings  and  certain  of  its  Regulated  Operating  Subsidiaries  had  the  following 
unsecured revolving credit facilities available:

(In millions of USD, except percentages)

ITC Holdings

ITCTransmission

METC

ITC Midwest
ITC Great Plains

Total

____________________________

Total
Available
Capacity

Outstanding 
Balance (a)

Unused
Capacity

$ 

400  $ 

37  $ 

363  (d)

100 

100 

225 
75 

33 

20 

75 
33 

$ 

900  $ 

198  $ 

67 

80 

150 
42 

702 

Weighted 
Average 
Interest Rate on
Outstanding 
Balance (b)

1.4%

1.1%

1.1%

1.1%
1.1%

Commitment 
Fee Rate (c)

 0.175 %

 0.10 %

 0.10 %

 0.10 %
 0.10 %

(a) Included within long-term debt in the consolidated statements of financial position.

(b) Interest  charged  on  borrowings  depends  on  the  variable  rate  structure  we  elected  at  the  time  of  each 

borrowing. 

(c) Calculation  based  on  the  average  daily  unused  commitments,  subject  to  adjustment  based  on  the 

borrower’s credit rating.

(d) ITC Holdings’ revolving credit agreement may be used for general corporate purposes, including to repay 
commercial paper issued pursuant to the commercial paper program described above, if necessary. While 
outstanding  commercial  paper  does  not  reduce  available  capacity  under  ITC  Holdings’  revolving  credit 
agreement, the unused capacity under this agreement adjusted for the commercial paper outstanding was 
$296 million as of December 31, 2020.

11.  INCOME TAXES

Our effective tax rate varied from the statutory federal income tax rate due to differences between the book 

and tax treatment of various transactions as follows:

(In millions of USD)

Year Ended December 31,

2020

2019

2018

Income tax expense at federal statutory rate (a)

$ 

114  $ 

118  $ 

State income taxes (net of federal benefit) (b)

AFUDC equity

Other, net

Total income tax provision

____________________________

28 

(4)   

(2)   

22 

(5)   

(3)   

93 

31 

(6) 

(7) 

$ 

136  $ 

132  $ 

111 

(a) The federal statutory rate is 21% for 2020, 2019 and 2018.

(b) Amounts  for  the  years  ended  December  31,  2020,  2019  and  2018  include  $2  million,  $1  million  and  $6 
million,  respectively,  related  to  the  remeasurement  of  Iowa  NOLs  due  to  the  rate  change  from  12.0%  to 
9.8% effective January 1, 2021. 

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Components of the income tax provision were as follows:

(In millions of USD)

Current income tax (benefit) expense

Deferred income tax expense

Total income tax provision

Year Ended December 31,

2020

2019

2018

$ 

$ 

(2)  $ 

(3)  $ 

138 

135 

136  $ 

132  $ 

4 

107 

111 

For  the  years  ended  December  31,  2020,  2019  and  2018,  our  effective  tax  rates  were  25.0%,  23.6%  and 

25.2%, respectively.

Deferred income tax assets (liabilities) consisted of the following:

(In millions of USD)

Property, plant and equipment

Federal income tax NOLs and other credits

METC regulatory deferral (a)
Acquisition adjustments — ADIT deferrals (a)

Goodwill

Refund liabilities (a)

Regulatory liability gross up — TCJA

Pension and postretirement liabilities

State income tax NOLs (net of federal benefit) 

True-up adjustment principal & interest

Other, net

Net deferred tax liabilities 

Gross deferred income tax liabilities

Gross deferred income tax assets

Net deferred tax liabilities

____________________________

December 31,

2020

2019

$ 

(1,156)  $ 

(1,071) 

85 

(4)   
(5)   

117 

(5) 
(7) 

(139)   

(133) 

— 

134 

20 

58 

(14)   

8 

19 

134 

18 

52 

(1) 

4 

$ 

$ 

(1,013)  $ 

(873) 

(1,333)  $ 

(1,233) 

320 

$ 

(1,013)  $ 

360 

(873) 

(a) Deferred income tax assets for refund liabilities are related to the Initial Complaint and the ITC Great Plains 

incentive adder complaint. See Note 7 for additional details regarding these matters.

We  have  federal  income  tax  NOLs  as  of  December  31,  2020.  We  expect  to  use  our  NOLs  prior  to  their 
expirations  starting  in  2036.  We  also  have  state  income  tax  NOLs  as  of  December  31,  2020,  all  of  which  we 
expect to use prior to their expiration starting in 2022.

12.  RETIREMENT BENEFITS AND ASSETS HELD IN TRUST

Pension and Postretirement Plan Benefits

We have a qualified defined benefit pension plan (“retirement plan”) for eligible employees, comprised of a 
traditional  final  average  pay  plan  and  a  cash  balance  plan.  The  traditional  final  average  pay  plan  is 
noncontributory, covers select employees, and provides retirement benefits based on years of benefit service, 
average  final  compensation,  and  age  at  retirement.  The  cash  balance  plan  is  also  noncontributory,  covers 
substantially  all  employees,  and  provides  retirement  benefits  based  on  eligible  compensation  and  interest 
credits. Our funding practice for the retirement plan is generally to fund the annual net pension cost, though we 
may contribute additional amounts as necessary to meet the minimum funding requirements of the Employee 
Retirement Income Security Act of 1974, or as we deem appropriate. We made contributions of $4 million to the 
retirement plan in each of 2020, 2019, and 2018. We expect to contribute $4 million to the retirement plan in 
2021.

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We  also  have  two  supplemental  nonqualified,  noncontributory,  defined  benefit  pension  plans  for  selected 
management  employees  (the  “supplemental  benefit  plans”  and  collectively  with  the  retirement  plan,  the 
“pension  plans”).  The  supplemental  benefit  plans  provide  for  benefits  that  supplement  those  provided  by  the 
retirement  plan.  The  obligations  under  these  supplemental  benefit  plans  are  included  in  the  pension  benefit 
obligation calculations below. The investments held in trust for the supplemental benefit plans of $56 million and 
$54 million at December 31, 2020 and 2019, respectively, are not included in the plan asset amounts presented 
throughout this footnote, but are included in other assets on our consolidated statements of financial position. 
For the years ended December 31, 2020, 2019, and 2018, we contributed $3 million, $1 million, and $3 million, 
respectively, to these supplemental benefit plans.

We provide certain postretirement health care, dental, and life insurance benefits for eligible employees (the 
“postretirement benefit plan”). We contributed $10 million, $9 million, and $9 million to the postretirement benefit 
plan  in  2020,  2019,  and  2018,  respectively.  We  expect  to  contribute  $11  million  to  the  postretirement  benefit 
plan in 2021.

Net  periodic  benefit  costs  by  component  for  the  pension  plans  and  postretirement  benefit  plan  were  as 

follows:

(In millions of USD)

2020

2019

2018

2020

2019

2018

Pension Plans

Years Ended December 31,

Postretirement Benefit Plan

 Years Ended December 31,

10 

3 

(3) 

— 

10 

Service cost

Interest cost

Expected return on plan assets

Amortization of unrecognized loss  

$ 

8  $ 

7  $ 

7  $ 

11  $ 

9  $ 

4 

(6)   

1 

5 

(5)   

1 

4 

(5)   

1 

4 

(5)   

— 

4 

(4)   

— 

Net benefit cost

$ 

7  $ 

8  $ 

7  $ 

10  $ 

9  $ 

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The  following  table  reconciles  the  obligations,  assets,  and  funded  status  of  the  pension  plans  and 
postretirement  benefit  plan  as  well  as  the  presentation  of  the  funded  status  of  the  plans  in  the  consolidated 
statements of financial position:

(In millions of USD)
Change in Benefit Obligation:

Pension Plans

December 31,

Postretirement Benefit Plan

December 31,

2020

2019

2020

2019

Beginning projected benefit obligation

$ 

(141)  $ 

(123)  $ 

(113)  $ 

Service cost

Interest cost

Plan amendments

Actuarial net gain/(loss)

Benefits paid

Ending projected benefit obligation

Change in Plan Assets:

Beginning plan assets at fair value

Actual return on plan assets

Employer contributions

Benefits paid

Ending plan assets at fair value

Funded status, underfunded

Accumulated benefit obligation:

Retirement plan

Supplemental benefit plans

Total accumulated benefit obligation 

Amounts recorded as:

Funded Status:

(8)   

(4)   

— 

(16)   

7 

(7)   

(5)   

— 

(12)   

6 

(11)   

(4)   

2 

3 

1 

(162)   

(141)   

(122)   

91 

15 

4 

(3)   

107 

73 

16 

4 

(2)   

91 

95 

16 

10 

(1)   

120 

(55)  $ 

(50)  $ 

(2)  $ 

(95)  $ 

(60)   

(78) 

(57) 

N/A

N/A

(155)  $ 

(135)  $ 

—  $ 

$ 

$ 

$ 

Accrued pension and postretirement liabilities

$ 

(57)  $ 

(55)  $ 

(2)  $ 

Other non-current assets

Other current liabilities

Total
Unrecognized Amounts in Non-current Regulatory 
Assets/(Liabilities):

Net actuarial loss/(gain)

Net prior service cost/(credit)

Total

$ 

$ 

$ 

6 

(4)   

9 

(4) 

N/A

N/A

(55)  $ 

(50)  $ 

(2)  $ 

30  $ 

— 

30  $ 

24  $ 

— 

24  $ 

(14)  $ 

(2)   

(16)  $ 

(90) 

(9) 

(4) 

— 

(11) 

1 

(113) 

72 

15 

9 

(1) 

95 

(18) 

N/A

N/A

— 

(18) 

N/A

N/A

(18) 

1 

— 

1 

The unrecognized amounts that otherwise would have been charged and/or credited to AOCI in accordance 
with the GAAP guidance on accounting for retirement benefits are recorded as a regulatory asset or regulatory 
liability on our consolidated statements of financial position, as discussed in Note 7. The amounts recorded as a 
regulatory  asset  or  regulatory  liability  represent  a  net  periodic  benefit  cost  or  credit  to  be  recognized  in  our 
operating  income  in  future  periods.  Our  measurement  of  the  accumulated  benefit  obligation  for  the 
postretirement  benefit  plan  as  of  December  31,  2020  and  2019  does  not  reflect  the  potential  receipt  of  any 
subsidies under the Medicare Prescription Drug, Improvement and Modernization Act of 2003.

The  net  actuarial  losses  for  the  year  ended  December  31,  2019  within  the  change  in  benefit  obligation  for 
both  the  Pension  Plans  and  Postretirement  Benefit  Plan  are  primarily  the  result  of  decreases  in  the  discount 
rates.

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The net actuarial loss for the year ended December 31, 2020 within the change in benefit obligation for the 
Pension  Plans  is  primarily  the  result  of  decreases  in  the  discount  rates.  The  net  actuarial  gain  for  the  year 
ended December 31, 2020 within the change in benefit obligation for the Postretirement Benefit Plan was driven 
primarily  by  per  capita  experience  gains  as  well  as  other  actuarial  gains,  partially  offset  by  a  decrease  in  the 
discount rate. 

The combined projected benefit obligation and fair value of plan assets for those plans in which the projected 

benefit obligation is in excess of the fair value of plan assets are as follows:

(In millions of USD)

Projected benefit obligation

Fair value of plan assets (a)

____________________________

Pension Plans

December 31,

2020

2019

$ 

(61)  $ 

— 

(59) 

— 

(a) The investments held in trust for our supplemental benefit plans are not included in the plan asset amounts 
presented herein, but are included in Other Assets on our consolidated statements of financial position.

The  combined  accumulated  benefit  obligation  and  fair  value  of  plan  assets  for  those  plans  in  which  the 

accumulated benefit obligation is in excess of the fair value of plan assets are as follows:

(In millions of USD)

Accumulated benefit obligation

Fair value of plan assets (a)

____________________________

Pension Plans

December 31,

2020

2019

$ 

(60)  $ 

— 

(57) 

— 

(a) The investments held in trust for our supplemental benefit plans are not included in the plan asset amounts 
presented herein, but are included in Other Assets on our consolidated statements of financial position.

Actuarial  assumptions  used  to  determine  the  benefit  obligations  for  the  pension  plans  and  postretirement 

benefit plan are as follows:

Weighted average discount rate

Weighted average interest crediting rate

Annual rate of salary increases

Health care cost trend rate

Ultimate health care cost trend rate

Year that the ultimate trend rate is reached

Annual rate of increase in dental benefit costs

Pension Plans

December 31,

2020

2.49%

4.00%

4.00%

N/A

N/A

N/A

N/A

2019

3.27%

4.00%

4.00%

N/A

N/A

N/A

N/A

2018

4.28%

4.50%

4.00%

N/A

N/A

N/A

N/A

Postretirement Benefit Plan

December 31,

2020

2019

2018

2.94%

3.61%

4.47%

N/A

4.00%

6.00%

5.00%

2025

N/A

4.00%

6.25%

5.00%

2025

N/A

4.00%

6.50%

5.00%

2025

4.50%

4.50%

4.50%

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Actuarial  assumptions  used  to  determine  the  benefit  cost  for  the  pension  plans  and  postretirement  benefit 

plan are as follows:

Pension Plans

Postretirement Benefit Plan

Years Ended December 31,

Years Ended December 31,

2020

2019

2018

2020

2019

2018

Weighted  average  discount  rate  —  service 
cost
Weighted  average  discount  rate  —  interest 
cost

Weighted average interest crediting rate

Annual rate of salary increases

Health care cost trend rate

Ultimate health care cost trend rate

Year that the ultimate trend rate is reached
Expected  long-term  rate  of  return  on  plan 
assets

3.47%

4.42%

3.70%

3.80%

4.58%

3.80%

2.91%

4.00%

4.00%

N/A

N/A

N/A

3.99%

4.50%

4.00%

N/A

N/A

N/A

3.26%

4.50%

4.00%

N/A

N/A

N/A

3.30%

4.28%

3.58%

N/A

4.00%

6.25%

5.00%

2025

N/A

4.00%

6.50%

5.00%

2025

N/A

4.00%

6.75%

5.00%

2025

6.00%

6.60%

6.40%

4.50%

5.00%

4.90%

At December 31, 2020, the projected benefit payments for the pension plans and postretirement benefit plan 
calculated using the same assumptions as those used to calculate the benefit obligations described above are 
as follows:

(In millions of USD)

2021

2022

2023

2024

2025

2026 through 2030

Investment Objectives and Fair Value Measurement

Pension Plans

$ 

7  $ 

8 

9 

9 

10 

59 

Postretirement 
Benefit Plan

2 

2 

2 

2 

3 

21 

The general investment objectives of the retirement plan and postretirement benefit plan include maximizing 
the  return  within  reasonable  and  prudent  levels  of  risk  and  controlling  administrative  and  management  costs. 
Investment decisions are made by our retirement benefits board as delegated by our board of directors. Equity 
investments may include various types of U.S. and international equity securities, such as large-cap, mid-cap, 
and  small-cap  stocks.  Fixed  income  investments  may  include  cash  and  short-term  instruments,  U.S. 
Government securities, corporate bonds, mortgages, and other fixed income investments. No investments are 
prohibited for use in the retirement plan or postretirement benefit plan, including derivatives, but our exposure to 
derivatives  currently  is  not  material.  We  intend  that  the  long-term  capital  growth  of  the  retirement  and 
postretirement  benefit  plans,  together  with  employer  contributions,  will  provide  for  the  payment  of  the  benefit 
obligations.

As of December 31, 2020 and 2019, the plan assets of the retirement plan and postretirement benefit plan 

consisted of the following assets by category:

Asset Category

Fixed income securities
Equity securities

Total

Target Allocation

Pension Plans

Postretirement Benefit Plan

2020

2020

2019

2020

2019

 50 %
 50 %

 100 %

 50 %
 50 %

 100 %

 50 %
 50 %

 100 %

 50 %
 50 %

 100 %

 50 %
 50 %

 100 %

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We determine our expected long-term rate of return on plan assets based on the current and expected target 
allocations  of  the  retirement  plan  and  postretirement  benefit  plan  investments  and  considering  historical  and 
expected long-term rates of return on comparable fixed income investments and equity investments.

The  measurement  of  fair  value  is  based  on  a  three-tier  hierarchy,  which  prioritizes  the  inputs  used  in 
measuring fair value. These tiers include: Level 1, defined as observable inputs, such as quoted prices in active 
markets;  Level  2,  defined  as  inputs  other  than  quoted  prices  in  active  markets  that  are  either  directly  or 
indirectly  observable;  and  Level  3,  defined  as  unobservable  inputs  in  which  little  or  no  market  data  exists, 
therefore, requiring an entity to develop its own assumptions. Changes in economic conditions or model-based 
valuation  techniques  may  require  the  transfer  of  financial  instruments  from  one  fair  value  level  to  another.  In 
such instances, the transfer is reported at the beginning of the reporting period. For the years ended December 
31, 2020 and 2019, there were no transfers between levels.

For  the  years  ended  December  31,  2020  and  2019,  the  fair  value  of  retirement  plan  and  postretirement 

benefit plan assets measured on a recurring basis at the Level 1 tier were as follows:

(In millions of USD)

Mutual funds — U.S. equity securities

Mutual funds — international equity securities

Mutual funds — fixed income securities

Total

Pension Plans

December 31,

Postretirement Benefit Plan

December 31,

2020

2019

2020

2019

$ 

43  $ 
11 
53 

$ 

107  $ 

36  $ 

9 
46 
91  $ 

57  $ 

3 
60 

120  $ 

45 
2 
48 
95 

The mutual funds consist primarily of publicly traded mutual funds and are recorded at fair value based on 

observable trades for identical securities in an active market.

Defined Contribution Plan

We  also  sponsor  a  defined  contribution  retirement  savings  plan.  Participation  in  this  plan  is  available  to 
substantially  all  employees.  We  match  employee  contributions  up  to  certain  predefined  limits  based  upon 
eligible  compensation  and  the  employee’s  contribution  rate. The  cost  of  this  plan  was  $6  million  in  2020  and 
$5 million in each of 2019 and 2018.

13.  FAIR VALUE MEASUREMENTS

The  measurement  of  fair  value  is  based  on  a  three-tier  hierarchy,  which  prioritizes  the  inputs  used  in 
measuring fair value. These tiers include: Level 1, defined as observable inputs such as quoted prices in active 
markets;  Level  2,  defined  as  inputs  other  than  quoted  prices  in  active  markets  that  are  either  directly  or 
indirectly  observable;  and  Level  3,  defined  as  unobservable  inputs  in  which  little  or  no  market  data  exists, 
therefore requiring an entity to develop its own assumptions. Changes in economic conditions or model-based 
valuation  techniques  may  require  the  transfer  of  financial  instruments  from  one  fair  value  level  to  another.  In 
such instances, the transfer is reported at the beginning of the reporting period. For the years ended December 
31, 2020 and 2019, there were no transfers between levels.

Our assets measured at fair value subject to the three-tier hierarchy at December 31, 2020, were as follows:

(in millions of USD)

Financial assets measured on a recurring basis:

Cash equivalents

Mutual funds — fixed income securities

Mutual funds — equity securities

Total

Fair Value Measurements at Reporting Date Using

Quoted Prices in
Active Markets for
Identical Assets

Significant
Other Observable
Inputs

Significant
Unobservable
Inputs

(Level 1)

(Level 2)

(Level 3)

$ 

$ 

1  $ 

52 

10 

63  $ 

—  $ 
—  $ 

— 

—  $ 

— 
— 

— 

— 

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Our assets measured at fair value subject to the three-tier hierarchy at December 31, 2019, were as follows:

(in millions of USD)

Financial assets measured on a recurring basis:

Mutual funds — fixed income securities

Mutual funds — equity securities

Interest rate swap derivatives

Total

Fair Value Measurements at Reporting Date Using

Quoted Prices in
Active Markets for
Identical Assets

Significant
Other Observable
Inputs

Significant
Unobservable
Inputs

(Level 1)

(Level 2)

(Level 3)

$ 

$ 

50  $ 

8 
— 
58  $ 

—  $ 
— 
3 
3  $ 

— 
— 
— 
— 

As of December 31, 2020 and 2019, we held certain assets that are required to be measured at fair value on 
a  recurring  basis.  The  assets  included  in  the  table  consist  of  investments  recorded  within  cash  and  cash 
equivalents and other long-term assets, including investments held in a trust associated with our supplemental 
benefit plans described in Note 12. The mutual funds we own are publicly traded and are recorded at fair value 
based on observable trades for identical securities in an active market. Changes in the observed trading prices 
and liquidity of money market funds are monitored as additional support for determining fair value. Gains and 
losses for all mutual fund investments are recorded in other operating income and expense.

As  of  December  31,  2019,  the  assets  related  to  derivatives  consisted  of  interest  rate  swaps  discussed  in 
Note  10.  The  fair  value  of  our  interest  rate  swap  derivatives  is  determined  based  on  a  DCF  method  using 
LIBOR swap rates, which are observable at commonly quoted intervals.

We also held non-financial assets that are required to be measured at fair value on a non-recurring basis. 
These consist of goodwill and intangible assets. We did not record any impairment charges on long-lived assets 
and  no  other  significant  events  occurred  requiring  non-financial  assets  and  liabilities  to  be  measured  at  fair 
value (subsequent to initial recognition) during the years ended December 31, 2020 and 2019. Refer to Note 9 
for additional information on our goodwill and intangible assets.

Fair Value of Financial Assets and Liabilities

Fixed Rate Debt

Based on the borrowing rates obtained from third party lending institutions currently available for bank loans 
with similar terms and average maturities from active markets, the fair value of our consolidated long-term debt 
and debt maturing within one year, excluding revolving and term loan credit agreements and commercial paper, 
was  $7,119  million  and  $5,672  million  at  December  31,  2020  and  2019,  respectively.  These  fair  values 
represent Level 2 under the three-tier hierarchy described above. The total book value of our consolidated long-
term  debt  and  debt  maturing  within  one  year,  net  of  discount  and  deferred  financing  fees  and  excluding 
revolving  and  term  loan  credit  agreements  and  commercial  paper,  was  $6,097  million  and  $5,108  million  at 
December 31, 2020 and 2019, respectively.

Revolving and Term Loan Credit Agreements

At December 31, 2020 and 2019, we had a consolidated total of $198 million and $499 million, respectively, 
outstanding under our revolving and term loan credit agreements, which are variable rate loans. The fair value 
of these loans approximates book value based on the borrowing rates currently available for variable rate loans 
obtained from third party lending institutions. These fair values represent Level 2 under the three-tier hierarchy 
described above.

Other Financial Instruments

The carrying value of other financial instruments included in current assets and current liabilities, including 
cash  and  cash  equivalents,  special  deposits  and  commercial  paper,  approximates  their  fair  value  due  to  the 
short-term nature of these instruments.

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14. STOCKHOLDER'S EQUITY

Accumulated Other Comprehensive Income

The following table provides the components of changes in AOCI:

(In millions of USD)

Balance at the beginning of period

Year Ended December 31,

2020

2019

2018

$ 

7  $ 

4  $ 

Reclassification of deferred tax effects on interest rate cash flow hedges 

stranded in AOCI, subject to the TCJA, into retained earnings

— 

— 

Other Comprehensive Income

Derivative Instruments

Reclassification of net loss relating to interest rate cash flow hedges 

from AOCI to earnings (net of tax of $1 for the year ended December 
31, 2020 and less than $1 for each of the years ended December 31, 
2019 and 2018) (a)

(Loss) gain on interest rate swaps relating to interest rate cash flow 

hedges (net of tax of $8 and $1 for the years ended December 31, 
2020 and 2019, respectively)

Total other comprehensive (loss) income, net of tax

Balance at the end of period

____________________________

3 

(18)   

(15)   

1 

2 

3 

$ 

(8)  $ 

7  $ 

2 

1 

1 

— 

1 

4 

(a) The reclassification of the net loss relating to interest rate cash flow hedges is reported in interest expense 

on a pre-tax basis.

The amount of net loss relating to interest rate cash flow hedges to be reclassified from AOCI to earnings for 
the 12-month period ending December 31, 2021 is expected to be approximately $4 million (net of tax of less 
than $2 million). The reclassification is reported in interest expense on a pre-tax basis.

15.  SHARE-BASED COMPENSATION AND EMPLOYEE SHARE PURCHASE PLAN

We recorded share-based compensation costs as follows:

(In millions of USD)

Operation and maintenance expenses

General and administrative expenses

Amounts capitalized to property, plant and equipment

Total share-based compensation costs
Total tax benefit recognized in the consolidated statements of 

comprehensive income

Long-Term Incentive Plans 

Year Ended December 31,

2020

2019

2018

$ 

$ 

$ 

2  $ 

2  $ 

23 

7 

30 

8 

32  $ 

40  $ 

8  $ 

8  $ 

1 

7 

3 

11 

4 

Under  our  long-term  incentive  plans,  we  may  grant  long-term  incentive  awards  of  PBUs  and  SBUs  to 
employees,  including  executive  officers,  of  ITC  Holdings  and  its  subsidiaries.  Generally,  each  PBU  and  SBU 
granted  will  be  valued  based  on  one  share  of  Fortis  common  stock  traded  on  the  Toronto  Stock  Exchange, 
converted to U.S. dollars and settled only in cash. However, certain SBUs granted to the executives may settle 
in  cash,  100%  Fortis  common  stock,  or  50%  cash  and  50%  Fortis  common  stock  depending  on  executives’ 
settlement  elections  and  whether  certain  share  ownership  requirements  are  met.  PBUs  and  SBUs  that  are 
granted pursuant to our long-term incentive plans generally vest on either the third December 31st or January 
1st following the grant date, provided the service and performance criteria, as applicable, are satisfied, and will 
be  settled  during  the  subsequent  quarter.  However,  certain  awards  may  vest  over  a  shorter  period  or  on  the 

75

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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grant date if certain retirement eligibility criteria are met. The granted awards and related dividend equivalents 
have no shareholder rights.

Performance-Based Units

The PBUs are classified as liability awards based on the cash settlement feature. The PBUs are measured at 
fair value at the end of each reporting period, which will fluctuate based on the price of Fortis common stock and 
the level of achievement of the financial performance criteria, including a market condition and a performance 
condition.  The  payout  may  range  from  0%  -  200%  of  the  target  award,  depending  on  actual  performance 
relative to the performance criteria. The PBUs earn dividend equivalents which are also re-measured consistent 
with the target award and settled in cash at the end of the vesting period.

The following table shows the changes in PBUs during the year ended December 31, 2020:

PBUs at December 31, 2019

Granted
Vested and paid out

Forfeited

PBUs at December 31, 2020

Number of

Performance

Based Units

976,228 

319,440 
(335,619) 

(59,098) 

900,951 

The  following  table  presents  the  classification  in  the  consolidated  statements  of  financial  position  of 

obligations related to outstanding PBUs not yet settled:

(In millions of USD)

Accrued compensation

Other long-term liabilities

Total

December 31,

2020

2019

$ 

$ 

20  $ 

22 

42  $ 

17 

19 

36 

The  aggregate  fair  value  of  PBUs  as  of  December  31,  2020  and  2019  was  $59  million  and  $54  million, 
respectively. At December 31, 2020, $17 million of total unrecognized compensation cost related to PBUs not 
yet vested is expected to be recognized over the remaining weighted-average period of 1.6 years.

Service-Based Units

The  SBUs  are  classified  as  liability  awards  based  on  the  possibility  of  cash  settlement.  The  SBUs  are 
measured  at  fair  value  at  the  end  of  each  reporting  period,  which  will  fluctuate  based  on  the  price  of  Fortis 
common stock. The SBUs earn dividend equivalents which are also re-measured based on the price of Fortis 
common stock and settled in cash at the end of the vesting period.

The following table shows the changes in SBUs during the year ended December 31, 2020:

SBUs at December 31, 2019

Granted

Vested and paid out

Forfeited

SBUs at December 31, 2020

76

Number of

Service

Based Units

745,250 

246,714 

(266,918) 

(37,336) 
687,710 

 
 
 
 
 
 
 
 
 
 
 
 
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The  following  table  presents  the  classification  in  the  consolidated  statements  of  financial  position  of 

obligations related to outstanding SBUs not yet settled:

(In millions of USD)

Accrued compensation

Other long-term liabilities

Total

December 31,

2020

2019

$ 

$ 

9  $ 

10 

19  $ 

10 

10 

20 

The  aggregate  fair  value  of  SBUs  as  of  December  31,  2020  and  2019  was  $28  million  and  $30  million, 
respectively. At December 31, 2020, $9 million of the total unrecognized compensation cost related to SBUs not 
yet vested is expected to be recognized over the remaining weighted-average period of 1.6 years.

Employee Share Purchase Plan

ITC  employees  are  permitted  to  purchase  common  shares  of  Fortis  stock  under  the  Fortis  ESPP.  ITC 
Holdings also makes contributions as additional compensation to participating employees’ ESPP accounts. The 
cost of ITC Holdings’ contribution for the years ended December 31, 2020, 2019, and 2018 was less than $1 
million, respectively.

16.  JOINTLY OWNED UTILITY PLANT/COORDINATED SERVICES

Certain of our Regulated Operating Subsidiaries have agreements with other utilities for the joint ownership 
of substation assets and transmission lines as discussed in Note 3. We have investments in jointly owned utility 
assets as shown in the table below as of December 31, 2020:

(In millions of USD)

ITCTransmission (b)

METC (c)

ITC Midwest (d)

ITC Great Plains (e)

Total

____________________________

Net Investments (a)

Substations

Lines

$ 

$ 

—  $ 

17 

44 

10 

29 

41 

41 

23 

71  $ 

134 

(a) Amount represents our investment in jointly held plant, which has been reduced by the ownership interest 

amounts of other parties.

(b) ITCTransmission has joint ownership in two 345 kV transmission lines with a municipal power agency that 
has a 50.4% ownership interest in the transmission lines. An Ownership and Operating Agreement with the 
municipal power agency provides ITCTransmission with authority for construction of capital improvements 
and  for  the  operation  and  management  of  the  transmission  lines.  The  municipal  power  agency  is 
responsible for the capital and operation and maintenance costs allocable to their ownership interest.

(c) METC  has  joint  ownership  in  several  assets  within  various  substations  with  Consumers  Energy,  other 
municipal  distribution  systems  and  other  generators.  The  rights,  responsibilities  and  obligations  for  these 
jointly owned assets are documented in the DT Interconnection Agreement with Consumers Energy and in 
numerous  interconnection  facilities  agreements  with  various  municipalities  and  other  generators.  In 
addition,  other  municipal  power  agencies  and  cooperatives  have  an  ownership  interest  in  several  METC 
345  kV  transmission  lines.  This  ownership  entitles  these  municipal  power  agencies  and  cooperatives  to 
approximately  608  MW  of  network  transmission  service  from  the  METC  transmission  system.  As  of 
December 31, 2020, METC’s ownership percentages for jointly owned substation facilities and lines ranged 
from less than 1.0% to 92.0% and 1.0% to 41.9%, respectively.

(d) ITC  Midwest  has  joint  ownership  in  several  substations  and  transmission  lines  with  various  parties.  ITC 
Midwest’s  ownership  percentages  for  jointly  owned  substation  facilities  and  lines  ranged  from  28.0%  to 
80.0% and 11.0% to 80.0%, respectively, as of December 31, 2020.

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(e) ITC Great Plains has joint ownership in a transmission project with an electric cooperative. ITC Great Plains 
is  responsible  for  construction  and  operation  of  the  project  and  the  electric  cooperative  is  responsible  for 
their ownership percentage of capital and operation and maintenance costs. As of December 31, 2020, ITC 
Great Plains’ ownership percentage in the project was 51.0%.

17.  RELATED PARTY TRANSACTIONS 

Intercompany Receivables and Payables

ITC Holdings may incur charges from Fortis and other subsidiaries of Fortis that are not subsidiaries of ITC 
Holdings for general corporate expenses incurred. In addition, ITC Holdings may perform additional services for, 
or receive additional services from, Fortis and such subsidiaries. These transactions are in the normal course of 
business  and  payments  for  these  services  are  settled  through  accounts  receivable  and  accounts  payable,  as 
necessary.  We  had  intercompany  receivables  from  Fortis  and  such  subsidiaries  of  less  than  $1  million  at 
December 31, 2020 and December 31, 2019 and intercompany payables to Fortis and such subsidiaries of less 
than $1 million at December 31, 2020 and December 31, 2019. 

Related party charges for corporate expenses from Fortis and such subsidiaries are recorded in general and 
administrative expense. ITC Holdings had such expense for the years ended December 31, 2020 and 2019 of 
$10 million and for the year ended December 31, 2018 of $8 million. Related party billings for services to Fortis 
and other subsidiaries recorded as an offset to general and administrative expenses for ITC Holdings were $2 
million for the year ended December 31, 2020 and less than $1 million for the years ended December 31, 2019 
and 2018.

Dividends

We paid dividends of $330 million, $250 million and $200 million during the years ended December 31, 2020, 
2019 and 2018, respectively, to ITC Investment Holdings. ITC Holdings also paid dividends of $58 million to ITC 
Investment Holdings in January 2021.

Transfer of Membership Interests

In February 2021, we transferred our membership interests in certain wholly-owned development entities to 
our  parent  company,  ITC  Investment  Holdings.  The  transfer  was  accounted  for  at  book  value  as  a  non-
reciprocal transfer of value. There was no gain or loss recognized on the transfer. The transfer will not have a 
material impact on our consolidated results of operations, cash flows or financial condition.

Intercompany Tax Sharing Agreement

We  are  organized  as  a  corporation  for  tax  purposes  and  subject  to  a  tax  sharing  agreement  as  a  wholly-
owned  subsidiary  of  ITC  Investment  Holdings.  Additionally,  we  record  income  taxes  based  on  our  separate 
company tax position and make or receive tax-related payments with ITC Investment Holdings. In April 2020, 
ITC  Holdings  paid  $2  million  to  ITC  Investment  Holdings  for  matters  related  to  the  State  of  Michigan  income 
taxes.  During  the  years  ended  December  31,  2020  and  2019,  we  received  a  payment  of  $2  million  from 
FortisUS for a tax refund that originated prior to establishing the tax sharing agreement.

18.  COMMITMENTS AND CONTINGENT LIABILITIES

Environmental Matters

We are subject to federal, state and local environmental laws and regulations, which impose limitations on 
the discharge of pollutants into the environment, establish standards for the management, treatment, storage, 
transportation and disposal of solid and hazardous wastes and hazardous materials, and impose obligations to 
investigate  and  remediate  contamination  in  certain  circumstances.  Liabilities  relating  to  investigation  and 
remediation of contamination, as well as other liabilities concerning hazardous materials or contamination, such 
as  claims  for  personal  injury  or  property  damage,  may  arise  at  many  locations,  including  formerly  owned  or 
operated properties and sites where wastes have been treated or disposed of, as well as properties currently 
owned  or  operated  by  us.  Such  liabilities  may  arise  even  where  the  contamination  does  not  result  from 
noncompliance  with  applicable  environmental  laws.  Under  some  environmental  laws,  such  liabilities  may  also 
be  joint  and  several,  meaning  that  a  party  can  be  held  responsible  for  more  than  its  share  of  the  liability 
involved, or even the entire share. Although environmental requirements generally have become more stringent 
and compliance with those requirements more expensive, we are not aware of any specific developments that 

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would increase our costs for such compliance in a manner that would be expected to have a material adverse 
effect on our results of operations, financial condition or liquidity.

Our  assets  and  operations  also  involve  the  use  of  materials  classified  as  hazardous,  toxic  or  otherwise 
dangerous. Many of the properties that we own or operate have been used for many years and include older 
facilities and equipment that may be more likely than newer ones to contain or be made from such materials. 
Some of these properties include aboveground or underground storage tanks and associated piping. Some of 
them  also  include  large  electrical  equipment  filled  with  mineral  oil,  which  may  contain  or  previously  have 
contained  PCBs.  Some  of  our  facilities  and  electrical  equipment  may  also  contain  asbestos  containment 
materials. Our facilities and equipment are often situated on or near property owned by others so that, if they 
are the source of contamination, others’ property may be affected. For example, aboveground and underground 
transmission lines sometimes traverse properties that we do not own and transmission assets that we own or 
operate are sometimes commingled at our transmission stations with distribution assets owned or operated by 
our transmission customers.

Some  properties  in  which  we  have  an  ownership  interest  or  at  which  we  operate  are,  or  are  suspected  of 
being, affected by environmental contamination. We are not aware of any pending or threatened claims against 
us  with  respect  to  environmental  contamination  relating  to  these  properties,  or  of  any  investigation  or 
remediation of contamination at these properties, that entail costs likely to materially affect us. Some facilities 
and properties are located near environmentally sensitive areas such as wetlands.

Litigation

We  are  involved  in  certain  legal  proceedings  before  various  courts,  governmental  agencies  and  mediation 
panels  concerning  matters  arising  in  the  ordinary  course  of  business.  These  proceedings  include  certain 
contract  disputes,  eminent  domain  and  vegetation  management  activities,  regulatory  matters  and  pending 
judicial matters. We cannot predict the final disposition of such proceedings. We regularly review legal matters 
and record provisions for claims that are considered probable of loss.

Rate of Return on Equity Complaints

Two  complaints  were  filed  with  the  FERC  by  combinations  of  consumer  advocates,  consumer  groups, 
municipal  parties  and  other  parties  challenging  the  base  ROE  in  MISO.  The  complaints  were  filed  with  the 
FERC under Section 206 of the FPA requesting that the FERC find the MISO regional base ROE rate (the “base 
ROE”)  for  all  MISO  TO’s,  including  our  MISO  Regulated  Operating  Subsidiaries,  to  no  longer  be  just  and 
reasonable.

Initial Complaint

On  November  12,  2013,  the  Association  of  Businesses  Advocating  Tariff  Equity,  Coalition  of  MISO 
Transmission  Customers,  Illinois  Industrial  Energy  Consumers,  Indiana  Industrial  Energy  Consumers,  Inc., 
Minnesota Large Industrial Group and Wisconsin Industrial Energy Group (collectively, the “complainants”) filed 
the Initial Complaint with the FERC. The complainants sought a FERC order to reduce the base ROE used in 
the  formula  transmission  rates  for  our  MISO  Regulated  Operating  Subsidiaries  to  9.15%,  reducing  the  equity 
component of our capital structure and terminating the ROE adders approved for certain Regulated Operating 
Subsidiaries.  The  FERC  set  the  base  ROE  for  hearing  and  settlement  procedures,  while  denying  all  other 
aspects of the Initial Complaint. The ROE collected through the MISO Regulated Operating Subsidiaries’ rates 
during the period November 12, 2013 through  September 27, 2016 consisted of a base ROE of 12.38% plus 
applicable incentive adders.

On  September  28,  2016,  the  FERC  issued  the  September  2016  Order  that  set  the  base  ROE  at  10.32%, 
with a maximum ROE of 11.35%, effective for the period from November 12, 2013 through February 11, 2015 
based  on  the  two-step  DCF  methodology  adopted  in  previous  complaint  matters  for  other  utilities.  The 
September  2016  Order  required  our  MISO  Regulated  Operating  subsidiaries  to  provide  refunds,  including 
interest, which were completed in 2017. Additionally, the base ROE established by the September 2016 Order 
was to be used prospectively from the date of that order until a new approved base ROE was established by the 
FERC.  On  October  28,  2016,  the  MISO  TOs,  including  our  MISO  Regulated  Operating  Subsidiaries,  filed  a 
request with the FERC for rehearing of the September 2016 Order regarding the short-term growth projections 
in the two-step DCF analysis. Additional impacts to the base ROE for the period of the Initial Complaint and the 

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related  accrued  refund  liabilities  resulted  from  the  November  2019  Order  and  May  2020  Order  issued  by  the 
FERC, as discussed below.

Second Complaint

On  February  12,  2015,  the  Second  Complaint  was  filed  with  the  FERC  by Arkansas  Electric  Cooperative 
Corporation,  Mississippi  Delta  Energy  Agency,  Clarksdale  Public  Utilities  Commission,  Public  Service 
Commission  of  Yazoo  City  and  Hoosier  Energy  Rural  Electric  Cooperative,  Inc.,  seeking  a  FERC  order  to 
reduce the base ROE used in the formula transmission rates of our MISO Regulated Operating Subsidiaries to 
8.67%, with an effective date of February 12, 2015.

On June 30, 2016, the presiding ALJ issued an initial decision that recommended a base ROE of 9.70% for 
the refund period from February 12, 2015 through May 11, 2016, with a maximum ROE of 10.68%, which also 
would be applicable going forward from the date of a final FERC order. The Second Complaint was dismissed 
as  a  result  of  the  November  2019  Order  and  the  dismissal  of  the  complaint  was  reaffirmed  in  the  May  2020 
Order, as discussed below.

Related FERC Orders

In April  2017,  the  D.C.  Circuit  Court  vacated  certain  precedent-setting  FERC  orders  that  established  and 
applied the two-step DCF methodology for the determination of base ROE for ISO New England TOs. The court 
remanded the orders to the FERC for further justification of its establishment of the new base ROE for the ISO 
New  England TOs. The  vacated  orders  in  the  ISO  New  England  matters  also  provided  the  precedent  for  the 
September  2016  Order  on  the  Initial  Complaint  and  the ALJ  initial  decision  on  the  Second  Complaint  for  our 
MISO Regulated Operating Subsidiaries. On October 16, 2018, in the New England matters, the FERC issued 
an order on remand which proposed a new methodology for 1) determining when an existing ROE is no longer 
just and reasonable; and 2) setting a new just and reasonable ROE if an existing ROE has been found not to be 
just and reasonable.

The FERC issued a similar order, the November 2018 Order, in the MISO ROE Complaints, establishing a 
paper  hearing  on  the  application  of  the  proposed  new  methodology  to  the  proceedings  pending  before  the 
FERC  involving  the  ROE  of  the  MISO  TOs,  including  our  MISO  Regulated  Operating  Subsidiaries.  The 
November  2018  Order  included  illustrative,  non-binding  calculations  for  the  ROE  that  could  have  been 
established for the Initial Complaint using the FERC's proposed methodology. The November 2018 Order and 
our response to the order through briefs and reply briefs did not provide a reasonable basis for a change to the 
reserve or ROEs utilized for any of the complaint refund periods nor all subsequent periods.

November 2019 Order

On November 21, 2019, the FERC issued an order on the MISO ROE Complaints. The FERC did not adopt 
the  methodology  proposed  in  the  November  2018  Order,  but  rather  applied  a  methodology  to  the  Initial 
Complaint  period  that  used  two  financial  models  to  determine  the  base  ROE. The  FERC  determined  that  the 
base ROE for the Initial Complaint should be 9.88% and the top of the range of reasonableness for that period 
should be 12.24% and that this base ROE should apply during the first refund period of November 12, 2013 to 
February 11, 2015 and from the date of the September 2016 Order prospectively. In the November 2019 Order, 
the  FERC  also  dismissed  the  Second  Complaint.  Therefore,  based  on  the  November  2019  Order,  for  the 
Second  Complaint  refund  period  from  February  12,  2015  to  May  11,  2016,  no  refund  is  due. As  a  result,  we 
reversed  the  aggregate  estimated  current  liability  we  had  previously  recorded  for  the  Second  Complaint,  as 
noted below in “Financial Statement Impacts”. In addition, for the period from May 12, 2016 to September 27, 
2016, no refund is due because no complaint had been filed for that period. The FERC ordered refunds to be 
made  in  accordance  with  the  November  2019  Order  and,  on  December  18,  2019,  the  FERC  granted  an 
extension until December 23, 2020 for settlement of the refunds. The MISO TOs, including our MISO Regulated 
Operating Subsidiaries, and several other parties filed requests for rehearing of the November 2019 Order. The 
MISO TOs filed their request for rehearing primarily on the basis that the methodology applied by the FERC in 
the November 2019 Order does not allow the MISO TOs to earn a reasonable rate of return on their investment, 
as  required  by  precedent.  On  January  21,  2020,  the  FERC  issued  an  order  granting  rehearing  for  further 
consideration.

May 2020 Order

On May 21, 2020, the FERC issued an order on rehearing of the November 2019 Order. In this order, the 
FERC  revised  its  November  2019  Order  methodology,  finding  that  three  financial  models  should  be  used  to 

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determine the base ROE, among other revisions. By applying the new methodology, FERC determined that the 
base ROE for the Initial Complaint should be 10.02% and the top of the range of reasonableness for that period 
should  be  12.62%.  The  FERC  determined  that  this  base  ROE  should  apply  during  the  first  refund  period  of 
November 12, 2013 to February 11, 2015 and from the date of the September 2016 Order prospectively. The 
FERC  ordered  refunds  to  be  made  in  accordance  with  the  May  2020  Order  by  December  23,  2020,  and  on 
October  8,  2020,  the  FERC  granted  an  extension  to  September  23,  2021.  In  the  May  2020  Order,  the  FERC 
also reaffirmed its decision to dismiss the Second Complaint and its finding that no refunds would be ordered on 
the  Second  Complaint.  Our  MISO  Regulated  Operating  Subsidiaries  are  parties  to  multiple  appeals  of  the 
September 2016 Order, November 2019 Order and May 2020 Order at the D.C. Circuit Court.

Financial Statement Impacts

As  of  December  31,  2020,  we  had  recorded  an  aggregate  current  regulatory  asset  and  current  regulatory 
liability of $8 million and $13 million, respectively, and as of December 31, 2019, we had recorded an aggregate 
current  regulatory  liability  of  $70  million  in  the  consolidated  statements  of  financial  position.  These  impacts 
reflect  amounts  owed  from  or  due  to  customers  under  the  terms  outlined  in  the  May  2020  Order  and  the 
November  2019  Order  on  the  Initial  Complaint  and  the  periods  subsequent  to  the  September  2016  Order. 
During the year ended December 31, 2020, we refunded $31 million of the regulatory liability to customers. We 
had  recorded  an  aggregate  estimated  current  regulatory  liability  in  the  consolidated  statements  of  financial 
position of $151 million as of December 31, 2018 for the Second Complaint, which was reversed in November 
2019 following the November 2019 Order. Although the November 2019 Order and May 2020 Order dismissed 
the Second Complaint with no refunds required, it is possible upon appeal that our MISO Regulated Operating 
Subsidiaries  will  be  required  to  provide  refunds  related  to  the  Second  Complaint  and  these  refunds  could  be 
material.

Our  MISO  Regulated  Operating  Subsidiaries  currently  record  revenues  at  the  base  ROE  of  10.02% 
established  in  the  May  2020  Order  plus  applicable  incentive  adders.  See  Note  6  for  a  summary  of  incentive 
adders for transmission rates.

The  recognition  of  the  obligations  associated  with  the  MISO  ROE  Complaints  resulted  in  the  following 

impacts to the consolidated statements of comprehensive income:

(In millions of USD)

Revenue increase
Interest expense (decrease) increase
Estimated net income increase (reduction)

Year Ended December 31,

2020

2019

2018

$ 

32  $ 
(3)   
25 

69  $ 
(12)   
61 

1 
7 
(4) 

As  of  December  31,  2020,  our  MISO  Regulated  Operating  Subsidiaries  had  a  total  of  approximately  $5 
billion of equity in their collective capital structures for ratemaking purposes. Based on this level of aggregate 
equity, we estimate that each 10 basis point change in the authorized ROE would impact annual consolidated 
net income by approximately $5 million.

Purchase Obligations

At December 31, 2020, we had purchase obligations of $83 million representing commitments for materials, 
services  and  equipment  that  had  not  been  received  as  of  December  31,  2020,  primarily  for  construction  and 
maintenance  projects  for  which  we  have  an  executed  contract.  Of  these  purchase  obligations,  $73  million  is 
expected to be paid in 2021, with the majority of the items related to materials and equipment that have long 
production lead times.

Other Commitments

METC

Amended  and  Restated  Purchase  and  Sale  Agreement  for  Ancillary  Services.  Since  METC  does  not  own 
any  generating  facilities,  it  must  procure  ancillary  services  from  third  party  suppliers,  such  as  Consumers 
Energy. Currently, under the Ancillary Services Agreement, METC pays Consumers Energy for providing certain 
generation-based services necessary to support the reliable operation of the bulk power grid, such as voltage 
support and generation capability and capacity to balance loads and generation.

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Amended  and  Restated  Easement  Agreement.  Under  the  Easement  Agreement,  Consumers  Energy 
provides METC with an easement to the land on which a majority of METC’s transmission towers, poles, lines 
and other transmission facilities used to transmit electricity for Consumers Energy and others are located. The 
term  of  the  Easement  Agreement  runs  through  December  31,  2050  and  is  subject  to  10  automatic  50-year 
renewals  thereafter  unless  METC  gives  notice  of  nonrenewal  at  least  one  year  in  advance.  METC  pays 
Consumers Energy $10 million in annual rent per year for the easement and also pays for any rentals, property, 
taxes,  and  other  fees  related  to  the  property  covered  by  the  Easement Agreement.  Payments  to  Consumers 
Energy under the Easement Agreement are charged to operation and maintenance expenses.

ITC Midwest

Operations Services Agreement For 34.5 kV Transmission Facilities. ITC Midwest and IP&L entered into the 
OSA under which IP&L performs certain operations functions for ITC Midwest’s 34.5 kV transmission system. 
The OSA provides that when ITC Midwest upgrades 34.5 kV facilities to higher operating voltages it may notify 
IP&L of the change and the OSA is no longer applicable to those facilities.

ITC Great Plains

Amended  and  Restated  Maintenance  Agreement.  Mid-Kansas  and  ITC  Great  Plains  have  entered  into  the 
Mid-Kansas  Agreement  pursuant  to  which  Mid-Kansas  has  agreed  to  perform  various  field  operations  and 
maintenance services related to certain ITC Great Plains assets.

Concentration of Credit Risk

Our  credit  risk  is  primarily  with  DTE  Electric,  Consumers  Energy  and  IP&L,  which  were  responsible  for 
approximately  21.6%,  23.9%  and  23.9%,  respectively,  or  $265  million,  $292  million  and  $292  million, 
respectively,  of  our  consolidated  billed  revenues  for  the  year  ended  December  31,  2020.  These  percentages 
and  amounts  of  total  billed  revenues  of  DTE  Electric,  Consumers  Energy  and  IP&L  include  the  collection  of 
2018 revenue accruals and deferrals and exclude any amounts for the 2020 revenue accruals and deferrals that 
were  included  in  our  2020  operating  revenues  but  will  not  be  billed  to  our  customers  until  2022.  Under  DTE 
Electric’s and Consumers Energy’s current rate structure, DTE Electric and Consumers Energy include in their 
retail  rates  the  actual  cost  of  transmission  services  provided  by  ITCTransmission  and  METC,  respectively,  in 
their billings to their customers, effectively passing through to end-use consumers the total cost of transmission 
service.  IP&L  currently  includes  in  their  retail  rates  an  allowance  for  transmission  services  provided  by  ITC 
Midwest  in  their  billings  to  their  customers.  However,  any  financial  difficulties  experienced  by  DTE  Electric, 
Consumers  Energy  or  IP&L  may  affect  their  ability  to  make  payments  for  transmission  service  to 
ITCTransmission,  METC,  and  ITC  Midwest,  which  could  negatively  impact  our  business.  MISO,  as  our  MISO 
Regulated  Operating  Subsidiaries’  billing  agent,  bills  DTE  Electric,  Consumers  Energy,  IP&L  and  other 
customers  on  a  monthly  basis  and  collects  fees  for  the  use  of  the  MISO  Regulated  Operating  Subsidiaries’ 
transmission systems. SPP is the billing agent for ITC Great Plains and bills transmission customers for the use 
of  ITC  Great  Plains  transmission  systems.  MISO  and  SPP  have  implemented  strict  credit  policies  for  its 
members’  customers,  which  include  customers  using  our  transmission  systems.  Specifically,  MISO  and  SPP 
require a letter of credit or cash deposit equal to the credit exposure, which is determined by a credit scoring 
model and other factors, from any customer using a member’s transmission system.

The  financial  results  of  ITC  Interconnection  are  currently  not  material  to  our  consolidated  financial 

statements, including billed revenues.

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19.  SUPPLEMENTAL FINANCIAL INFORMATION

Reconciliation of Cash, Cash Equivalents and Restricted Cash

The  following  table  provides  a  reconciliation  of  cash,  cash  equivalents  and  restricted  cash  reported  on  the 
consolidated  statements  of  financial  position  that  sum  to  the  total  of  the  same  such  amounts  shown  in  the 
consolidated statements of cash flows:

(In millions of USD)

Cash and cash equivalents

Restricted cash included in:

Other non-current assets

Total cash, cash equivalents and restricted cash

December 31,

2020

2019

2018

2017

4  $ 

4  $ 

6  $ 

66 

2 

6  $ 

2 

4 

6  $ 

10  $ 

2 

68 

$ 

$ 

Restricted  cash  included  in  other  non-current  assets  primarily  represents  cash  on  deposit  to  pay  for 
vegetation management, land easements and land purchases for the purpose of transmission line construction. 

Supplementary Cash Flow Information

(In millions of USD)

Supplementary cash flows information:

Interest paid (net of interest capitalized)

Income taxes paid

Income tax refunds received

Year Ended December 31,

2020

2019

2018

$ 

236  $ 

228  $ 

223 

2 

2 

135 

27 

— 

— 

3 

92 

29 

5 

— 

13 

94 

33 

— 

Supplementary non-cash investing and financing activities:

Additions to property, plant and equipment and other long-lived assets (a)  

Allowance for equity funds used during construction
Right-of-use assets obtained in exchange for new operating lease 
liabilities

____________________________

(a) Amounts consist of current and accrued liabilities for construction, labor, materials and other costs that have 
not been included in investing activities. These amounts have not been paid for as of December 31, 2020, 
2019 or 2018, respectively, but will be or have been included as a cash outflow from investing activities for 
expenditures for property, plant and equipment when paid.

Excess tax benefits are recognized as an adjustment to income tax expense in the consolidated statements 
of  comprehensive  income.  Cash  retained  as  a  result  of  those  excess  tax  benefits  is  presented  in  the 
consolidated statements of cash flows as cash inflows from operating activities.

20.  SEGMENT INFORMATION

We  identify  reportable  segments  based  on  the  criteria  set  forth  by  the  FASB  regarding  disclosures  about 
segments of an enterprise, including the regulatory environment of our subsidiaries and the business activities 
performed to earn revenues and incur expenses.

Regulated Operating Subsidiaries

We  aggregate  ITCTransmission,  METC,  ITC  Midwest,  ITC  Great  Plains  and  ITC  Interconnection  into  one 
reportable  operating  segment  based  on  their  similar  regulatory  environment  and  economic  characteristics, 
among other factors. They are engaged in the transmission of electricity within the United States, earn revenues 
from the same types of customers and are regulated by the FERC.

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ITC Holdings and Other

Information  below  for  ITC  Holdings  and  Other  consists  primarily  of  a  holding  company  whose  activities 
include debt financings and general corporate activities. The other subsidiaries of ITC Holdings, excluding the 
Regulated Operating Subsidiaries, do not have significant operations.

2020

(In millions of USD)

Operating revenues

Depreciation and amortization

Interest expense, net

Income (loss) before income taxes

Income tax provision (benefit)

Net income

Property, plant and equipment, net
Goodwill

Total assets (a)

Capital expenditures

2019

(In millions of USD)

Operating revenues

Depreciation and amortization

Interest expense, net

Income (loss) before income taxes

Income tax provision (benefit) 

Net income 

Property, plant and equipment, net

Goodwill

Total assets (a)

Capital expenditures

Regulated

Operating

ITC Holdings

Reconciliations/

Subsidiaries

and Other

Eliminations

Total

$ 

1,333  $ 

1  $ 

(36)  $ 

1,298 

218 

118 

683 

179 

504 

9,319 
950 

10,710 

886 

1 

122 

(140)   

(43)   

407 

8 
— 

5,830 

— 

— 

— 

— 

— 

(504)   

— 
— 

219 

240 

543 

136 

407 

9,327 
950 

(5,715)   

10,825 

(1)   

885 

Regulated

Operating

ITC Holdings

Reconciliations/

Subsidiaries

and Other

Eliminations

Total

$ 

1,358  $ 

—  $ 

(31)  $ 

1,327 

201 

105 

710 

179 

531 

8,573 

950 

9,946 

874 

2 

119 

(150)   

(47)   

428 

9 

— 

5,402 

— 

— 

— 

— 

— 

(531)   

— 

— 

203 

224 

560 

132 

428 

8,582 

950 

(5,290)   

10,058 

(9)   

865 

84

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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2018

(In millions of USD)

Operating revenues

Depreciation and amortization

Interest expense, net

Income (loss) before income taxes

Income tax provision (benefit) 

Net income 

Property, plant and equipment, net

Goodwill

Total assets (a)

Capital expenditures

Regulated

Operating

ITC Holdings

Reconciliations/

Subsidiaries

and Other

Eliminations

Total

$ 

1,185  $ 

—  $ 

(29)  $ 

1,156 

179 

110 

585 

148 

437 

7,901 

950 

9,224 

773 

1 

114 

(144)   

(37)   

330 

9 

— 

4,977 

— 

— 

— 

— 

— 

(437)   

— 

— 

(4,872)   

(4)   

180 

224 

441 

111 

330 

7,910 

950 

9,329 

769 

____________________________
(a) Reconciliation  of  total  assets  results  primarily  from  differences  in  the  netting  of  deferred  tax  assets  and 
liabilities  in  our  segments  as  compared  to  the  classification  in  our  consolidated  statements  of  financial 
position.

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ITEM  9.    CHANGES  IN  AND  DISAGREEMENTS  WITH  ACCOUNTANTS  ON  ACCOUNTING  AND 

FINANCIAL DISCLOSURE.

None.

ITEM 9A.   CONTROLS AND PROCEDURES.

Management’s Report on Internal Control Over Financial Reporting is included in Item 8 of this Form 10-K.

Disclosure Controls and Procedures

We  maintain  disclosure  controls  and  procedures  that  are  designed  to  provide  reasonable  assurance  that 
material  information  required  to  be  disclosed  in  our  reports  that  we  file  or  submit  under  the  Exchange Act,  is 
recorded, processed, summarized and reported within the time periods specified in the SEC’s rules and forms, 
and that such information is accumulated and communicated to our management, including our Chief Executive 
Officer  and  Chief  Financial  Officer,  as  appropriate,  to  allow  timely  decisions  regarding  required  financial 
disclosure. In designing and evaluating the disclosure controls and procedures, management recognized that a 
control  system,  no  matter  how  well  designed  and  operated,  can  provide  only  reasonable,  not  absolute, 
assurance  that  the  objectives  of  the  control  system  are  met.  Because  of  the  inherent  limitations  in  all  control 
systems, no evaluation of controls can provide absolute assurance that all control issues and instances of fraud, 
if any, with a company have been detected.

As of the end of the period covered by this report, we carried out an evaluation, under the supervision and 
with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, of 
the effectiveness of the design and operation of our disclosure controls and procedures pursuant to Rule 13a-15 
of  the  Exchange  Act.  Based  upon  that  evaluation,  our  Chief  Executive  Officer  and  Chief  Financial  Officer 
concluded that our disclosure controls and procedures are effective, at the reasonable assurance level.

Changes in Internal Control over Financial Reporting

There  have  been  no  changes  in  our  internal  control  over  financial  reporting  during  the  quarter  ended 
December  31,  2020  that  have  materially  affected,  or  are  reasonably  likely  to  materially  affect,  our  internal 
control over financial reporting.

ITEM 9B.   OTHER INFORMATION.

None.

PART III

ITEM 10.   DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE.

DIRECTORS

Our  Bylaws  provide  for  the  election  of  directors  at  each  annual  meeting  of  shareholders.  Each  director 
serves until the next annual meeting and until his or her successor is elected and qualified, or until his or her 
resignation or removal.

Pursuant  to  the  Merger Agreement  and  the  Shareholders Agreement,  the  Board  must  consist  of  the  Chief 
Executive Officer of the Company (Ms. Apsey), a representative of Eiffel, the GIC subsidiary that is a minority 
investor in ITC Investment Holdings (Mr. Greenbaum), a minority of representatives of Fortis (Messrs. Hutchens 
and Laurito) and a majority of directors who are independent of Fortis. All directors must be independent of any 
“market participant” in MISO and SPP and a majority of the directors must be “independent” as defined in the 
Shareholders  Agreement.  See  “Item  13  Certain  Relationships  And  Related  Transactions,  And  Director 
Independence — Director Independence.”

Linda H. Apsey, 51. Ms. Apsey became President and Chief Executive Officer of the Company in November 
2016 and was elected a director of the Company in January 2017. From May 2016 through January 2017, Ms. 
Apsey  served  as  the  Company’s  Executive  Vice  President  and  Chief  Business  Unit  Officer,  where  she  was 
responsible for leading all aspects of the financial and operational performance of our five Regulated Operating 
Subsidiaries  and  the  Company’s  development.  She  had  previously  served  as  the  Company’s  Executive  Vice 
President,  Chief  Business  Unit  Officer  and  President,  ITC  Michigan  since  February  2015  where  she  was 
responsible  for  leading  all  aspects  of  the  financial  and  operational  performance  of  the  Company’s  five 

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Regulated Operating Subsidiaries and acting as the business unit head and president of the ITCTransmission 
and  METC  operating  companies.  Ms.  Apsey  currently  serves  as  a  director  of  the  Fortis  utility  subsidiary, 
FortisAlberta Inc.

Robert A. Elliott, 65. Mr. Elliott became a director of the Company in January 2017. Mr. Elliott has served as 
President  and  Owner  of  Elliott  Accounting,  an  accounting,  income  tax  and  management  advisory  services 
organization  in  Tucson,  Arizona,  since  1983.  He  also  serves  as  an  Investment  Advisor  Representative  for 
Greenberg  Financial  Group,  a  brokerage  firm,  a  position  in  which  he  has  served  since  2001.  Mr.  Elliott  is 
currently the Chairman of the Board of UNS Energy Corporation, a subsidiary of Fortis, and has been a board 
member  of  that  company  since  2014.  Mr.  Elliott  currently  serves  on  the  board  of  directors  of AAA Auto  Club 
Partners  and AAA  Mountain  West  Group  and  served  as  the  Chair  of  the  board  of  directors  of AAA  Mountain 
West Group from 2016 to 2020. He previously served on the board of directors of AAA Arizona Inc. from 2007 to 
2016  and  AAA  CSAA  Insurance  from  2018  to  2020.  The  Board  selected  Mr.  Elliott  to  serve  as  a  director 
because  of  his  accounting  experience,  his  familiarity  with  Fortis  subsidiary  operations  and  his  experience 
serving as a leader on other boards of directors.

Albert  Ernst,  71.  Mr.  Ernst  became  a  director  of  the  Company  in  January  2017.  Mr.  Ernst  was  also  a 
member  of  the  ITC  Holdings  Board  of  Directors  from  August  2014  through  the  closing  of  the  transactions 
resulting  from  the  Merger Agreement  in  October  2016,  as  described  in  the  Merger Agreement.  Mr.  Ernst  is  a 
retired member of the law firm of Dykema Gossett PLLC, where he also served as director of Dykema’s Energy 
Industry  Group.  His  experience  with  companies  in  the  public  utility,  energy,  transmission,  telecommunications 
and  rural  electric  cooperative  fields  spans  more  than  three  decades.  With  Dykema,  Mr.  Ernst  worked  with 
leading energy clients including our subsidiaries, ITCTransmission and METC. He also served as a consultant 
on  utility-related  matters  to  the  U.S.  Department  of  Defense,  the  Department  of  Energy  and  the  General 
Services Administration.  The  Board  selected  Mr.  Ernst  to  serve  as  a  director  due  to  his  lifelong  career  in  the 
energy  industry,  as  well  as  his  invaluable  experience  with  public  utility  and  energy  matters  and  decades  of 
experience in the practice of law.

Debora M. Frodl, 55. Ms. Frodl became a director of the Company in August 2020. Ms. Frodl is the founder 
of DF Strategies, a strategic consultancy firm in Minneapolis, MN, since 2018. She previously enjoyed a 28-year 
career  at  General  Electric,  where  she  most  recently  was  Global  Executive  Director,  Ecomagination  from 
December 2012 to December 2017. Ms. Frodl gained over twenty years of senior executive experience at GE 
Capital, serving in roles including Senior Vice President and CEO and President. Ms. Frodl currently serves as 
a member of the Board of Directors for Renewable Energy Group, Inc., XL Fleet Corporation, and Spring Valley 
Acquisition  Corporation.  Since  2014,  Ms.  Frodl  has  served  as  an  ambassador  for  the  US  Department  of 
Energy’s  Clean  Energy,  Education  &  Empowerment  for  Women  Initiative.  She  also  serves  on  the  Advisory 
Board  for  the  National  Renewable  Energy  Lab,  Joint  Institute  of  Strategic  Energy Analysis  and  University  of 
Minnesota, Institute on the Environment. The Board selected Ms. Frodl to serve as a director due to her career 
in the energy industry, and her leadership experience and familiarity within the geographic region in which the 
Company operates and conducts its business.

Alexander  I.  Greenbaum,  37.  Mr.  Greenbaum  became  a  director  of  the  Company  in  July  2019.  Mr. 
Greenbaum is the North America Head of Infrastructure for GIC. In this role he is responsible for acquisitions 
and asset management for a diverse portfolio of infrastructure assets. Prior to joining GIC in May 2015, he was 
an Executive Director in the Infrastructure group of UBS Investment Bank from July 2005 until May 2015. Mr. 
Greenbaum  currently  serves  on  the  board  of  directors  of  Tallgrass  Energy,  LP,  a  partnership  that  owns, 
operates, acquires and develops midstream energy assets in North America, and Genesee & Wyoming Inc., a 
railroad  holding  company  that  operates  railroads  in  North America  and  Europe.  He  previously  served  on  the 
boards of directors of Arrowhead ST Holdings, a crude oil pipeline operator, HEP Catalyst InvestCo, a crude oil 
and natural gas gathering and processing company that operates in the Permian Basin, Starwest Generation, 
an  independent  power  producer  with  operations  in Arizona,  and  Texas  Transmission  Holdings  Company.  Mr. 
Greenbaum was appointed as a member of our Board of Directors by Eiffel. 

Lt. Gen. Ronnie Hawkins, Jr., USAF, Retired, 65. Lt. Gen. Hawkins, Jr. became a director of the Company 
in June 2020. Lt. Gen. Hawkins Jr. was appointed as President of Angelo State University, which is part of the 
Texas  Tech  University  System,  in  2020.  Lt.  Gen.  Hawkins  Jr.  is  also  the  President  and  CEO  of  the  Hawkins 
Group, a consultancy focusing on digital, information technology and cybersecurity challenges for Fortune 500 
clients  and  the  U.S.  Government.  He  founded  the  Hawkins  Group  in  2015  after  serving  more  than  a  37-year 
decorated career in the United States Air Force, which included leadership roles in critical infrastructure and key 

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information systems used by the Department of Defense and its coalition partners. The Board selected Lt. Gen. 
Hawkins  Jr.  due  to  his  vast  knowledge  of  cybersecurity  and  information  systems  as  well  as  his  leadership 
experience.

David G. Hutchens, 54. Mr. Hutchens became a director of the Company in January 2021. Mr. Hutchens is 
the  President  and  Chief  Executive  Officer  of  Fortis  and  has  served  as  such  since  January  2021.  Prior  to  his 
current  position,  Mr.  Hutchens  was  appointed  to  Chief  Operating  Officer  of  Fortis  in  January  2020  while 
concurrently  serving  as  the  Chief  Executive  Officer  of  UNS  Energy  Corporation,  a  position  in  which  he  held 
since May 2014. Mr. Hutchens also served as Executive Vice President, Western Utility Operations with Fortis 
from 2018 to 2020. His career in the energy sector spans more than 25 years, having held a variety of positions 
at electric and gas utilities in Arizona. He currently serves as a director of the Fortis utility subsidiaries, FortisBC, 
Fortis Alberta and UNS Energy Corporation.

James  P.  Laurito,  64.  Mr.  Laurito  became  a  director  of  the  Company  in  October  2016.  Mr.  Laurito  has 
served  as  Fortis’  Executive  Vice  President,  Business  Development  since  April  2016  and  was  named  Chief 
Technology Officer in 2018. Previously, Mr. Laurito served as the President and Chief Executive Officer of Fortis’ 
Central  Hudson  Gas  &  Electric  Corporation  subsidiary  from  January  2010  to  November  2014.  Prior  to  joining 
Central Hudson, Mr. Laurito served as the President and Chief Executive Officer of both New York State Electric 
and Gas Corporation and Rochester Gas and Electric Corporation, subsidiaries of Avangrid, Inc. Mr. Laurito has 
been Chairman of the Hudson Valley Economic Development Corporation since January 1, 2015 and currently 
serves  on  the  board  of  Belize  Electricity  Co.  Ltd.  and  Fortis’  Central  Hudson  Gas  &  Electric  Corporation 
subsidiary. 

Sandra E. Pierce, 62. Ms. Pierce was appointed as Chair of the Board of Directors of the Company in May 
2020  and  has  served  as  a  director  of  the  Company  since  January  2017.  Ms.  Pierce  is  Senior  Executive  Vice 
President,  Private  Client  Group  &  Regional  Banking  Director  and  Chair  of  Michigan  for  Huntington  National 
Bank.  Ms.  Pierce  joined  Huntington  in  2016  after  its  merger  with  FirstMerit  Corporation  in  2016.  While  at 
FirstMerit, Ms. Pierce served as Vice Chairman of FirstMerit Corporation and Chairman and CEO of FirstMerit 
Michigan,  from  2013  to  2016.  Ms.  Pierce  currently  serves  as  a  board  member  of  Barton  Malow  Enterprises, 
Penske  Automotive  Group  and  American  Axle  &  Manufacturing,  Inc.  She  also  serves  as  the  vice  chair  of 
Business  Leaders  of  Michigan,  chair  of  the  Detroit  Financial Advisory  Board  and  the  chair  of  the  Henry  Ford 
Health  System.  The  Board  selected  Ms.  Pierce  to  serve  as  a  director  due  to  her  leadership  experience  and 
familiarity with the geographic region in which the Company operates and conducts business.

Kevin L. Prust, 65. Mr. Prust became a director of the Company in January 2017. Mr. Prust retired in 2014 
as  Executive  Vice  President  and  Chief  Financial  Officer  of  The  Weitz  Company,  LLC,  a  large  national  and 
international construction firm, a position he held since joining the company in 2009. Prior to that, Mr. Prust was 
with  McGladrey  &  Pullen  LLP,  a  national  CPA  firm,  from  1978  through  2008  serving  in  various  positions  and 
becoming partner in 1985. Mr. Prust previously served on the board of Mercy Medical Center, in Des Moines, 
Iowa from 2009 to 2018. In 2015 Mr. Prust served on the board of Stock Building Supply Holdings, Inc. until the 
company was acquired. The Board selected Mr. Prust to serve as a director because of the expansive financial 
and accounting experience he obtained as a chief financial officer as well as his familiarity with the geographic 
region in which the Company operates and conducts business. The Board has determined that Mr. Prust is an 
“audit committee financial expert”, as that term is defined under SEC rules.

A.  Douglas  Rothwell,  64.  Mr.  Rothwell  became  a  director  of  the  Company  in  October  2017.  Mr.  Rothwell 
served as President and CEO of Business Leaders for Michigan - a business roundtable of the state’s top 100 
CEOs  from  2005  through  2020.  Mr.  Rothwell  currently  chairs  the  University  of  North  Carolina  at  Chapel  Hill’s 
(“UNC”) Ackland Museum board in addition to serving as an Executive Residence for Economic Development at 
UNC. He previously chaired the Michigan Economic Development Corporation, the American Center for Mobility 
and  the  UNC  Board  of  Visitors.  The  Board  selected  Mr.  Rothwell  to  serve  as  a  director  because  of  his  vast 
experience working with business leaders in various industries to foster business development and growth and 
his familiarity and business contacts within the geographic region in which the Company operates and conducts 
business.

Set  forth  below  are  the  names,  ages  and  titles  of  our  current  executive  officers  and  a  description  of  their 
business  experience.  Our  executive  officers  serve  as  executive  officers  at  the  pleasure  of  the  Board  of 
Directors. 

EXECUTIVE OFFICERS

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Linda H. Apsey, 51. Ms. Apsey’s background is described above under “Directors.”

Gretchen L. Holloway, 46. Ms. Holloway was named Senior Vice President and Chief Financial Officer in 
July  2017.  Prior  to  this  role,  Ms.  Holloway  served  as  Vice  President,  Interim  Chief  Financial  Officer  and 
Treasurer, a position in which she served since October 2016. In her role, Ms. Holloway is responsible for the 
Company’s  accounting,  internal  audit,  treasury,  financial  planning  and  analysis,  management  reporting,  risk 
management  and  tax  functions.  From  May  2016  to  October  2016,  Ms.  Holloway  was  Vice  President  and 
Treasurer  and  from  November  2015  until  May  2016,  Ms.  Holloway  served  as  Vice  President,  Finance  and 
Treasurer  of  the  Company.  In  this  role  and  her  immediate  past  role,  she  was  responsible  for  all  treasury  and 
corporate  planning  activities  including  cash  management  and  as  the  Company’s  liaison  with  the  investment 
banking community and rating agencies. Ms. Holloway served from February 2015 to November 2015 as Vice 
President,  Finance  of  the  Company,  where  she  was  responsible  for  corporate  finance  activities  including 
oversight of the budget and forecast processes and other financial analysis. Ms. Holloway currently serves as a 
member of the Finance & Audit Committee for the Children’s Hospital of Michigan Foundation and as a member 
of the Board of Directors of Inforum.

Jon  E.  Jipping,  54.  Jon  E.  Jipping  has  served  as  Executive  Vice  President  and  Chief  Operating  Officer 
since June 2007. Mr. Jipping is responsible for transmission system planning, system operations, engineering, 
supply  chain,  field  construction  and  maintenance,  and  information  technology.  Prior  to  this  appointment,  Mr. 
Jipping  served  as  Senior  Vice  President  -  Engineering  and  was  responsible  for  transmission  system  design, 
project  engineering  and  asset  management.  Mr.  Jipping  joined  the  Company  as  Director  of  Engineering  in 
March  2003,  was  appointed  Vice  President  -  Engineering  in  2005  and  was  named  Senior  Vice  President  in 
February 2006. Mr. Jipping currently serves on the board of Wataynikaneyap Power PM Inc., an entity owned 
by FortisOntario, Inc., a subsidiary of Fortis, which was created to develop and operate transmission to connect 
remote First Nation communities to the electrical grid in northwestern Ontario, Canada. He was appointed to the 
Michigan Technological University Board of Trustees as a Board Member in 2020.

Christine  Mason  Soneral,  48.  Christine  Mason  Soneral  has  served  as  Senior  Vice  President,  General 
Counsel, Secretary and Chief Compliance Officer since October 2020. She was named Senior Vice President 
and  General  Counsel  in April  2015  and  served  as  Vice  President  and  General  Counsel  from  February  2015 
through  this  appointment.  She  is  responsible  for  all  corporate  legal  affairs  and  the  leadership  of  our  legal 
department, which includes the legal, real estate, contract administration and corporate compliance functions. 
Prior  to  this  role,  Ms.  Mason  Soneral  was  Vice  President  and  General  Counsel-Utility  Operations  since  2007 
and  was  responsible  for  legal  matters  connected  with  the  operations,  capital  projects,  contract,  regulatory, 
property and litigation matters of the Company’s Regulated Operating Subsidiaries. Ms. Mason Soneral served 
on the board of Citizens Research Council, a privately funded, not-for-profit public affairs research organization 
from  2014  to  2020.  Ms.  Mason  Soneral  also  currently  serves  as  a  member  of  the  Michigan  State  University 
College  of  Social  Science's  External  Advisory  Board  and  is  a  Co-Founder  and  Director  of  Michigan  State 
University’s Women’s Leadership Institute.

Krista K. Tanner, 46. Ms. Tanner has served as our Senior Vice President and Chief Business Unit Officer 
since February 2019. Ms. Tanner is responsible for strategic direction, customer service, local government and 
community affairs and financial performance for four of the Company’s operating subsidiaries: ITC Midwest, ITC 
Great  Plains,  ITCTransmission  and  METC.  Ms.  Tanner  joined  the  Company  in  November  2014  where  she 
served as Vice President, ITC Holdings and President, ITC Midwest. In this role she served as the business unit 
head, providing leadership and strategic direction for ITC Midwest. Ms. Tanner joined the Company from Alliant 
Energy,  where  she  served  as  director  of  regulatory  policy  from  2011  to  2014.  While  at  Alliant  Energy  she 
directed  Alliant  Energy’s  regional  and  federal  regulatory  policy  group  and  led  Alliant  Energy’s  legal  strategy 
across  regulatory  jurisdictions.  Ms.  Tanner  previously  served  as  a  member  of  the  Board  of  Directors  of  the 
Midwest Reliability Organization from 2017 to 2019. Ms. Tanner currently serves as a member of the Board of 
Directors of Delta Dental of Iowa.

Code of Conduct and Ethics

We have adopted a Code of Conduct and Ethics that applies to all of our directors, employees and executive 
officers, including our chief executive officer, chief financial officer and principal accounting officer. The Code of 
Conduct  and  Ethics,  as  currently  in  effect  (together  with  any  amendments  that  may  be  adopted  from  time  to 
time), is available on our website at www.itc-holdings.com. To the extent required by the Code of Conduct and 
Ethics or by applicable law, we will post any amendments to the Code of Conduct and Ethics and any waivers 

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that are required to be disclosed by the rules of the SEC on our website, within the required periods.

ITEM 11.   EXECUTIVE COMPENSATION.

COMPENSATION OF EXECUTIVE OFFICERS AND DIRECTORS

Compensation Discussion and Analysis

The following Compensation Discussion and Analysis describes the elements of compensation for our Chief 
Executive Officer (or “CEO”), our Chief Financial Officer and the three other most highly compensated executive 
officers who were serving as such at December 31, 2020, and our former Executive Vice President and Chief 
Administrative Officer. We refer to these individuals collectively as the “named executive officers” or “NEOs”.

The Company’s named executive officers for 2020 were:

Name

Linda H. Apsey
Gretchen L. Holloway
Jon E. Jipping

Christine Mason Soneral
Krista Tanner
Daniel J. Oginsky

Position

President and Chief Executive Officer
Senior Vice President and Chief Financial Officer 
Executive Vice President and Chief Operating Officer
Senior Vice President, General Counsel, Secretary and Chief 
Compliance Officer
Senior Vice Present and Chief Business Unit Officer
Former Executive Vice President and Chief Administrative Officer

Mr. Oginsky, whose employment with the Company terminated in May 2020, is included as an NEO in the 

discussion below in accordance with applicable SEC rules.

Executive Summary

The  Governance  and  Human  Resources  Committee  (the  “Committee”)  is  responsible  for  determining  the 
compensation  of  our  NEOs  and  administering  the  plans  in  which  the  NEOs  participate.  The  goals  of  our 
compensation system are to attract first-class executive talent in a competitive environment and to motivate and 
retain  key  employees  who  are  crucial  to  our  success  by  rewarding  Company  and  individual  performance  that 
promotes  long-term  sustainable  growth  and  increases  shareholder  value.  The  key  components  of  our  NEOs' 
compensation package include base salary, annual cash incentive bonuses, long-term equity incentives, as well 
as  certain  perquisites  and  other  benefits.  In  determining  the  amount  of  NEO  compensation,  we  consider 
competitive compensation practices of other utilities and similarly sized organizations, the executive's individual 
performance against objectives, the executive's responsibilities and expertise, and our performance in relation 
to annual goals that are designed to strengthen and enhance our value.

The Committee made the following decisions with regard to executive compensation in 2020:

• Base  salary  increases.  Base  salary  increases  were  provided  to  each  of  our  NEOs  in  2020  to  reward 

individual performance and to remain competitive and aligned with market.

• Annual  cash  incentive  bonuses.  The  NEOs  earned  cash  incentive  bonuses  for  2020  performance  of 
approximately 141% of target. This was based on achieving 85% of the performance targets established 
under  the  annual  corporate  performance  bonus  plan  in  early  2020  and  achievement  of  certain 
performance  factors  which  resulted  in  a  bonus  multiplier  of  1.66.  See  “Compensation  Discussion  and 
Analysis  -  Key  Components  of  Our  NEO  Compensation  Program  -  Annual  Corporate  Performance 
Bonus.”

• Long-term  equity  incentives.  We  granted  long-term  equity  incentive  awards  to  our  NEOs  in  January 
2020. Total  award  opportunities  were  set  as  a  percentage  of  base  salary  and  delivered  one-third  in  the 
form of SBUs and two-thirds in the form of PBUs.  

Overview and Philosophy

The  objectives  of  our  compensation  program  are  to  attract  first-class  executive  talent  in  a  competitive 
environment and to motivate and retain key employees who are crucial to our success by rewarding Company 
and individual performance that promotes long-term sustainable growth and increases shareholder value by:

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• Performing best-in-class utility operations;

• Improving reliability, reducing congestion, and facilitating access to generation resources; and

• Utilizing our experience and skills to seek and identify opportunities to invest in needed transmission and 

to optimize the value of those investments.

Our compensation program is designed to motivate and reward individual and corporate performance. Our 

compensation philosophy is to:

• Provide for flexibility in pay practices to recognize our unique position and growth proposition;

• Use a market-based pay program aligned with pay-for-performance objectives;

• Leverage  incentives,  where  possible,  and  align  long-term  incentive  awards  with  improvements  in  our 

financial performance and shareholder value;

• Provide  benefits  through  flexible,  cost-effective  plans  while  taking  into  account  business  needs  and 

affordability; and

• Provide other non-monetary awards to recognize and incentivize performance.

Risk and Reward Balance

When  reviewing  the  compensation  program,  the  Committee  considers  the  impact  of  the  program  on  the 
Company’s  risk  profile. The  Committee  believes  that  the  compensation  program  has  been  structured  with  the 
appropriate mix and design of elements to provide strong incentives for executives to balance risk and reward, 
without excessive risk taking.

The  Committee  engaged  FW  Cook,  its  independent  compensation  consultant,  to  conduct  an  annual 
comprehensive  compensation  program  risk  assessment.  In  July  2020,  FW  Cook  reviewed  the  attributes  and 
structure of our executive compensation programs for the purpose of identifying potential sources of risk within 
the program design. The review covered compensation plan design and administration/governance risk.

Based on a report from FW Cook concluding that the Company’s compensation programs do not create risks 
that  are  reasonably  likely  to  have  a  material  adverse  impact  on  the  Company,  the  Committee  concluded  that 
none  of  our  compensation  programs  and  features  contain  elements  that  create  material  risk  to  the  Company. 
Risk  mitigating  factors  with  respect  to  the  Company’s  compensation  programs  included  a  market  competitive 
pay  mix,  the  linking  of  pay  to  performance  through  annual  cash  bonus  and  long-term  equity  incentive  plans, 
caps  on  annual  cash  bonus  and  long-term  equity  incentive  plan  payouts,  various  performance  measures  that 
are both financially and operationally focused, stock ownership guidelines, prohibition on hedging and pledging, 
oversight by an independent committee of directors, regular review of NEO tally sheets and engagement of an 
independent compensation consultant.

Benchmarking and Relationship of Compensation Elements

Benchmarking. We reviewed market competitive target pay levels from two distinct market samples, utility 
and general industry data, as reflected in published surveys. FW Cook, the Committee’s independent advisor, 
compiled data for the following components of compensation — base salary, target annual cash bonus incentive 
and target long-term incentive, as well as target total cash compensation and target total direct compensation. 
Position-specific  market  target  pay  levels  are  reviewed  for  utility-specific  data  from  the  Willis  Towers  Watson 
Energy  Services  Executive  Compensation  Survey  and  general  industry  data  from  the  Willis  Towers  Watson 
General Industry Executive Compensation Survey. The energy services data is used as our primary source with 
the general industry data provided as an additional reference point for positions other than those specific to the 
utility industry. The market data were aged and size-adjusted to correspond to our adjusted revenue scope. The 
adjusted  revenue  scope  accounts  for  our  unique  business  model  and  reflects  the  competitive  incremental 
revenue that would normally be embedded in rates to reflect a typical cost of goods sold factor.

Our compensation strategy is to target compensation at the median (50th percentile) of the energy services 
benchmark  data,  plus  or  minus  20%,  based  on  consideration  of  individual  characteristics  (performance, 
experience,  etc.),  internal  equity  and  other  factors.  The  Committee  adopted  this  strategy  in  October  2019.  In 
November  2019,  the  Committee  reviewed  the  benchmarking  study  conducted  by  its  independent  consultant 
comparing NEO target total direct compensation, which is the sum of base salary, target annual incentives and 

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target  long-term  incentives,  to  the  25th,  50th  and  75th  percentile  survey  data  to  assess  the  market 
competitiveness  of  our  compensation  opportunities.  Overall,  the  study  found  target  total  direct  compensation 
provided to our NEOs is at the high end of the targeted competitive position.

Use of Tally Sheets. The Committee reviews tally sheets, every other year, as prepared by management to 
facilitate  its  assessment  of  the  total  annual  compensation  of  our  NEOs. The  tally  sheets  contain  annual  cash 
compensation  (salary  and  bonuses),  long-term  equity  incentives,  benefit  contributions  and  perquisites.  In 
addition, the tally sheets include retirement program balances, outstanding vested and unvested equity values 
and potential severance and termination scenario values.

Pay  Review  Process.  In  addition  to  the  Committee’s  benchmarking  analysis,  our  CEO  reviewed  and 
examined  market  survey  compensation  levels  and  practices,  as  well  as  individual  responsibilities  and 
performance,  our  compensation  philosophy  and  other  related  information  to  develop  proposed  compensation 
for each of our NEOs, other than herself. Ms. Apsey evaluated the performance of the NEOs, other than herself, 
and made recommendations on their salaries, target cash bonus incentive levels and long-term equity incentive 
awards.  The  Committee  considered  these  recommendations  in  its  decision  making  and  conferred  with  FW 
Cook,  its  compensation  consultant,  to  understand  the  impact  and  result  of  any  such  recommendations.  The 
Committee  uses  market  data  and  recommendations  from  FW  Cook  and  makes  recommendations  on  Ms. 
Apsey’s salary, cash bonus incentive targets and long-term equity incentive awards to the Board of Directors. 
The  Board  of  Directors  (other  than  Ms.  Apsey)  evaluates  Ms.  Apsey’s  performance  and  considers  the 
Committee’s recommendations in its decision making.

The Committee reviewed and considered each element of compensation and the resulting target total direct 
compensation,  along  with  the  objectives  of  our  compensation  program,  the  input  of  the  CEO  and  the  market 
data  to  set  the  2020  target  pay  levels.  The  Committee  did  not  determine  the  mix  of  compensation  elements 
using  a  pre-set  formula.  In  setting  executive  compensation  levels,  the  Committee  retained  full  discretion  to 
consider  or  disregard  data  collected  through  benchmarking  studies.  Compensation  decisions  also  considered 
individual  and  Company  performance,  retention  concerns,  the  importance  of  the  position,  internal  equity  and 
other factors.

Key Components of Our NEO Compensation Program

The key components of our executive compensation program are discussed below.

• Base  Salary  —  provides  sufficient  competitive  pay  to  attract  and  retain  experienced  and  successful 

executives.

• Cash  Bonus  Incentive  —  encourages  and  rewards  contributions  to  our  annual  corporate  performance 

goals.

• Long  Term  Equity  Incentives  —  encourages  a  multi-year  focus  on  performance,  rewards  building  long-

term shareholder value and helps retain NEOs.

The other elements of our executive compensation program are discussed below under the heading “Other 
Components  of  Our  Executive  Compensation  Program”  which  summarize  the  benefit  programs  that  are 
available to our NEOs.

In  aggregate,  the  NEOs’  target  total  direct  compensation  value  (salary,  annual  target  bonus  and  long-term 
incentive opportunities) was at the high end of the targeted competitive position of median plus or minus 20% 
when compared to the energy services benchmark data. Current positioning reflects median base salaries and 
above  median  target  bonus  and  long-term  incentive  opportunities.  The  Committee  continues  to  monitor  and 
balance competitive practice, talent needs and cost considerations when setting compensation.

Base Salary

The Committee annually reviews and approves the base salaries, and any adjustments thereto, of the NEOs. 
In  making  these  determinations,  the  Committee  considers  the  executive’s  job  responsibilities,  individual 
performance, leadership and years of experience, the performance of the Company, the recommendation of the 
CEO (except for the base salary of the CEO) and the target total direct compensation package as well as the 
benchmarking analysis conducted by its advisor.

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The 2020 base salaries for the NEOs, including any year-over-year change, were:

NEO

2019 Base Salary

2020 Base Salary

Percent Increase

Linda H. Apsey

Gretchen L. Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

Daniel J. Oginsky

$ 

800,000  $ 

816,000 

390,000 

580,000 

390,000 

325,000 

485,000 

397,800 

585,800 

393,900 

339,600 

485,000 

 2.0 %

 2.0 %

 1.0 %

 1.0 %

 4.5 %

 — %

Ms. Tanner’s higher percentage increase reflects her expanding role and responsibilities.

Annual Corporate Performance Bonus

Early each year, the Committee approves our annual corporate performance bonus plan goals and targets, 
which  are  based  on  key  Company  objectives  relating  to  operational  excellence  and  superior  financial 
performance. The corporate performance goals and targets were designed to align the interests of customers, 
the shareholder and management, and encourage teamwork and coordination among all of our executives and 
employees  with  a  common  focus  on  the  growth  and  success  of  the  Company. Target  levels  for  the  corporate 
performance  goals  were  determined  based  on  long-term  strategic  plans,  historical  performance,  expectations 
for future growth and desired improvement over time.

The annual corporate performance bonus plan goals were individually weighted. Weights were assigned to 
each goal based on areas of focus during the year and difficulty in achieving target performance. Weights were 
also  assigned  so  that  there  was  a  balance  between  operational  and  financial  goals.  Each  goal  operated 
independently,  and,  for  most  goals,  there  was  not  a  range  of  acceptable  performance;  if  a  goal  was  not 
achieved,  there  was  no  payout  for  that  goal.  Where  performance  goals  were  stated  in  a  range,  the  threshold 
goals were generally expected to be achieved while the maximum goals were considered “stretch” goals with 
lower  expectation  of  achievement.  The  bonus  goal  targets  were  established  to  motivate  NEOs  toward 
operational excellence and superior financial performance and were designed to be challenging to meet, while 
remaining achievable.

For 2020, Financial goals, representing 20%, plus Safety & Compliance, representing 20%, determined 40% 
of  the  target  bonus  opportunity,  while  System  Performance,  representing  30%,  and  Capital  Project  Plan, 
representing  30%,  determined  the  remaining  60%  of  the  target  bonus  opportunity. This  reflected  the  inherent 
importance of driving operational performance, reliability and needed investment in our transmission system for 
the benefit of our customers.

The  annual  corporate  performance  bonus  plan  consisted  of  three  primary  measurement  categories: 
Financial,  Safety  &  Compliance,  and  System  Performance.  Our  safety,  operations  and  security  goals  were 
established  to  deliver  high  performance  in  core  company  operations.  Benchmarks  and  metrics  were  used  in 
connection with these goals to establish a level of performance in the top decile or quartile within our industry. 
Likewise,  our  infrastructure  protection  goals  led  to  the  deployment  of  industry  leading  practices  resulting  in  a 
generally enhanced security posture.

Corporate performance goal criteria approved by the Committee for 2020, the rationale for the target goal (in 

some cases in relation to the prior year target) and actual bonus results, were as set forth below.

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Financial goals represented 20% of the total maximum annual bonus target and included specific measures 

for Non-Field Operation and Maintenance Expense and Net Income.

Category

Goal

Rationale for Goal

Rationale for Target Goal

Non-field Operation and 
Maintenance Expense and 
General and Administrative 
Expenses

Adjusted Net Income (1)

Financial

20% 
Maximum 
Potential 
Payout

Controlling 
general and 
administrative 
expenses is an 
important part of 
controlling rates 
charged to 
transmission 
customers.

Target is consistent 
with the approach used 
in 2019 and based on 
the 2020 Board-
approved budget.

Non-Field O&M and 
G&A expense at or 
under budget of 
$168M.

Represents the 
Company’s 
financial 
performance as it 
reflects a true 
measure of 
earnings 
contributions 
from our 
Regulated 
Operating 
Subsidiaries.

Target based on the 
2020 Board-approved 
budget.

Adjusted Net Income 
at or above $491M to 
achieve 10%; 
Adjusted Net Income 
at or above $467M to 
achieve 5%.

Potential 
Payout

2020 
Results
 10 % $140M

Actual 
Payout

10%

5% - 10% $496M

10%

Total

 20  %

20%

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Safety & Compliance goals represented 20% of the total maximum annual bonus target and included specific 

measures for Lost Time, Recordable Incidents and Infrastructure Protection.

Potential 
Payout

 5 %

2020 Results
0

Actual 
Payout

5%

 5 %

2

5%

 10 % Completed

10%

Category

Goal
Safety as 
measured by 
lost time

Rationale for Goal
Maintaining the 
safety of our 
employees and 
contractors is a 
core value and 
is at the 
foundation of 
our success.

Safety & 
Compliance

20% Maximum 
Potential Payout

Safety as 
measured by 
recordable 
incidents

Maintaining the 
safety of our 
employees and 
contractors is a 
core value and 
is at the 
foundation of 
our success.

Infrastructure 
Protection

Maintaining 
cyber and 
physical security 
is critical to 
ensuring system 
reliability and 
ongoing 
operations.

Rationale for Target

Target number of 
incidents remained the 
same as prior years 
and was based on 
industry top decile 
performance, which 
reflects an aggressive 
view and philosophy 
on the importance of 
safety.

2 or fewer lost work 
day cases for injuries 
to Company 
employees and 
specified contract 
employees.

Target number of 
incidents reduced by 1 
from prior year and 
was based on industry 
top decile 
performance, which 
reflects an aggressive 
view and philosophy 
on the importance of 
safety. 

8 or fewer recordable 
incidents for injuries to 
Company employees 
and specified contract 
employees.

Goal focused on 
implementing updated 
security objectives. 
Emphasized securing 
our information 
systems and physical 
space, helping protect 
our most important 
assets.

Implementation of the 
2020 Cyber Plan and 
Physical Security Plan, 
as presented to and 
approved by the Board 
of Directors, 
implementation of each 
Plan worth 5%.

Total

 20  %

 20 %

System Performance goals represented 60% of the total maximum annual bonus target and included specific 
measures for System Outages, Maintenance Plans and Capital Project Plan. Achievement of targets for outage 
frequency  were  made  more  difficult  for  ITC  Midwest  in  2020  from  previous  years  due  to  improved  system 
performance.

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Category

Goal
Outage 
frequency

Rationale for 
Goal
Reducing and 
limiting 
system 
outages are 
critical to 
ensuring 
system 
reliability.

System 
Performance 
and Capital 
Project Plan

60% 
Maximum 
Potential 
Payout

Field 
Operation 
and 
Maintenance 
Plan

Performing 
necessary 
preventive 
maintenance 
is critical to 
ensuring 
system 
reliability.

Capital 
Project Plan

Performing 
necessary 
system 
upgrades is 
critical to 
ensuring 
system 
reliability, 
providing a 
robust 
transmission 
grid and 
delivering 
financial 
performance.

Potential 
Payout

2020 Results
 15 % ITCTransmis

Actual 
Payout

10%

sion - 13

METC - 32

ITC Midwest 
- 63/50

 15 % ITCTransmis

5%

sion and 
METC high 
priority 
initiatives not 
completed;

ITC Midwest 
high priority 
initiatives 
completed 
under 
budget;

All completed 
high priority 
Field O&M 
initiatives 
under budget 
of $91.0M

15 - 30% $938M

30%

Rationale for Target

Target unchanged from prior 
year for ITCTransmission and 
METC, reduced from prior year 
for ITC Midwest; all targets 
aligned with industry benchmark 
data. Number of Forced, 
Sustained Line Outages, 
excluding the "External" cause 
classification, for:

ITCTransmission (13 or fewer, 
representing top decile 
performance); 

METC (25 or fewer, representing 
top decile performance);

ITC Midwest (63 or fewer, 
representing a reduction of 3 
outages and top decile 
performance, no more than 52 at 
the 69kV level representing top 
quartile performance.); 

Each target is worth 5%.

Target is reflective of goal to 
complete the normal 
maintenance schedule of high 
priority maintenance activities. 
Complete high priority 2020 Field 
O&M Initiatives for:

ITCTransmission (15)
METC (13)
ITC Midwest (10)

Each target worth 5%. 

Payout reduced by 5% if not at 
or under Field O&M overall 
maintenance budget of $91.0M.

Target is based on accrued 
capital investment. 

The maximum payout represents 
the risk-adjusted capital 
investment plan for 2020, with a 
threshold level also established.

Complete $721M of the 2020 
Capital Project Plan to achieve 
30%; Complete $683M to 
achieve 15%.

Total Bonus (as a percent of target bonus level)

____________________________

 60 %

 100 %

45%

85%

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(1) We utilize adjusted net income as a criterion in measuring achievement of financial goals for our annual 
corporate  performance  bonus.  This  non-GAAP  financial  measure  reconciles  to  net  income  of  our 
Regulated Operating Subsidiaries as follows:

(In millions of USD)
Net Income of Regulated Operating Subsidiaries
Adjustments Related to ROE Matters
Other Adjustments

Adjusted Net Income

$ 

$ 

2020

504 
(12) 
4 
496 

Additionally,  our  executives,  including  the  NEOs,  are  eligible  for  an  executive  bonus  multiplier.  To  further 
motivate management to provide value to the shareholder, we include a performance factor under which their 
ACPBs may be increased for outperformance by as much as 100% based on multiple measures, as follows:

Measure
Capital Project Plan
Cash from Operations 
Pre-Working Capital
Adjusted Consolidated 
Net Income (1)
Inclusion & Diversity 
Plan
Bonus Multiplier

Threshold
$759M

Maximum Achievement  Multiplier
$938M

$820M

2.00x

Weight
30%

Result
0.60x

$669M

$703M

$680M

$391M

Create Plan

$411M
Level 2 
Milestones

$401M
Level 2 
Milestones

1.25x

1.50x

2.00x

25%

30%

15%

0.31x

0.45x

0.30x
1.66x

____________________________

(1) We utilize adjusted consolidated net income as a criterion in measuring achievement of financial goals 
for  the  executive  bonus  multiplier.  This  non-GAAP  financial  measure  reconciles  to  consolidated  net 
income of ITC Holdings as follows:

(In millions of USD)
Net Income
Adjustments Related to ROE Matters
Other

Adjusted Consolidated Net Income

$ 

$ 

2020

407 
(12) 
6 
401 

Each  measure  has  an  established  scale,  which  includes  a  threshold  level  and  below  equating  to  a  1.00x 
multiplier, having no impact on the bonus award, to a maximum of 2.00x, which would increase the bonus by 
100%. Achievement  against  performance  scales  related  to  each  of  the  above  metrics  produced  an  executive 
bonus  multiplier  of  1.66x.  This  performance  factor  was  applied  to  each  executive’s  ACPB  factor  of  85%  to 
produce a final payment of approximately 141% of target.

Bonuses are based on a target bonus, which for each executive is a percentage of his or her base salary. 
The  Committee  considers  each  individual’s  job  responsibilities  and  the  results  of  its  benchmarking  analysis 
when determining the base bonus percentage for the executive officers, including the NEOs, which we refer to 
as the “target bonus levels”. Target bonus levels for 2020 were 100% of base salary for each NEO. Mr. Oginsky 
received a prorated portion of the annual bonus based on his time employed by the Company in 2020.

Long-Term Incentive

The Committee provides and maintains a long-term equity incentive program under the 2017 Omnibus Plan, 
the  Executive  Omnibus  Plan  and  the  Fortis  Inc.  2020  Restricted  Share  Unit  Plan.  In  February  2020,  the 
Committee approved grants of SBUs and PBUs to the NEOs, based on our CEO’s recommendation (except for 
grants  to  the  CEO),  and  also  on  the  Committee’s  assessment  of  the  performance  of  the  Company  and  the 
executive.  Award  opportunities  for  the  NEOs  were  provided  in  a  mix  of  PBUs  (weighted  67%)  and  SBUs 
(weighted  33%).  The  PBUs  can  be  earned  for  results  in  two  equally-weighted  measures,  Total  Shareholder 
Return (relative to Fortis’ peer group) and cumulative consolidated net income, over the three-year performance 
period.  The  PBU  metrics  were  selected  as  Total  Shareholder  Return  aligns  with  the  Fortis  shareholder 
the  sustained  growth  (organic  and 
experience  and  cumulative  consolidated  net 

income  measures 

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development), cost management and efficiency. Each unit is generally equivalent to one share of Fortis stock 
(as traded on the Toronto Stock Exchange) and earned PBU units are payable in cash and earned SBU units 
are payable in cash or Fortis common stock. Awards to the CEO were also presented to the Board of Directors 
by the Committee and ratified by the Board of Directors (other than the CEO). The amounts and more detailed 
terms  of  the  2020  SBU  and  PBU  grants  made  under  the  Fortis  Inc.  2020  Restricted  Share  Unit  Plan  and  the 
Executive Omnibus Plan are described in the narrative following the Grants of Plan-Based Awards Table. The 
awards  were  designed  to  reward,  motivate  and  encourage  long-term  performance,  act  as  a  retention 
mechanism, and further align the interests of the NEOs with the interests of the Fortis shareholder. Total value 
for the award for each grantee was determined based on a percentage of salary. For the NEOs, when the 2020 
awards were made, the award values were targeted to be:

NEO

Ms. Apsey
Ms. Holloway
Mr. Jipping
Ms. Mason Soneral
Ms. Tanner
Mr. Oginsky

Grant Value 
Percent of 
Salary

 250 %
 175 %
 175 %
 175 %
 175 %
 175 %

In determining the size of grants under the long-term incentive program and the award mix, the Committee 
considered market practice, the recommendation of the CEO (with respect to grants other than to the CEO) in 
light  of  comparisons  to  benchmarking  data,  expense  to  the  Company  and  the  practice  of  other  U.S.  Fortis 
subsidiary companies.

Other Components of Our Executive Compensation Program

Pension  Benefits.  As  is  common  in  our  industry  and  as  established  pursuant  to  our  initial  formation 
requirements included in the acquisition agreement with DTE Energy for ITCTransmission, we maintain a tax-
qualified  defined  benefit  retirement  plan  for  eligible  employees,  comprised  of  a  traditional  pension  component 
and  a  cash  balance  component.  All  employees,  including  the  NEOs,  participate  in  either  the  traditional 
component  or  the  cash  balance  component.  We  have  also  established  a  supplemental  nonqualified, 
noncontributory  retirement  benefit  plan  for  selected  management  employees:  the  Executive  Supplemental 
Retirement Plan, or ESRP, in which all of the NEOs participate. This plan provides for benefits that supplement 
those provided by our qualified defined benefit retirement plan. Benefits payable to the NEOs pursuant to the 
retirement plans are set by the terms of those plans. The Committee exercises no regular discretionary authority 
in  the  determination  of  benefits.  The  retirement  plans  may  be  modified,  amended  or  terminated  at  any  time, 
although no such action may reduce a NEO’s earned benefits. See “Pension Benefits” for information regarding 
participation by the NEOs in our retirement plans as well as a description of the terms of the plans.

Benefits  and  Perquisites.  The  NEOs  participate  in  a  variety  of  benefit  programs,  which  are  designed  to 
enable us to attract and retain our workforce in a competitive marketplace. These programs include our Savings 
and  Investment  Plan,  which  consists  of  an  employee  deferral  contribution  component  and  an  employer  safe-
harbor matching contribution component.

Our  NEOs  are  provided  a  limited  number  of  perquisites  in  addition  to  benefits  provided  to  our  other 
employees. The purpose of these perquisites is to minimize distractions from the NEOs’ attention to important 
Company  initiatives,  to  facilitate  their  access  to  work  functions  and  personnel,  and  to  encourage  interactions 
among NEOs and others within professional, business and local communities. NEOs are provided perquisites 
such  as  auto  allowance,  financial,  estate  and  legal  planning,  income  tax  return  preparation,  annual  physical, 
club memberships, and personal liability insurance. Additionally, we own aircraft to facilitate the business travel 
schedules  of  our  executives  and  other  employees,  particularly  to  locations  that  do  not  provide  efficient 
commercial  flight  schedules.  Ms.  Apsey  and  guests  who  travel  with  her  are  permitted  to  travel  for  personal 
business on our aircraft, with an annual maximum of 50 flight hours for such personal travel. Ms. Apsey incurs 
imputed  income  for  all  guests  and  herself  for  personal  travel  in  the  amount  of  the  incremental  cost  to  the 
Company of such travel.

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We  purchase  tickets  to  various  sporting,  civic,  cultural,  charity  and  entertainment  events.  We  use  these 
tickets for business development, partnership building, charitable donations and community involvement. If not 
used for business purposes, we may make these tickets available to employees, including the NEOs, as a form 
of  recognition  and  reward  for  their  efforts.  Because  such  tickets  have  already  been  purchased,  we  do  not 
believe  that  there  is  any  aggregate  incremental  cost  to  the  Company,  if  a  NEO  uses  a  ticket  for  personal 
purposes.

None  of  the  NEOs  are  reimbursed  for  income  taxes  associated  with  the  value  of  the  perquisites.  The 
Committee  continues  to  monitor  and  review  the  Company’s  perquisite  program.  Perquisites  are  further 
discussed in footnote 5 to the “Summary Compensation Table”.

Potential  Severance  Compensation.  Pursuant  to  their  employment  agreements,  each  NEO  is  entitled  to 
certain  benefits  and  payments  upon  a  termination  of  his  or  her  employment.  Benefits  and  payments  to  be 
provided  vary  based  on  the  circumstances  of  the  termination.  We  believe  it  is  important  to  provide  these 
protections in order to ensure our NEOs will remain engaged and committed to us during an acquisition of the 
Company  or  other  transition  in  management.  See  “Employment  Agreements  and  Potential  Payments  Upon 
Termination or Change in Control” for further detail on these employment agreements, including a discussion of 
the compensation to be provided upon termination or a change in control.

Stock Ownership Policy

The Board believes that having a share ownership policy is a key element of strong corporate governance 
and aligns the interests of management with the interests of Fortis shareholders. Under these guidelines, which 
became effective January 1, 2020, officers, including NEOs, must achieve and maintain the applicable level of 
Fortis stock ownership by the fifth anniversary of when the guidelines first became applicable to the individual. 
The current levels are as follows:

Position

Chief Executive Officer
Executive and Senior Vice Presidents
Vice Presidents

Ownership Level

2x annual base salary
1.5x annual base salary
1x annual base salary

The securities that qualify for the purpose of determining compliance with the policy are common shares of 
Fortis  stock  and  the  executive’s  outstanding  SBU  awards.  Share  ownership  levels  include  Fortis  securities 
beneficially owned: (i) in a trust; (ii) by the executive’s spouse; and (iii) by the executive’s minor children. Any 
executive that fails to maintain minimum stock ownership under these guidelines, will not be eligible for future 
equity-based compensation awards until the later of (i) the end of the one-year period commencing on the date 
of such failure or (ii) such time as the executive is again in compliance with the guidelines. Each of the NEOs is 
in compliance with this policy.

Governance and Human Resources Committee Report

The  Governance  and  Human  Resources  Committee  has  reviewed  and  discussed  this  Compensation 
Discussion  and Analysis  with  management  and,  based  on  the  review  and  discussions  with  management,  has 
recommended  to  the  Board  of  Directors  that  the  Compensation  Discussion  and  Analysis  be  included  in  this 
report.

DEBORA M. FRODL  ALEXANDER I. GREENBAUM  DAVID G. HUTCHENS  A. DOUGLAS ROTHWELL 

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Summary Compensation

The  following  table  provides  a  summary  of  compensation  paid  or  accrued  by  the  Company  and  its 
subsidiaries to or on behalf of the NEOs for services rendered by them during each of the last three calendar 
years, as required by SEC rules and regulations. The material terms of plans and agreements pursuant to which 
certain  items  set  forth  below  were  paid  are  discussed  elsewhere  in  Compensation  of  Executive  Officers  and 
Directors.

Summary Compensation Table

Stock Awards ($) 
(1)

Non-Equity 
Incentive Plan 
Compensation 
($) (2)

Change in 
Pension Value & 
Non-qualified 
Deferred 
Compensation 
Earnings
($)(3)

All Other 
Compensation 
($) (4)

(e)

(f)

(g)

(h)

Salary ($)

(c)

Total ($)

(i)

$ 

819,630  $ 

2,036,614  $ 

1,151,376  $ 

359,039  $ 

84,625  $ 

4,451,284 

794,692 

752,712 

399,570 

388,115 

367,962 

589,347 

578,000 

553,674 

396,285 

389,469 

377,204 

2,061,860 

1,747,386 

695,003 

703,598 

599,433 

1,023,422 

1,046,405 

899,149 

688,169 

703,598 

612,373 

1,352,000 

1,169,118 

561,296 

659,100 

572,945 

826,564 

980,200 

859,418 

555,793 

659,100 

585,333 

339,797 

593,288 

479,176 

252,759 

483,988 

466,685 

847,330 

875,001 

758,200 

— 

819,650 

724,698 

322,636 

123,927 

181,670 

147,032 

81,152 

522,326 

568,493 

63,980 

200,948 

170,742 

66,424 

123,653 

23,000 

236,208 

51,865 

55,516 

66,909 

36,936 

36,362 

34,351 

38,199 

38,169 

37,869 

35,950 

36,500 

35,250 

4,586,704 

3,860,052 

1,874,475 

1,934,207 

1,655,843 

2,999,858 

3,211,267 

2,414,090 

1,877,145 

1,959,409 

1,676,584 

34,620 

1,570,534 

1,662,596 

36,742 

36,556 

2,785,685 

2,451,589 

2,038,004 

Name

(a)

Linda H. Apsey, 
President & CEO 

Gretchen L. Holloway
SVP & CFO 

Jon E. Jipping, 
EVP & COO

Christine Mason Soneral, 
SVP, General Counsel, 
Secretary & CCO

Krista Tanner,
SVP & CBUO

Daniel J. Oginsky, 
Former EVP & CAO (5)

Year

(b)

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2020

2019

2018

____________________________

(1)  The amounts reported in this column represent the fair value of PBU awards and SBU awards granted to 
the NEOs under the 2017 Omnibus Plan, the Executive Omnibus Plan and the Fortis Inc. 2020 Restricted 
Share Unit Plan in accordance with FASB Accounting Standards Codification Topic 718, or ASC 718.

The grant date fair value of the SBU awards is based on the applicable share price on the grant date. The 
grant date fair value of the PBU awards is based on the applicable share price on the grant date and the  
payout  of  the  performance  (which  approximates  target  achievement),  and  market  conditions,  with  the 
market condition fair value determined using a Monte Carlo simulation valuation model. The SBU awards 
and  PBU  awards  are  liability  awards,  subject  to  remeasurement  through  the  vesting  date,  and  settled  in 
cash, see “Grants of Plan-Based Awards.”  The value of the 2020 PBU awards at the grant date assuming 
that the highest level of performance conditions will be achieved are as follows:

Ms. Apsey

Ms. Holloway

Mr. Jipping

Ms. Mason Soneral

Ms. Tanner

Mr. Oginsky

$ 

2,715,447 

926,663 

1,364,526 

917,538 

791,024 

1,129,749 

(2)  The  amounts  reported  in  this  column  include  cash  awards  tied  to  the  achievement  of  annual  Company 
performance goals under our annual corporate performance bonus plan in effect for each of 2020, 2019 and 
2018. For information regarding the corporate goals for 2020, see “Compensation Discussion and Analysis - 

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Key  Components  of  Our  NEO  Compensation  Program  -  Annual  Corporate  Performance  Bonus."  Mr. 
Oginsky’s 2020 bonus was prorated based on his time employed by the Company in 2020.

(3)  All  amounts  reported  in  this  column  pertain  to  the  tax-qualified  defined  benefit  pension  plan  and  the 
supplemental  nonqualified,  noncontributory  retirement  plan  maintained  by  the  Company.  None  of  the 
income on nonqualified deferred compensation was above-market or preferential. Variations in the amounts 
from year to year reflect an additional year of service and pay changes used in the accrued benefit, as well 
as  changes  in  assumptions  on  which  the  benefits  are  calculated,  for  which  the  formula  has  not  been 
materially revised. The discount rate used for the present value of accumulated benefits was 4.39% in 2018,  
3.44%  in  2019  and  2.74%  for  2020.  The  mortality  assumption  was  changed  from  the Adjusted  RP-2014 
table  projected  for  future  mortality  improvements  with  MP-2017  generational  scale  to  the  Pri-2012  tables 
with MP-2020 mortality improvement scale.

(4)  All Other Compensation includes amounts for auto allowance, financial, estate and legal planning, income 
tax  return  preparation,  annual  physical,  club  memberships,  event  tickets,  personal  liability  insurance, 
personal  use  of  company  aircraft  and  for  other  benefits  such  as  Company  contributions  on  behalf  of  the 
NEOs  pursuant  to  the  matching  component  of  the  Savings  and  Investment  Plan.  Perquisites  have  been 
valued  for  purposes  of  these  tables  on  the  basis  of  the  aggregate  incremental  cost  to  the  Company. The 
incremental cost of the personal use of the Company aircraft was determined based upon the Company’s 
expenses incurred in connection with the actual costs of maintenance, landing, parking, crew and catering 
and estimated fuel costs relating to Ms. Apsey’s hours of use of the aircraft. Fuel expense was determined 
by  calculating  the  average  fuel  cost  for  the  month  and  the  average  amount  of  fuel  used  per  hour. These 
benefits and perquisites for 2020, 2019 and 2018 are itemized in the table below as required by applicable 
SEC rules.

Name

Linda H. Apsey

Gretchen L. Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

Daniel J. Oginsky

Year

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2020

2019

2018

401(k) Match

Personal Use of 
Company 
Aircraft

Other Benefits

Severance 
Payments

Total

$ 

17,100  $ 

40,440  $ 

27,085  $ 

—  $ 

16,800 

14,750 

15,450 

15,100 

14,750 

17,100 

16,800 

16,500 

15,450 

15,100 

14,750 

14,120 

15,450 

15,100 

14,750 

19,777 

25,074 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

18,939 

27,085 

21,486 

21,262 

19,601 

21,099 

21,369 

21,369 

20,500 

21,400 

20,500 

20,500 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

84,625 

55,516 

66,909 

36,936 

36,362 

34,351 

38,199 

38,169 

37,869 

35,950 

36,500 

35,250 

34,620 

3,385 

  1,643,761 

1,662,596 

21,642 

21,806 

— 

— 

36,742 

36,556 

We  purchase  tickets  to  various  sporting,  civic,  cultural,  charity  and  entertainment  events.  We  use  these 
tickets for business development, partnership building, charitable donations and community involvement. If 
not used for business purposes, we may make these tickets available to employees, including the NEOs, as 
a form of recognition and reward for their efforts. Because such tickets have already been purchased, we do 
not believe that there is any aggregate incremental cost to the Company, if a NEO uses a ticket for personal 
purposes. The severance payments made to Mr. Oginsky include cash payments totaling $1,643,761, made 
up of (i) $259,898 paid as a prorated portion of his annual bonus, (ii) continuation of his base salary totaling 
$283,192, (iii) acceleration of SBUs totaling $337,849 (iv) $743,232 paid as a prorated portion of his PBU 
award, and (v) premiums for COBRA coverage totaling $19,590.

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(5) Mr. Oginsky’s employment with the Company was terminated in May 2020.

Grants of Plan-Based Awards

The following table sets forth information concerning each grant of an award made to a NEO during 2020.

Estimated Future Payouts Under 
Non-Equity Incentive Plan Awards

Estimated Future Payouts Under 
Equity Incentive Plan Awards

Grant 
Date

Award 
Type

Threshold 
($)

Target 
($)(1)

Maximum 
($)(1)

Threshold 
(#)

Target 
(#)(2)

Maximum 
(#)(2)

All Other 
Stock 
Awards: 
Number 
of Shares 
of Stock 
or Units 
(#)

Grant 
Date Fair 
Value of 
Stock and 
Option 
Awards 
($)(3)

(c)

(d)

(e)

(f)

(g)

(h)

(i)

(j)

$ 

—  $ 

—  $ 

— 

— 

— 

16,367  $  678,890 

Name

(a)

Linda H. Apsey

Gretchen L. 
Holloway

Jon E. Jipping

Christine Mason 
Soneral

Krista Tanner

Daniel J. Oginsky

(b)

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

1/1/2020

SBU

PBU

ACPB

SBU

PBU

ACPB

SBU

PBU

ACPB

SBU

PBU

ACPB

SBU

PBU

ACPB

SBU

PBU

ACPB

— 

— 

— 

816,000 

  1,632,000 

— 

— 

— 

— 

397,800 

  795,600 

— 

— 

— 

— 

585,800 

  1,171,600 

— 

— 

— 

— 

393,900 

  787,800 

— 

— 

— 

— 

339,600 

  679,200 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

16,366 

32,732 

65,464 

— 

— 

— 

— 

— 

— 

5,585 

11,170 

22,340 

— 

— 

— 

— 

— 

— 

8,224 

16,448 

32,896 

— 

— 

— 

— 

— 

— 

5,530 

11,060 

22,120 

— 

— 

— 

— 

— 

— 

4,768 

9,535 

19,070 

— 

— 

— 

— 

— 

— 

6,809 

13,618 

27,236 

— 

— 

  1,357,723 

— 

5,585 

  231,671 

— 

— 

  463,332 

— 

8,225 

  341,159 

— 

— 

  682,263 

— 

5,530 

  229,400 

— 

— 

  458,769 

— 

4,768 

  197,777 

— 

— 

  395,512 

— 

6,809 

  282,455 

— 

— 

  564,875 

— 

485,000 

  970,000 

— 

— 

— 

____________________________

(1)  The  amount  shown  in  Column  (d)  represents  the  potential  payout  for  the ACPB  based  on  “target  bonus 
levels.” The amount payable assuming maximum achievement of all bonus goals is set forth in column (e). 
Actual  dollar  amounts  paid  are  disclosed  and  reported  in  the  “Summary  Compensation  Table”  as  Non-
Equity  Incentive  Plan  Compensation.  For  more  information  regarding  the  ACPBs,  see  “Compensation 
Discussion  and  Analysis  —  Key  Components  of  Our  NEO  Compensation  Program  —  Annual  Corporate 
Performance Bonus.”

(2)  Payment  of  each  PBU  award  is  contingent  on  meeting  performance  targets  based  on  (1)  Fortis  Total 
Shareholder Return in comparison to the Total Shareholder Return during the performance period for each 
of the companies that comprise the 2020 Fortis peer group and (2) cumulative consolidated net income for 
each fiscal year during the performance period. The performance measures are independent of each other. 
If threshold, target or maximum performance goals are attained in the performance period, 50%, 100% or 
200%  of  the  target  amount,  respectively,  may  be  earned.  If  actual  performance  falls  between  threshold, 
target  and  maximum,  the  awards  would  be  prorated  between  levels  based  on  performance  outcome.  For 
more  information  regarding  performance  share  awards,  see  “Grant  of  Plan-Based Awards  -  Performance-
Based Unit Award Agreements.”

(3)  Grant  Date  Fair  Value  consists  of  SBUs  and  PBUs  awarded  under  the  Fortis  Inc.  2020  Restricted  Share 
Unit Plan and Executive Omnibus Plan, respectively, with a grant date of January 1, 2020. The SBUs and 
PBUs reflected here are recorded at fair value at the date of grant, which was $41.48 per share. Share fair 
values were converted from Canadian Dollars to US Dollars using the “Award Conversion Rate” defined in 
the plans.

The Committee has established long-term incentive targets as a percentage of the base salary for each NEO 
in consideration of benchmarking data on total direct compensation, the importance of the NEO’s position to the 

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success of the Company, our need to create meaningful incentives to enhance performance and the culture of 
teamwork  that  makes  our  company  successful.  The  Committee  did  not  have  a  pre-established  targeted 
allocation of total direct compensation.

The  Committee  had  the  power  to  award  SBUs  in  the  form  of  equity  or  cash  under  the  Fortis  Inc.  2020 
Restricted Share Unit Plan and PBUs in the form of equity or cash under the Executive Omnibus Plan with the 
terms of each award set forth in a written agreement with the recipient. Grants made in 2020 to the NEOs were 
made under their respective plans pursuant to terms stated in the SBU and PBU award agreements.

Performance-Based Unit Award Agreements

The PBU award agreements entered into with each NEO on January 1, 2020 (the “PBU Grant Date”) (each a 
“PBU Agreement”) provide generally that the award will vest on January 1, 2023 (the “PBU Vesting Date”) to the 
extent  one  or  more  of  the  performance  goals  are  met  and  if  the  grantee  continues  to  be  employed  by  the 
Company through the PBU Vesting Date. One-half of the Target Number of PBUs shall be related to the Fortis 
Total Shareholder Return goal (the “TSR goal”) and one-half of the Target Number of PBUs shall be related to 
the Cumulative Consolidated Net Income goal (the “CCNI goal”). The PBUs will become earned as set forth in 
the following table:

Measurement Category

Goal at 
Threshold

Shares at 
Threshold

Goal at 
Target

Fortis Total Shareholder 
Return

30th 
percentile

Cumulative Consolidated Net 
Income

99% of 
Target

50% of TSR 
Target Units
50% of 
CCNI 
Target Units

50th 
percentile

100% of 
Target

Shares at 
Target
100% of 
TSR Target 
Units
100% of 
CCNI 
Target Units

Goal at 
Maximum

Shares at 
Maximum

85th 
percentile

102% of 
Target

200% of 
TSR Target 
Units
200% of 
CCNI 
Target Units

The performance period for the award is January 1, 2020 through December 31, 2022 (the “Payment Criteria 
Period”).  The  performance  measures  are  independent  of  each  other;  that  is,  if  the  threshold  level  of  one 
performance measure is attained, units relating to that measure will be “earned” (subject to vesting as otherwise 
provided in the PBU Agreement) even if the threshold level of the other performance measure is not attained. 
The  number  of  PBUs  that  are  “earned”  with  respect  to  each  performance  measure  will  be  prorated  between 
levels based on performance. The Committee will have discretion to reduce the number of PBUs earned under 
certain circumstances.

Total Shareholder Return of Fortis will be compared to each of the companies (the “Peer Companies”) listed 
in  the  Fortis  Peer  Group  2020  Report  excluding  any  company  that  is  no  longer  traded  on  the  Toronto  Stock 
Exchange or a “national securities exchange” at the end of the Payment Criteria Period. The Peer Companies 
currently consist of the following 25 U.S. and Canadian public utility companies:

Alliant Energy Corporation
Ameren Corporation
Atmos Energy Corporation
Canadian Utilities Limited
CenterPoint Energy Inc.
CMS Energy Corporation
Consolidated Edison Inc.
DTE Energy Company
Edison International

Emera Incorporated
Entergy Corporation
Evergy, Inc.
Eversource Energy
FirstEnergy Corp.
Hydro One Limited
NiSource Inc.
OGE Energy Corp.

PG&E Corporation
Pinnacle West Capital Corporation
PPL Corporation
Public Service Enterprise Group Inc.
Sempra Energy
UGI Corporation
WEC Energy Group, Inc.
Xcel Energy Inc.

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The Total Shareholder Return of Fortis and the Peer Companies shall be computed in U.S. dollars as follows:

A: Calculate the Market Price as of the first day of the Payment Criteria Period (if necessary, converted 

into U.S. dollars based on the Award Conversion Rate as defined in the Executive Omnibus Plan)

B: Calculate the Market Price as of the last day of the Payment Criteria Period (if necessary, converted 

into U.S. dollars based on the Award Conversion Rate)

C:  Calculate  the  total  dividends  paid  per  share  of  its  common  stock  (or  equivalent  security)  during  the 
Payment  Criteria  Period  (if  necessary,  converted  into  U.S.  dollars  based  on  the  Award  Conversion 
Rate)

Total Shareholder Return = ((B - A) + C)/A

Adjusted Consolidated Net Income for the Company for each calendar year in the Payment Criteria Period 
shall be equal to net income as set forth in the Company’s audited consolidated financial statements contained 
in its annual report on Form 10-K for such year, as adjusted for extraordinary items and changes in Return on 
Equity,  in  each  case  in  the  Committee’s  discretion.  Cumulative  Consolidated  Net  Income  for  the  Company 
during the Payment Criteria Period shall be the sum of the Adjusted Consolidated Net Income for each of the 
three years in the Payment Criteria Period.

If the grantee ceases to be employed before the PBU Vesting Date due to death, disability or “Retirement”, 
and the grantee has been employed with the Company for 15 years or more, the grantee will receive, following 
the  PBU  Vesting  Date,  the  number  of  PBUs  to  which  the  grantee  would  have  otherwise  been  entitled  if  the 
grantee had remained employed through the PBU Vesting Date. If the grantee ceases to be employed before 
the  PBU  Vesting  Date  due  to  death,  disability  or  Retirement,  and  the  grantee  has  been  employed  with  the 
Company for less than 15 years, the grantee will receive, following the PBU Vesting Date, (i) one-third of the 
number  of  PBUs  to  which  the  grantee  would  have  otherwise  been  entitled  if  the  grantee  had  remained  an 
employee  through  the  PBU  Vesting  Date  shall  be  deemed  to  have  vested  on  the  PBU  Vesting  Date  if 
termination  occurred  on  or  after  the  one-year  anniversary  of  the  PBU  Grant  Date  and  before  the  two-year 
anniversary of the PBU Grant Date, and (ii) two-thirds of the number of PBUs to which the grantee would have 
otherwise  been  entitled  if  the  grantee  had  remained  an  employee  through  the  PBU  Vesting  Date  shall  be 
deemed to have vested on the PBU Vesting Date if termination occurred one or after the two-year anniversary 
of the PBU Grant Date but before the PBU Vesting Date. If termination occurs prior to the PBU Vesting Date 
other than as a result of death, disability or Retirement, grantee will forfeit the award.

“Retirement”  is  defined  to  mean  termination  of  grantee’s  employment  with  the  Company  upon  or  after 
completing 10 years of service with the Company after attaining the age of 45 if the grantee has provided the 
Company with at least six months’ written notice of such retirement.

Upon  a  “Change  of  Control”,  as  defined  in  the  Executive  Omnibus  Plan,  all  outstanding  PBUs  become 
redeemable  on  the  effective  date  of  the  consummation  of  the  event  resulting  in  the  Change  of  Control  (the 
“Change  of  Control  Redemption  Date”).  In  the  event  of  a  Change  of  Control,  the  payout  percentage  for 
outstanding PBUs is the product of (i) the higher of (A) 100% of the target number of PBUs in the award or (B) 
the  actual  payout  percentage  based  on  the  Committee’s  assessment  of  performance  of  the  payment  criteria 
from  the  beginning  of  the  Payment  Criteria  Period  for  the  award  through  the  date  of  the  Change  of  Control, 
multiplied by (ii) a fraction, the numerator of which is the number of days elapsed in the Payment Criteria Period 
for the award through the date on which the Change of Control occurred and the denominator of which is the 
total number of days in the payment criteria period for the award.

Grantees are entitled to receive additional PBUs equal to the “dividend equivalent” when a cash dividend is 
paid on common shares of Fortis stock (each a “Common Share”). Such “dividend equivalent” shall be equal to 
a fraction where the numerator is the product of (a) the number of PBUs in the grantee’s account on the date 
that the dividends are paid, including PBUs previously credited as “dividend equivalents,” multiplied by (b) the 
dividend paid per Common Share and the denominator of which is the “Market Price” of one Common Share 
calculated on the date that dividends are paid, converted to U.S. dollars based on the Award Conversion Rate. 
All “dividend equivalent” PBUs shall have a PBU Vesting Date which is the same as the PBU Vesting Date for 
the PBUs in respect of which such additional PBUs are credited.

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Service-Based Unit Award Agreements

The SBU award agreements entered into with each NEO on January 1, 2020 (the “SBU Grant Date”) (each a 
“SBU Agreement”) provide generally that, so long as the grantee remains employed by the Company, the SBUs 
fully vest upon the earlier of (i) January 1, 2023 (the “SBU Vesting Date”) or (ii) the grantee's death, disability or 
“Retirement”.  If  the  grantee  ceases  to  be  employed  before  the  SBU  Vesting  Date  due  to  death,  disability  or 
Retirement,  and  the  grantee  has  been  employed  with  the  Company  for  15  years  or  more,  the  grantee  will 
receive,  the  number  of  SBUs  to  which  the  grantee  would  have  otherwise  been  entitled  if  the  grantee  had 
remained  employed  through  the  SBU  Vesting  Date.  If  the  grantee  ceases  to  be  employed  before  the  SBU 
Vesting Date due to death, disability or Retirement, and the grantee has been employed with the Company for 
less than 15 years, the grantee will receive a prorated number of SBUs to reflect the actual period between the 
SBU Grant Date and the date of the grantee’s death, disability or Retirement. If termination occurs prior to the 
SBU Vesting Date other than as a result of death, disability or Retirement, grantee will forfeit the award. 

Upon a “Change of Control”, all outstanding SBUs become redeemable on the date that is immediately prior 

to the Change of Control Redemption Date. 

“Retirement” and “Change of Control” are defined in the same manner as defined in the description of the 
PBU Agreement  disclosed  above.  Grantees  are  entitled  to  receive  additional  dividend  equivalent  SBUs  in  the 
same manner as defined in the description of the PBU Agreement disclosed above.

The SBU Agreement provides that the grantee may elect to have their SBU awards vest as common shares 
of Fortis Inc. stock or cash payment. If the grantee does not satisfy their share holding requirement stated in the 
Stock Ownership Policy, 50% of the SBU awards must settle in common shares of Fortis Inc. stock.

Outstanding Equity Awards at Fiscal Year-End

The following table provides information with respect to SBUs and PBUs that have not vested as of the end 

of 2020 held by the NEOs.

Number of Shares or 
Units of Stock That 
Have Not Vested (#) 
(SBUs)

Market Value of 
Shares or Units of 
Stock That Have Not 
Vested ($) (SBUs) (1)

Equity Incentive Plan 
Awards: Number of 
Unearned Shares, Units 
or Other Rights That 
Have Not Vested (#) 
(PBUs)

Equity Incentive Plan 
Awards: Market or 
Payout Value of 
Unearned Shares, 
Units or Other Rights 
That Have Not Vested 
($) (PBUs) (1)

(b)

(c)

(d)

(e)

21,432 (2) $ 

16,967 (4)  

7,314 (2)  

5,790 (4)  

10,877 (2)  

8,527 (4)  

7,314(2)  

5,733 (4)  

4,353 (2)  

4,943 (4)  

—   

874,897 

692,621 

298,544 

236,357 

444,014 

348,059 

298,544 

234,040 

177,702 

201,777 

— 

42,865 (3) $ 

33,934 (5)  

29,254 (3)  

23,160 (5)  

43,506 (3)  

34,104 (5)  

29,254 (3)  

22,932 (5)  

17,413 (3)  

19,770 (5)  

12,128 (3)  

3,499,470 

2,770,369 

1,194,174 

945,405 

1,775,971 

1,392,125 

1,194,174 

936,095 

710,805 

807,022 

495,065 

Name

(a)

Linda H. Apsey

Gretchen L. Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

Daniel J. Oginsky

____________________________

(1) Value was determined by multiplying the number of units that have not vested by the closing price of Fortis 

common stock on the NYSE as of December 31, 2020 ($40.82).

(2) These  unvested  SBUs  were  granted  in  2019  and  generally  vest  on  December  31,  2021.  These  SBU 

numbers include the original SBU grant plus dividend equivalent units earned.

(3) These  unvested  PBUs  were  granted  in  2019  and  generally  vest  on  December  31,  2021.  These  PBU 
numbers  include  the  original  PBU  grant  plus  dividend  equivalent  units  earned.  The  award  contains 

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performance  conditions  established  by  the  Committee.  In  order  for  PBUs  to  vest  such  performance 
conditions must be achieved. Amounts reported reflect PBU payouts as if the maximum performance goals 
have been achieved. Mr. Oginsky’s PBUs were prorated on the date of the termination of his employment 
with the Company and remain outstanding until performance conditions are achieved.

(4) These unvested SBUs were granted in 2020 and generally vest on January 1, 2023. These SBU numbers 

include the original SBU grant plus dividend equivalent units earned.

(5) These unvested PBUs were granted in 2020 and generally vest on January 1, 2023. These PBU numbers 
include  the  original  PBU  grant  plus  dividend  equivalent  units  earned.  The  award  contains  performance 
conditions established by the Committee. In order for PBUs to vest such performance conditions must be 
achieved.  Amounts  reported  reflect  PBU  payouts  as  if  the  maximum  performance  goals  have  been 
achieved.

Equity grants made to NEOs in 2019 were made pursuant to the 2017 Omnibus Plan. The PBU grants made 
to  NEOs  in  2020  were  made  pursuant  to  the  Executive  Omnibus  Plan  and  the  SBU  grants  made  to  NEOs  in 
2020 were made pursuant to the Fortis Inc. Restricted Share Unit Plan. The terms of the grants are described 
above in the narrative discussion accompanying the “Grants of Plan-Based Awards” Table.

In February 2019, Mr. Jipping entered into a letter agreement with the Company amending his employment 
agreement  and  long-term  incentive  awards,  including  his  SBU  and  PBU  awards  granted  under  the  2017 
Omnibus Plan. Under the terms of the letter agreement upon Mr. Jipping’s voluntary termination of employment, 
his  SBU  and  PBU  awards,  which  would  otherwise  be  forfeited,  will  continue  to  vest  on  their  normal  schedule 
even  if  Mr.  Jipping  does  not  meet  the  retirement  age,  as  defined  in  the  2017  Omnibus  Plan,  for  continued 
vesting  at  the  time  of  his  termination.  The  letter  agreement  also  removes  Section  7c(ii)(B)  of  Mr.  Jipping’s 
employment  agreement  which  defines  his  rights  to  terminate  the  employment  agreement  if  his  job 
responsibilities and authority were substantially diminished.

Option Exercises and Stock Vested

The  following  table  provides  information  with  respect  to  SBUs  and  PBUs  held  by  the  NEOs  that  vested 

during 2020:

Name
(a)

Stock Awards

Number of Shares or Units of 
Stock Acquired on Vesting (#)
(b)

Value of Shares or Units of Stock 
Realized on Vesting ($) (1)
(c)

Linda H. Apsey

Gretchen L. Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

Daniel J. Oginsky

19.032 (2) $ 

61,664 (3)  

6,529 (2)  

21,153 (3)  

9,793 (2)  

31,730 (3)  

6,670 (2)  

21,610 (3)  

1,705 (2)  

5,521 (3)  

8,380 (4)

17,838 (3)  

793,001 

2,569,323 

272,051 

881,369 

408,054 

1,322,093 

272,260 

900,422 

71,023 

230,035 

337,849 (4)

743,232 

____________________________

(1) Value is based on the 5-day VWAP price of common stock on the TSX on the vesting date, converted from 
Canadian  Dollars  to  US  Dollars  using  the  “Award  Conversion  Rate”  defined  in  the  2017  Omnibus  Plan, 
which is $41.6667.

(2) Amounts  reported  reflect  the  vesting  of  SBUs  granted  March  7,  2018  and  associated  dividend  equivalent 

units.

(3) Amounts  reported  reflect  the  vesting  of  PBUs  granted  March  7,  2018  and  associated  dividend  equivalent 

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units. The award contains performance conditions established by the Committee. The performance period 
ended  on  December  31,  2020.  The  Committee  certified  the  achievement  of  162%  of  the  applicable 
performance goals on February 2, 2021. Amount for Mr. Oginsky is prorated based on his termination date.

(4) Amounts  reported  reflect  the  prorated  vesting  of  SBUs  granted  March  7,  2018  and  March  6,  2019,  and 
associated  dividend  equivalent  units,  that  vested  upon  Mr.  Oginsky’s  termination  of  employment  with  the 
Company. The value is based on the 5-day VWAP price of common stock on the TSX on the vesting date, 
converted  from  Canadian  Dollar  to  US  Dollars  using  the  “Award  Conversion  Rate”  defined  in  the  2017 
Omnibus Plan.

Pension Benefits

The following table provides information with respect to each pension benefit plan that provides for payments 
or other benefits at, following or in connection with retirement. Those plans are the International Transmission 
Company Retirement Plan (the “Qualified Plan”) and the ESRP.

Pension Benefits Table

Name

(a)

Linda H. Apsey

Gretchen Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

Daniel J. Oginsky

Plan Name

(b)

Cash Balance Component

ESRP Shift

        Total Qualified Plan

ESRP

Cash Balance Component

        Total Qualified Plan

ESRP

Traditional Component

        Total Qualified Plan

ESRP

Cash Balance Component

        Total Qualified Plan

ESRP

Cash Balance Component

        Total Qualified Plan

ESRP

Cash Balance Component

        Total Qualified Plan

ESRP

Number of Years 
Credited Service 
(#)(1)

Present Value of 
Accumulated 
Benefit ($)(2)

Payments During 
Last Fiscal Year 
($)

(c)

(d)

(e)

26.58  $ 

N/A  

17.83 

16.95 

5.91 

30.03 

15.92 

13.29 

13.28 

6.14 

6.14 

15.58 

467,421 

39,359 

506,780 

2,131,664 

327,627 

327,627 

418,557 

2,075,036 

2,075,036 

1,693,928 

319,719 

319,719 

825,637 

136,977 

136,977 

281,183 

393,485 

393,485 

15.58 

1,173,054 

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

____________________________

(1) Credited  service  is  estimated  as  of  December  31,  2020  and  represents  the  service  reflected  in  the 
determination of benefits. For determining vesting, service with DTE Energy is counted for the Qualified 
Plan only.

For Ms. Apsey and Mr. Jipping, the credited service for the cash balance and traditional components of 
the Qualified Plan, respectively, includes service with DTE Energy. The Company began operations on 
February 28, 2003, following its acquisition of ITCTransmission from DTE Energy. As of that date, the 
benefits from DTE Energy’s qualified plan that had accrued, as well as the associated assets from DTE 
Energy’s  pension  trust,  were  transferred  to  the  Qualified  Plan.  Therefore,  even  though  DTE  Energy 
service is included in determining the benefits under the traditional and cash balance components of the 
Qualified  Plan,  the  benefits  associated  with  this  additional  service  do  not  represent  a  benefit 
augmentation,  but  rather  a  transfer  of  benefit  liability  and  associated  assets  from  DTE  Energy’s 
qualified  plan  to  the  Qualified  Plan.  With  respect  to  the  ESRP,  credited  service  includes  Company 
service only for the period during which the NEO was an ESRP participant.

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(2) The “Present Value of Accumulated Benefit” is the estimated lump-sum equivalent value measured as 
of December 31, 2020 (the “measurement date” used for financial accounting purposes) of the benefit 
that was earned as of that date. Certain benefits are payable as an annuity only, not as a lump sum, 
and/or may not be payable for several years in the future. The values reflected are based on several 
assumptions. The date at which the present values were estimated was December 31, 2020. The rate 
at  which  future  expected  benefit  payments  were  discounted  in  calculating  present  values  was  2.74%, 
the same rate used for fiscal year-end 2020 financial accounting disclosure of the Qualified Plan. The 
future annual earnings rate on account balances under the cash balance and ESRP shift components 
of the Qualified Plan, and for ESRP benefits, was assumed to be 1.42% for 2021 and 4.00% thereafter.

We assumed no NEOs would die or become disabled prior to retirement or terminate employment with 
us prior to becoming eligible for benefits unreduced for early retirement. The assumed retirement age 
for each executive was generally the earliest age at which benefits unreduced for early retirement were 
available under the respective plans. For the traditional component of the defined benefit plan, that age 
is the earlier of (1) age 58 with 30 years of service (including service with DTE Energy), or (2) age 60 
with  15  years  of  service.  For  consistency,  we  generally  use  the  same  assumed  retirement 
commencement  age  for  other  benefits,  including  benefits  expressed  as  an  account  value  where  the 
concept  of  benefit  reductions  for  early  retirement  is  not  meaningful.  The  assumed  retirement  benefit 
commencement ages were 58 for each NEO, except that Mr. Oginsky’s ESRP benefit will be paid in a 
lump sum on March 1, 2021.

Post-retirement mortality was assumed to be in accordance with the Pri-2012 mortality table projected 
for  future  mortality  improvements  with  MP-2020  generational  scale.  Benefits  under  the  traditional 
component of the Qualified Plan were assumed to be paid as a monthly annuity payable for the lifetime 
of  the  employee.  For  all  other  benefits,  payment  was  assumed  to  be  as  a  single  lump  sum,  although 
other actuarially equivalent forms are available.

We  maintain  one  tax-qualified  noncontributory  defined  benefit  pension  plan  and  one  supplemental 
nonqualified,  noncontributory  defined  benefit  retirement  plan.  First,  we  maintain  the  Qualified  Plan,  which 
provides  funded,  tax-qualified  benefits  up  to  the  limits  on  compensation  and  benefits  under  the  Internal 
Revenue Code. Generally, all of our salaried employees, including the NEOs, are eligible to participate.

We  maintain  the  ESRP,  in  which  all  of  our  NEOs  participate.  The  ESRP  provides  additional  retirement 

benefits which are not tax qualified.

The following describes the Qualified Plan and the ESRP, and pension benefits provided to the NEOs under 

those plans.

Qualified Plan

There are two primary retirement benefit components of the Qualified Plan. Each NEO earns benefits from 

the Company under only one of these primary components.

Because our first operating utility subsidiary was acquired from DTE Energy, a component of the Qualified 
Plan bears relation to the DTE Energy Corporation Retirement Plan (the “DTE Plan”). Generally, persons who 
were  participants  in  the  “traditional  component”  of  the  DTE  Plan  as  of  February  28,  2003  (the  date 
ITCTransmission was acquired from DTE Energy) earn benefits under the traditional component of our Qualified 
Plan. All other participants earn benefits under the cash balance component. Ms. Apsey also has benefits under 
the ESRP shift described below.

Benefits under the Qualified Plan are funded by an irrevocable tax-exempt trust. A NEO’s benefit under the 

Qualified Plan is payable from the assets held by the tax-exempt trust.

NEOs  become  fully  vested  in  their  normal  retirement  benefits  described  below  with  3  years  of  service, 
including  service  with  DTE  Energy,  or  upon  attainment  of  the  plan’s  normal  retirement  age  of  65.  If  a  NEO 
terminates  employment  with  less  than  3  years  of  service,  the  NEO  is  not  vested  in  any  portion  of  his  or  her 
benefit.

Traditional Component of Qualified Plan

Mr. Jipping participates in the traditional component of the Qualified Plan. The benefits are determined under 
the following formula, stated as an annual single life annuity payable in equal monthly installments at the normal 

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retirement age of 65: 1.5% times average final compensation times credited service up to 30 years, plus 1.4% 
times  average  final  compensation  times  credited  service  in  excess  of  30  years.  Credited  service  includes 
service with DTE Energy. Although benefits under the formula are defined in terms of a single life annuity, other 
annuity forms (e.g., joint and survivor benefits) are available that have the same actuarial value as the single life 
annuity benefit. The benefits are not payable in the form of a lump sum.

Average final compensation is equal to one-fifth of the NEO’s salary (excluding any bonuses or special pay) 
during  the  260  weeks  of  credited  service,  not  necessarily  consecutive,  at  any  time  during  the  NEO’s 
employment that results in the highest average.

Benefits provided under the Qualified Plan are based on compensation up to a compensation limit under the 
Internal  Revenue  Code  (which  was  $285,000  in  2020  and  is  indexed  in  future  years).  In  addition,  benefits 
provided under the Qualified Plan may not exceed a benefit limit under the Internal Revenue Code (which was 
$230,000 payable as a single life annuity beginning at normal retirement age in 2020).

NEOs may retire with a reduced benefit as early as age 45 after 15 years of credited service. If a NEO has 
30 years of credited service at retirement, the benefit that would be payable at normal retirement age is reduced 
for  commencement  ages  below  58.  The  percentage  of  the  normal  retirement  benefit  payable  at  sample 
commencement ages is as follows:

Age 58 and older:  100%

Age 55: 

          85%

Age 50: 

             40%

If  a  NEO  has  less  than  30  years  but  more  than  15  years  of  credited  service  at  retirement,  the  benefit  that 
would be payable at normal retirement age is reduced for commencement ages below age 60. The percentage 
of the normal retirement benefit payable at sample commencement ages is as follows:

Age 60 and older:  100%

Age 55: 

             71%

Age 50: 

             40%

If a NEO terminates employment prior to earning 15 years of credited service, the annuity benefit may not 
commence  prior  to  attaining  age  65.  If  the  NEO  terminates  employment  after  earning  15  years  of  credited 
service  but  below  age  45,  the  benefit  may  commence  as  early  as  age  45.  The  percentage  of  the  normal 
retirement benefit payable at sample commencement ages is as follows:

Age 65 and older:  100%

Age 60: 

  58%

Age 55: 

             36%

Age 50: 

             23%

Mr. Jipping’s annual accrued benefit payable in monthly installments as an annuity for his lifetime, beginning 

at age 60, is approximately $124,000. He is fully vested.

Cash Balance Component of Qualified Plan

Mses.  Apsey,  Holloway,  Mason  Soneral  and  Tanner  participate  in  the  cash  balance  component  of  the 

Qualified Plan. The benefits are stated as a notional account value.

Each year, a NEO’s account is increased by a “contribution credit” equal to 7% of pay. For this purpose, pay 
is  equal  to  base  salary  plus  bonuses  and  overtime  up  to  the  same  compensation  limit  as  applies  under  the 
traditional component of the Qualified Plan ($285,000 in 2020). Each year, a NEO’s account is also increased 
by an “interest credit” based on 30-year Treasury rates.

Upon termination of employment, a vested NEO may elect full payment of his or her account. Alternate forms 
of  benefit  (e.g.,  various  forms  of  annuities)  are  available  as  well  that  have  the  same  actuarial  value  as  the 
account.

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Mses. Apsey, Holloway, Mason Soneral and Tanner are entitled to immediate payment of their account value 
on termination of employment, even if before normal retirement age. Ms. Apsey’s estimated account value as of 
year-end 2020 is approximately $440,000, Ms. Holloway’s is approximately $291,000, Ms. Mason Soneral’s is 
approximately  $291,000,  Ms. Tanner  is  approximately  $122,000.  Mr.  Oginsky  is  entitled  to  receive  a  payment 
equal to his account value of $355,000 in connection with the termination of his employment in May 2020.

The ESRP provides notional account accruals similar to the cash balance component of the Qualified Plan. 
The  “compensation  credit”  to  the  NEO’s  notional  account,  analogous  to  the  contribution  credit  in  the  cash 
balance  component  of  the  Qualified  Plan,  is  equal  to  9%  of  base  salary  plus  actual  bonus  earned  under  the 
Company’s  annual  bonus  plan.  The  “investment  credit,”  analogous  to  the  interest  credit  in  the  cash  balance 
component of the Qualified Plan, is similarly based on 30-year Treasury rates.

The ESRP shift benefit is an amount that would otherwise be payable from the ESRP, but is instead being 
paid from the Qualified Plan, subject to applicable qualified plan legal limits on the ability to discriminate in favor 
of  highly  paid  employees.  The  NEO’s  cash  balance  account  is  increased  by  any  amounts  shifted  from  the 
ESRP.  The  purpose  of  the  benefit  is  to  provide  the  NEO  and  the  Company  the  tax  advantages  of  providing 
benefits through a tax qualified plan.

Ms. Apsey has received ESRP shift additions to her Qualified Plan cash balance account. There was no shift 
of compensation credits for 2020, although previous shifts have continued to earn interest credits. As of year-
end 2020, her ESRP shift balance was approximately $37,000.

Executive Supplemental Retirement Plan

The  ESRP  is  a  nonqualified  retirement  plan.  Only  selected  executives  participate,  including  all  our  NEOs. 
The purpose of the ESRP is to promote the success of the Company and its subsidiaries by providing the ability 
to  attract  and  retain  talented  executives  by  providing  such  designated  executives  with  additional  retirement 
benefits.

The ESRP resembles the cash balance component of the Qualified Plan in that benefits are expressed as a 
notional  account  value  and  the  vested  account  balance  is  payable  as  a  lump  sum  on  termination  of 
employment, although an installment option of equivalent value is also available.

Each year, a NEO’s account is increased by a “compensation credit” equal to 9% of pay. For this purpose, 
pay  is  equal  to  base  salary  plus  any  bonus  under  the  Company’s  annual  corporate  performance  bonus  plan. 
There is no limit on compensation that may be taken into account as in the Qualified Plan. Each year, a NEO’s 
account is also increased by an “investment credit” equal to the same earnings rate as the interest credit in the 
cash balance component of the Qualified Plan, based on 30-year Treasury rates.

The plan has been in effect since March 1, 2003. Vesting occurs at 20% for each year of participation. All of 

our NEOs are fully vested.

As  noted  above  in  the  description  of  the  Qualified  Plan,  a  portion  of  the  ESRP  account  balance  may  be 
shifted to the cash balance component of the Qualified Plan each year, as permitted under the rules for qualified 
plans. Such a shift allows the NEOs to become immediately vested in the account values shifted and confers 
certain  tax  advantages  to  the  NEOs  and  us. As  of  December  31,  2020,  the  ESRP  account  values,  net  of  the 
amounts shifted to the Qualified Plan, are as follows:

Ms. Apsey

Ms. Holloway

Mr. Jipping

Ms. Mason Soneral

Ms. Tanner
Mr. Oginsky

$ 

2,007,114 

371,553 

1,671,249 

749,482 

251,388 
1,173,054 

The ESRP is funded with a Rabbi Trust, which we cannot use for any purpose other than to satisfy the benefit 
obligations  under  the  ESRP,  except  in  the  event  of  the  Company’s  bankruptcy,  in  which  case  the  assets  are 
available to general creditors. 

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Nonqualified Deferred Compensation

We maintain the Executive Deferred Compensation Plan under which nonqualified deferred compensation is 
permissible. Only selected officers of the Company, including the NEOs, are eligible to participate in this plan. 
NEOs are allowed to defer up to 100% of their salary and bonus. Investment earnings are based on the various 
investment options available under the plan and are selected by the individual NEOs. Distributions will generally 
be made at the NEO’s termination of employment for any reason. Mr. Jipping elected to participate in 2019 and 
his deferral was withheld in 2020. Mr. Jipping also elected to participate in 2020, and his deferral will be made in 
2021  due  to  his  2020  bonus  payment  occurring  in  2021.  Mr.  Jipping  is  the  only  NEO  that  participated  in  the 
Executive Deferred Compensation Plan in 2020.

Employment Agreements and Potential Payments Upon Termination or Change in Control

Employment Agreements

As referenced above, we entered into employment agreements with Ms. Apsey and Mr. Jipping in December 
2012  which  superseded  the  employment  agreements  then  in  effect.  In  February  2015,  we  entered  into  an 
employment agreement with Ms. Mason Soneral which superseded her employment agreement then in effect. 
In July 2017, we entered into an employment agreement with Ms. Holloway, which superseded her employment 
agreement then in effect. In February 2019, we entered into an employment agreement with Ms. Tanner which 
superseded  her  employment  agreement  then  in  effect.  Each  employment  agreement  is  subject  to  automatic 
one-year  employment  term  renewals  each  year  beginning  on  its  second  anniversary,  unless  either  party 
provides the other with 30 days’ advance written notice of intent not to renew the employment term. Ms. Apsey’s 
agreement was modified in October 2016 in connection with her appointment as President and Chief Executive 
Officer and the initial term of the agreement expired on December 31, 2018 but is subject to the automatic one-
year  renewal  provision  described  above.  The  following  describes  the  material  terms  of  the  employment 
agreements, as amended, with the NEOs who remained employed by the Company on December 31, 2020.

The employment agreements provide that each NEO will receive an annual base salary equal to their current 
base  salary,  which  is  subject  to  annual  review  and  increase  by  our  Board  of  Directors  at  its  discretion.  The 
employment agreements also provide that NEOs are eligible to receive an annual cash bonus, subject to our 
achievement of certain performance targets established by our Board of Directors, as detailed in “Compensation 
Discussion  and Analysis.” The  employment  agreements  also  provide  the  NEOs  with  the  right  to  participate  in 
equity  plans,  employee  benefit  plans  and  retirement  plans,  including  but  not  limited  to  welfare  plans,  retiree 
welfare benefit plans and defined benefit and defined contribution plans.

In  addition,  the  NEOs’  employment  agreements  provide  for  payments  by  us  of  certain  benefits  upon 
termination  of  employment.  The  rights  available  at  termination  depend  on  the  situation  and  circumstances 
surrounding  the  terminating  event.  The  terms  “Cause”  and  “Good  Reason”  are  used  in  the  employment 
agreements of each NEO and an understanding of these terms is necessary to determine the appropriate rights 
for which a NEO is eligible. The terms are defined as follows:

•

Cause  means:  a  NEO’s  continued  failure  substantially  to  perform  his  or  her  duties  (other  than  as  a 
result  of  total  or  partial  incapacity  due  to  physical  or  mental  illness)  for  a  period  of  10  days  following 
written notice by the Company to the NEO of such failure; dishonesty in the performance of the NEO’s 
duties;  a  NEO’s  conviction  of,  or  plea  of  nolo  contender  to,  a  crime  constituting  a  felony  or 
misdemeanor  involving  moral  turpitude;  willful  malfeasance  or  willful  misconduct  in  connection  with  a 
NEO’s duties; any act or omission which is injurious to the financial condition or business reputation of 
the  Company;  or  violation  of  the  non-compete  or  confidentiality  provisions  of  the  employment 
agreement.

• Good reason means: a greater than 10% reduction in the total value of the NEO’s base salary, target 
bonus,  and  employee  benefits;  or  if  the  NEO’s  responsibilities  and  authority  are  substantially 
diminished.

If a NEO’s employment is terminated with cause by the Company or by the NEO without good reason, the 
NEO will generally only receive his or her accrued but unpaid compensation and benefits as of the date of his or 
her  employment  termination.  If  the  NEO  terminates  due  to  death  or  disability  (as  defined  in  the  employment 
agreements),  the  NEO  (or  the  NEO’s  spouse  or  estate)  would  also  receive  a  pro  rata  portion  of  his  or  her 
current year annual target bonus.

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If  a  NEO’s  employment  is  terminated  by  the  Company  without  cause  or  by  the  NEO  for  good  reason,  the 
NEO  will  receive  the  following,  subject  to  the  NEO’s  execution  of  a  release  agreement  and  commencing 
generally on the earliest date that is permitted under Section 409A of the Internal Revenue Code:

•

any accrued but unpaid compensation and benefits including:

◦ Ms. Apsey: cash balance and ESRP shift under the Qualified Plan and vested portion of ESRP 

balance;

◦ Mr.  Jipping:  annual  benefit  under  the  traditional  component  of  the  Qualified  Plan  and  vested 

portion of ESRP balance; and

◦ Ms. Mason Soneral, Ms. Holloway and Ms. Tanner: cash balance under the Qualified Plan and 

vested portion of ESRP balance

continued payment of the NEO’s then-current base salary for two years;

if the termination is within six months before or two years after a “Change of Control” (as defined in the 
employment  agreements),  payment  of  an  amount  equal  to  two  times  the  average  of  the ACPBs,  that 
were payable to the NEO for the three fiscal years immediately preceding the fiscal year in which his or 
her  employment  terminates,  payable  in  equal  installments  over  the  period  in  which  continued  base 
salary payments are made;

a  pro  rata  portion  of  the  ACPB  for  the  year  of  termination,  based  upon  the  Company’s  actual 
achievement  of  the  performance  targets  for  such  year  as  determined  under  the  annual  corporate 
performance bonus plan and paid at the time that such bonus would normally be paid;

eligibility to continue coverage under our active medical, dental and vision plans subject to applicable 
COBRA rules; if such coverage is elected, we will reimburse the NEO for the shorter of 18 months, or 
until  the  NEO  becomes  eligible  for  coverage  under  another  employer-sponsored  group  plan,  in  an 
amount equal to our periodic cost of such coverage for other executives, plus a tax gross-up amount;

outplacement services for up to two years; and

for Ms. Apsey, deemed satisfaction of the eligibility requirements of our Postretirement Welfare Plan for 
purposes  of  participation  therein;  and  for  Mr.Jipping,  participation  in  our  Postretirement  Welfare  Plan 
only if, by the end of their specified severance period, he has achieved the necessary age and service 
credit  otherwise  necessary  to  meet  the  eligibility  requirements.  In  addition,  if  we  terminate  our 
Postretirement Welfare Plan and, by application of the provisions described in the prior sentence, any of 
these NEOs would otherwise be entitled to retiree welfare benefits, we will establish other coverage for 
the NEO or the NEO will receive a cash payment equal to our cost of providing such benefits, in order 
to assist the NEO in obtaining other retiree welfare benefits.

•

•

•

•

•

•

In addition, while employed by us and for a period of two years after any termination of employment without 
cause by the Company (other than due to their disability) or for good reason by them and for a period of one 
year following any other termination of their employment, the NEOs will be subject to certain covenants not to 
compete  with  or  assist  other  entities  in  competing  with  our  business  and  not  to  encourage  our  employees  to 
terminate  their  employment  with  us. At  all  times  while  employed  and  thereafter,  all  of  the  NEOs  will  also  be 
subject to a covenant not to disclose confidential information.

In the event the NEO becomes subject to excise taxes under Section 4999 of the Internal Revenue Code as 
a result of payments and benefits received under the employment agreements or any other plan, arrangement 
or agreement with us, we will pay the NEO only that portion of such payments which are in total equal to one 
dollar less than the amount that would subject the NEO to the excise tax.

Payments in the Event of Termination

The benefits to be provided to the NEOs as a result of termination under various scenarios are detailed in 

the tables below. The tables assume that the termination occurred on December 31, 2020.

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Linda H. Apsey - Termination Scenarios: Value of Potential Payments

Total Value of Severance, Benefits and Unvested Equity Awards(1)(2)

Voluntary 
Resignation

Involuntary For 
Cause

Involuntary Not-
for-Cause or 
Voluntary Good 
Reason

Change In 
Control (pre-
tax)(3)

Disability

Death (pre-
retirement)(4)

$ 

—  $ 

—  $ 

1,632,000  $ 

4,116,287  $ 

—  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

816,000 

816,000 

1,151,376 

1,151,376 

— 

— 

— 

— 

— 

— 

291,622 

1,651,740 

1,651,740 

1,651,740 

583,245 

1,628,218 

3,134,919 

3,134,919 

— 

— 

— 

— 

— 

25,000 

25,000 

31,733 

31,733 

848,541 

848,541 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

4,563,517  $ 

9,452,895  $ 

5,602,659  $ 

5,602,659 

Gretchen L. Holloway - Termination Scenarios: Value of Potential Payments

Total Value of Severance, Benefits and Unvested Equity Awards(1)(2)

Voluntary 
Resignation

Involuntary For 
Cause

Involuntary Not-
for-Cause or 
Voluntary Good 
Reason

Change In 
Control (pre-
tax)(3)

Disability

Death (pre-
retirement)(4)

$ 

—  $ 

—  $ 

795,600  $ 

2,004,880  $ 

—  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

397,800 

397,800 

561,296 

561,296 

— 

— 

499,515 

565,071 

565,071 

565,071 

199,029 

— 

— 

— 

555,626 

(828,134) 

— 

— 

25,000 

25,000 

10,787 

10,787 

1,069,790 

1,069,790 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

2,091,227  $ 

2,894,526  $ 

2,032,661  $ 

2,032,661 

Compensation

  Cash Severance

  Target Short-term Bonus

  Pro Rata Short-term 
(Annual) Incentive 
Comp

Retention Awards

  Service-Based Unit 

Awards (5)

  Performance-Based Unit 

Awards (6)

Benefits and Perquisites

  Retirement Plan

  ESRP

  Perquisites

  Health & Welfare 

Benefits

  Postretirement Welfare 

Plan (7)

Total Payout:

Compensation

  Cash Severance

  Target Short-term Bonus

  Pro Rata Short-term 
(Annual) Incentive 
Comp

  Service-Based Unit 

Awards (5)

  Performance-Based Unit 

Awards (6)

  280G Cutback

Benefits and Perquisites

  Retirement Plan

  ESRP

  Perquisites

  Health & Welfare 

Benefits

Total Payout:

113

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Jon E. Jipping - Termination Scenarios: Value of Potential Payments

Total Value of Severance, Benefits and Unvested Equity Awards(1)(2)

Voluntary 
Resignation or 
Voluntary Good 
Reason

Involuntary For 
Cause

Involuntary Not-
for-Cause

Change In 
Control (pre-
tax)(3)

Disability

Death (pre-
retirement)(4)

$ 

—  $ 

—  $ 

1,171,600  $ 

2,990,971  $ 

—  $ 

— 

— 

— 

843,749 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

585,800 

585,800 

826,564 

826,564 

— 

— 

148,005 

843,749 

843,749 

843,749 

295,995 

824,011 

1,584,048 

1,584,048 

— 

— 

— 

— 

25,000 

25,000 

25,137 

25,137 

874,856 

874,856 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

843,749  $ 

—  $ 

3,367,157  $ 

6,410,288  $ 

3,013,597  $ 

3,013,597 

Christine Mason Soneral - Termination Scenarios: Value of Potential Payments

Total Value of Severance, Benefits and Unvested Equity Awards(1)(2)

Voluntary 
Resignation

Involuntary For 
Cause

Involuntary Not-
for-Cause or 
Voluntary Good 
Reason

Change In 
Control (pre-
tax)(3)

Disability

Death (pre-
retirement)(4)

$ 

—  $ 

—  $ 

787,000  $ 

2,021,964  $ 

—  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

393,900 

393,900 

555,793 

555,793 

— 

— 

99,515 

570,827 

570,827 

570,827 

199,029 

554,074 

1,065,135 

1,065,135 

— 

— 

— 

— 

25,000 

25,000 

24,793 

24,793 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

1,691,130  $ 

3,752,451  $ 

2,029,862  $ 

2,029,862 

Compensation

  Cash Severance

  Target Short-term Bonus

  Pro Rata Short-term 
(Annual) Incentive 
Comp

  Service-Based Unit 

Awards (5)

  Performance-Based Unit 

Awards (6)

Benefits and Perquisites

  Retirement Plan

  ESRP

  Perquisites

  Health & Welfare 

Benefits

  Postretirement Welfare 

Plan (7)

Total Payout:

Compensation

  Cash Severance

  Target Short-term Bonus

  Pro Rata Short-term 
(Annual) Incentive 
Comp

  Service-Based Unit 

Awards (5)

  Performance-Based Unit 

Awards (6)

Benefits and Perquisites

  Retirement Plan

  ESRP

  Perquisites

  Health & Welfare 

Benefits

Total Payout:

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Krista Tanner - Termination Scenarios: Value of Potential Payments

Total Value of Severance, Benefits and Unvested Equity Awards(1)(2)

Voluntary 
Resignation

Involuntary For 
Cause

Involuntary Not-
for-Cause or 
Voluntary Good 
Reason

Change In 
Control (pre-
tax)(3)

Disability

Death (pre-
retirement)(4)

$ 

—  $ 

—  $ 

679,200  $ 

1,172,021  $ 

—  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

339,600 

339,600 

479,176 

479,176 

— 

— 

59,234 

247,288 

247,288 

247,288 

118,468 

— 

— 

— 

371,439 

(415,126) 

— 

— 

25,000 

25,000 

20,545 

20,545 

758,914 

758,914 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

1,381,623  $ 

1,900,343  $ 

1,345,802  $ 

1,345,802 

Compensation

  Cash Severance

  Target Short-term Bonus

  Pro Rata Short-term 
(Annual) Incentive 
Comp

  Service-Based Unit 

Awards (5)

  Performance-Based Unit 

Awards (6)

  280G Cutback

Benefits and Perquisites

  Retirement Plan

  ESRP

  Perquisites

  Health & Welfare 

Benefits

Total Payout:

____________________________

(1) All  scenarios  include  the  value  of  severance.  For  Ms.  Apsey  and  Mr.  Jipping,  the  value  of  the 
Postretirement  Welfare  Plan  is  additionally  included  where  applicable.  The  Pension  Benefits  Table 
assumes that none of the NEOs are terminated prior to retirement age and that benefits are paid once 
retirement  commences  (age  58  is  assumed).  All  other  accrued  pension  benefits,  outside  of  present 
value  reductions  outlined  in  footnote  (5),  and  additional  pension  benefits  upon  death,  have  not  been 
included in these termination scenarios but can be found in the “Pension Benefits Table”.

(2) Upon any termination of employment, benefits that are accrued but unpaid prior to that event are paid. 

These benefits are assumed to be $0 in the above tables.

(3) Change  in  control  values  include  severance  amounts  reflecting  cutbacks  to  the  extent  employer 
payments exceed the executive respective limits. Ms. Holloway and Ms. Tanner would be subject to an 
excise tax on the employer payments as of the assumed change in control date; therefore, cutbacks in 
the amounts of $828,134 (Ms. Holloway) and $415,126 (Ms. Tanner) have been reflected.

(4) In  the  event  of  Mr.  Jipping’s  termination  for  death  (pre-retirement),  his  spouse  would  receive  half  the 
50% joint and survivor annuity under the traditional component of the Qualified Plan. Under termination 
for  death  (pre-retirement),  Ms.  Apsey’s,  Ms.  Mason  Soneral’s,  Ms.  Holloway’s  and  Ms.  Tanner’s 
Qualified Plan benefits are payable immediately to the surviving spouse (if any) and ESRP benefits are 
payable  to  a  designated  beneficiary.  The  above  termination  scenarios  do  not  reflect  the  reduction  in 
present value of death benefits ($154,161 for Ms. Apsey, $83,796 for Ms. Holloway, $1,045,683 for Mr. 
Jipping, $105,645 for Ms. Mason Soneral and $44,310 for Ms. Tanner compared to present value in the 
Pension Benefits Table).

(5) Under  the  2017  Omnibus  Plan,  outstanding  and  unvested  SBUs  and  respective  dividend  equivalents 
shall be deemed to be vested SBUs and redeemable on the Change of Control Redemption Date (as 
defined  in  the  2017  Omnibus  Plan).  In  the  case  of  Death  or  Disability  (each  as  defined  in  the  2017 
Omnibus Plan) termination, outstanding and unvested SBUs and respective dividend equivalents shall 
be deemed to be vested SBUs and redeemable on the date of the death or on the date on which the 
grantee’s  service  is  terminated  due  to  Disability.  In  the  case  of  Retirement  or  Involuntary Termination 
Without  Cause  (each  as  defined  in  the  2017  Omnibus  Plan)  within  one  year  of  the  grant  date, 
outstanding and unvested SBUs and respective dividend equivalents shall be deemed to be forfeited. If 
Retirement  or  Involuntary  Termination  Without  Cause  occurs  one  year  or  more  after  the  grant  date, 

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SBUs  and  respective  dividend  equivalents  shall  be  deemed  to  have  vested  pro-rata  based  on  the 
period  served  from  the  grant  date  to  termination.  For  Mr.  Jipping,  pursuant  to  the  Jipping  Letter 
Agreement, upon a voluntary termination of employment, his SBUs, which would otherwise be forfeited, 
will continue to vest on their normal schedule. Under the Fortis Inc. 2020 Restricted Share Unit Plan, 
outstanding  and  unvested  SBUs  and  respective  dividend  equivalents  shall  be  deemed  to  be  vested 
SBUs and redeemable on the date that is immediately prior to the effective date of the consummation of 
the  transaction  resulting  from  the  Change  of  Control.  In  the  case  of  Death,  Disability  or  Retirement 
termination  and  15  years  or  more  of  service  with  the  Company  or  its  Affiliates,  the  outstanding  and 
unvested SBU awards and respective dividend equivalents shall be deemed vested and redeemable on 
the  date  of  the  death  or  on  the  date  on  which  the  grantee’s  service  is  terminated  due  to  Disability  or 
Retirement. In the case of Death, Disability or Retirement termination and less than 15 years of service 
with the Company or its Affiliates, the outstanding and unvested SBU awards and respective dividend 
equivalents  shall  be  deemed  to  have  vested  pro-rata  based  on  the  period  served  from  grant  date  to 
termination and redeemable on the date of the death or on the date on which the grantee’s service is 
terminated due to Disability or Retirement. In the case of Cause, Involuntary Termination Without Cause 
and Voluntary Termination outstanding and unvested SBU awards and respective dividend equivalents 
shall be deemed to be forfeited.

(6) Under  the  2017  Omnibus  Plan,  outstanding  and  unvested  PBU  awards  and  respective  dividend 
equivalents accelerate on a prorated basis under a Change in Control (as defined in the 2017 Omnibus 
Plan),  based  on  the  higher  of  (A)  100%  of  the  target  number  of  PBUs  in  the  award  or  (B)  the  actual 
payout percentage based on the Committee’s assessment of performance of the payment criteria from 
the beginning of the Payment Criteria Period for the award through the date of the Change of Control 
(as defined in the 2017 Omnibus Plan). In the case of Death or Disability termination, the outstanding 
and unvested PBU awards and respective dividend equivalents will remain outstanding and be payable 
on  the  payout  date  of  such  awards  subject  to  the  achievement  of  the  applicable  payment  criteria. 
Values  shown  in  the  tables  above  are  based  on  target  performance  as  an  estimate  of  potential 
payments. In the case of Retirement or Involuntary Termination Without Cause within one year of the 
award grant date, outstanding and unvested PBU awards and respective dividend equivalents shall be 
deemed  to  be  forfeited.  If  Retirement  or  Involuntary  Termination  Without  Cause  occurs  one  year  or 
more after the grant date, PBU awards  and respective dividend equivalents shall be deemed to have 
vested pro-rata based on the period served from grant date to termination. For Mr. Jipping, pursuant to 
the Jipping Letter Agreement, upon a voluntary termination of employment, his PBUs, awarded under 
the  2017  Omnibus  Plan,  which  would  otherwise  be  forfeited,  will  continue  to  vest  on  their  normal 
schedule. The table does not reflect any value for Mr. Jipping’s outstanding and unvested PBUs as the 
payout  is  subject  to  achievement  of  the  performance  measures.  Under  the  Executive  Omnibus  Plan, 
outstanding and unvested PBU awards and respective dividend equivalents shall become redeemable 
on  the  Change  of  Control  Redemption  Date  under  a  Change  in  Control  (as  defined  in  the  Executive 
Omnibus  Plan).  In  the  case  of  Death,  Disability  or  Retirement  termination  and  15  years  or  more  of 
service  with  the  Company  or  its Affiliates,  the  outstanding  and  unvested  PBU  awards  and  respective 
dividend equivalents will remain outstanding and be payable on the payout date of such awards subject 
to  the  achievement  of  the  applicable  payment  criteria.  In  the  case  of  Death,  Disability  or  Retirement 
termination  and  less  than  15  years  of  service  with  the  Company  or  its Affiliates,  the  outstanding  and 
unvested  PBU  awards  and  respective  dividend  equivalents  shall  be  deemed  to  have  vested  pro-rata 
based on the period served from grant date to termination and be payable on the payout date of such 
awards subject to the achievement of the applicable payment criteria. Values shown in the tables above 
are  based  on  target  performance  as  an  estimate  of  potential  payments.  In  the  case  of  Cause, 
Involuntary  Termination  Without  Cause  and  Voluntary  Termination  outstanding  and  unvested  PBU 
awards and respective dividend equivalents shall be deemed to be forfeited.

(7) The value of the Postretirement Welfare Plan benefit is included in involuntary termination not for cause 
and  change  in  control  scenarios  for  Ms.  Apsey  and  Mr.  Jipping  since  their  employment  agreement 
includes a provision for deemed satisfaction of the eligibility requirements when terminated under these 
scenarios. It is assumed each would commence their Postretirement Welfare Benefits at age 58. The 
rate  at  which  future  expected  benefit  payments  were  discounted  in  calculating  the  Postretirement 
Welfare  Plan  present  values  was  2.94%,  the  same  rate  used  for  fiscal  year-end  2020  accounting 
disclosure of the Postretirement Welfare Plan.

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Upon death or disability, a NEO (or his or her estate) receives a pro rata portion of his or her current year 
target corporate performance bonus. All balances under the cash balance and ESRP shift components of the 
Qualified Plan, and the ESRP balance (vested portion only for disability), are immediately payable. If the NEO 
has  10  years  of  service  after  age  45,  then  the  NEO  (and  his  or  her  spouse)  is  eligible  for  retiree  medical 
benefits.

Pursuant to his May 2020 Separation and Release Agreement, subject to his compliance with the terms set 
forth  in  his  employment  agreement,  Mr.  Oginsky  will  receive  (i)  a  pro  rata  portion  of  his  2020  bonus,  (ii) 
continuation of his base salary for (2) years to be paid in accordance with normal Company payroll practices, 
(iii) continued employee benefits under COBRA with a portion of applicable COBRA premium costs reimbursed 
for a period of up to 18 months and, (iv) outplacement services for up to (2) years post the termination date. The 
aforementioned payments and benefits are in exchange for entering into the Separation and Release of Claims 
Agreement and replaces all employment arrangements and benefits programs available to Mr. Oginsky prior to 
his termination date. Mr. Oginsky received LTIP payments of $337,849 for SBUs and $743,232 for PBUs that 
were accelerated and paid in accordance with the LTIP provisions. Mr. Oginsky is entitled to a future payment 
pursuant  to  PBU  grants  made  prior  to  his  employment  termination,  subject  to  performance  conditions  and 
dividend equivalents, in February 2022. Mr. Oginsky will receive a lump sum distribution of his ESRP on March 
1, 2021 and at this time he has made no election to commence his Retirement Plan benefit.

Pay Ratio

As required by the U.S. Congress under the Dodd-Frank Wall Street Reform and Consumer Protection Act, 
and  the  SEC  under  Item  402(u)  of  Regulation  S-K,  we  are  providing  the  following  information  about  the 
relationship of the annual total compensation of our employees and the annual total compensation of Linda H. 
Apsey our CEO:

For 2020, our last completed fiscal year:

the  median  of  the  annual  total  compensation  of  all  employees  of  the  Company  (other  than  Ms. 

Apsey), was $156,386; and

the annual total compensation of Ms. Apsey as reported in the Summary Compensation Table was 

$4,451,284.

Based  on  this  information,  Ms. Apsey’s  2020  annual  total  compensation  was  estimated  to  be  29  times  the 

median annual total compensation for all employees, other than Ms. Apsey.

We determined that, as of December 31, 2020, our employee population consisted of 698 individuals with all 
of  those  individuals  located  in  the  United  States.  To  identify  the  “median  employee”  from  our  employee 
population,  excluding  Ms. Apsey,  we  utilized  a  consistently  applied  compensation  measure  that  included  the 
sum  of  each  employee’s  2020  annualized  base  salary  as  of  December  31,  2020  as  reflected  in  our  payroll 
records,  and  target  2020  awards  made  under  our  annual  corporate  performance  plan,  2017  Omnibus  Plan, 
Executive  Omnibus  Plan  and  Fortis  Inc.  2020  Restricted  Share  Unit  Plan  that  were  not  paid  in  2020.  We 
arrayed these values to select our “median employee”.

Under Item 402(u), a company is permitted to identify its “median employee” once every three years if there 
has been no significant change to its employee population or employee compensation arrangements that would 
result in a significant change to its pay ratio disclosure. We updated our “median employee” for 2020 as it had 
been three years since we had last identified the “median employee” for this analysis.

Using our “median employee” and Ms. Apsey, we calculated the 2020 Summary Compensation Table values 

for each according to SEC rules.

Director Compensation

The following table provides information concerning the compensation of each person who served as a non-

employee director of the Company during 2020.

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Non-Employee Director Compensation Table

Robert A. Elliott

Albert Ernst

Debora Frodl (2)

Alexander I. Greenbaum (3)

Ronnie Hawkins, Jr. (2)

David G. Hutchens (2)

James P. Laurito 

Barry V. Perry 

Sandra E. Pierce (4)

Kevin L. Prust

A. Douglas Rothwell (4)

Thomas G. Stephens (5)

Joseph L. Welch (5)

Name

(a)

Fees Earned or 
Paid in Cash ($) (1)

(b)

$ 

140,000  $ 

140,000 

46,667 

— 

74,668 

— 

140,000 

140,000 

175,417 

155,000 

148,748 

155,000 

76,505 

Total ($)

(h)

140,000 

140,000 

46,667 

— 

74,668 

— 

140,000 

140,000 

175,417 

155,000 

148,748 

155,000 

76,505 

____________________________

(1) Includes annual Board retainer and committee chairmanship retainer, as well as a chairperson fee 

(for Mr. Welch and Ms. Pierce only).

(2) Ms.  Frodl  joined  the  Board  in August  2020,  Mr.  Hawkins  joined  the  Board  in  June  2020  and  Mr. 

Hutchens joined the Board in January 2021.

(3) Mr. Greenbaum waived all compensation due to him for his service on the Board.

(4) Ms. Pierce was appointed to chairperson of the Board and Mr. Rothwell was appointed Governance 

and Human Resources chair in May 2020.

(5) Mr. Welch left the Board in May 2020 and Mr. Stephens left the Board in February 2021.

Directors who are employees of the Company do not receive separate compensation for their services as a 
director. All  non-employee  directors  are  compensated  under  our  non-employee  director  compensation  policy, 
pursuant  to  which  they  are  paid  an  annual  cash  retainer  of  $140,000.  In  addition,  we  pay  an  additional  cash 
retainer of $15,000 annually to the chair of each Board committee and $50,000 annually to our chairperson. We 
do  not  pay  per-meeting  fees  under  the  policy.  Non-employee  directors  are  reimbursed  for  their  out-of-pocket 
expenses incurred for the performance of their duties as directors.

We  maintain  a  Director  Deferred  Compensation  Plan  under  which  nonqualified  deferred  compensation  is 
permissible. Only non-employee directors of the Company are eligible to participate in this plan. Directors are 
allowed to defer up to 100% of their annual board compensation. Investment earnings are based on the various 
investment  options  available  under  the  plan  and  are  selected  by  the  individual  directors.  Distributions  will  be 
made when the director ceases to serve on the Board and/or ceases to provide other non-employee consulting 
services to the Company or any Fortis entity. Messrs. Laurito, Stephens and Ms. Pierce participate in this plan.

ITEM  12.    SECURITY  OWNERSHIP  OF  CERTAIN  BENEFICIAL  OWNERS  AND  MANAGEMENT  AND 

RELATED STOCKHOLDER MATTERS.

The following table sets forth certain information regarding the ownership of our common stock and Fortis’ 

common stock as of February 1, 2021, except as otherwise indicated, by:

•

•

each of our current directors;

each of the persons named in the “Summary Compensation Table” under Item 11; and

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•

all current directors and executive officers as a group.

The  number  of  shares  beneficially  owned  is  determined  under  rules  of  the  SEC  and  the  information  is  not 
necessarily  indicative  of  beneficial  ownership  for  any  other  purpose.  Under  such  rules,  beneficial  ownership 
includes any shares as to which the individual has sole or shared voting power or investment power and also 
any  shares  which  the  individual  has  the  right  to  acquire  on  February  1,  2021  or  within  60  days  thereafter 
through  the  exercise  of  any  stock  option  or  other  right.  Unless  otherwise  indicated,  each  holder  has  sole 
investment and voting power with respect to the shares set forth in the following table:

Name of Beneficial Owner

Linda H. Apsey
Gretchen L. Holloway
Jon E. Jipping
Christine Mason Soneral
Krista Tanner
Daniel J. Oginsky
Robert A. Elliott
Albert Ernst
Debora Frodl
Alexander I. Greenbaum
Ronnie Hawkins
David G. Hutchens
James P. Laurito
Sandra E. Pierce
Kevin L. Prust
A. Douglas Rothwell
Thomas G. Stephens
All current directors and executive officers as a group 
(17 persons)

Number of 
Company 
Shares
Beneficially 
Owned (#)

—   
—   
—   
—   
—   
—   
—  
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   

Percent of 
Class (%)
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 

Number of 
Fortis shares 
Beneficially 
Owned (#)

Percent 
of Class 
(%)

(1)

53,889 
7,771 
60,000 
— 
— 
72,621 
—
14,511
— 
— 
— 
63,891 
48,311 
— 
500 
— 
2,098 

*
*
*
— 
— 
*
—
*
— 
— 
— 
— 
*
— 
*
— 
*

*

— 

 — %  

309,081 

* Less than one percent

____________________________

(1) Includes 4,234 shares owned by the spouse of Mr. Ernst.

ITC Investment Holdings, which owns all of our outstanding common stock, is 80.1% owned by FortisUS and 

19.9% owned by Eiffel. FortisUS is a wholly-owned subsidiary of Fortis.

At December 31, 2020, there were no securities authorized for issuance under any compensation plans of 

ITC Holdings.

ITEM  13. 
INDEPENDENCE.

  CERTAIN  RELATIONSHIPS  AND  RELATED  TRANSACTIONS,  AND  DIRECTOR 

CERTAIN TRANSACTIONS

Pursuant to its charter, the Governance and Human Resources Committee is charged with monitoring and 
reviewing  issues  involving  independence  and  potential  conflicts  of  interest  with  respect  to  our  directors  and 
executive  officers.  The  Committee  also  determines  whether  or  not  a  particular  relationship  serves  the  best 
interest of the Company and its shareholder and whether the relationship should be continued or eliminated. In 
addition, our Code of Conduct and Ethics generally forbids conflicts of interest unless approved by the Board or 
a designated committee.

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Although the Company does not have a written policy with regard to the approval of transactions between 
the Company and its executive officers and directors, each director and officer must annually submit a form to 
the  General  Counsel  disclosing  his  or  her  conflicts  or  potential  conflicts  of  interest  or  certifying  that  no  such 
conflicts  of  interest  exist.  Throughout  the  year,  if  any  transaction  constituting  a  conflict  of  interest  arises  or 
circumstances otherwise change that would cause a director’s or officer’s annual conflict certification to become 
incorrect,  the  director  or  officer  must  inform  the  General  Counsel  of  such  circumstances.  The  Committee 
reviews existing conflicts as well as potential conflicts of interest and determines whether any further action is 
necessary, such as recommending to the Board whether a director or officer should be requested to offer his or 
her resignation. Where the Board makes a determination regarding a potential conflict of interest, a majority of 
the Board (excluding any interested member or members) shall decide upon an appropriate course of action. 
Additionally,  any  director  or  officer  who  has  a  question  about  whether  a  conflict  exists  must  bring  it  to  the 
attention of the Company’s General Counsel or Chairperson of the Committee.

Clayton  Welch,  Jennifer  Welch,  Jessica  Uher  and  Katie  Welch  (each  of  whom  is  a  son,  daughter  or 
daughter-in-law  of  Joseph  L.  Welch,  the  Company’s  Chairperson  until  May  2020)  were  employed  by  us  as  a 
Senior  Engineer,  Fleet  Manager,  Manager  of  Corporate  and  Field  Facilities,  and  Senior  Accountant, 
respectively,  during  2020  and  continue  to  be  employed  by  us. These  individuals  are  employed  on  an  “at  will” 
basis  and  compensated  on  the  same  basis  as  our  other  employees  of  similar  function,  seniority  and 
responsibility without regard to their relationship with Mr. Welch. These four individuals, none of whom resides 
with  or  is  supported  financially  by  Mr.  Welch,  received  aggregate  salary,  bonus,  long-term  incentives  and 
taxable perquisites for services rendered in the above capacities totaling $586,777 during 2020.

DIRECTOR INDEPENDENCE

Based  on  the  absence  of  any  material  relationship  between  them  and  us,  other  than  their  capacities  as 
directors, the Board has determined that Mmes. Frodl and Pierce and Messrs. Elliott, Ernst, Hawkins, Jr., Prust, 
and  Rothwell  are  “independent”  as  defined  in  the  Shareholders  Agreement.  In  addition,  our  Board  has 
determined that, as the committees are currently constituted, a majority of the members of the Audit and Risk 
Committee are “independent” as defined in the Shareholders Agreement. None of the directors determined to 
be independent is or ever has been employed by us. 

An  independent  director  under  the  Shareholders  Agreement  is  a  director  who  meets  all  of  the  following 
requirements:  (a)  is  elected  by  the  shareholders  of  ITC  Investment  Holdings;  (b)  is  designated  as  an 
independent  director  by  the  ITC  Investment  Holdings’  board  and  Company  Board,  or  the  shareholders  of  ITC 
Investment  Holdings;  (c)  is  not  a  director  that  is  nominated  by  Finn  Investment  Pte  Ltd  or  any  successor  or 
permitted  assign  thereof  and  appointed  as  a  member  of  the  ITC  Investment  Holdings’  board  and  Company 
Board  in  accordance  with  the  Shareholders  Agreement;  (d)  is  not  and  during  the  three  years  prior  to  being 
designated as an independent director has not been any of the following: (i) a director of FortisUS or any of its 
affiliates (other than ITC Investment Holdings or the Company); or (ii) an officer or employee of ITC Investment 
Holdings,  the  Company,  FortisUS  or  any  of  their  affiliates;  and  (e)  would  meet  the  definition  of  “independent 
director” under the NYSE Listed Company Manual if such director were a member of the board of directors of 
Fortis, FortisUS, ITC Investment Holdings, or the Company (assuming, in the case of FortisUS, ITC Investment 
Holdings and the Company, that such entities were listed on the NYSE).

Mr.  Elliott  serves  on  the  board  of  directors  of  UNS  Energy  Corporation,  a  wholly-owned  subsidiary  of 
FortisUS.  When  determining  Mr.  Elliott’s  independence,  the  board  and  shareholders  agreed  to  waive  the 
requirements set forth in the definition of independent director under the Shareholders Agreement which states 
that a director is not and during the three years prior to being designated as a director of the company has not 
served as a director of FortisUS or any of its affiliates.

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ITEM 14.   PRINCIPAL ACCOUNTANT FEES AND SERVICES.

The  following  table  provides  a  summary  of  the  aggregate  fees  incurred  for  Deloitte’s  services  in  2020  and 

2019:

Audit fees (1)
Audit-related fees (2)
Tax fees (3)
All other fees (4)

Total fees

$ 

2020
1,995,000  $ 
56,000   
16,000   
4,000   

$ 

2,071,000  $ 

2019
1,901,000 
54,000 
208,000 
9,000 
2,172,000 

____________________________

(1)  Audit fees were for professional services rendered for the audit of our consolidated financial statements 
and internal controls and reviews of the interim consolidated financial statements included in quarterly 
reports and services that are normally provided by Deloitte in connection with statutory and regulatory 
filing engagements.

(2)  Audit-related  fees  were  for  assurance  and  related  services  that  are  reasonably  related  to  the 
performance of the audit or review of our consolidated financial statements and are not reported under 
“Audit Fees.” These services include audit of our employee benefit plans.

(3)  Tax fees were professional services for federal and state tax compliance, tax advice and tax planning.

(4)  All  other  fees  were  for  services  other  than  the  services  reported  above.  These  services  included 
subscriptions  to  the  Deloitte  Accounting  Research  Tool  and  attendance  at  Deloitte  sponsored 
conferences and labs.

The  Audit  and  Risk  Committee  of  the  Board  of  Directors  does  not  consider  the  provision  of  the  services 

described above by Deloitte to be incompatible with the maintenance of Deloitte’s independence.

The  Audit  and  Risk  Committee  has  adopted  a  pre-approval  policy  for  all  audit  and  non-audit  services 
pursuant to which it pre-approves all audit and non-audit services provided by the independent registered public 
accounting  firm  prior  to  the  engagement  with  respect  to  such  services.  To  the  extent  that  we  need  an 
engagement  for  audit  and/or  non-audit  services  between Audit  and  Risk  Committee  meetings,  the Audit  and 
Risk Committee chairman is authorized by the Audit and Risk Committee to approve the required engagement 
on its behalf.

The Audit  and  Risk  Committee  approved  all  of  the  services  performed  by  Deloitte  in  2020  pursuant  to  the 

pre-approval policy.

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PART IV

ITEM 15.   EXHIBITS AND FINANCIAL STATEMENT SCHEDULES.

(a)

(1) Financial Statements:

Management’s Report on Internal Control over Financial Reporting

Report of Independent Registered Public Accounting Firm

Consolidated Statements of Financial Position as of December 31, 2020 and 2019

Consolidated Statements of Comprehensive Income for the Years Ended December 31, 2020, 2019 and 2018
Consolidated Statements of Changes in Stockholder's Equity for the Years Ended December 31, 2020, 2019 
and 2018
Consolidated Statements of Cash Flows for the Years Ended December 31, 2020, 2019 and 2018

Notes to Consolidated Financial Statements

(2) Financial Statement Schedules

Schedule I — Condensed Financial Information of Registrant

All other schedules for which provision is made in Regulation S-X either (i) are not required under the related 
instructions or are inapplicable and, therefore, have been omitted, or (ii) the information required is included in 
the consolidated financial statements or the notes thereto that are a part hereof.

(b)

Exhibit Listing

The following exhibits are filed as part of this report or filed previously and incorporated by reference 

to the filing indicated. Our SEC file number is 001-32576.

Exhibit No.

Description of Exhibit

2.1 

3.1 

3.2 

4.3 

4.5 

4.6 

4.7 

4.8 

4.9 

Agreement  and  Plan  of  Merger,  dated  as  of  February  9,  2016,  among  FortisUS  Inc.,  Element 
Acquisition Sub Inc., Fortis Inc., and ITC Holdings Corp. (filed with Registrant’s Form 8-K on February 
11, 2016)

Restated  Articles  of  Incorporation  of  ITC  Holdings  Corp.  (filed  with  Registrant’s  Form  10-Q  for  the 
quarter ended September 30, 2016)

Eighth Amended and Restated Bylaws of ITC Holdings Corp.

Indenture, dated as of July 16, 2003, between ITC Holdings Corp. and BNY Midwest Trust Company, 
as  trustee  (filed  with  Registrant’s  Registration  Statement  on  Form  S-1,  as  amended,  Reg.  No. 
333-123657)

First  Mortgage  and  Deed  of  Trust,  dated  as  of  July  15,  2003,  between  International  Transmission 
Company and BNY Midwest Trust Company, as trustee (filed with Registrant’s Registration Statement 
on Form S-1, as amended, Reg. No. 333-123657)

First Supplemental Indenture, dated as of July 15, 2003, supplementing the First Mortgage and Deed of 
Trust dated as of July 15, 2003, between International Transmission Company and BNY Midwest Trust 
Company,  as  trustee  (filed  with  Registrant’s  Registration  Statement  on  Form  S-1,  as  amended,  Reg. 
No. 333-123657)

Second  Supplemental  Indenture,  dated  as  of  July  15,  2003,  supplementing  the  First  Mortgage  and 
Deed  of  Trust  dated  as  of  July  15,  2003,  between  International  Transmission  Company  and  BNY 
Midwest  Trust  Company,  as  trustee  (filed  with  Registrant’s  Registration  Statement  on  Form  S-1,  as 
amended, Reg. No. 333-123657)

Amendment to Second Supplemental Indenture, dated as of January 19, 2005, between International 
Transmission  Company  and  BNY  Midwest  Trust  Company,  as  trustee  (filed  with  Registrant’s 
Registration Statement on Form S-1, as amended, Reg. No. 333-123657)

Second  Amendment  to  Second  Supplemental  Indenture,  dated  as  of  March  24,  2006,  between 
International Transmission Company and The Bank of New York Trust Company, N.A. (as successor to 
BNY Midwest Trust Company), as trustee (filed with Registrant’s Form 8-K on March 30, 2006)

4.10 

Third  Supplemental  Indenture,  dated  as  of  March  28,  2006,  supplementing  the  First  Mortgage  and 
Deed  of  Trust  dated  as  of  July  15,  2003,  between  International  Transmission  Company  and  BNY 
Midwest Trust Company, as trustee (filed with Registrant’s Form 8-K on March 30, 2006)

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Exhibit No.

Description of Exhibit

4.12 

4.14 

4.17 

4.18 

4.19 

4.20 

4.23 

4.24 

4.25 

4.26 

4.27 

4.28 

4.29 

4.30 

4.31 

4.32 

4.33 

4.34 

Second Supplemental Indenture, dated as of October 10, 2006, supplemental to the Indenture dated as 
of  July  16,  2003,  between  the  Registrant  and  The  Bank  of  New  York  Trust  Company,  N.A.,  (as 
successor to BNY Midwest Trust Company, as trustee) (filed with Registrant’s Form 8-K on October 10, 
2006)

First Mortgage Indenture between Michigan Electric Transmission Company, LLC and JPMorgan Chase 
Bank,  dated  as  of  December  10,  2003  (filed  with  Registrant’s  Form  10-Q  for  the  quarter  ended 
September 30, 2006)

ITC Holdings Corp. Note Purchase Agreement, dated as of September 20, 2007 (filed with Registrant’s 
Form 10-Q for the quarter ended September 30, 2007)

Third Supplemental Indenture, dated as of January 24, 2008, supplemental to the Indenture dated as of 
July 16, 2003, between the Registrant and The Bank of New York Trust Company, N.A. (as successor 
to BNY Midwest Trust Company), as trustee (filed with Registrant’s Form 8-K on January 25, 2008)

First Mortgage and Deed of Trust, dated as of January 14, 2008, between ITC Midwest LLC and The 
Bank  of  New  York  Trust  Company,  N.A.,  as  trustee  (filed  with  Registrant’s  Form  8-K  on  February  1, 
2008)

First  Supplemental  Indenture,  dated  as  of  January  14,  2008,  supplemental  to  the  First  Mortgage 
Indenture between ITC Midwest LLC and The Bank of New York Trust Company, N.A., as trustee, First 
Mortgage  and  Deed  of  Trust,  dated  as  of  January  14,  2008  (filed  with  Registrant’s  Form  8-K  on 
February 1, 2008)

Second Supplemental Indenture, dated as of December 15, 2008, between ITC Midwest LLC and The 
Bank of New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, 
N.A.),  as  trustee,  to  the  First  Mortgage  and  Deed  of  Trust,  dated  as  of  January  14,  2008  (filed  with 
Registrant’s Form 8-K on December 23, 2008)

Third Supplemental Indenture, dated as of November 25, 2008, between METC and The Bank of New 
York Mellon Trust Company, N.A. (as successor to JPMorgan Chase Bank, N.A.), as trustee, to the First 
Mortgage  Indenture  between  Michigan  Electric  Transmission  Company,  LLC  and  JPMorgan  Chase 
Bank, dated as of December 10, 2003 (filed with Registrant’s Form 8-K on December 23, 2008)

Fourth Supplemental Indenture, dated as of December 11, 2009, between ITC Holdings Corp. and The 
Bank of New York Mellon Trust Company, N.A. (f.k.a. The Bank of New York Trust Company, N.A., as 
successor to BNY Midwest Trust Company), as trustee (filed with Registrant’s Form 8-K on December 
14, 2009)

Fourth Supplemental Indenture, dated as of December 10, 2009, between ITC Midwest LLC and The 
Bank of New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, 
N.A.), as trustee (filed with Registrant’s Form 8-K on December 17, 2009)

Fifth  Supplemental  Indenture,  dated  as  of  April  20,  2010,  between  Michigan  Electric  Transmission 
Company,  LLC  and  The  Bank  of  New  York  Mellon  Trust  Company,  N.A.  (as  successor  to  JPMorgan 
Chase Bank), as trustee (filed with Registrant’s Form 8-K on May 10, 2010)

Third  Supplemental  Indenture,  dated  as  of  December  15,  2008,  between  ITC  Midwest  LLC  and  The 
Bank  of  New  York  Mellon  Trust  Company,  N.A.  (The  Bank  of  New  York  Trust  Company,  N.A.),  as 
trustee (filed with Registrant’s Form 10-Q for the quarter ended June 30, 2011)

Fifth Supplemental Indenture, dated as of July 15, 2011, between ITC Midwest LLC and The Bank of 
New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, N.A.), 
as trustee (filed with Registrant’s Form 10-Q for the quarter ended June 30, 2011)

Sixth  Supplemental  Indenture,  dated  as  of  November  29,  2011,  between  ITC  Midwest  LLC  and  The 
Bank of New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, 
N.A.), as trustee (filed with Registrant’s Form 8-K on December 1, 2011)

Sixth  Supplemental  Indenture,  dated  as  of  October  5,  2012,  between  Michigan  Electric  Transmission 
Company,  LLC  and  The  Bank  of  New  York  Mellon  Trust  Company,  N.A.  (as  successor  to  JPMorgan 
Chase Bank), as trustee (filed with Registrant’s Form 8-K on October 29, 2012)

Seventh  Supplemental  Indenture,  dated  as  of  March  18,  2013,  between  ITC  Midwest  LLC  and  The 
Bank of New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, 
N.A.), as trustee (filed with Registrant’s Form 8-K on April 8, 2013)

Indenture,  dated  as  of April  18,  2013,  between  ITC  Holdings  Corp.  and  Wells  Fargo  Bank,  National 
Association, as trustee (including form of note) (filed with Registrant’s Form S-3 on April 18, 2013)

First Supplemental Indenture, dated as of July 3, 2013, between ITC Holdings Corp. and Wells Fargo 
Bank,  National Association,  as  trustee  (including  forms  of  notes)  (filed  with  Registrant’s  Form  8-K  on 
July 3, 2013)

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Exhibit No.

Description of Exhibit

4.35 

4.36 

4.38 

4.39 

4.40 

4.41 

4.42 

4.43 

4.44 

4.45 

4.46 

4.47 

4.48 

4.49 

4.50 

4.51 

4.52 

4.53 

Fifth  Supplemental  Indenture,  dated  as  of  August  7,  2013,  between  International  Transmission 
Company and The Bank of New York Mellon Trust Company, N.A. (as successor to BNY Midwest Trust 
Company), as trustee (including form of bonds) (filed with Registrant’s Form 8-K on August 16, 2013)

Fifth Supplemental Indenture, dated May 16, 2014, between ITC Holdings Corp. and The Bank of New 
York Mellon Trust Company, N.A. (f.k.a. The Bank of New York Trust Company, N.A., as successor to 
BNY Midwest Trust Company), as Trustee (filed with Registrant’s Form 8-K on May 16, 2014)

Second  Supplemental  Indenture,  dated  as  of  June  4,  2014  between  ITC  Holdings  Corp.  and  Wells 
Fargo Bank, National Association, as trustee, together with form of 3.65% Senior Note due 2024 (filed 
with Registrant’s Form 8-K on June 4, 2014)

Sixth Supplemental Indenture, dated as of May 23, 2014, between International Transmission Company 
and  The  Bank  of  New  York  Mellon  Trust  Company,  N.A.  (as  successor  to  BNY  Midwest  Trust 
Company), as trustee (filed with Registrant’s Form 8-K on June 10, 2014)

First Mortgage and Deed of Trust, dated as of November 12, 2014, between ITC Great Plains, LLC and 
Wells Fargo Bank, National Association, as trustee (filed with Registrant’s Form 8-K on November 26, 
2014)

First  Supplemental  Indenture,  dated  as  of  November  12,  2014,  between  ITC  Great  Plains,  LLC  and 
Wells Fargo Bank, National Association, as trustee (filed with Registrant’s Form 8-K on November 26, 
2014)

Seventh  Supplemental  Indenture,  dated  as  of  December  5,  2014,  between  Michigan  Electric 
Transmission Company, LLC and The Bank of New York Mellon Trust Company, N.A. (as successor to 
JPMorgan Chase Bank), as trustee (filed with Registrant’s Form 8-K on December 22, 2014)

Eighth Supplemental Indenture, dated as of March 18, 2015, between ITC Midwest LLC and The Bank 
of New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, N.A.), 
as trustee (filed with Registrant’s Form 8-K on April 8, 2015)

Eighth Supplemental Indenture, dated as of March 31, 2016, between Michigan Electric Transmission 
Company, LLC and Bank of New York Mellon Trust Company, N.A. (as successor to JPMorgan Chase 
Bank), as trustee (filed with Registrant’s Form 8-K on April 26, 2016)

Third Supplemental Indenture, dated as of July 5, 2016, between ITC Holdings Corp. and Wells Fargo 
Bank,  National  Association,  as  trustee,  together  with  form  of  3.25%  Note  due  2026  (filed  with 
Registrant’s Form 8-K on July 5, 2016)

Ninth Supplemental Indenture, dated as of March 15, 2017, between ITC Midwest LLC and The Bank of 
New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, N.A.), 
as trustee (filed with Registrant’s Form 8-K on April 18, 2017)

Fourth Supplemental Indenture, dated as of November 14, 2017 between ITC Holdings Corp. and Wells 
Fargo  Bank,  National  Association,  as  trustee  (with  Form  of  2.700%  Notes  due  2022  and  Form  of 
3.350% Notes due 2027) (filed with Registrant’s Form 8-K on November 15, 2017)

Seventh  Supplemental  Indenture,  dated  as  of  March  14,  2018,  between  International  Transmission 
Company and The Bank of New York Mellon Trust Company, N.A. (as successor to BNY Midwest Trust 
Company), as trustee (filed with Registrant’s Form 8-K on March 29, 2018)

Tenth  Supplemental  Indenture,  dated  as  of  September  28,  2018,  between  ITC  Midwest  LLC  and The 
Bank of New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, 
N.A.) as trustee (filed with Registrant’s Form 8-K on November 2, 2018)

Ninth  Supplemental  Indenture,  dated  as  of  November  28,  2018,  between  Michigan  Electric 
Transmission Company, LLC and The Bank of New York Mellon Trust Company, N.A. (as successor to 
JP Morgan Chase Bank), as trustee (filed with Registrant’s Form 8-K on January 15, 2019)

Eighth  Supplemental  Indenture,  dated  as  of  August  14,  2019,  between  International  Transmission 
Company and The Bank of New York Mellon Trust Company, N.A. (as successor to BNY Midwest Trust 
Company), as trustee (filed with Registrant’s Form 8-K on August 28, 2019).

Fifth Supplemental Indenture, dated as of May 14, 2020, between ITC Holdings Corp. and Wells Fargo 
Bank,  National Association,  as  trustee  (with  Form  of  2.95%  Notes  due  2030)  (filed  with  Registrant’s 
Form 8-K on May 14, 2020).

Eleventh Supplemental Indenture, dated as of May 8, 2020, between ITC Midwest LLC and The Bank 
of New York Mellon Trust Company, N.A. (as successor to The Bank of New York Trust Company, N.A.) 
as trustee (filed with Registrant’s Form 8-K on July 15, 2020).

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Exhibit No.

Description of Exhibit

4.54 

*10.27

10.51 

Tenth Supplemental Indenture, dated as of August 12, 2020, between Michigan Electric Transmission 
Company,  LLC  and The  Bank  of  New York  Mellon Trust  Company,  N.A.  (as  successor  to  JP  Morgan 
Chase Bank), as trustee (filed with Registrant’s Form 8-K on October 14, 2020).

Deferred Compensation Plan (filed with Registrant’s Registration Statement on Form S-1, as amended, 
Reg. No. 333-123657)

Form  of  Amended  and  Restated  Easement  Agreement  between  Consumers  Energy  Company  and 
Michigan  Electric  Transmission  Company  (filed  with  Registrant’s  Form  10-Q  for  the  quarter  ended 
September 30, 2006)

*10.81

Executive Supplemental Retirement Plan (filed with Registrant’s 2008 Form 10-K)

*10.109

Employment Agreement between ITC Holdings Corp. and Linda H. Blair, effective as of December 21, 
2012 (filed with Registrant’s Form 8-K on December 26, 2012)

*10.110

Employment Agreement between ITC Holdings Corp. and Jon E. Jipping, effective as of December 21, 
2012 (filed with Registrant’s Form 8-K on December 26, 2012)

*10.111

Employment Agreement between ITC Holdings Corp. and Daniel J. Oginsky, effective as of December 
21, 2012 (filed with Registrant’s Form 8-K on December 26, 2012)

*10.120

First  Amendment  to  Executive  Supplemental  Retirement  Plan,  dated  as  of  May  16,  2013  (filed  with 
Registrant’s Form 10-Q for the quarter ended June 30, 2013)

*10.122

Recoupment Policy and Related Consent, effective January 1, 2014 (filed with Registrant’s Form 8-K on 
December 2, 2013)

*10.150

Employment  Agreement  between  ITC  Holdings  Corp.  and  Christine  Mason  Soneral,  effective  as  of 
February 3, 2015 (filed with Registrant’s Form 10-Q for the quarter ended June 30, 2015)

*10.168

Letter Agreement, dated as of October 14, 2016, between ITC Holdings Corp. and Linda H. Blair (filed 
with Registrant’s Form 8-K on October 12, 2016)

*10.172

*10.173

Employment Agreement between ITC Holdings Corp. and Gretchen L. Holloway, effective as of July 10, 
2017

Letter  Agreement,  dated  as  of  October  12,  2016  between  ITC  Holdings  Corp.  and  Christine  Mason 
Soneral (filed with Registrant’s 2016 Form 10-K)

*10.176

2017  Omnibus  Plan,  effective  February  27,  2017  (filed  with  Registrant’s  Form  10-Q  for  the  quarter 
ended March 31, 2017)

*10.177

Summary of 2017 Annual Incentive Plan (filed with Registrant’s Form 10-Q for the quarter ended March 
31, 2017)

*10.178

Form  of  Service-Based  Unit Award Agreement  under  2017  Omnibus  Plan  (February  2017)  (filed  with 
Registrant’s Form 10-Q for the quarter ended March 31, 2017)

*10.179

Form  of  Performance-Based  Unit Award Agreement  under  2017  Omnibus  Plan  (February  2017)  (filed 
with Registrant’s Form 10-Q for the quarter ended March 31, 2017)

10.182 

Amendment to 2017 Omnibus Plan, dated as of July 10, 2017 (filed with Registrant’s Form 10-Q for the 
quarter ended June 30, 2017)

10.183 

ITC  Holdings  Corp.  Director  Deferred  Compensation  Plan,  effective  March  1,  2017  (filed  with 
Registrant’s Form 10-Q for the quarter ended June 30, 2017)

10.184 

ITC Holdings Revolving Credit Agreement, dated as of October 23, 2017, among ITC Holdings Corp., 
with  the  banks,  financial  institutions  and  other  institutional  lenders  listed  on  the  respective  signature 
pages thereof, JPMorgan Chase Bank, N.A., as administrative agent for the Lenders, JPMorgan Chase 
Bank,  N.A.,  Barclays  Bank  PLC,  Wells  Fargo  Securities,  LLC,  The  Bank  of  Nova  Scotia  and  Mizuho 
Bank, Ltd., as joint lead arrangers and joint bookrunners, Barclays Bank PLC and Wells Fargo Bank, 
National Association, as co-syndication agents and The Bank of Nova Scotia and Mizuho Bank, Ltd. as 
co-documentation agents (filed with Registrant’s Form 8-K on October 23, 2017)

125

 
 
 
 
 
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Exhibit No.

10.185 

10.186 

10.187 

10.188 

Description of Exhibit

ITCTransmission  Revolving  Credit  Agreement,  dated  as  of  October  23,  2017,  among  International 
Transmission Company, with the banks, financial institutions and other institutional lenders listed on the 
respective  signature  pages  thereof,  JPMorgan  Chase  Bank,  N.A.,  as  administrative  agent  for  the 
Lenders, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Wells Fargo Securities, LLC, The Bank of 
Nova Scotia and Mizuho Bank, Ltd., as joint lead arrangers and joint bookrunners, Barclays Bank PLC 
and  Wells  Fargo  Bank,  National Association,  as  co-syndication  agents  and The  Bank  of  Nova  Scotia 
and  Mizuho  Bank,  Ltd.  as  co-documentation  agents  (filed  with  Registrant’s  Form  8-K  on  October  23, 
2017)

METC  Revolving  Credit  Agreement,  dated  as  of  October  23,  2017,  among  Michigan  Electric 
Transmission Company, LLC, with the banks, financial institutions and other institutional lenders listed 
on the respective signature pages thereof, JPMorgan Chase Bank, N.A., as administrative agent for the 
Lenders, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Wells Fargo Securities, LLC, The Bank of 
Nova Scotia and Mizuho Bank, Ltd., as joint lead arrangers and joint bookrunners, Barclays Bank PLC 
and  Wells  Fargo  Bank,  National Association,  as  co-syndication  agents  and The  Bank  of  Nova  Scotia 
and  Mizuho  Bank,  Ltd.  as  co-documentation  agents  (filed  with  Registrant’s  Form  8-K  on  October  23, 
2017)

ITC Midwest Revolving Credit Agreement, dated as of October 23, 2017, among ITC Midwest LLC, with 
the banks, financial institutions and other institutional lenders listed on the respective signature pages 
thereof, JPMorgan Chase Bank, N.A., as administrative agent for the Lenders, JPMorgan Chase Bank, 
N.A.,  Barclays  Bank  PLC,  Wells  Fargo  Securities,  LLC,  The  Bank  of  Nova  Scotia  and  Mizuho  Bank, 
Ltd., as joint lead arrangers and joint bookrunners, Barclays Bank PLC and Wells Fargo Bank, National 
Association,  as  co-syndication  agents  and  The  Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.  as  co-
documentation agents (filed with Registrant’s Form 8-K on October 23, 2017)

ITC Great Plains Revolving Credit Agreement, dated as of October 23, 2017, among ITC Great Plains, 
LLC,  with  the  banks,  financial  institutions  and  other  institutional  lenders  listed  on  the  respective 
signature  pages  thereof,  JPMorgan  Chase  Bank,  N.A.,  as  administrative  agent  for  the  Lenders, 
JPMorgan  Chase  Bank,  N.A.,  Barclays  Bank  PLC,  Wells  Fargo  Securities,  LLC,  The  Bank  of  Nova 
Scotia and Mizuho Bank, Ltd., as joint lead arrangers and joint bookrunners, Barclays Bank PLC and 
Wells  Fargo  Bank,  National Association,  as  co-syndication  agents  and The  Bank  of  Nova  Scotia  and 
Mizuho Bank, Ltd. as co-documentation agents (filed with Registrant’s Form 8-K on October 23, 2017)

*10.190

International Transmission Company Executive Deferred Compensation Plan, effective January 1, 2019 
(filed with Registrant’s 2018 Form 10-K)

*10.191

ITC  Holdings  Corp.  Director  Deferred  Compensation  Plan,  effective  January  1,  2019  (filed  with 
Registrant’s 2018 Form 10-K)

*10.192

10.193 

10.194 

Letter Agreement, effective as of February 18, 2019, between ITC Holdings Corp. and Jon E. Jipping 
(filed with Registrant’s Form 8-K on February 22, 2019).

Term  Loan  Credit  Agreement,  dated  as  of  June  12,  2019,  among  ITC  Holdings  Corp.,  the  various 
financial  institutions  and  other  persons  from  time  to  time  parties  thereto  as  lenders  and  Toronto-
Dominion (Texas) LLC, as administrative agent for the Lenders, Mizuho Bank, Ltd. and TD Securities 
(USA) LLC, as joint lead arrangers and joint bookrunners and Mizuho Bank, Ltd., as syndication agent 
(filed with the Registrant’s Form 8-K on June 14, 2019).

ITC  Holdings  Amendment  and  Restatement  Agreement  dated  as  of  January  10,  2020,  among  ITC 
Holdings Corp., the banks, financial institutions and other institutional lenders listed on the respective 
signature  pages  thereof,  Wells  Fargo  Bank,  National  Association,  in  its  capacity  as  successor 
administrative  agent    and  JPMorgan  Chase  Bank,  N.A.,  in  its  capacity  as  resigning  administrative 
agent,  amending  and  restating  as  of  January  10,  2020  in  the  form  attached  as  Exhibit A  thereto  the 
Revolving  Credit  Agreement,  dated  as  of  October  23,  2017,  among  ITC  Holdings  Corp.,  the  banks, 
financial institutions and other institutional party thereto, JPMorgan Chase Bank, N.A., as administrative 
agent for the lenders, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Wells Fargo Securities, LLC, 
The  Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.,  as  joint  lead  arrangers  and  joint  bookrunners, 
Barclays  Bank  PLC  and  Wells  Fargo  Bank,  National  Association,  as  co-syndication  agents  and  The 
Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.  as  co-documentation  agents  (filed  with  the  Registrant’s 
Form 8-K on January 10, 2020).

126

 
 
 
 
 
 
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Exhibit No.

10.195 

10.196 

10.197 

10.198 

Description of Exhibit

ITCTransmission  Amendment  and  Restatement  Agreement  dated  as  of  January  10,  2020,  among 
International  Transmission  Company,  the  banks,  financial  institutions  and  other  institutional  lenders 
listed on the respective signature pages thereof, Wells Fargo Bank, National Association, in its capacity 
as  successor  administrative  agent    and  JPMorgan  Chase  Bank,  N.A.,  in  its  capacity  as  resigning 
administrative agent, amending and restating as of January 10, 2020 in the form attached as Exhibit A 
thereto  the  Revolving  Credit  Agreement,  dated  as  of  October  23,  2017,  among  International 
Transmission Company, the banks, financial institutions and other institutional party thereto, JPMorgan 
Chase Bank, N.A., as administrative agent for the lenders, JPMorgan Chase Bank, N.A., Barclays Bank 
PLC,  Wells  Fargo  Securities,  LLC,  The  Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.,  as  joint  lead 
arrangers and joint bookrunners, Barclays Bank PLC and Wells Fargo Bank, National Association, as 
co-syndication  agents  and  The  Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.  as  co-documentation 
agents (filed with the Registrant’s Form 8-K on January 10, 2020).

METC  Amendment  and  Restatement  Agreement  dated  as  of  January  10,  2020,  among  Michigan 
Electric  Transmission  Company,  LLC,  the  banks,  financial  institutions  and  other  institutional  lenders 
listed on the respective signature pages thereof, Wells Fargo Bank, National Association, in its capacity 
as  successor  administrative  agent    and  JPMorgan  Chase  Bank,  N.A.,  in  its  capacity  as  resigning 
administrative agent, amending and restating as of January 10, 2020 in the form attached as Exhibit A 
thereto  the  Revolving  Credit  Agreement,  dated  as  of  October  23,  2017,  among  Michigan  Electric 
Transmission  Company,  LLC,  the  banks,  financial  institutions  and  other  institutional  party  thereto, 
JPMorgan  Chase  Bank,  N.A.,  as  administrative  agent  for  the  lenders,  JPMorgan  Chase  Bank,  N.A., 
Barclays Bank PLC, Wells Fargo Securities, LLC, The Bank of Nova Scotia and Mizuho Bank, Ltd., as 
joint  lead  arrangers  and  joint  bookrunners,  Barclays  Bank  PLC  and  Wells  Fargo  Bank,  National 
Association,  as  co-syndication  agents  and  The  Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.  as  co-
documentation agents (filed with the Registrant’s Form 8-K on January 10, 2020).

ITC  Midwest  Amendment  and  Restatement  Agreement  dated  as  of  January  10,  2020,  among  ITC 
Midwest  LLC,  the  banks,  financial  institutions  and  other  institutional  lenders  listed  on  the  respective 
signature  pages  thereof,  Wells  Fargo  Bank,  National  Association,  in  its  capacity  as  successor 
administrative  agent    and  JPMorgan  Chase  Bank,  N.A.,  in  its  capacity  as  resigning  administrative 
agent,  amending  and  restating  as  of  January  10,  2020  in  the  form  attached  as  Exhibit A  thereto  the 
Revolving  Credit  Agreement,  dated  as  of  October  23,  2017,  among  ITC  Midwest  LLC,  the  banks, 
financial institutions and other institutional party thereto, JPMorgan Chase Bank, N.A., as administrative 
agent for the lenders, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Wells Fargo Securities, LLC, 
The  Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.,  as  joint  lead  arrangers  and  joint  bookrunners, 
Barclays  Bank  PLC  and  Wells  Fargo  Bank,  National  Association,  as  co-syndication  agents  and  The 
Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.  as  co-documentation  agents  (filed  with  the  Registrant’s 
Form 8-K on January 10, 2020).

ITC Great Plains Amendment and Restatement Agreement dated as of January 10, 2020, among ITC 
Great Plains, LLC, the banks, financial institutions and other institutional lenders listed on the respective 
signature  pages  thereof,  Wells  Fargo  Bank,  National  Association,  in  its  capacity  as  successor 
administrative agent and JPMorgan Chase Bank, N.A., in its capacity as resigning administrative agent, 
amending and restating as of January 10, 2020 in the form attached as Exhibit A thereto the Revolving 
Credit Agreement,  dated  as  of  October  23,  2017,  among  ITC  Great  Plains,  LLC,  the  banks,  financial 
institutions  and  other  institutional  party  thereto,  JPMorgan  Chase  Bank,  N.A.,  as  administrative  agent 
for  the  lenders,  JPMorgan  Chase  Bank,  N.A.,  Barclays  Bank  PLC,  Wells  Fargo  Securities,  LLC,  The 
Bank  of  Nova  Scotia  and  Mizuho  Bank,  Ltd.,  as  joint  lead  arrangers  and  joint  bookrunners,  Barclays 
Bank  PLC  and  Wells  Fargo  Bank,  National  Association,  as  co-syndication  agents  and  The  Bank  of 
Nova Scotia and Mizuho Bank, Ltd. as co-documentation agents (filed with the Registrant’s Form 8-K 
on January 10, 2020).

10.199 

Term  Loan  Credit Agreement,  dated  as  of  January  23,  2020,  among  Michigan  Electric  Transmission 
Company, LLC, the various financial institutions and other persons from time to time parties thereto as 
lenders and Toronto Dominion (Texas) LLC, as administrative agent for the lenders and TD Securities 
(USA) LLC, as sole lead arranger and bookrunner (filed with the Registrant’s Form 8-K on January 23, 
2020).

*10.200

2017  Omnibus  Plan,  as  amended  July  10,  2017  and  February  4,  2020  (filed  with  Registrant’s  2019 
Form 10-K).

*10.201

Executive Omnibus Plan, effective January 2020. (filed with Registrant’s 2019 Form 10-K)

*10.202

Form  of  Performance-Based  Unit  Award  Agreement  under  Executive  Omnibus  Plan  (January  2020). 
(Filed with Registrant’s 2019 Form 10-K)

*10.203

Employment Agreement between ITC Holdings Corp. and Krista K. Tanner, effective as of February 18, 
2019.

*10.204

Fortis Inc. 2020 Restricted Share Unit Plan, effective January 1, 2020 (filed with Registrant’s Form 10-Q 
for the quarter ended March 31, 2020).

*10.205

Form  of  Restricted  Share  Unit  Grant  Agreement  under  Fortis  Inc.  2020  Restricted  Share  Unit  Plan 
(January, 2020) (filed with Registrant’s Form 10-Q for the quarter ended March 31, 2020).

127

 
 
 
 
 
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Exhibit No.

Description of Exhibit

*10.206

Separation  and  Release Agreement,  effective  as  of  May  18,  2020,  between  ITC  Holdings  Corp.  and 
Daniel J. Oginsky.

21 

List of Subsidiaries

31.1 

31.2 

Certification of Chief Executive Officer pursuant to Rule 13a-14 of the Securities Exchange Act of 1934, 
as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

Certification of Chief Financial Officer pursuant to Rule 13a-14 of the Securities Exchange Act of 1934, 
as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

32 

Certification pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-
Oxley Act of 2002

101.INS

XBRL Instance Document - the instance document does not appear in the Interactive Data file because 
its XBRL tags are embedded within the Inline XBRL document

101.SCH

Inline XBRL Taxonomy Extension Schema

101.CAL

Inline XBRL Taxonomy Extension Calculation Linkbase

101.DEF

Inline XBRL Taxonomy Extension Definition Database

101.LAB

Inline XBRL Taxonomy Extension Label Linkbase

101.PRE

Inline XBRL Taxonomy Extension Presentation Linkbase

104

The  cover  page  from  the  Company’s Annual  Report  on  Form  10-K  for  the  year  ended  December  31, 
2020, formatted in Inline XBRL

____________________________

*

Management contract or compensatory plan or arrangement.

128

 
 
 
 
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SCHEDULE I — Condensed Financial Information of Registrant

ITC HOLDINGS CORP.

CONDENSED STATEMENTS OF FINANCIAL POSITION (PARENT COMPANY ONLY)

December 31,

2020

2019

(In millions of USD, except share data)

ASSETS

Current assets

Cash and cash equivalents

Accounts receivable from subsidiaries

Intercompany tax receivable from subsidiaries

Prepaid and other current assets

Total current assets

Other assets

Investment in subsidiaries

Deferred income taxes

Advances to subsidiaries

Other assets

Total other assets

TOTAL ASSETS

LIABILITIES AND STOCKHOLDER’S EQUITY

Current liabilities

Accrued compensation

Accrued interest

Debt maturing within one year

Other current liabilities

Total current liabilities

Accrued pension and postretirement liabilities

Other liabilities

Long-term debt (net of deferred financing fees and discount of $21 and $17, respectively)

TOTAL LIABILITIES

STOCKHOLDER’S EQUITY

Common stock, without par value, 235,000,000 shares authorized, 224,203,112 shares issued and 

outstanding at December 31, 2020 and 2019

Retained earnings

Accumulated other comprehensive (loss) income

Total stockholder’s equity

$ 

2  $ 

$ 

$ 

9 

8 

— 

19 

5,496 

160 

54 

101 

5,811 

5,830  $ 

55  $ 

23 

67 

8 

153 

59 

58 

3,266 

3,536 

892 

1,410 

(8) 

2,294 

TOTAL LIABILITIES AND STOCKHOLDER’S EQUITY

$ 

5,830  $ 

See notes to condensed financial statements (parent company only).

129

2 

17 

3 

5 

27 

5,136 

140 

5 

94 

5,375 

5,402 

61 

21 

200 

11 

293 

73 

37 

2,767 

3,170 

892 

1,333 

7 

2,232 

5,402 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

SCHEDULE I — Condensed Financial Information of Registrant

ITC HOLDINGS CORP.

CONDENSED STATEMENTS OF COMPREHENSIVE INCOME (PARENT COMPANY ONLY)

(In millions of USD)

Other income (expense), net

General and administrative expense

Taxes other than income taxes

Interest expense

LOSS BEFORE INCOME TAXES

INCOME TAX BENEFIT

LOSS AFTER TAXES

EQUITY IN SUBSIDIARIES’ NET EARNINGS

NET INCOME

OTHER COMPREHENSIVE (LOSS) INCOME

Derivative instruments (net of tax of $7 for the year ended December 31, 2020, $1 
for the year ended December 31, 2019 and less than $1 for the year ended 
December 31, 2018)

TOTAL OTHER COMPREHENSIVE (LOSS) INCOME, NET OF TAX

Year Ended December 31,

2020

2019

2018

$ 

5  $ 

5  $ 

(20) 

(1) 

(122) 

(138) 

(43) 

(95) 

502 

407 

(15) 

(15) 

(25) 

(2) 

(119) 

(141) 

(44) 

(97) 

525 

428 

3 

3 

1 

(7) 

— 

(114) 

(120) 

(30) 

(90) 

420 

330 

1 

1 

TOTAL COMPREHENSIVE INCOME

$ 

392  $ 

431  $ 

331 

See notes to condensed financial statements (parent company only).

130

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

SCHEDULE I — Condensed Financial Information of Registrant
ITC HOLDINGS CORP.
CONDENSED STATEMENTS OF CASH FLOWS (PARENT COMPANY ONLY)

(In millions of USD)

CASH FLOWS FROM OPERATING ACTIVITIES
Net income
Adjustments to reconcile net income to net cash used in operating activities:

Equity in subsidiaries' earnings
Dividends from subsidiaries
Deferred and other income taxes
Net intercompany tax payments from (to) subsidiaries
Other
Changes in assets and liabilities, exclusive of changes shown separately:

Accounts receivable from subsidiaries
Intercompany tax receivable from subsidiaries
Income tax receivable 
Accrued compensation
Other current and non-current assets and liabilities, net

Net cash used in operating activities

CASH FLOWS FROM INVESTING ACTIVITIES

Equity contributions to subsidiaries
Return of capital from subsidiaries
Advances to subsidiaries
Other

Net cash provided by investing activities

CASH FLOWS FROM FINANCING ACTIVITIES

Issuance of long-term debt
Borrowings under revolving credit agreement
Borrowings under term loan credit agreements
Net issuance of commercial paper
Retirement of long-term debt — including extinguishment of debt costs
Repayments of revolving credit agreement
Repayments of term loan credit agreement
Dividends to ITC Investment Holdings
Settlement of interest rate swaps
Other

Net cash provided by (used in) financing activities

Year Ended December 31,

2020

2019

2018

$ 

407  $ 

428  $ 

330 

(502) 
3 
(46) 
33 
2 

9 
(4) 
— 
(6) 
6 
(98) 

(88) 
228 
(50) 
(2) 
88 

700 
293 
200 
(133) 
— 
(290) 
(400) 
(330) 
(23) 
(7) 
10 

— 

2 

(525) 
3 
(51) 
14 
6 

9 
11 
1 
31 
9 
(64) 

(120) 
239 
— 
(1) 
118 

— 
72 
200 
200 
(203) 
(75) 
— 
(250) 
— 
— 
(56) 

(2) 

4 

(420) 
26 
(23) 
59 
2 

(4) 
(13) 
14 
2 
13 
(14) 

(202) 
324 
— 
(1) 
121 

— 
37 
— 
— 
— 
— 
— 
(200) 
— 
(1) 
(164) 

(57) 

61 

4 

NET INCREASE (DECREASE) IN CASH, CASH EQUIVALENTS AND RESTRICTED CASH  

CASH, CASH EQUIVALENTS AND RESTRICTED CASH — Beginning of period

CASH, CASH EQUIVALENTS AND RESTRICTED CASH — End of period

$ 

2  $ 

2  $ 

See notes to condensed financial statements (parent company only).

131

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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SCHEDULE I — Condensed Financial Information of Registrant

ITC HOLDINGS CORP.

NOTES TO CONDENSED FINANCIAL STATEMENTS (PARENT COMPANY ONLY)

1.   GENERAL

For  ITC  Holdings  Corp.’s  (“ITC  Holdings,”  “we,”  “our”  and  “us”)  presentation  (Parent  Company  only),  the 
investment in subsidiaries is accounted for using the equity method. The condensed parent company financial 
statements and notes should be read in conjunction with the consolidated financial statements and notes of ITC 
Holdings appearing in this Annual Report on Form 10-K.

As a holding company with no business operations, ITC Holdings’ assets consist primarily of investments in 
our subsidiaries. ITC Holdings’ material cash inflows are only from dividends and other payments received from 
our subsidiaries, the proceeds raised from the sale of debt securities, issuances under our commercial paper 
program and borrowings under our revolving and term loan term credit agreements. ITC Holdings may not be 
able  to  access  cash  generated  by  our  subsidiaries  in  order  to  fulfill  cash  commitments.  The  ability  of  our 
subsidiaries to make dividend and other payments to us is subject to the availability of funds after taking into 
account their respective funding requirements, the terms of their respective indebtedness, the regulations of the 
FERC  under  the  FPA  and  applicable  state  laws.  In  addition,  there  are  practical  limitations  on  using  the  net 
assets  of  each  of  our  Regulated  Operating  Subsidiaries  as  of  December  31,  2020  for  dividends  based  on 
management's intent to maintain the FERC-approved capital structure targeting 60% equity and 40% debt for 
each  of  our  Regulated  Operating  Subsidiaries.  These  net  assets  are  included  in  Schedule  I  as  the  line-item 
“Investments  in  subsidiaries.”  Each  of  our  subsidiaries,  however,  is  legally  distinct  from  us  and  has  no 
obligation, contingent or otherwise, to make funds available to us.

Recent Developments Regarding the COVID-19 Pandemic

In March 2020, the World Health Organization declared COVID-19 a pandemic. Efforts to control the recent 
outbreak  of  COVID-19  have  resulted  in  impacts  to  businesses  and  facilities  in  various  industries  around  the 
world, such as operating restrictions and closures, and disruptions to the global economy and supply chains. To 
date, COVID-19 has not had a material impact on our results of operations, cash flows or financial condition. 

The duration and total impact on our operations from COVID-19 is unknown at this time and will ultimately 
depend  on  the  duration  and  severity  of  the  pandemic,  the  length  that  the  various  business  restrictions  are  in 
effect, the impact of recent resurgences of COVID-19 cases and deaths in the United States, and the efficacy 
and distribution of COVID-19 vaccines. We are continuing to monitor developments and cannot predict whether 
COVID-19 will have a material impact on our results of operations, cash flows or financial condition. We are also 
monitoring  the  evolving  situation  and  guidance  from  federal,  state  and  local  public  health  authorities.  We  are 
taking  steps  to  mitigate  the  potential  risks  to  us  and  our  employees  posed  by  COVID-19,  including  enabling 
remote work arrangements for employees when appropriate, and are following all government requirements to 
reduce the transmission of COVID-19.

2.   DEBT

As of December 31, 2020, the maturities of our debt outstanding were as follows:

(In millions of USD)
2021
2022
2023
2024
2025
2026 and thereafter

Total

$ 

$ 

67 
500 
287 
400 
— 
2,100 
3,354 

Refer  to  Note  10  to  the  consolidated  financial  statements  for  additional  information  on  the  ITC  Holdings 
Senior  Notes,  the  ITC  Holdings  Revolving  and  Term  Loan  Credit Agreements,  the  ITC  Holdings  Commercial 
Paper Program and the ITC Holdings Derivative Instruments and Hedging Activities.

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Fixed Rate Debt

Based on the borrowing rates obtained from third party lending institutions currently available for bank loans 
with similar terms and average maturities from active markets, the fair value of the ITC Holdings Senior Notes 
was $3,670 million and $2,752 million at December 31, 2020 and 2019, respectively. The total book value of the 
ITC Holdings Senior Notes, net of discount and deferred financing fees, was $3,229 million and $2,533 million 
at December 31, 2020 and 2019, respectively. The fair values of the ITC Holdings Senior Notes represent Level 
2 under the three-tier hierarchy described in Note 13 to the consolidated financial statements. 

Revolving and Term Loan Credit Agreements

At December 31, 2020 and 2019, we had $37 million and $234 million respectively, outstanding under our 
revolving  and  term  loan  credit  agreements,  which  are  variable  rate  loans.  The  fair  value  of  these  loans 
approximates book value based on the borrowing rates currently available for variable rate loans obtained from 
third party lending institutions. The fair values of the revolving and term loan credit agreements represent Level 
2 under the three-tier hierarchy described in Note 13 to the consolidated financial statements

Other Financial Instruments

The carrying value of other financial instruments included in current assets and current liabilities, including 
cash  and  cash  equivalents,  special  deposits  and  commercial  paper,  approximates  their  fair  value  due  to  the 
short-term nature of these instruments.

3.   RELATED-PARTY TRANSACTIONS

Our related-party transactions during were as follows:

(In millions of USD)

Equity contributions to subsidiaries

Dividends from subsidiaries (a)

Return of capital from subsidiaries (a)

Net income tax payments (to) from: (b)

ITCTransmission

METC

ITC Midwest

ITC Great Plains

ITC Interconnection

Year Ended December 31,

2020

2019

2018

$ 

(88)  $ 

(120)  $ 

3 

228 

3 

239 

$ 

17  $ 

7  $ 

9 

1 

6 

— 

4 

3 

(1)   

1 

(202) 

26 

324 

39 

7 

3 

9 

1 

____________________________

(a) Includes ITCTransmission, MTH, ITC Midwest and other subsidiaries.

(b) The  net  income  tax  payments  were  pursuant  to  intercompany  tax  sharing  arrangements,  and  the  total  of 
these tax payments is presented as a net cash outflow or inflow from operating activities in the condensed 
parent  company  statements  of  cash  flows.  Other  reconciling  items  between  the  parent  company  and  the 
consolidated tax liabilities are presented as deferred and other income taxes in the adjustments to reconcile 
net income to net cash provided by operating activities. Additionally, ITC Holdings paid its subsidiaries for 
NOLs utilized by the consolidated group.

Net Intercompany Receivables and Payables

We may incur charges from our subsidiaries for general corporate expenses incurred. In addition, we may 
perform additional  services for, or receive additional services from our subsidiaries. These transactions are in 
the  normal  course  of  business  and  payments  for  these  services  are  settled  through  accounts  receivable  and 
accounts  payable,  as  necessary.  We  generally  settle  our  intercompany  balances  with  our  affiliates  on  a  net 
basis monthly.

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Intercompany Tax Sharing Arrangement

As  discussed  in  Note  1  to  the  condensed  financial  statements  of  the  parent  company,  we  are  a  holding 
company with no business operations. We file consolidated income tax returns that include our affiliates, which 
are taxed as a corporation for federal and Michigan income tax purposes. We operate under an intercompany 
tax sharing arrangement with our subsidiaries and as a result may receive or pay federal and state income tax 
based on their stand-alone company tax positions.

Retirement Benefits

We are the plan sponsor for a pension plan, other postretirement plans and a defined contribution plan. The 
benefits-related expenses recorded by our affiliates result from the inclusion of benefit costs as a component of 
the  total  charge  for  services  performed  by  our  employees  under  the  cost  assignment  and  allocation  methods 
used by us and our subsidiaries.

Intercompany Loan Agreement

On September 21, 2020, we advanced an intercompany loan to ITC Transmission totaling $50 million, which 
remained outstanding at December 31, 2020. We received interest payments of less than $1 million during the 
year ended December 31, 2020 from ITC Transmission associated with this intercompany loan. Additionally, at 
December  31,  2020  we  had  a  $4  million  intercompany  loan  with  ITC  Interconnection.  During  the  year  ended 
December  31,  2020,  we  received  principal  and  interest  payments  of  less  than  $1  million  from  ITC 
Interconnection associated with this intercompany loan.

4.  SUPPLEMENTAL FINANCIAL INFORMATION 

Reconciliation of Cash, Cash Equivalents and Restricted Cash

The  following  table  provides  a  reconciliation  of  cash,  cash  equivalents  and  restricted  cash  reported  on  the 
condensed  statements  of  financial  position  that  sum  to  the  total  of  the  same  such  amounts  shown  in  the 
condensed statements of cash flows:

(In millions of USD)
Cash and cash equivalents
Restricted cash included in:
Other non-current assets

Total cash, cash equivalents and restricted cash

Supplementary Cash Flows Information

(In millions of USD)
Supplementary cash flows information:

Interest paid
Income taxes paid
Income tax refunds received

ITEM 16.   FORM 10-K SUMMARY.

Not applicable.

December 31,

2020

2019

2018

2017

2  $ 

2  $ 

3  $ 

60 

— 
2  $ 

— 
2  $ 

1 
4  $ 

1 
61 

$ 

$ 

Year Ended December 31,

2020

2019

2018

$ 

116  $ 
2 
2 

117  $ 
— 
3 

117 
— 
13 

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Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant 
has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized in the City 
of Novi, State of Michigan, on February 11, 2021.

SIGNATURES

ITC HOLDINGS CORP.

By:

/s/ LINDA H. APSEY

Linda H. Apsey

President and Chief Executive Officer

Pursuant  to  the  requirements  of  the  Securities  Exchange Act  of  1934,  this  report  has  been  signed  by  the 

following persons on behalf of the registrant and in the capacities and on the dates indicated:

Signature

Title

Date

/s/ LINDA H. APSEY
Linda H. Apsey

President and Chief Executive
Officer (principal executive officer)

February 11, 2021

/s/ GRETCHEN L. HOLLOWAY
Gretchen L. Holloway

Senior Vice President and Chief Financial Officer
 (principal financial and accounting officer)

February 11, 2021

/s/ SANDRA E. PIERCE
Sandra E. Pierce

/s/ ROBERT A. ELLIOTT
Robert A. Elliott

/s/ ALBERT ERNST
Albert Ernst

/s/ DEBORA FRODL
Debora Frodl

/s/ ALEXANDER I. GREENBAUM
Alexander I. Greenbaum

/s/ RONNIE D. HAWKINS, JR
Ronnie D. Hawkins, Jr

/s/ DAVID G. HUTCHENS
David G. Hutchens

/s/ JAMES P. LAURITO
James P. Laurito

/s/ KEVIN L. PRUST
Kevin L. Prust

/s/ A. DOUGLAS ROTHWELL
A. Douglas Rothwell

Director and Chairman

February 11, 2021

February 11, 2021

February 11, 2021

February 11, 2021

February 11, 2021

February 11, 2021

February 11, 2021

February 11, 2021

February 11, 2021

February 11, 2021

Director

Director

Director

Director

Director

Director

Director

Director

Director

135